Introduction
Vajraaditya Ventures ("we," "our," or "us") is committed to protecting the privacy and security of your personal information. This Privacy Policy describes how we collect, use, store, share, and protect your information when you use our services as a stock broker registered with the Securities and Exchange Board of India (SEBI).
This Privacy Policy applies to all clients, prospective clients, and visitors to our website and mobile applications. By using our services, you consent to the collection and use of information in accordance with this policy.
Information We Collect
1. Personal Information
We collect personal information that you provide to us directly, including but not limited to:
- Identity Information: Name, date of birth, gender, photograph, signature, PAN number, Aadhaar number, passport details, and other government-issued identification documents
- Contact Information: Email address, phone number, residential address, and correspondence address
- Financial Information: Bank account details, demat account details, annual income, net worth, source of income, investment objectives, and trading experience
- KYC Documents: Proof of identity, proof of address, income proof, and other documents required under Know Your Customer (KYC) norms
- Transaction Information: Details of securities transactions, trading patterns, holdings, and account balances
2. Technical Information
When you access our website or trading platforms, we automatically collect certain technical information, including:
- IP address, browser type, and operating system
- Device identifiers and mobile network information
- Pages visited, time spent on pages, and clickstream data
- Login times, frequency of visits, and usage patterns
- Cookies and similar tracking technologies
3. Information from Third Parties
We may receive information about you from:
- KYC Registration Agencies (KRAs) and Central KYC Records Registry (CKYCR)
- Stock exchanges (NSE, BSE, MCX) and depositories (NSDL, CDSL)
- Credit bureaus and financial institutions
- Regulatory authorities (SEBI, Income Tax Department)
- Public databases and government records
How We Use Your Information
We use your personal information for the following purposes:
1. Service Provision
- Opening and maintaining your trading and demat accounts
- Executing buy and sell orders on your behalf
- Processing payments and settlements
- Providing account statements, contract notes, and margin statements
- Offering customer support and responding to inquiries
2. Regulatory Compliance
- Complying with KYC and Anti-Money Laundering (AML) requirements
- Meeting SEBI regulations and stock exchange requirements
- Reporting to regulatory authorities as required by law
- Preventing fraud, money laundering, and terrorist financing
- Maintaining audit trails and records as mandated by regulations
3. Risk Management
- Assessing and managing credit risk
- Monitoring trading activities for suspicious patterns
- Enforcing margin requirements and position limits
- Protecting against unauthorized access and cyber threats
4. Communication
- Sending account-related notifications and alerts
- Providing market updates and research reports (if consented)
- Informing you about changes to our services and policies
- Responding to your questions and complaints
5. Business Operations
- Improving our services and developing new products
- Conducting data analysis and research
- Maintaining business records and archives
- Enforcing our terms and conditions
Information Sharing and Disclosure
We do not sell your personal information to third parties. We may share your information with:
1. Regulatory and Legal Requirements
- SEBI and Stock Exchanges: We share information as required under securities laws and regulations
- Depositories: For demat account operations and settlements
- Government Authorities: When required by law, court order, or regulatory directive
- Tax Authorities: For tax compliance and reporting purposes
2. Service Providers
- KYC Agencies: For identity verification and KYC compliance
- Payment Processors: For processing fund transfers and settlements
- Technology Providers: For hosting, data storage, and IT services
- Professional Advisors: Lawyers, auditors, and consultants (under confidentiality agreements)
3. Business Transfers
In the event of a merger, acquisition, or sale of assets, your information may be transferred to the acquiring entity, subject to the same privacy protections.
4. With Your Consent
We may share your information with third parties when you have given explicit consent for such sharing.
Data Security
We implement robust security measures to protect your personal information:
- Encryption: We use SSL/TLS encryption for data transmission and encrypt sensitive data at rest
- Access Controls: Strict access controls and authentication mechanisms to limit access to authorized personnel only
- Firewalls and Monitoring: Network security measures including firewalls, intrusion detection systems, and 24/7 monitoring
- Secure Data Centers: Data stored in secure, access-controlled data centers with physical security measures
- Regular Audits: Periodic security audits and vulnerability assessments
- Employee Training: Regular training on data protection and confidentiality for all employees
- Incident Response: Procedures in place to respond to and manage data breaches
While we take all reasonable steps to protect your information, no method of transmission over the internet or electronic storage is 100% secure. We cannot guarantee absolute security but commit to promptly notifying you of any security breaches as required by law.
Data Retention
We retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.
- Active Accounts: We retain information for active accounts throughout the duration of your relationship with us
- Closed Accounts: After account closure, we retain records for a minimum period as mandated by SEBI regulations (typically 5-8 years)
- Regulatory Requirements: Certain records may be retained longer to comply with legal, regulatory, tax, auditing, and accounting requirements
- Legal Claims: Information may be retained for the duration of any legal proceedings or disputes
Once the retention period expires and there is no legal requirement to retain the data, we securely delete or anonymize your personal information.
Your Rights
Under applicable data protection laws, you have the following rights:
1. Right to Access
You have the right to request access to the personal information we hold about you and obtain a copy of such information.
2. Right to Correction
You can request correction of inaccurate or incomplete personal information. You can update your information through your account settings or by contacting us.
3. Right to Erasure
You may request deletion of your personal information, subject to legal and regulatory retention requirements.
4. Right to Data Portability
You have the right to receive your personal information in a structured, commonly used, and machine-readable format and to transmit it to another data controller.
5. Right to Object
You can object to the processing of your personal information for direct marketing purposes or on grounds relating to your particular situation.
6. Right to Withdraw Consent
Where we rely on your consent to process your personal information, you have the right to withdraw that consent at any time.
Exercising Your Rights: To exercise any of these rights, please contact our Data Protection Officer at geetha@vajvt.com. We will respond to your request within 30 days.
Cookies and Tracking Technologies
We use cookies and similar tracking technologies to enhance your experience on our website and trading platforms.
Types of Cookies We Use:
- Essential Cookies: Required for the operation of our website and services (e.g., authentication, security)
- Functional Cookies: Remember your preferences and settings (e.g., language, font size, high contrast mode)
- Analytics Cookies: Help us understand how visitors use our website and identify areas for improvement
- Performance Cookies: Collect information about how you use our website to improve performance
Managing Cookies
You can control and manage cookies through your browser settings. However, disabling certain cookies may limit your ability to use some features of our services.
Third-Party Links
Our website may contain links to third-party websites and services. We are not responsible for the privacy practices or content of these third parties. We encourage you to review the privacy policies of any third-party sites you visit.
Children's Privacy
Our services are not intended for individuals under the age of 18. We do not knowingly collect personal information from children. If we become aware that we have collected information from a child without parental consent, we will take steps to delete such information.
International Data Transfers
Your personal information is primarily stored and processed in India. If we transfer your information to countries outside India, we ensure appropriate safeguards are in place to protect your information in accordance with applicable data protection laws.
Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of any material changes by:
- Posting the updated policy on our website with a revised "Last Updated" date
- Sending you an email notification (for significant changes)
- Displaying a prominent notice on our website or trading platform
Your continued use of our services after the effective date of the revised Privacy Policy constitutes your acceptance of the changes.
Grievance Redressal
If you have any concerns, complaints, or questions about this Privacy Policy or our data practices, please contact:
We will investigate and respond to your complaint within 30 days. If you are not satisfied with our response, you may escalate your complaint to:
- SEBI Complaints Redress System (SCORES): https://scores.gov.in
- Stock Exchange Investor Grievance Redressal Cell
Legal Basis for Processing
We process your personal information on the following legal bases:
- Contractual Necessity: Processing is necessary to perform our contract with you (i.e., providing brokerage services)
- Legal Obligation: Processing is required to comply with legal and regulatory obligations (KYC, AML, tax laws, SEBI regulations)
- Legitimate Interests: Processing is necessary for our legitimate business interests (fraud prevention, risk management, service improvement)
- Consent: Processing is based on your explicit consent (marketing communications, optional services)
Your Consent
By using our services, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, use, and disclosure of your personal information as described herein.
If you do not agree with this Privacy Policy, please do not use our services or provide us with your personal information.
