In the course of using this website or any of the websites under the ‘Manalitrading’ domain and/or belonging to Manali Trading and Holdings Private Limited (hereinafter shall be referred together as ‘MTHPL’), for availing any of the products/services and/or data/information vide the online platform, web services, application forms, questionnaires, consents and such other details required from time to time on any of MTHPL’s (and/or its affiliates) web platforms or mobile applications, MTHPL and/or its affiliates may become privy to some of your personal information, including which may or may not be of confidential nature. MTHPL is strongly committed to protecting the privacy of its users/clients and has taken all necessary and reasonable measures to protect the confidentiality of any customer information.

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For the purpose of these Privacy Policy, wherever the context so mentions “Covered Persons”, "Client", "You" or "Your”, it shall mean any natural or legal person who has visited this website/platform and/or has agreed to or has enquired open an account and/or initiated the process of opening an account with MTHPL (also defined as “Covered Persons”).

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MTHPL allows any person to use/visit/browse the website without registering on the website. Also, the terms "We", "Us" or "Our" shall mean MHTPL.

 

Access to your MTHPL account and the usage of your account is subject to your compliance with all the terms and conditions set forth herein, read along with all documents, including but not limited to, applications forms and undertakings, signed by you during account opening and subsequently from time to time (if any), and any terms/consents/policies included on MTHPL’s website/domain, i.e. https://manalitrading.com/, including its “Terms and Conditions”, “Policies & Procedures” and “Disclosure”.

 

Scope of this Policy

Any natural or legal person who has visited the MTHPL website/platform and/or the mobile application, and/or who may or may not have further agreed to initiate the process of opening an account with MTHPL shall come under the purview of the scope of this Privacy Policy. MTHPL shall at all times follow all such rules prescribed under the Information Technology Act, 2000, and rules & procedural guidelines set by the Securities Exchange Board of India (“SEBI”) and/or any of its regulated entities/intermediaries that MTHPL is a member of.

 

Collection and use of your personal information

MTHPL may or may not collect your Personal Information to provide services on its web-based platform or mobile application. While opening a trading and demat account with MTHPL, you may be asked for certain Sensitive Personal Data or Information (as defined under the Information Technology Act, 2000) to complete your KYC (as per the ‘Know Your Client’ requirements set by SEBI) and as per the Prevention of Money Laundering Act, 2002.

MTHPL, may or may not, request for sensitive information from You at the time of account opening, which would include but not be limited to; (i) setting a password (ii) financial information such as Bank account or credit card or debit card or other payment instrument details (iii) information such as name, contact number, gender, date of birth, residence and employment addresses, name of father/mother/spouse, bank account details, scans/copies of document/proofs of address & identity such as photograph, PAN Card, passport, driving license, Aadhaar Card, etc. (iv) uploading signature proof/photo, etc. All such information would be for the purpose of identity verification and background checking for account opening as per KYC & PMLA Rules, personalising services offered to you, keeping you updated of our products and services relevant to you, information pertaining to our services you’ve subscribed to, and for any legal and regulatory / audit purposes.

 

Under Regulation 5 of the Information Technology (Reasonable Security and Procedures and Sensitive Personal Data or Information) Rules, 2011, MTHPL is obliged to provide every registered user of MTHPL with a readable copy of the personal information you have provided us.

 

We would save such information as required by the law, and as directed by the regulators along with such intermediaries regulated by them, for the purpose of offering you our services and for such further regulatory, audit, and business purposes. We collect Personal Information from you only when you voluntarily use the services provided by MTHPL and/or enquire to begin an association with MTHPL and/or complete the process of opening an account with MTHPL.

 

If MTHPL choose to sell, transfer, merge or otherwise reorganise part/s of our business/assets, we shall share your personal data with the new/incoming owners who may use your personal data in the same/similar way as set out herein.

 

With regard to security, we respect all information provided to us, and take all reasonable steps towards protection of the same. We have implemented technology and policies, with the objective of protecting your privacy from unauthorised access and improper use, and periodically review the same. We maintain procedural safeguards to protect the confidentiality and security of personally identifiable information transmitted to us.

 

Aadhaar user consent policy

Voluntary Act

The act of providing your Aadhaar is voluntary in nature, which may be required for completing your account opening procedure and for digitally signing the MTHPL account opening related forms. Your Aadhaar may also be used as a proof of address as an alternative choice to driving license or Passport copy, which is a voluntary decision to be made by you. Please note that opening of account by physically signing all such account opening documents does not require you to share your Aadhaar information at all.

 

Collection and use of your non-personal information

MTHPL may from time to time collect information, i.e. Non-personal information which cannot be used to identify you personally, while you are using the website or mobile application. MTHPL may from time to time collect information such as Non-personal information such as IP (internet protocol) addresses, browser types, the name of your ISP (internet service provider), information about a third party link/URL from where You arrive to our website/mobile application, which pages/URLs do you click on the MTHPL website / mobile application, and the amount of time spent on each.

 

Usage of Cookies

MTHPL may, from time to time, use cookies. Cookies are small data files that a website stores on your computer. MTHPL may use persistent cookies which are permanently placed on your computer to store non-personal (Browser, ISP, OS, Clickstream information etc) and profiling information (age, gender, income etc). While cookies have unique identification nos., personal information (name, a/c no, contact nos., etc.) shall not be stored on the cookies. We will use the information stored in the cookies to improve your browsing experience on our website, by throwing up relevant content where possible. We will also use the cookies to store visitor preferences to ease visitor navigation on the site.

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Disclosure and transfer of collected information

MTHPL does not share any of your information with third parties except: (i) with respect to providing the information or services that you have requested earlier, (ii) or with your express permission for sharing such information, or (iii) with intermediaries/applications who require such information as per regulatory requirements and procedure laid down by SEBI/Exchanges.

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Under no circumstances will we sell or rent your personal information to anyone, for any reason, at any time. MTHPL has taken best and reasonable steps to ensure prevention of any unauthorised disclosure of your sensitive personal information.

 

Disclosure for regulatory compliances: MTHPL will share your information with judicial, administrative and regulatory entities to comply with any legal and regulatory requirements.

 

Disclosures with your prior consent: If, at any time, you choose to utilise the integrated services of third party service partners through us, we will share your information with these third party service partners with your prior consent.

 

Disclosure for provision of services: MTHPL will share your information with third party vendors of MTHPL as necessary for the provision of services. Authorised third party vendors will be 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 unauthorised disclosure of your personal information.

 

Security

Our hosting services and servers maintain its systems in accordance with industry standards and best practices to reasonably secure the information of its customers, such as using SSL encryption in certain places to prevent eavesdropping and employing up-to-date software on the server. However, no data transmission over the Internet can be guaranteed to be 100% secure. “Perfect security” does not exist on the Internet, and therefore you shall be using the website and mobile application at your own risk.

 

Your data is transmitted between your device and our servers using HTTPS protocol for encryption. HTTPS is the technology used to create secure connections for your web browser, and is indicated by a padlock icon in your browser.

 

MTHPL follows industry best practices, using open and known principles when transferring and storing your data. We believe the biggest threat to the security and privacy of your data is if someone gains access to any of your devices. Remember to keep your password safe and secret to prevent unauthorised access to your MTHPL account. If you think that the security of your MTHPL account has been compromised, change your password and contact us immediately for further assistance.

 

Correction/Updating or Access to Personal Information

In case of any changes with respect to any of your information, especially if Personal Information has been changed or in case you would not like to continue the services of MTHPL, then you would be required to either update your Personal Information or unsubscribe from any updates/information with respect to notifications on the products/services that you had earlier utilised or enquired upon at MTHPL. In case you would like to modify/delete any details with respect to your Personal/Non-personal information or to access your information in readable format, you would have to write/mail to us.

 

Subject to Change

This Privacy Policy has been adopted by MTHPL and is subject to change and may be reviewed, updated or revised from time to time, without any prior notification to the User, at the sole discretion of MTHPL. It is the responsibility of the User to periodically review the Privacy Policy to determine whether there have been any revisions or updates.

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If you do not agree with the terms of this Privacy Policy or any changes made to this Policy, please stop using all products and services provided by MTHPL immediately and write/mail to us.

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Disclaimer: Since MTHPL cannot control the privacy policy/ies of any third party/ies, MTHPL shall not be responsible for any non-compliance with respect to disclosure of information done by such third party/ies and thus MTHPL shall not be held liable and/or accountable for the same.