Privacy Policy

1. 📥 Information We Collect

We collect the following personal information from you during registration, eKYC, and use of our services:

• Identity Information: Full name, date of birth, PAN card number, Aadhaar card number, passport photo
• Contact Information: Mobile number, email address, residential address
• Financial Information: Payment transaction details, UTR numbers, bank account details (for refunds only)
• Professional Information: Nature of occupation, investment experience
• Technical Information: IP address, browser type, device information (when you visit our website)
• Communication Records: WhatsApp/SMS messages, emails and calls for service delivery and support

2. 🎯 How We Use Your Information

Your personal information is used for the following purposes:

• To complete your eKYC verification as required under SEBI Regulations
• To deliver research calls, alerts and market updates to your registered mobile number
• To process subscription payments and issue GST invoices
• To create and maintain your client profile and subscription records
• To respond to your queries, complaints and support requests
• To comply with SEBI regulations, legal obligations and audit requirements
• To send important service updates, renewal reminders and company notifications
• To improve our research services and client experience

3. 🔗 Information Sharing & Disclosure

Sanwariya Capital does NOT sell, rent or trade your personal information to any third party. We may share your information only in the following limited circumstances:

• Regulatory Compliance: With SEBI, tax authorities or other regulatory bodies when legally required
• Legal Obligations: When required by a court order, subpoena or applicable law
• Service Providers: With SMS/WhatsApp gateway providers solely for delivering research calls (under strict confidentiality)
• Auditors: With internal and external auditors as required for regulatory compliance

Any third party receiving your information is contractually bound to maintain its confidentiality and security.

4. 🛡️ Data Security

We implement robust technical and administrative measures to protect your personal information from unauthorized access, disclosure, alteration or destruction:

• All client data is stored on secure, encrypted servers
• Access to client information is restricted to authorized personnel only on a need-to-know basis
• Regular security audits and vulnerability assessments are conducted
• All employees are trained on data protection and confidentiality obligations
• Physical records are stored in locked, access-controlled facilities
• We do NOT store your complete bank account, Demat account or trading passwords

5. 📦 Data Retention

We retain your personal information for the following periods:

• Client KYC Records: Minimum 5 years after the end of the client relationship as per SEBI regulations
• Transaction Records: Minimum 5 years for tax and audit purposes
• Communication Records: 2 years from date of communication
• Research Reports & Calls: 5 years as required by SEBI regulations

After the retention period, your data is securely deleted or anonymized in compliance with applicable laws.

6. 🍪 Cookies & Website Tracking

Our website uses cookies and similar tracking technologies to enhance your browsing experience:

• Essential Cookies: Required for the website to function properly (cannot be disabled)
• Analytics Cookies: Help us understand how visitors use our website (can be disabled)
• Marketing Cookies: Used to show relevant advertisements (can be disabled)

You can control cookie preferences through your browser settings. Disabling certain cookies may affect website functionality.

7. ✊ Your Rights

As a client, you have the following rights regarding your personal information:

• Right to Access: Request a copy of the personal information we hold about you
• Right to Correction: Request correction of inaccurate or incomplete information
• Right to Deletion: Request deletion of your personal information (subject to legal retention requirements)
• Right to Object: Object to processing of your information for marketing purposes
• Right to Data Portability: Request transfer of your data in a structured format

To exercise any of these rights, please email us at privacy@sanwariyacapital.com. We will respond within 30 days.

8. 📞 Contact for Privacy Concerns

If you have any questions, concerns or requests regarding this Privacy Policy or our data practices, please contact our Privacy Officer:

• Email: privacy@sanwariyacapital.com
• Phone: +91 98934-46393 (Mon–Sat, 9 AM–6 PM)
• Address: [Office Address], Bhopal, Madhya Pradesh – 462001

We will investigate all legitimate privacy complaints and respond within 30 days. This Policy may be updated periodically. Please check this page regularly for the latest version.