Privacy Policy

1. Privacy Commitment

Swaraj FinPro Private Limited (ARN-91802), AMFI Registered Mutual Fund Distributor, is committed to maintaining the privacy, confidentiality, and security of personal information collected from investors, employees, and website visitors.

This Privacy Policy explains how we collect, use, store, share, and protect personal data in accordance with the Digital Personal Data Protection Act, 2023 (DPDPA), Information Technology Act 2000, SEBI Master Circulars for Mutual Funds, and AMFI Data Sharing Principles prescribed under the AMFI Master Circular for MFDs dated 14-January-2026.

2. Scope & Applicability

This policy applies to all individuals interacting with Swaraj FinPro Private Limited through our website https://swarajfinpro.com, during client onboarding, Know Your Customer (KYC) verification, risk profiling, and mutual fund transaction processing.

It extends to all employees, sub-distributors, service providers, and vendors authorized to access or process client information on our behalf.

By engaging with Swaraj FinPro Private Limited or accessing our website, you consent to the collection and use of your personal information as described in this policy.

3. Information We Collect

Personal Details:

Name, address, date of birth, PAN, Aadhaar (for KYC), contact details (mobile number, email ID), bank account information, nomination details, and investment preferences.

Financial Details:

Annual income range, net worth, existing investments, risk profile assessment responses, investment horizon, goals, and transaction history.

KYC Documents:

PAN card copy, Aadhaar copy, address proof, photograph, bank statement or cancelled cheque, FATCA/CRS self-declaration, and UBO details (for non-individual investors).

Technical Data:

IP address, browser type, device information, operating system, and cookies when you visit our website.

We do NOT collect unnecessary personal data such as religion, caste, political affiliation, or any data not required for mutual fund distribution services and regulatory compliance.

4. Purpose of Data Collection

Your data is used strictly for:

  • Processing mutual fund transactions
  • Completing KYC and meeting SEBI/AMFI/PMLA regulatory obligations
  • Conducting risk profiling and suitability assessment
  • Sending transaction confirmations, account statements, and service communications
  • Responding to queries and complaints
  • Meeting regulatory reporting requirements to SEBI and AMFI
  • Improving our website functionality and user experience

We do NOT use your data for any purpose other than what is stated above.

5. Data Sharing Rules

We share your data only in the following situations:

  • With AMCs and RTAs: For processing mutual fund transactions (CAMS, KFintech, etc.)
  • With SEBI and AMFI: Upon regulatory request or compliance requirement
  • With auditors: During compliance audits
  • With KRAs: CAMS KRA, CVL KRA, NDML KRA, CKYC for KYC verification
  • With third parties: Only with your explicit written consent

We do NOT sell, rent, lease, or share your personal or financial data with any marketing agency or unrelated third party under any circumstances.

6. Data Storage & Security Measures

  • Data is stored on secure, encrypted systems with two-factor authentication (2FA)
  • Role-based access controls are implemented
  • Physical documents are stored securely at the registered office
  • Employees sign confidentiality agreements
  • Strong password policies and regular security audits are enforced

No client data is stored on personal devices of employees.

7. Data Retention & Disposal

Client records are retained as per SEBI, AMFI, PMLA, and Income Tax regulations.

After the required retention period:

  • Physical records are securely shredded
  • Digital data is permanently deleted

All disposals are documented and require approval.

8. Your Rights Under DPDPA 2023

You have the right to:

  • Access your personal data
  • Request correction of inaccurate data
  • Request deletion (subject to regulatory requirements)
  • Withdraw consent
  • File a complaint with the Data Protection Board of India

To exercise these rights, contact: marketing@swarajfinpro.com

9. Cookies

Our website uses cookies to enhance user experience and analyze traffic.

You can disable cookies through browser settings, but some features may not function properly.

10. Third-Party Links

Our website may contain links to external websites (AMC, SEBI, AMFI, etc.).

Swaraj FinPro Private Limited is not responsible for their privacy practices or content. Users are advised to review their policies separately.

11. Changes to This Policy

We may update this Privacy Policy periodically.

The latest version will always be available on our website. Users are encouraged to review it regularly.