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Privacy Policy

Effective Date: April 01, 2021
 
Welcome to Sage Capital!
 
Sage Capital (hereinafter referred to as "Sage Capital," "we," "us," or "our") is an AMFI Registered Mutual Fund Distributor with ARN-177251 registered under its Proprietor Nikhil Satish Gupta. Sage Capital is a proprietary micro enterprise registered under the MSME Act, 2006, with Udyam Registration Number: UDYAM-MH-18-0051482, owned and operated by Nikhil Satish Gupta (hereinafter referred to as "the Proprietor").
 
We are deeply committed to protecting the privacy and confidentiality of your personal and financial information. This Privacy Policy outlines how we collect, use, store, process, and disclose your information when you access or use our website, mobile application, or any other services (collectively, "Services").
 
By accessing or using our Services, you explicitly consent to the collection, use, processing, and disclosure of your information as described in this Privacy Policy. If you do not agree with the terms of this policy, please do not use our Services.
 
1. Information We Collect
 
To facilitate your mutual fund investments and provide related services, we collect various types of information, including:
 
Personal Information:

  • Contact Details: Name, address, email address, mobile number, telephone number.

  • Identity Information: PAN Card, Aadhaar Card, Passport, Voter ID, Driving License, date of birth, gender, marital status, photograph.

  • Financial Information: Bank account details, Demat account details, existing investments, income details, source of funds, tax information.

  • KYC (Know Your Client) & AML (Anti-Money Laundering) Information: As mandated by regulatory bodies and mutual fund industry standards.

  • Risk Profile Information: Data pertaining to your investment objectives, risk appetite, and investment experience, necessary for suitability assessment.

  • Nominee Details: Information about nominees for your investments.

Technical & Usage Information:

  • Device Information: IP address, device type, operating system, browser type, unique device identifiers.

  • Usage Data: Pages visited, features used, time spent on the platform, navigation paths, referring URLs, clickstream data.

  • Cookies & Tracking Technologies: Information collected through cookies, web beacons, and similar technologies to enhance user experience, analyze trends, and administer the website.

 
Information from Third Parties:

  • We may receive information about you from third-party service providers such as KYC Registration Agencies (KRAs), Asset Management Companies (AMCs), Registrar and Transfer Agents (RTAs), payment gateways, and other financial institutions, where permissible by law and with your consent.

 
2. How We Use Your Information
 
We use your information for the following purposes, which are necessary for facilitating your mutual fund investments and complying with legal and regulatory obligations:
 
To Facilitate and Manage Mutual Fund Transactions:

  • Onboarding and account opening.

  • Conducting KYC and risk profiling for suitability assessment as per AMFI guidelines.

  • Processing your mutual fund purchase, redemption, switch, and SIP/STP/SWP requests.

  • Transmitting your application and transaction requests to relevant AMCs and RTAs.

  • Sending statements, transaction confirmations, and other service-related communications.

To Improve and Personalize Services:

  • Analyzing usage patterns to enhance user experience and optimize our platforms.

  • Developing new services and features based on client needs and market trends.

  • Personalizing content and recommendations for mutual fund schemes that may be suitable for you.

For Legal and Regulatory Compliance:

  • Complying with the AMFI Code of Conduct for Mutual Fund Distributors, SEBI (Mutual Funds) Regulations, 1996, and other applicable SEBI/AMFI circulars and guidelines.

  • Adhering to general data protection principles as per the DPDP Act, 2023, and obligations under the MSME Act, 2006.

  • Fulfilling KYC, AML, and CFT (Combating Financing of Terrorism) obligations.

  • Responding to requests from regulatory authorities (e.g., AMFI, SEBI, RBI), government agencies, or law enforcement as required by law.

  • Maintaining records as per statutory requirements (e.g., AMFI mandates retention of records for specified periods).

  • Detecting, preventing, and investigating fraud, money laundering, and other illegal activities.

For Communication:

  • Sending important updates, alerts, and notifications related to your investments and services.

  • Responding to your queries, feedback, or complaints.

  • Sending marketing communications about mutual fund products and services that may be of interest to you (you may opt-out at any time).

For Internal Operations:

  • Internal auditing, data analysis, and research.

  • Ensuring the security and integrity of our systems and data.

  • Troubleshooting technical issues.

​

3. Disclosure and Sharing of Your Information
 
We understand the importance of your data privacy and will not sell or rent your personal information to third parties. We may share your information only in the following circumstances and for the purposes outlined above:
 

  • With Your Explicit Consent: For any purpose not covered by this Privacy Policy or where specific consent is required by law.

  • Regulatory and Legal Requirements: With AMFI, SEBI, RBI, government authorities, courts, tribunals, or other regulatory/legal bodies as required by law, court order, or to fulfill our statutory obligations (e.g., Anti-Money Laundering disclosures).

  • Mutual Fund Ecosystem Participants: With Asset Management Companies (AMCs) and their Registrar and Transfer Agents (RTAs) for processing your mutual fund transactions and maintaining your folio.

  • Service Providers: With trusted third-party service providers who assist us in operating our business and providing Services (e.g., KYC verification agencies, payment gateways, cloud service providers, IT support, auditors, legal advisors). These third parties are contractually bound to protect your information and use it only for the purposes for which it was shared.

  • Business Transfers: In connection with a merger, acquisition, restructuring, or sale of all or a portion of our assets, subject to confidentiality agreements.

  • For Fraud Prevention and Security: To protect the rights, property, or safety of Sage Capital, our clients, or others, or to prevent financial crime.

 
4. Data Security
 
We implement reasonable security practices and procedures commensurate with the nature of the information being stored, as per applicable Indian laws (including the IT Act, 2000, and rules thereunder, and the principles of the DPDP Act, 2023). Our measures include:
 

  • Technical Safeguards: Encryption of data in transit and at rest, firewalls, secure server environments, access controls, regular security audits, and vulnerability assessments.

  • Organizational Safeguards: Strict internal policies and procedures for data access and handling, employee training on data privacy and security, and confidentiality agreements with third-party vendors.

  • Physical Safeguards: Restricted access to our premises and data storage locations.

 
While we strive to protect your personal information, no method of transmission over the internet or method of electronic storage is 100% secure. Therefore, we cannot guarantee absolute security.
 
5. Data Retention
 
We will retain your personal information for as long as necessary to fulfill the purposes for which it was collected, to provide our Services, to comply with our legal and regulatory obligations (including AMFI's record-keeping requirements), resolve disputes, and enforce
 
our agreements. This period may extend beyond the termination of your client relationship with us.
 
6. Your Rights
 
As a data principal, you have certain rights concerning your personal data, subject to applicable laws and regulations:
 

  • Right to Access: You have the right to request access to your personal information held by us.

  • Right to Correction/Rectification: You can request us to correct or update any inaccurate or incomplete personal information.

  • Right to Erasure/Deletion: You may request the deletion of your personal information, subject to our legal and regulatory obligations (e.g., AMFI's record- keeping requirements).

  • Right to Withdraw Consent: You have the right to withdraw your consent at any time where consent is the basis for processing your personal information. Withdrawal of consent may affect our ability to provide certain Services to you.

  • Right to Grievance Redressal: You have the right to lodge a complaint with our Grievance Officer regarding any privacy-related concerns.

 
To exercise any of these rights, please contact our Grievance Officer using the details provided below. We will respond to your request in accordance with applicable laws.
 
7. Cookies and Tracking Technologies
 
We use cookies and similar tracking technologies to collect information about your Browse behavior on our website and mobile application. Cookies are small data files stored on your device. They help us:
 

  • Remember your preferences.

  • Analyze website traffic and usage patterns.

  • Improve the performance and functionality of our Services.

  • Deliver relevant content and advertisements.

 
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. However, if you disable or refuse cookies, some parts of our Services may become inaccessible or not function properly.
 
8. 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 business operations. Any changes will be effective immediately upon posting the revised Privacy Policy on our website. We encourage you to review this policy periodically to stay informed about how we are protecting your information. Your continued use of our Services after any changes indicates your acceptance of the updated Privacy Policy.
 
9. Grievance Officer
 
If you have any questions, concerns, or complaints regarding this Privacy Policy or our data practices, please contact our Grievance Officer:
 
Name: Nikhil Gupta Email: contactus@sagecapital.in
 
We will endeavor to resolve your concerns in a timely and effective manner.

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