Introduction and Purpose:
The Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011 ("Data Protection Rules") under the Information Technology Act, 2000 ("IT Act") currently governs data protection in India. The Data Protection provisions of the IT Act regulate the processing and control of personal data, which is any information about an identifiable living individual, and provide these individuals with specific rights and remedies concerning that information.
Equity360 is dedicated to protecting your privacy. The purpose of this notification is to provide you with the necessary information at the time of providing us with your personal data. This Privacy Notice outlines how we collect and use your personal data and the rights and options you have concerning it. This should help you feel more secure about the privacy and security of your personal data.
Please read this Privacy Notice thoroughly. By visiting our website or using any of our services, you indicate your agreement to our use of your personal information as outlined in this Privacy Notice.
Who is responsible for your personal data?
Equity360 is responsible for your personal data. The registered office of Equity360 is located at 1605,16th Floor, Logix City Center Mall, Plot No.BW-58, Sector 32, Noida, Uttar Pradesh 201301. Specifically, your data will be controlled by the Equity360 that you have instructed or that is providing services or communication to you in your region.
Information we collect about you:
When do we collect information?
We may collect personal data about you in several circumstances:
•When you register with us on our website, apply to use any of our services, become our client, or contact us in person, by phone, by email or by post;
•When you provide feedback or complete a contact form on our website;
•When you or your organization offer to provide or provide services to us;
•In some circumstances, we collect personal data about you from a third-party source. For example, we may collect personal data from your organization, other organizations with whom you have dealings, government agencies, a credit reporting agency, fraud prevention agencies, financial crime agencies, an information or service provider, all of which forms part of publicly available records.
What information will we collect and why?
We may collect the following information, depending on the service provided:
•Your contact details, such as your name, job title, postal address, including your home address, where you have provided this to us, business address, telephone number, mobile phone number, fax number, and email address;
•Your date of birth, nationality, country of birth, country of residence, employment status, and tax identification number (i.e. National Insurance Number);
•Passport details, driving license, and utility bills;
•Details of the services you request from us;
•Details of your visit to our offices or other visits to third-party locations as may be organized, depending upon the nature of services provided by us;
•Details of your employment status, income, and source of wealth.
•IP address and browser-generated data when you visit our website.
•From time to time, personal data relating to health and details of dietary preferences when relevant to meetings or events to which we invite you.
Are you required to provide us with personal data?
As a general rule, providing personal data to Equity360 is entirely voluntary, and there are typically no detrimental effects if you choose not to consent or provide such information. However, there may be circumstances where Equity360 cannot take action without certain personal data, such as sending you newsletters or meeting legal obligations under the Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017, and other applicable legislation for crime prevention and fraud prevention purposes, before entering into any contractual obligations to provide services.
How will we use your information?
We will use the information provided by you in the following ways:
•To process your application to use our services and provide you with the requested services.
•To conduct identification verification checks and comply with our anti-money laundering obligations and legal obligations for crime and fraud prevention purposes (e.g., record keeping).
•To comply with our contractual obligations and provide you with the requested information, products, and services.
•To protect your information and prevent unauthorized access.
•To handle any queries, complaints, or problems reported by you.
•To generate statistics on the use of our website and application (no personally identifiable information used for this purpose).
•If required by law, to protect us/customers, or enforce any agreement between you and us.
•To notify you of changes to our services.
•To improve the services we provide to you.
We may also use your information to inform you about other services we offer, similar to those you have already engaged us to provide or enquired about, or to provide information about Equity360 via email. In such cases, we will only do so if we have your consent or if we have a legitimate interest in sending you the communication. When evaluating legitimate interest, we will balance our interests with your rights and only send communications where you would reasonably expect to hear from us. You can opt-out of receiving this information when we collect your details or at any time by contacting us at firstname.lastname@example.org.
How will we protect and disclose your information?
We take the security of your personal information seriously and have implemented appropriate physical, electronic, and procedural measures to safeguard it from unauthorized access and disclosure. We may disclose your information to the following:
•Businesses that are part of the same group of companies as Equity360, or become part of that group;
•Our appointed auditors, accountants, lawyers, and other professional advisers who require access to the information to advise us;
•Fraud prevention agencies and other organizations to allow us to undertake the necessary checks;
•Auditors appointed by providers of such products or services;
•Regulators, the Financial Conduct Authority, or any relevant regulatory authority entitled to require disclosure;
•Relevant tax, payments, and customs authorities as tax regulations require us to collect information about each investor’s tax residency;
•Prospective sellers or buyers of such businesses or assets if we sell or buy any business or assets, in which case we will disclose your personal information. If all of Equity360's assets are acquired by a third party, personal information held about clients may be one of the transferred assets. We will not lend or sell your information to third parties.
Personal data about other people which you provide to us:
If you provide personal data to us about someone else (such as one of your directors or employees, or someone with whom you have business dealings) you must ensure that you are entitled to disclose that personal data to us and that, without our taking any further steps, we may collect, use and disclose that personal data as described in this Privacy Notice. In particular, you must ensure the individual concerned is aware of the various matters detailed in this Privacy Notice, as those matters relate to that individual, including our identity, how to contact us, our purposes of collection, our personal data disclosure practices (including disclosure to overseas recipients), the individual's right to obtain access to the personal data and make complaints about the handling of the personal data, and the consequences if the personal data is not provided (such as our inability to provide services).
We are committed to only keeping your personal data for as long as we need to in order to fulfill the relevant purpose(s) it was collected for, as set out above in this notice, and for as long as we are required or permitted to keep it by law.
We retain copies of our customer contracts in order to enable us to deal with any legal issues and the information provided to us for identification verification checks, financial crime and anti-money laundering checks (as required by law) for up to 10 years after termination or expiry of our contract with you. We retain details of complaints for up to 10 years from the date of receipt.
We shall keep records of the following for up to 10 years:
•Electronic communications and minutes of face-to-face meetings;
•Suitability and appropriateness assessments;
•Periodic statements (for example, valuations); and
•All orders and transactions in financial instruments on your behalf (including information about your identity).
We may transfer your personal information between businesses that are legally part of Equity360 for the purposes of providing our services to you as follows:
Your rights You have the right to request a copy of the personal data we hold about you, to have any inaccurate personal data corrected, and to object to or restrict our use of your personal data. If you have a concern about our handling of your personal data, you may also make a complaint. If you wish to exercise any of these rights, please send an email to email@example.com. We may ask you to provide proof of your identity by submitting a copy of a valid identification document to comply with our security obligations and prevent unauthorized disclosure of data. Upon receiving your request, we will aim to provide you with the requested information without delay and no later than one month after receiving your request. We may extend the period of compliance by two additional months in complex or numerous requests, in which case, we will inform you of the reason for the extension within one month of receiving your request. We will provide a copy of the information held free of charge. However, we may charge a reasonable fee for further copies of the same information based on administrative costs. In cases where we believe a request is manifestly unfounded or excessive, we may charge a reasonable fee, which will be decided on a case-by-case basis or refuse to respond to such requests. In addition, you have the following rights, which you can exercise by contacting us using the details provided below, unless exemptions apply:
•To ask us not to process your personal data for marketing purposes
•To prevent any processing of personal data causing or likely to cause unwarranted and substantial damage or distress to you or another individual
•To request the rectification or completion of inaccurate or incomplete personal data
•To request the erasure of personal data under certain circumstances
•In certain circumstances, to receive your personal data, which you have provided to us, in a structured, commonly-used and machine-readable format, or to have that personal data transmitted to another data controller where technically feasible
•To be informed about any use of your personal data to make automated decisions about you and obtain meaningful information about the logic involved, as well as the significance and the envisaged consequences of this processing. When you contact us to exercise any of the rights above, we may ask you to provide additional information, such as your name, address, and proof of identity, to verify your identity. If you would like to lodge a complaint or exercise any of your rights set out above, you can contact us at:
India Post: 1605,16th Floor, Logix City Center Mall, Plot No.BW-58, Sector 32, Noida, Uttar Pradesh 201301