PLEASE READ THIS PRIVACY POLICY CAREFULLY. THIS PRIVACY POLICY DESCRIBES THE WAY AKTA CAPITAL ADVISERS LLP (“WE”, “US” OUR”) COLLECT, STORE, SECURE AND USE YOUR PERSONAL INFORMATION.

THE DOMAIN NAME (www.modelfunds.com) (HEREINAFTER REFERRED TO AS "WEBSITE") IS OWNED AND MANAGED BY AKTA CAPITAL ADVISERS LLP, A LLP INCORPORATED UNDER THE LAWS OF INDIA HAVING REG. NO. AAT-7865, AND ITS REGISTERED ADDRESS AT C/O GAUTAM HARSHADRAI DESAI, HILLA HOUSE, NEAR ICICI BANK, TITHAL ROAD, VALSAD, GUJARAT-396001, INDIA.

THROUGHOUT THIS PRIVACY POLICY, “YOU” REFERS TO THE PERSONS ACCESSING AND USING THE WEBSITE www.modelfunds.com. AKTA CAPITAL ADVISERS LLP’S AFFILIATES INCLUDES www.modelfunds.com. YOU ACCEPT THIS PRIVACY POLICY AND THE CONTENTS THEREOF BY CLICKING ON “I ACCEPT” ON OUR WEBSITE www.modelfunds.com as the case may be (hereinafter referred to as the “website”).

1. General
   1. We are committed to protecting your privacy and respecting your privacy and the protection of the Personal information provided by You.

      For the purposes of this Privacy Policy, “Personal Information” or “Personal Data” shall mean any information that identifies or can be used to identify, contact or locate the person, to whom such information pertains, including, but not limited to, name, address, date of birth, phone number, fax number, email address, PAN, Aadhaar number, driving license/ passport/ voter identity card/ government issued identification card, e-KYC, demographic information, photographs, video recordings, oral or written communications, biometric information, digital signature keys, bank account, credit/debit card information, passwords, and other personal information required by us for the purpose of providing research analyst services through our website.

   2. We are committed to keeping your Personal Information confidential and will only give it to others for the purposes set out in this Privacy Policy.
   3. This Privacy Policy explains how and why your Personal Information is collected, through the use of our website. You agree that your use of the website implies your consent to the collection, retention, suitable modification and use of your personal information in accordance with the terms of this Privacy Policy.
   4. This Privacy Policy is to be treated as an electronic form of contract under the Information Technology Act, 2000 and the rules made thereunder, as may be amended, re-enacted or substituted from time to time. This Privacy Policy does not require any physical, electronic or digital signature and is a legally binding document between You and Us.
   5. Our Privacy Policy is regularly reviewed to make sure that we continue to serve your privacy interests. We reserve the right to update this Privacy Policy and these changes will be posted on our website. We will notify you of any changes to this Privacy Policy as required under the applicable laws. The date of last revision appears at the top and all changes take effect immediately upon posting.
   6. Access to the contents or the website is conditional upon your approval of this Privacy Policy which should be read together with the Terms and Conditions of use (“T & C”) and Disclaimer which can be accessed here (T&C) and (Disclaimer) respectively. You acknowledge that this Privacy Policy, together with Our T & C and Disclaimer, forms our agreement with you in relation to your use/access of the website. (“Agreement”).
2. Collection and Use of Personal Information
   1. When You use the Website, We collect and store the Personal Information provided by You from time to time, in compliance with applicable laws. The primary aim in doing so is to provide You with a safe, efficient, customized, and required experience while using the Website, and to enable to you the provision of services available through the website, and to verify your identity and other information that You provide.
   2. If You opt to create an account with the Website, for registration purposes we may collect information including but not limited to your name, email address, postal address, telephone or mobile number, gender date of birth, PAN, personal information stored with third parties such as social media sites (such as Facebook or Twitter), photographic identification and proof of address documents (to carry out due diligence), banking, financial & payment details, your account login details, such as your username and password.
   3. During your use of the website, we may collect information to track your behavior and pattern while using Our website. This is to give You an enhanced and better experience in using the Website.
   4. We may collect any information regarding the type of devices used by You to access our Website including but not limited to operating system, browser type, geolocation information.
   5. If We collect any Personal Information about someone else, then We shall not do so without their permission. Where We collect any Personal Information about a third party through You, or by a third party about You, it may be added to any Personal Information that is already held by Us and it will be used in the manner described in this Privacy Policy.
   6. We use cookies in order to remember your preferences, tracking your interests, facilitating your payment transactions and to provide a customised experience of using the Website. “Cookies” are small text files that are stored on your computer or other device when You visit certain online pages that record your preferences and actions. Most web browsers automatically accept cookies, but, if You prefer, You can usually modify your browser setting to decline cookies. However, please note that refusing a cookie may limit your access to the website and its services/features. Any kinds of cookies may be used in order to make sale on the Website in the most efficient manner.
   7. We may use other tools like Google Analytics, a web analytics service provided by Google, Inc. Google Analytics uses first-party cookies to report on user interactions with our website. These cookies store non-personally identifiable information. We may use this information to identify the most popular areas of interest and how to best present and customize them. We may use the unique identifier of your device for security purposes to track suspicious activity. For instance, if We detect that your account is being accessed from multiple devices, We may contact You to ensure that You have authorized such access. Under no circumstance will your email address, password and any financial data be collected by or shared with Google Analytics. For more information about how Google handles technical information, please visit the site, "How Google uses data when You use our partners' sites or apps", (located at: www.google.com/policies/privacy/partners). Provided that, the privacy policy of Google shall be in addition to but not in derogation to any of the clauses of this policy.
   8. We may occasionally ask You to complete optional online surveys. These surveys may ask You for contact information, preferences, routine needs & requirements and demographic information (such as PIN code, age, gender, financial health/habits/preferences, etc.). We use this data to customize your experience on the Website, providing You with content that We think You might be interested in and by displaying content according to your preferences, needs and requirements.
   9. We may record, save and retain with us the written, verbal, audio or visual communication You do, in the course of using our website, and we may use them or share (only after making suitable modifications to remove identification traits), only for staff training, quality checks, combating frauds and other legally permitted educational purposes. AKTA CAPITAL ADVISERS LLP shall endeavor to ensure that such records are kept adequately secured and no one shall ever be allowed to use, access, or share the abovementioned records for the purposes other than those specified hereinabove. You may not allow AKTA CAPITAL ADVISERS LLP to use your abovementioned private information/record, by not accepting to this Privacy Policy.
   10. By providing your email and phone number to us, You are authorizing us, Our representatives and our affiliates to communicate with You through various modes like call, email or other audio-visual means to offer You Our services, marketing material about products, promotional offers offered by Our Website. Irrespective of the fact that You have registered yourself under Do Not Disturb (“DND”) or Do Not Call (“DNC”) service, You are still authorizing us, Our representatives and Our partners to communicate with You for the abovementioned purposes. There is no DNC check required for a number You leave on Our Website or with Our agents. If You wish to opt-out receiving such communication from Us You can do so by sending Us an e-mail at info@modelfunds.com.
   11. If You send Us personal correspondences, such as emails or letters, or if other users or third parties send Us correspondence about your activities or postings on the Website, We may collect such information into a file specific to You.
   12. If You telephone Us, We may also record and/or monitor calls for quality checks and staff training. Such recordings may also be used to help Us combat fraud.
3. Our Policy concerning children
   1. We will not knowingly solicit or collect personal data from children below the age of (18). If We discover that We have unintentionally collected personal data from a child below (18), We will remove that child's personal data from Our records promptly. However, We may collect personal data about children below the age of (18) years of age from the parent or guardian directly, and with that person's consent.
   2. In case We detect personal data submission from children using different tools and cookies, We will inform (via email or phone) the child user to get permission from their parents or legal guardians. If We do not receive a confirmation on the action required from their parents or legal guardians within 15 (fifteen) days, we will delete the user personal data.
   3. We will not share marketing information with children below (18) years of age and any information regarding such children, if shared with any third parties will require the parents/ legal guardians’ consent to share such information. Their parents/ legal guardians’ may not give Us the consent to collect, use or share their child's information, by not agreeing to the terms of this Privacy Policy.
   4. However, We will not be responsible for cases where the parental supervisions are missing or the child uses the Website by misrepresenting as being an adult.
4. Disclosure and Sharing of Personal Information
   1. We will keep your Personal Information confidential and only share it with others for the purposes stated in this Privacy Policy. We have trusted relationships with carefully selected banking and financial entities (whose service We avail) or other third parties or our affiliates (who work with us to enable us to perfom research analyst activities), some of which may be located within or outside of India. Examples of service providers we use are payment processors, email service providers, providers of hosting services, routine advisers, etc. All service providers & affiliates are required to maintain the security of your Personal Information and to use it only as permitted by Us and they must comply with the security practices and procedures as maintained by Us as set out in this Privacy Policy.
   2. Disclosure of Information. Under no circumstance will We sell or rent your Personal Information to anyone, for any reason, at any time. We use authorized third party service providers who are bound by the same standards of data security practices and procedures as We are under law and contract. They are subject to the same penalties as We are for the unauthorized disclosure of your Personal Information. However, under Indian law, We remain liable to You, Our customer, for any unauthorized disclosure of your Personal Information.
   3. We may share your Personal Information:
      1. To transfer data, personal information etc. with any banking or financial entity or third-party firm.
      2. To analyze usage of the Website or to improve the product or service mechanism.
      3. To send communications relevant to your use of website or research analyst activities.
      4. In relation to research, to effectively control against error, fraud or other criminal activity and to improve our services or products.
      5. To enforce Our T & C.
      6. To any person who has told Us and who We reasonably believe to be your parent, carer or helper where You are unable to handle your own affairs because of mental capacity, being a minor or other similar issues.
      7. To any person to whom We sell or transfer (or enter into negotiations to sell or transfer) or with whom We merge Our business or any of Our rights or obligations under any agreement. If the merger, transfer or sale consummates, the transferee or purchaser may use your Personal Information in the same way as Us.
      8. To regulators, ombudsmen, or other authorities, including tax authorities, including those overseas, where We are requested by them to do so.
      9. To other Government, regulatory or other authorities, as may be required under applicable laws.
   4. The Personal Information shared by You may be used to perform background checks on your identity and your fitness to access the website and purchase/take/avail our products/services.
5. Security Precautions
   1. Security measures (physical, electronic and managerial) are in place to protect You against the loss, misuse, and alteration of the Personal Information under Our control. We store Personal Information in encrypted form on computers and control access via secure web pages. We employ firewalls and other security technologies to protect Our servers from external attack. Access to the Website’s server is restricted to authorized personnel and shared with employees strictly on a ‘need to know basis’. We shall also promptly notify You and take protective measures, if any security breach is made known to Us in relation to unauthorized access to your Personal Information.
   2. Our security systems meet or exceed industry standards and We are constantly monitoring internet developments to ensure Our systems evolve as required. However, while We strive to use commercially acceptable means to protect your Personal Information, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, by using this Website, You agree that We will have no liability for disclosure of your Personal Information due to errors in transmission, infrastructure failures by Us or any intermediary (including telecom and internet service providers), or unauthorized acts of third parties which may be beyond our control.
6. Opting Out
   1. We will generally retain your Personal Information for as long as needed to provide You with details of Our products/services. If You change your mind, and don’t wish to remain on Our contact list, just let Us know at info@modelfunds.com.
   2. You may at any time opt-out from receiving mails relating to such promotions/surveys, by emailing Us at info@modelfunds.com. In addition, whenever We send You a non-essential email communication, You can optout of similar future mailings by simply clicking on a link provided in the e-mail message.
   3. As part of the registration process, We ask You whether We may contact You about Our products/services/activities by telephone, post, email and SMS (or other reasonable method). If You ticked “yes” but no longer wish to receive such communications, please contact Us on info@modelfunds.com.
   4. You have the right to withdraw your consent to Our Use of your Personal Information at any time where We rely on your consent to use or process that information by sending an email to info@modelfunds.com. In such case, the Website may not be in a position to provide the required details/access.
7. Grievance Officer
   1. In accordance with the Information Technology Act, 2000 and the rules made thereunder, the name and contact details of the Grievance Officer are provided below in the event You have any questions or complaints regarding Our Privacy Policy or practices:

      Name of Grievance Officer: Kaushik Patel

      E-mail of Grievance Officer: Kaushik@aktaconnect.com

      Contact No. of Grievance Officer: +91.9824503572

      We are committed to providing a first response within 24 hours of receiving the complaint, and We aim to resolve all complaints within 3 (three) business days. Any delay in the resolution time shall be proactively communicated to You. If You do not hear back from Us within a week’s time, please do write to Us at info@modelfunds.com for escalation of your specific complaint to the relevant grievance redressal officer.

8. Our Legal Obligations
   1. This Privacy Policy is published on the Website in compliance with Regulation 4 of the (Indian) Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information) Rules, 2011.
   2. We are bound by the (Indian) Information Technology Act, 2000, and comply with all its provisions available at https://indiacode.nic.in/bitstream/123456789/1999/3/A2000-21.pdf. Under Section 43A of the (Indian) Information Technology Act, 2000, www.modelfunds.com and all its service providers and affiliates are obliged to maintain reasonable security procedures to safeguard your Personal Information. Should there be any negligent disclosure of your Personal Information, you have the right to claim compensation from Us.
   3. Under Regulation 5 of the Information Technology (Reasonable Security and Procedures and Sensitive Personal Data or Information) Rules, 2011, We are obliged to provide every user of the Website with a readable copy of the Personal Information You have provided us. If You would like a copy, do get in touch with Us at info@modelfunds.com.
   4. The Websites www.modelfunds.com or other communications of Akta Capital Advisers LLP, might contain links to and from other Web sites. Akta Capital Advisers LLP, is not responsible for the privacy practices or the content of such Web sites.