Privacy Policy

1.About Us and Scope of This Policy

Jarfin is a mutual fund distributor duly registered with the Association for Mutual Funds in India (“AMFI”), bearing AMFI registration number: ARN-282924. Jarfin facilitates investment in mutual fund schemes through the Platform on an execution-only basis. Jarfin acts solely as a distributor between You and the Mutual Fund and its Asset Management Companies ("AMCs") and it does not manage, advise upon, or guarantee any mutual fund scheme or return. The Platform is owned, operated and managed by Jarfin.

Any natural or legal person who has visited the Platform, and/or who is in the process of or has agreed to initiate the process of opening an account with Jarfin to avail the Services shall come under the purview of the scope of this Privacy Policy.

Your account is subject to Your compliance with all the terms and conditions governing the Platform, read along with all documents, disclosures, including but not limited to applications forms and undertakings executed by You during account opening, and any terms/consents/policies included on the Platform including the Terms and Conditions available at sipse.in/terms.

2.Collection and Use of Your Personal Information

Jarfin collects your personal information in the course of providing, improving and facilitating Services on its Platform. While opening an account with Jarfin to avail the Services, You will be asked for certain sensitive personal data or information including to complete Your ‘Know Your Client’ (“KYC”) requirements set by the Association of Mutual Funds in India) and other applicable law requirements.

The information Jarfin collects includes but is not 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 full legal name, contact details (email address, mobile 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 and identity such as photograph, permanent account number (PAN) card, passport, driver’s license, Aadhaar, etc.; (iv) uploading signature proof/photograph; and (v) such other information or digital permissions (SMS, camera, gallery, location) as may be required from time to time for the purpose of providing the Services, including investment and transaction details, nominee information, and tax residency information. All such information is collected for the purpose of identity verification and background checks for account opening carried out by Jarfin or authorised third parties appointed for this purpose, personalising the Services offered to You, keeping You updated of Our products and Services relevant to You, information pertaining to our services You have subscribed to, and for any legal and regulatory/audit purposes.

Jarfin would save such information as required by the applicable law, and as directed by the AMFI, regulators along with such intermediaries regulated by them, for the purpose of offering You the Services, and for such further regulatory, audit, business and applicable law compliance purposes. We collect personal information from You only when You voluntarily use the Services provided by Jarfin, and/or enquire to begin an association with Jarfin and/or complete the process of opening an account with Jarfin in relation to the Services.

3.Aadhaar User Consent Policy

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 Jarfin account opening form. Your Aadhaar may also be used as a proof of address as an alternative choice to driver’s license or passport copy, which is a voluntary decision to be made by You.

Where You choose to provide Your Aadhaar for digital account opening, Jarfin uses the DigiLocker facility (operated by the Ministry of Electronics and Information Technology through the National e-Governance Division) as the user-consented mechanism through which You authorise access to Your Aadhaar-derived documents. DigiLocker delivers Your Aadhaar document as a digitally signed document issued by the issuing authority, which satisfies the "original seen and verified" requirement under applicable KYC norms. Jarfin does not conduct biometric e-KYC authentication through the UIDAI portal.

Your Aadhaar number will not be stored or saved by Jarfin in its systems. Where You provide Your Aadhaar document, Jarfin shall ensure that Your Aadhaar number is redacted or blacked out by appropriate means before the document is retained. Jarfin retains only the last four digits of Your Aadhaar number in masked form and the KYC reference identifier issued by the KYC Registration Agency ("KRA"), as required under applicable law. As part of the KYC process, Your KYC information is transmitted to the applicable KRA and, where applicable, to the Central KYC Records Registry ("CKYCR"), in accordance with SEBI's regulatory framework. These disclosures are made pursuant to Jarfin's legal obligations and do not require separate consent from You.

4.Non-Personal Information, Cookies, and Analytics

In the course of Your use of the Platform, Jarfin may from time to time collect information that is non-personal information, technical or behavioural which cannot be used to identify you personally, while You are using the Platform. Jarfin may from time to time collect information such as non-personal information including but not limited to internet protocol (IP) addresses, browser types, the name of your internet service provider (“ISP”), device model and operating system, mobile application version, pages, screens, and features accessed on the Platform, crash logs, push notification tokens, and coarse location data, where You have expressly granted relevant permission on Your device. This information is used to operate, maintain, and improve the Platform and the Services, to detect and prevent fraud and security incidents, and for analytics and product development purposes. Certain other information about a third party link from where You arrive to our Platform is also collected, which pages do You click on the Platform, and the amount of time spent on each.

Jarfin uses Google analytics or such other product analytics service, to analyse user interactions and product engagement on the Platform. These cookies store non-personally identifiable information and Processes such non-personally identifiable behavioural data (such as feature usage, session flows, and event sequences) for the purposes of product improvement and service development.

Jarfin may from time to time use cookies on the web-based version of the Platform. Cookies are small data files stored on Your device by Your browser. Jarfin may use the following types of cookies: (a) Session cookies: Temporary cookies that expire at the end of Your browser session, used to maintain Your login state and enable core Platform functionality; (b) Persistent cookies: Cookies that remain on Your device across sessions, used to store non-personal technical information (browser type, ISP, operating system, and clickstream data) and, where applicable, visitor preferences to improve navigation and content relevance on the Platform and (c) Analytics cookies: Non-personally identifiable cookies used in connection with Our analytics services to understand how users interact with the Platform. While cookies have unique identification numbers, personal information (name, account number, contact numbers, etc.) shall not be stored on the cookies. We will use the information stored in the cookies to improve Your browsing experience on Our Platform, by throwing up relevant content where possible. We will also use the cookies to store visitor preferences to ease visitor navigation on the site.

5.Disclosure and Transfer of Collected Information

Jarfin does not share any of Your information with third parties except: (i) with respect to providing the information or services, (ii) with Your express permission for sharing such information, (iii) for the purposes of Your verification (including KYC), or with AMC, intermediaries, authorised vendors and service providers to facilitate the provision of Services, which may include: (a) AMCs and their authorised RTAs; (b) KYC KRA and the CKCYR; (c) Jarfin's technology service providers; (d) payment gateway service providers engaged to facilitate payment transactions; (e) cloud infrastructure and hosting service providers; (f) communication and messaging service providers; (g) analytics service providers; and (h) such other authorised intermediaries as are necessary for the provision of the Services, or (iv) with such other persons who require Your information as per regulatory requirements and procedures laid down by the law including Securities and Exchange Board of India or AMFI.

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

Disclosure for regulatory compliances: Jarfin will share your information with judicial, administrative and regulatory entities to comply with any legal and regulatory requirements. This may include disclosures required under anti-money laundering law, tax reporting obligations (including FATCA and CRS reporting), SEBI reporting requirements, and cyber incident reporting obligations under applicable law. Jarfin treats Your KYC data, investor identity data, transaction data, and financial information as confidential and non-public information. Such data is shared only with regulated entities for legally required purposes and is not disclosed to any external party for commercial, research, or analytical purposes.

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

We use cloud-based software tools to perform certain business-related functions, including, maintaining databases and servers, processing text messages, phone calls, chats and emails, and marketing and sales analytics. All such cloud-based infrastructure is configured to store and process data within India. Your data is retained by Jarfin or by the authorised third party, acting solely on Jarfin's behalf and subject to Jarfin's written instructions and contractual controls. It is clarified for abundant clarity that any service partners or vendors engaged by Us (including for the aforementioned purposes) are bound by the same standards of data security practices and procedures as we are under law and contract.

Disclosure for provision of Services: Jarfin will share Your information with third party vendors and service providers of Jarfin as necessary for the provision of Services. The authorized third party are bound by the same standards of data security practices and procedures as We are, under law and contract. The authorized third party vendors are also subject to the same penalties as We are, for the unauthorised disclosure of Your personal information.

We are permitted to process Your personal data in compliance with applicable laws (including the data protection legislations) 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 including executing mutual fund purchase, redemption, SIP registration, and switch transactions, and all service communications integral to the distribution relationship;
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 account and the Services availed by You are running properly;
5. To prevent, detect, investigate and prosecute fraud and alleged fraud, money laundering and any other crimes or complaints 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 evaluate, develop or improve Our services; and
7. To keep Our customers informed about relevant services, where You have provided express opt-in consent for such communications. Your data will not be used to market non-AMFI-registered financial products without Your separate specific consent. You may withdraw this consent at any time by opting out through the Platform or by contacting Our customer support.

Jarfin retains Your information for the period necessary to fulfil the purposes for which it was collected and for such additional periods as are required under applicable law. Retention periods are governed by applicable regulatory and statutory requirements, including anti-money laundering record-keeping obligations (which prescribe a minimum retention period of five years and up to ten years in certain circumstances), tax record retention obligations, regulatory grievance record requirements, and technical system log obligations under applicable cyber security directions. Upon the expiry of the applicable retention period, Your information will be deleted or rendered irreversibly anonymised.

6.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 encryption in certain places to prevent eavesdropping and employing up-to-date software on the server.

Your data is transmitted between your device and our servers using due standards and protocols for encryption as is standard through the industry and in compliance with applicable laws. We use the HTTPS protocol to create secure connections for Your web browser, which is indicated by a padlock icon in Your browser.

Jarfin 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 Jarfin account. If You think that the security of Your Jarfin account has been compromised, change Your password and contact us immediately for further assistance.

Notwithstanding the above, You acknowledge that no data transmission over the internet or electronic storage system can be guaranteed to be entirely secure, and "perfect security" does not exist. Your use of the Platform is therefore subject to this inherent risk, and Jarfin shall not be liable for any interception or compromise of Your data that occurs despite Jarfin's reasonable security measures and in circumstances outside Jarfin's reasonable control.

In the event of a data security breach affecting Your information, Jarfin will take all reasonable steps to contain the breach and will notify You and the relevant authorities in accordance with the timelines and procedures prescribed under applicable law.

7.Correction or Access to Personal Information

You have the right to access, review, and correct the personal information that Jarfin holds about You. If any of Your personal information is inaccurate, incomplete, or outdated, You may update it directly through the Platform or by contacting Jarfin's customer support at the details provided below.

In case of any changes with respect to any of Your information, especially in case Your personal information has been changed or in case You would not like to continue availing Services, then You would be required to either update your personal information or unsubscribe from any updates/information with respect to notifications on the Services that You had earlier utilised or enquired upon, at the Platform.

You may withdraw any consent previously granted to Jarfin at any time by contacting Jarfin's customer support. Withdrawal of consent will be processed within a reasonable time. Please note that (a) withdrawal of consent for processing that is necessary to perform the Services may result in Jarfin suspending or closing Your account. Any such actions will be subject to the completion of pending transactions and obligations; (b) withdrawal of consent does not affect the lawfulness of processing carried out prior to withdrawal; (c) Jarfin will continue to retain Your information for the periods required under applicable law even after the closure of Your account and the withdrawal of consent, as such retention is required by law and not by consent; and (d) withdrawal of consent for marketing communications will result in You no longer receiving promotional or cross-selling communications from Jarfin, and will not affect Your ability to continue using the Services.

8.Grievance Officer

In accordance with applicable law, Jarfin has designated a Grievance Officer to address any concerns or grievances that You may have regarding the collection, storage, processing, use, or disclosure of Your personal information under this Privacy Policy.

If You have any grievance or complaint regarding the processing of Your personal information, You may contact the Grievance Officer at the following details:

Name

Arun S Kamath

Designation

Grievance Officer

Address

Jarfin Retail Private Limited, No. 752, Vasantham Building, 18th Main, 5th Cross Rd, 6th Block, Koramangala, Bengaluru, Karnataka 560095

Email

grievance@sipse.in

Telephone

+91 7337636611

Your grievance will be acknowledged and addressed within one month of receipt, in accordance with the timelines prescribed under applicable law.

9.Changes to This Privacy Policy

Jarfin reserves the right to update or modify this Privacy Policy from time to time to reflect changes in applicable law, Our data processing practices, or Our business operations. The updated Privacy Policy will be posted on the Platform and will be effective from the date of publication. Where a change is material, Jarfin will notify You through the Platform or by email to Your registered email address. Your continued use of the Platform after the effective date of any revision constitutes Your acceptance of the revised Privacy Policy. You are encouraged to review this Privacy Policy periodically.