We, at Senora Asset Management Company Limited (“Senora AMC”, "we", "us", "our", etc.) respect investors / customers / clients right to privacy.
We recognize that the lawful and correct treatment of personal data is very important to maintain investor's confidence in ourselves. It is our endeavor to ensure that any personal data that we collect, process, record or use in any way whether it is held on paper, on computer or other electronic media will have appropriate safeguards in place to comply with our obligations of confidentiality and privacy.
In this regard, we request investors / clients / customers to kindly read this “Privacy Policy” (The Policy) carefully. This Policy applies to all Personal Information collected and received from (i) our clients, (ii) visitors/users of our website, products, services and software; and (iii) such other persons who intend to enter into any kind of relationship with us through our website https://www.senoraamc.com/ ("Site") or any other mobile application and all Personal Information collected and received by us vide the physical scheme application form or any transactional document etc. Please note that Personal Information collected by us in the physical form and through the Site may be converted and stored in an electronic form at our sole discretion for the purposes as mentioned herein under. This Policy shall be read with and subject to the Disclaimer notified on the Site.
The terms as may be used in this document would be in accordance with “The Information Technology Act 2000 as amended till date, Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011” and such other rules/regulations and Circulars as may be applicable.
Interpretation
- All references to the masculine shall include the feminine and all references, to the singular shall include the plural and vice-versa. All references to client/customer/investor whether masculine or feminine include references to non-individuals also unless repugnant to the context thereof;
- Any reference to any statute or statutory provision shall be construed as including a reference to any statutory modifications or re-enactment therein from time to time;
- Headings are for ease of reference only.
The Policy
Senora AMC, is a Company incorporated under the Companies Act, 1956, has been appointed as the Investment Manager to the Schemes of Senora AIF. The AMC either directly or through third party service providers engaged by the AMC (Service Providers) such as the Registrar and Transfer agents collects, receives, possesses, stores, deals or handles information received from investors / client / customers whether existing or prospective.
Personal Information
Such information can be personal and sensitive in nature as per the indicative list given below:
- Bank Account details change of bank account details or registration of multiple bank accounts etc. through application forms
- Permanent Account Number details
- Payment instrument details at the time of submitting application at the time of investment or as proof for carrying out change of bank account or any other details of debit card obtained (if any)
- Generation and storing password (PIN) in encrypted form based on the request from the investor under the online mode of investments
- Biometric information obtained, if any;
- Demat Account details like beneficiary account no. etc;
- Annual Income and savings profile; and
- Other information as may be considered as sensitive and personal
By entering this Site and providing information to us when subscribing, sending inquiries, you expressly agree to this Policy. By entering this Site, you will be treated as having given your consent for the processing of your Personal Information as set out in this Policy.
Collection of Personal Information
The aforesaid information is being collected by the AMC/Service Providers to respond to your requests, to process the investment applications and to also ensure safe subscriptions/redemptions through points of acceptance in physical form, website, online portals, Automated Teller Machines and such other mode. Additionally, we may obtain Personal Information about you from third parties. Also, we obtain Personal Information about you through call recordings at our call centers, Internet technology, including our Site. The AMC may also call the investors with respect to the other products or services offered by the AMC. The said information is also being collected to be compliant with the Know Your Client (KYC) norms under the Prevention of Money Laundering Act, 2002, (PMLA), the rules issued thereunder, and guidelines and circular on Anti-Money Laundering issued by SEBI and SEBI (Mutual Funds) Regulations, 1996 as amended till date and any other guidelines issued by SEBI or AMFI or any other relevant authority from time to time.
The customers/ clients (whether existing/prospective) must ensure to recheck the information or data being provided to the AMC or any person acting on its behalf. Incase if any of the data/information is found to be inaccurate or incorrect, the same shall be informed to the AMC for immediate amendment. The AMC and any person acting on its behalf of AMC shall not be responsible for the authenticity of the personal information or sensitive personal data or information supplied by the customers/ clients (whether existing/prospective).
Our website may use cookies. By using our website and agreeing to these terms of use, you consent to our use of cookies in accordance with the terms of our privacy policy.
Investors / Customers / Clients shall not be covered by the terms of this Policy if they access other websites using links from this website.
Security Standards & Measures
The aforesaid information is the basis of our ability to provide investors / clients / customers with good, qualitative, timely and efficient service, while also keeping the information and data provided totally secure and confidential. We endeavor to have suitable technical, operational and physical security controls and measures to protect investors / customers / clients personal / sensitive data or information that are commensurate with the nature of our business at all times as per the security standards required under applicable laws.
We permit only authorized employees who are trained in the proper handling of customer information, to have access to aforesaid information. Further, the employees who violate the privacy and confidentiality promise shall be subjected to disciplinary action.
You agree and understand that when we use trusted third parties to act on our behalf for performing certain functions such as processing transactions, issuing account statements, payment gateway services, customer services etc., contractual or other means are used to ensure reasonable security safeguards appropriate to the sensitivity of the Personal Information, consistent with generally accepted standards of commercial business practice. Any account statement containing financial information pertaining to the investor, if it is to be sent over the internet to such investor, distributors or any other entity as indicated above will be sent only through a secure means and/or through encrypted electronic mail.
Use, Sharing and Disclosure of Personal Information
Your contact information (emails, postal address, phone numbers etc.) may be used by us to send periodic information (through emails, posts, SMSs, couriers, telephone etc.) on the services or upcoming events or announcements.
We shall reveal only such information to external authorities as may be found relevant and necessary in order to comply with the applicable laws of the land and to third party service providers to ensure smooth functioning of the activities as may be prescribed under applicable laws like Registrar and Transfer Agents/distributors/banks/sub-brokers/call-centers/custodians/depositories and such other entities/persons. By using our website or by agreeing to transact with us, you agree to the above sharing of information during your relationship with us. We may also be required from time to time to disclose investors / customers / clients personal information to governmental or judicial bodies or agencies or our regulators including but not limited to Reserve Bank of India or the Securities and Exchange Board of India.
We may share your investment account and transaction details and other Personal Information with the intermediaries, whose ARN / intermediary code stamp appears on the application forms / transaction slips.
We may share certain Personal Information with third parties such as post office, local and international couriers and other intermediaries for correspondence with the investor and for making payments to the investor by cheques, drafts, warrants, through Electronic Clearing Services (ECS), NEFT etc.
Personal Information will not be transferred to the aforesaid third parties, unless reasonable and appropriate steps have been taken to maintain the required level of data protection. Personal Information shall be communicated to third persons only for reasons consistent with the purposes for which the data were originally collected or other purposes authorized by law.
In addition to the above we may also use the information shared by investors / clients / customers for any service-related activities such as processing instructions, responding to service requests, resolve any grievances etc. or to contact investors / clients / customers regarding the products and services offered by us and seek feedback on the services provided. Further, such information may also be used by us to generate statistics and reports and/or to protect and defend the rights, interest and property of the Mutual Fund, AMC, Trustee Company, Sponsors & its affiliates and directors and/or to enforce legal rights or provisions of the Scheme related Documents of the Mutual Fund viz. Scheme Information Document (SID), Statement of Additional Information (SAI) and Key Information Memorandum (KIM). Further, it may be noted that Internet Protocol (IP) addresses, browser supplied information and site session information may be recorded as part of the normal operations and for security monitoring purposes.
Information Incidental to Website, Email and Electronic Communications
IP addresses, browser-supplied information and site session information (for example, the sequence of pages visited during a visit to the Service, the average time spent, information searched for, access times) may be recorded as part of the normal operation of the service for purposes of usage analysis and security monitoring. The amount of information recorded depends on the settings you have on your web browser; please refer to your browser if you want to learn about what information it sends.
Tracking cookies (both session and persistent) may be used to implement certain features. This will cause your browser to save certain information about your activities. Most browsers can disable tracking cookies at the user's option, but this may limit your use of certain services. Cookies, ensures that you do not need to re-enter your details every time you visit it. You can erase or choose to block this information from your computer if you want to.
All such incidental information will be used only to assist us in providing an effective service on this Site. We may from time to time supply this information to the owners or operators of third party websites from which it is possible to link to our Site with information relating to the number of users linking to our Site from such third party websites. You will not be identified from this information.
Storage of Personal Information
We shall store your Personal Information / data in a manner as is compliant with the applicable laws. To protect your Personal Information from unauthorized access, use, and disclosure, we implement reasonable physical, administrative, and technical safeguards. These safeguards include role-based access controls and encryption to keep personal information private while in transit. We also require our business partners, suppliers, agents and third parties to implement appropriate safeguards, such as access restrictions etc., to protect information from unauthorized access, use, and disclosure. We may store your data manually or electronically. Any data stored electronically will be stored in secure servers (either on-premises or contractually outsourced).
Breach of Internet Security
Despite efforts of Axis AMC, if unauthorized persons breach our security control measures resulting in the Site being hacked or presenting inaccurate information or such person illegally using such sensitive/ personal data or information etc., Senora AIF and its affiliates and their directors, officers, employees will not be responsible/ liable.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of data transmitted to our websites and any transmission is at your own risk.
Amendments/Modifications
This Policy available on our website is current and valid. However, the AMC reserves the right to amend/modify any of the sections of this policy at any time and the clients / customers / investors are requested to keep themselves updated for changes by reading the same from time to time.
Retention of information / data / Personal Information
It may be noted that we may retain the data / Personal Information as may be provided by the client / investors / customers till such time as may be provided under the law and as required to efficiently provide service to the clients / investors / customers.
Grievance Redressal
If investors / customers / clients have any concerns relating to their Personal Information / personal and sensitive information and / or require any sharing / rectification / review / access to the same, they may be addressed to our Investor Relations Officer as per the details below.
Name: Mridul Jalan
Contact no.: 9137056225