Welcome to the website of the Samco Mutual Fund. We understand that our customers and website visitors are concerned about the privacy of information. At Samco Mutual Fund we are strongly committed to protecting the privacy of your Personal Information. This Privacy Policy (as amended from time to time) describes how we collect, use and retain your Personal Information, vide various avenues including but not limited to usage of the various services both in the physical (offline) and online/electronic mode. Personal Information collected by us through physical/offline and online/electronic mode may be converted and stored in an electronic form at our sole discretion for the Purposes mentioned hereunder.

By accepting the terms and conditions of the website or through physical means, you have expressly agreed and acknowledged that you have read all the contents of our disclaimer, terms and conditions on our website www.samcomf.com and this Privacy Policy carefully and also acknowledge that you are aware of the Personal Information that is being collected by us and the manner in which the said Personal Information shall be handled and dealt with and its usage.

Location of servers and transfer of information to India. The website / mobile application is hosted by servers in India. If you are located outside of India, your Personal Information will be transferred to India. By submitting your Personal Information, you consent to its transfer to the India and to its storage, processing, and use there in accordance with this Privacy Statement.

However, the Provider of Information shall not be covered by this Privacy Policy, if he/she accesses any other/ third party links from the website.

Collection of Information:

In the course of using this website/mobile application or availing the products and services, Samco Mutual Fund may become privy to the personal information of the Users of the website/mobile application, including information that is of a confidential & sensitive nature. We may collect information about you from several sources. You may provide information as part of the application or enrollment process or our landing pages during online campaigns. Additionally, we may obtain information about you from third parties. We also develop and retain information about you based on our transactions and experience with you.

The personal information that we collect from you, includes personal information and other such information that is confidential in nature, and shall mean and include any information that relates to a person, that is either directly or indirectly, in combination with other information that is available or likely to be available to us, is capable of identifying the Provider of the Information (“Personal Information”)

Such information can be personal and sensitive in nature as per the indicative list given below:

• Full name;
• Address;
• Telephone / mobile number(s);
• Gender;
• E-mail address;
• Password (in the event of you signing up for the online facilities);
• any number, code, or other identifier, including Aadhaar number, Permanent Account Number assigned to the Provider of Information under any legislation and/or laws made by Parliament or any State Legislature which may be used for the purpose of verifying the identity of the Provider of Information;
• Financial information (pertaining to the investments/ applications/ transactions and any other related purposes vide which we would be providing the Services to you);
• facial images, fingerprints, iris scans, or any other similar personal data resulting from measurements or technical processing operations carried out on physical, physiological, or behavioural characteristics of Provider of Information, which allow or confirm the unique identification of the Provider of Information;
• Any other data relating to the Provider of Information who is directly or indirectly identifiable, by his/her characteristic, trait, attribute or any other feature of the identity of the Provider of Information, or any combination of such features, or any combination of such features with any other information;
• Any other information as defined under Rule 3 of the Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011, as may be required by us from time to time in order to provide Services to the Provider of Information.
• any other category of data as specified under any legislation or laws passed by the Parliament or any State Legislature which may be required for the Purposes or for verifying the identity of the Provider of Information.

However, any information that is freely available in the public domain is exempt from the above definition.

The aforesaid information is being collected by the AMC/Service Providers to respond to requests, to process the investment applications and to also ensure safe subscriptions/redemptions through points of acceptance in physical form, website, online portals and such other mode. The AMC may also call the Users to inform them with respect to the other products or services offered by the AMC. The said information is also being collected to be compliant with the Know Your Client (KYC) norms under the Prevention of Money Laundering Act, 2002, (PMLA), the rules issued thereunder, and guidelines and circular on Anti- Money Laundering issued by SEBI and SEBI (Mutual Funds) Regulations, 1996 as amended till date.

For each visitor to the AMC’s / the Mutual Fund’s website, the AMC’s web server automatically recognizes the visitor's Internet service provider. Additionally, the AMC/ the Mutual Fund collects information about the sites visitors connect from, and the browsers visitors use. The AMC/ the Mutual Fund uses this information to assemble aggregate information about the visitors to the AMC’s / the Mutual Fund’s website and assist with the AMC’s / the Mutual Fund’s systems administration and problem resolution activities.

USE OF PERSONAL INFORMATION (“PURPOSES”):

The information for the accounts the User has with the AMC/ the Mutual Fund website/application is kept secure and confidential through multiple security features and procedures. The information the User requests from the AMC’s / the Mutual Fund’s website for the User’s accounts can only be accessed with the User’s password. It is the User’s responsibility to keep the password confidential. The User should not disclose the password to anyone. The employees and associates of the AMC/ the Mutual Fund will never ask the User for the User’s password. The User should never write the password on something others may see.

We may share information in the course of normal business operations, such as providing services you have subscribed for, and any activity related to these services such as financial aggregator. It may become necessary for Samco Mutual Fund to disclose your personal information to its agents and contractors in the course of normal business operations for the above referred purpose. However, these parties would be required to use the information obtained from Samco Mutual Fund for such purposes exclusively. Samco Mutual Fund will endeavour to take all reasonable steps to ensure that the confidentiality of your information is maintained by imposing strict confidentiality standards on all the third parties to whom it discloses such information.

If the User supplies the AMC/ the Mutual Fund with e-mail address online then the User may receive periodic messages from the AMC/ the Mutual Fund with information on new products and services or upcoming events. If the User supplies the AMC/ the Mutual Fund with postal address online then the User may receive periodic mailings from the AMC/ the Mutual Fund with information on new products and services or upcoming events. If the User supplies the AMC/ the Mutual Fund with telephone number on-line then the User may receive telephone calls from the AMC/ the Mutual Fund with information regarding products or services, the User has asked about on-line. The User also may receive telephone calls from the AMC/ the Mutual Fund with information regarding new products and services or upcoming events.

You expressly agree and understand that:

• AMC may use your Personal Information for the Purposes of providing you with the certain services to which you have subscribed (“Services”) and any services incidental to the Services such as processing instructions, responding to service requests, resolve any grievances. The same may also be used to contact you whenever required and also to seek your feedback in relation to the offered Services.
• The Personal Information (like e-mail address, phone number, etc.) may be used to send periodic information on the Services or upcoming events or announcements and also to send various statutory reports and disclosures as required under SEBI (Mutual Funds) Regulations, 1996, SEBI Act, 1992, as amended from time to time.
• The Personal Information may be used to generate statistics and reports for both internal use and for sharing with affiliates, intermediaries, successors, vendors, data processors, service providers, agents, representatives and advertisers. Such statistics and reports will not contain Personal Information that could identify the Provider of Information, personally.

Any change in the use of Personal Information shall be notified to the Provider of Information.

WITHDRAWAL OF CONSENT:

The Provider of Information shall at all times be entitled to withdraw the consent granted by it pursuant to this Privacy Policy and/ or any other documentation executed by it in relation to sharing of its Personal Information, by submitting a request, in writing stating his/her reasons for withdrawal of such consent to the Investor Services department. Upon receipt of such request, AMC may, on a best efforts basis, cease any further disclosure and usage of the Personal Information within 30 (thirty) days However, all legal consequences for the effects of such withdrawal shall be borne by the Provider of Information.

Further, in the event, the Provider of Information desires to discontinue the Services or to restrict or prevent continuing disclosure of Personal Information, they shall submit a request, in writing, to the investor services department for such discontinuation. Subject to applicable laws in India, upon receipt of such request, AMC may, on a best efforts basis, cease any further disclosure of the Personal Information to any third party within 30 (thirty) days.

Notwithstanding anything contained herein, the Provider of Information shall have the right to access its Personal Information shared by them or as collected by the AMC, by submitting a request, in writing, to access or receive confirmation of completion of the processing of their Personal Information, to the Investor services department. Upon receipt of such request, AMC may, on a best efforts basis, provide a summary of the Personal Information or grant access to the Provider of Information within 30 (thirty) days. The Provider of Information shall further be entitled to share such Personal Information received by it to any third party. However, in the event, the Provider of Information shares such Personal Information received by him/her to any third party, Samco Mutual Fund, Samco AMC, Samco Trustee Private Limited, directors, trustees, officers, employees or affiliates’ shall not be held liable to you.

SECURITY STANDARDS AND MEASURES:

We have adopted reasonable security practices and procedures and have implemented such reasonable security practices and safeguards which are appropriate to protect the integrity and the sensitivity of the Personal Information. These security practices and standards are consistent with the generally accepted standards of commercial business practice, which includes technical, operational and physical security control measures which commensurate with the Personal Information being protected from any misuse, unauthorised access, unauthorised processing, unauthorised storage, unauthorised modification or alteration, destruction and/or unauthorised disclosures while the same is with us.

The Provider of Information, especially the investors agree and understand that trusted third parties who act on our behalf for performing of certain functions such as processing of transactions, issuing account statements etc. are under contractual obligations to ensure reasonable security safeguards commensurate to the sensitivity of the Personal Information being handled by them.

Notwithstanding anything contained in this Privacy Policy, in the event, the Provider of Information discloses the Personal Information to any third party or fails to follow the security instructions provided, then any unauthorised breach of our security control measures or unauthorised disclosure of your Personal Information caused to you due to the website being hacked or any such breach of our security control measures shall be your sole responsibility and liability. Samco Mutual Fund, Samco AMC, Samco Trustee Private Limited, directors, trustees, officers, employees or affiliates’ shall not be held liable to you.

DISCLOSURE OF PERSONAL INFORMATION:

Samco AMC may disclose the Provider’s information in order to:

• Enforce legal rights or claim, seeking any relief, defending any charge, opposing any claim, or obtaining any legal advice from an advocate in any impending legal proceeding;
• Conform to legal and/ or statutory requirements or comply with legal process;
• Protect and defend Samco AMC's or its Affiliates' rights, interests or property;
• Enforce our legal rights, terms and conditions or provisions of the offering documents of Schemes of the Mutual Fund or any other products or Services.

SHARING OF PERSONAL INFORMATION WITH THIRD PARTIES:

To the extent required or permitted under law, we may share your Personal Information for the uses mentioned here with the following third parties:

• Registrar and transfer agent(s), call centres, bankers, custodians, depositories and/ or authorised external third parties who are involved in transaction processing, dispatches, etc., of your investment / transactions with us and/or who are vendors/ service providers/ distributors to whom commission / brokerage / remuneration is paid;
• Distributors or sub-brokers or intermediaries through whom applications are received and whose ARN number (if applicable for the concerned business) is stamped / printed/ written on the application form/ transaction request;
• Any other organisation for verifying the identity of investors / distributors for complying with anti-money laundering requirements;
• Any governmental authority including but not limited to the Reserve Bank of India and/ or the Securities and Exchange Board of India;
• Certain Personal Information may be shared with post office, local & international courier service providers and other intermediaries for correspondence with the Provider of Information and for making payments to the Provider by cheques, drafts, warrants, through electronic clearing services, NEFT etc.

Nevertheless, it shall be the AMC’s foremost endeavor to ensure that the Customer’s Privacy is protected at all points in time. The Users must ensure to recheck the information or data being provided to the AMC or any person acting on its behalf. Incase if any of the data/information is found to be inaccurate or incorrect, the same shall be informed to the AMC for immediate amendment. The AMC and any person acting on its behalf shall not be responsible for the authenticity of the personal information or sensitive personal data or information supplied by the Users (whether existing/prospective).

RETENTION OF PERSONAL INFORMATION:

Subject to withdrawal of consent for processing of the Personal Information, we may retain your Personal Information for as long as may be reasonably required to provide our Services to you or otherwise if required under law.

MONITORING AND ENFORCEMENT

The AMC takes appropriate security measures to monitor unauthorized access to or unauthorized alteration, disclosure or destruction of data. These include internal reviews of the AMC’s/ the Mutual Fund’s data collection, storage and processing practices and security measures. The AMC would ensure to enter into suitable terms with third party service providers in order to protect client confidentiality and follow a non-disclosure or restricted disclosure policy. Further, the employees who violate the privacy and confidentiality promise shall be subjected to disciplinary action.

BREACH OF INTERNET SECURITY:

In addition to our efforts for the protection of the Personal Information, it is important that the Provider of Information should co-operate with us for the security of the Personal Information. It is recommended that the Provider of Information, especially the investors, should necessarily choose their passwords carefully such that no unauthorised access is made by any third party and not to disclose the same to any one and or keep a record of the same in writing.

However, despite our best efforts, if unauthorised persons breach our security control measures resulting in the website being hacked or presenting inaccurate information etc., Samco Mutual Fund, Samco AMC, Samco Trustee Private Limited, directors, trustees, officers, employees or affiliates’ shall not be held liable.

GRIEVANCE REDRESSAL:

f Users have any concerns relating to their personal and sensitive information they may be addressed to the Chief Information Security Officer (CISO) of the AMC, at ciso@samcomf.com For more details, the Users may refer to the Scheme related documents available on the AMC’s / the Mutual Fund’s website viz. www.samcomf.com. The Users shall be deemed to have expressly consented to the terms of this Policy if they enter and use the AMC’s/ the Mutual Fund’s website or provide any information while transacting with the AMC/ the Mutual Fund.

Where, a grievance is not resolved within the time period or where the Provider of Information is not satisfied with the manner in which the grievance is resolved, or the AMC has rejected the grievance raised, the Provider of Information shall have the right to file a complaint in the manner prescribed under the respective Act for concerned business activities.

AMENDMENT TO THE POLICY

The AMC reserves the right to amend/modify any of the sections of this policy at any time and the Users are requested to keep themselves updated for changes by reading the same from time to time.