PRIVACY POLICY
“Muni Broking House Limited,” is a Public Limited Company, having CIN: U66120WB2023PLC260758 and its registered office at Siddha Weston, 4th Floor, Room No. 429, 9, Weston Street, Kolkata, West Bengal – 700013 (hereinafter referred to as “Company”). The term “MUNI”, “We”, “Us” and “Our” shall mean “Muni Broking House Limited.” The Company owns and operates the website https://munibroking.com/ and/or the mobile application ‘Muni’ (collectively referred to as the “Platform”). MUNI is a Trading Member of NSE, BSE and MCX, registered with Securities & Exchange Board of India (“SEBI”) and having Registration No. INZ000316338.
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 MUNI.
In the course of using this website or any of the websites under the ‘MUNI’ domain or availing the products and services vide the online application forms and questionnaires, online consents and such other details required from time to time on any of web platforms or mobile applications, MUNI may become privy to some of Your personal information, including which may or may not be of confidential nature. We are committed to protecting Your privacy and the information You share with Us while using and operating the Platform. We value the trust You place in Us and thus We maintain the highest security standards for securing the transactions and Your information.
Scope of this Policy
Any natural or legal person who has visited the 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 MUNI shall come under the purview of the scope of this Privacy Policy. By accessing the Platform and/or using the Services, You accept and agree to be bound by the terms and conditions of this Privacy Policy. This Privacy Policy is incorporated into and shall be subject to the Terms & Conditions of the Platform (“Terms”). The Privacy Policy shall be read harmoniously and in conjunction with the Terms.
This Privacy Policy (i) is an electronic record under the Information Technology Act, 2000 read with rules and regulations made thereunder and is generated by a computer system; and (ii) will not require any physical, electronic, or digital signature. MUNI 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 MUNI is a member of.
In case of any non-compliance of the Privacy Policy by You or any of your representatives, We shall have the right to terminate Your access to the Services or any part thereof or Your usage rights to the Platform immediately or remove non-compliant information or both, as the case may be.
Collection and use of your personal information
MUNI 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 MUNI, 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.
MUNI, 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, father’s/mother’s and spouses names, bank account details, scans/copies of document proofs of address & identity such as Photograph, PAN, passport, driver’s license, Aadhaar (voluntarily) 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 & AML 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, MUNI is obliged to provide every registered user of MUNI 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 MUNI, and/or enquire to begin an association with MUNI and/or complete the process of opening an account with MUNI.
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 unauthorized 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.
All information disclosed by You including but not limited to Your Personal Information, Non-Personal Information, User Information and Transaction Information shall be deemed to be disclosed willingly and without any coercion. No liability pertaining to the authenticity/ genuineness/misrepresentation etc. of Your Personal provided to Us or with regard to any fraud or negligence thereof shall lie on the Company nor will the Company be in any way responsible to verify any information obtained from You.
Wherever possible, while providing the information to Us, We indicate which fields are mandatory and which fields are optional for You. You always have the option to not provide the Personal Information to Us through the Platform by choosing to not use a particular Service or feature being provided by Us on the Platform, which requires You to provide such information.
Aadhaar user consent policy
Voluntary Act
The act of providing your Aadhaar is voluntary in nature, which will only be required for completing your account opening procedure online and for digitally signing the MUNI account opening form. Your Aadhaar may also be used as a proof of address as an alternative choice to drivers license or Passport copy, which is a voluntary decision to be made by You.
You may alternatively choose to go through the offline route of account opening by physically signing all such account opening documents, which does not require you to share your Aadhaar information at all.
MUNI does not store any Aadhaar information
During your online account opening process, you do not input any Aadhaar details on the MUNI platform. You would be issuing your Digital Aadhaar to Digilocker, from where MUNI (MUNI is registered as a Requester on the Digilocker platform) would receive information, based on your consent to allow Digilocker to share such information with MUNI, limited to: (1) The last four digits of your Aadhaar / VID (Virtual ID created on the UIDAI website), (2) Full Name, (3) Date of Birth, (4) Gender, (5) Address, and (6) Your Photo.
Digilocker is a part of the National eGovernance Division under the Ministry of Electronics & Information Technology (MeitY), Government of India. The Digital Aadhaar issued within DigiLocker is the same as the eAadhaar issued by UIDAI (https://eaadhaar.uidai.gov.in). DigiLocker has partnered with UIDAI to make it available automatically to its users when they link their DigiLocker account with Aadhaar. This act of issuing an eAadhaar within Digilocker and subsequently Digilocker sharing the information limited to the above points, leads to behaving as a physical KYC. MUNI only receives information limited to the above points for the purposes of completing KYC of clients online.
All clients may alternatively follow the offline route of account opening, which does not require sharing any Aadhaar related information.
During your online account opening process, you would also be sharing your Aadhaar with Digiotech Solutions Pvt. Ltd. for the purpose of digitally signing the MUNI account opening form. Digiotech Solutions Pvt. Ltd. does not share your Aadhaar with MUNI. After the account opening form has been digitally signed by you, a copy of the digitally signed form would be emailed to you and to MUNI for reference/audit purposes. Digiotech Solutions Pvt. Ltd. is a licensed e-Sign ASP (Application Services Provider) with CDAC, compliant with the guidelines laid down by the Controller of Certifying Authorities (CCA), India and UIDAI, to enable you to eSign the account opening forms online.
Sharing of Information
You hereby specifically agree and provide Your consent thereby enabling Us to access, store, transfer, process your SMS data for the purpose of reviewing your profile or doing internal evaluation and analysis. Further We may also share Your SMS data with third parties such as Banks, NBFCs, Billers/Utility Service providers etc towards the services offered and You hereby give Your consent for the same
You further understand that MUNI may have access to and process your SMS data for the purpose of streamlining Your usage of the Platform. You understand that MUNI may gain such access through relevant encryption methodologies such as hashing and will utilise such SMS data only for the limited purposes set out under this Privacy Policy.
The Company may disclose Your information, to the extent necessary:
(i) to comply with laws and to respond to lawful requests and legal process,
(ii) to protect the rights and property of the Company, Our users, and others, including to enforce the Terms, and
(iii) in an emergency to protect the personal safety and assets of the Company, the users, or any person. In such an event the Company is in no manner responsible for informing You or seeking Your approval or consent.
Collection and use of your non-personal information
MUNI 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. MUNI 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 MUNI website / mobile application, and the amount of time spent on each.
MUNI uses Google Analytics, a web analytics service provided by Google, Inc. Google Analytics uses first-party cookies to report on user interactions with our web-based services. These cookies store non-personally identifiable information.
Usage of Cookies
MUNI may from time to time use cookies. Cookies are small data files that a website stores on Your computer. MUNI 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.
Connecting your email account
You hereby choose to provide Your explicit consent to connect/integrate Your email account(s) with Your account on the Platform by clicking on the authentication email sent by the Company on Your registered email address. You will be expressly asked in each case whether You want to connect Your email address with Your account on the Platform. You can also choose to enable Our access to one or more of Your email accounts by connecting such account(s) with Your account on the Platform.
We may upload Your image on our platform for app functionality and You hereby give Your consent for the same.
Such data obtained by this integration will be used by the Company solely for providing the Services and improving Your experience of the features of the Platform and to consolidate your investment details and history. The Company hereby agrees and acknowledges that it shall not use or transfer any data or information received from the integration of the email addresses with the account on the Platform to third parties for serving ads, including retargeting, personalized, or interest-based advertising.
We encourage You to review the information prior to giving Your consent for integration of the email addresses with the account on the Platform. You may at any time opt to de-link Your email addresses connected with the account opened on the Platform, by managing these connections with the options provided on the Platform.
Disclosure and transfer of collected information
MUNI 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.
Under no circumstances will we sell or rent your personal information to anyone, for any reason, at any time. MUNI has taken best and reasonable steps to ensure prevention of any unauthorised disclosure of your sensitive personal information.
a. Disclosure for regulatory compliances: MUNI will share your information with judicial, administrative and regulatory entities to comply with any legal and regulatory requirements.
b. 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.
c. Disclosure for provision of services: MUNI will share your information with third party vendors of MUNI as necessary for the provision of services. Authorized third party vendors 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 unauthorised disclosure of your personal information.
Privacy Statement as per EU-GDPR
MUNI shall implement and fulfil all its obligations under the EU General Data Protection Regulation 2016/679 (“GDPR”). MUNI shall process any personal data we collect from you in accordance with Data Protection Legislation and the provisions of this Policy.
We are permitted to process your personal data in compliance with Data Protection Legislation by relying on one or more of the following lawful grounds:
1) You have explicitly agreed to us processing such information for a specific reason.
2) The processing is necessary to perform the agreement we have with you or to take steps to enter into an agreement with you.
3) The processing is necessary for compliance with a legal obligation we have.
4) The processing is necessary for the purposes of a legitimate interest pursued by us, which might be: to provide services to you; to ensure that Your trading & demat account products/services are running smoothly;
5) To prevent, detect, investigate and prosecute fraud and alleged fraud, money laundering and other crimes and to verify your identity in order to protect our business and to comply with laws that apply to us and/or where such processing is a contractual requirement of the services you have requested;
6) To ensure that complaints are investigated;
7) To evaluate, develop or improve our services; or
8) To keep our customers informed about relevant services, unless you have indicated at any time that you do not wish us to do so.
You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. However, if you select this setting you may be unable to access certain parts of our website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you log on to our site.
The designated Data Protection Officer for the purposes of this GDPR shall be the Compliance Officer.
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 use 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.
MUNI 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 MUNI account. If you think that the security of your MUNI account has been compromised, change your password and contact us immediately for further assistance.
This Privacy Policy and the security controls and practices implemented by Us to Protect Your Personal Information shall be the reasonable security practices and procedures under Section 43A of the Information Technology Act, 2000.
You shall not host, display, upload, modify, publish, transmit, store, update or share any information that:
1) Belongs to another person and to which You do not have any right.
2) Is obscene, pornographic, paedophilic, invasive of another’s privacy including bodily privacy, insulting or harassing on the basis of gender, racially or ethnically objectionable, relating or encouraging money laundering or gambling, or promoting enmity between different groups on the grounds of religion or caste with the intent to incite violence.
3) Is harmful to child.
4) Infringes any patent, trademark, copyright or other proprietary rights.
5) Deceives or misleads the addressee about the origin of the message or knowingly and intentionally communicates any misinformation or information which is patently false and untrue or misleading in nature.
6) Impersonates another person.
7) Threatens the unity, integrity, defence, security or sovereignty of India, friendly relations with foreign States, or public order, or causes incitement to the commission of any cognizable offence, or prevents investigation of any offence, or is insulting other nation.
8) Contains software virus or any other computer code, file or program designed to interrupt, destroy or limit the functionality of any computer resource.
9) Violates any law for the time being in force.
Correction/Updating or Access to Personal Information
In case of any changes with respect to any of your information, especially Personal Information has been changed or in case you would not like to continue the services of MUNI, 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 MUNI. 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 to: compliance@munibroking.com or to the address: Muni Broking House Limited, Siddha Weston, 4th Floor, Room No. 429, 9, Weston Street, Kolkata, West Bengal – 700013.
Your Consent and Changes to Privacy Policy
Your Consent: By visiting the Platform or setting up/creating an account on the Platform for availing the Services on the Platform at such time, You signify Your acceptance to the provisions of the Privacy Policy.
Account Deletion: You may choose to delete your account on the Platform and any information associated with it, hereunder at any point of time. Such a request for deletion must be sent in writing to compliance@munibroking.com. In the event that You make a request for deletion of Your account or data, you will no longer be able to access the Platform and/or use the Services, and we reserve the right to not provide You any Services through the Platform. In the event of your request, We may delete Your information (Personal or otherwise) or de-identity it so that it is anonymous and no longer attributable to You. Notwithstanding anything contained herein, We may retain some or all of Your information in accordance with our policies and/or requirements under applicable law.
Changes to Privacy Policy: This Privacy Policy is subject to change and may be updated or revised from time to time, without any prior notification to the User, at the sole discretion of MUNI. It is the responsibility of the User to periodically review the Privacy Policy to determine whether there have been any revisions or updates. Your continued usage of the Platform shall signify Your consent to such changes and You shall be legally bound by the same.
Grievance Officer
If You have any grievance with respect to the Platform, please feel free to reach out to the grievance officer, the name and contact details have been provided below:
Name: Dipak Tibrewal
Email: compliance@munibroking.com
Governing Law & Jurisdiction
This policy will be governed by and construed in accordance with the laws of India and subjected to the exclusive jurisdiction of Courts of Kolkata.