This Privacy Policy is designed to help you understand what information we collect, generate, and/or process about or relating to you, why and how we use it, and with whom we share it. It also sets out the rights you have in relation to your information and how you may contact us for your queries.

DEFINITIONS USED IN THIS PRIVACY POLICY

“Client” means an investor in products distributed by us or a recipient of our services, who may be an individual investor, or an employee, director, officer, trustee, beneficiary, or representative of an institutional or intermediary client of Torient Services LLP.

“Torient Services LLP,” “we,” or “us” means Torient Services LLP with its registered office at 301, Orion Business Park, Shimpoli Signal, S. V. Road, Borivali (W), Mumbai – 400092, India, or any of its subsidiaries or affiliates. Together these are referred to as the Torient Services.

“Torient Services Website” means the website operated by Torient Services LLP or any of its subsidiaries or affiliates.

“Products and Services” means the products and services that we offer as a distributor/provider to our Clients, including through our related support, mobile, or cloud-based services.

Personal Data

“Personal Data” means any data which relates to a living individual who can be identified from that data or from that data and other information which is in the possession of, or is likely to come into the possession of, Torient Services LLP (or its representatives or service providers). In addition to factual information such as a name or address, it could include an expression of opinion about or an indication of intention in respect of an individual.

“You” means each individual to whom this notice is addressed, who may be: (a) a Client or prospective Client of ours; (b) a visitor to the Torient Services Website; or (c) an employee, director, officer, or representative of another organisation with which we have a business relationship.

BACKGROUND INFORMATION

Torient Services LLP collects and uses certain Personal Data. Torient Services LLP respects your privacy and is committed to keeping your Personal Data secure. This Privacy Policy is directed to individuals whose Personal Data we handle in the course of carrying on our commercial activities. Those individuals could be Clients or prospective Clients or their representatives, agents, or appointees, or an employee, director, officer, or representative of another organisation with which we have a business relationship. This Privacy Policy is also directed to visitors to our websites.

OVERVIEW OF CIRCUMSTANCES IN WHICH WE HANDLE YOUR PERSONAL DATA

Torient Services LLP gathers information about you in the following ways:

(a) Information we receive in the course of distributing/providing products or services to you. This may be provided directly from you or from other parties, such as, for example, providers of ‘know your client’ and anti-money laundering services which we sometimes use to help us meet our legal obligations.

(b) Information we receive as part of your interest in the products or services that we distribute/provide. This is only provided by you and includes enquiries and other activities you perform while visiting our premises, during our visit to your premises, by whatever name called, participating in informative events, and using the Torient Services Website.

We may combine the personal and other data we collect directly from you with information collected from or about you in other contexts, such as from our Website or obtained from third parties.

THE TYPE OF PERSONAL DATA WE COLLECT

Many of the products or services distributed/provided by Torient Services LLP require us to obtain and process Personal Data, such as:

• Basic Personal Data such as first name; family name; unique identification documents like tax identification number or Aadhar number (for Indian residents only); email address; phone number; address (including city, postcode, and country); occupation and job title; bank details; ID documentation; date of birth; life events; and family information.
• Sensitive Personal Data, which may be included in information we handle about your nationality, place of birth, health-related information, disability status, biometric data used for the purpose of authentication in connection with certain applications, details of political affiliations, or records of criminal offences and court proceedings. We also process personal data about any person on whose behalf you are acting, for example, investment beneficiaries, that you may have provided to us in connection with our provision of services to you. By providing us with their personal data, you agree to provide them with the information set out in this Privacy Policy.
• Information that we collect or generate about you. This may include:
  • files that we may produce as a record of our relationship with our Clients and prospective Clients, including contact history; and
  • any Personal Data that we obtain in relation to your use of the Torient Services Website.
• Information we obtain from other sources. Some of this personal data may be sensitive and may include:
  • information from publicly available sources, including third-party agencies such as credit reference agencies; fraud prevention agencies; law enforcement agencies; public databases, registers, and records such as Registrar of Companies, Ministry of Corporate Affairs, Ministry of Finance, Financial Intelligence Unit; and other publicly accessible sources.
  • information provided to us by third parties including but not limited to other distributors, other professionals, product providers, event organisers, other agents and/or representatives, industry databases, and other business intelligence tools Torient Services LLP subscribes to; and
  • information obtained from sanctions checking and background screening service providers.

HOW WE USE YOUR INFORMATION

Your Personal Data may be stored and processed by us in the following ways and for the following purposes:

• to allow Clients and prospective Clients to use and access products and services distributed/provided by Torient Services LLP;
• to assess Client and prospective Client applications or contracts for Products and Services distributed/provided by Torient Services LLP;
• to set up / on-board prospective Clients to use Products and Services distributed/provided by Torient Services LLP;
• to keep our records up to date;
• to monitor IT systems;
• to protect our premises from unauthorised access or use, or any unlawful activity;
• to administer or maintain IT systems in order to uphold standards of service;
• for ongoing review and improvement of the information provided on the Torient Services Website to make them user-friendly and prevent potential disruptions or cyberattacks;
• to understand feedback on Products and Services distributed/provided by Torient Services LLP and to help provide more information on the use of those products and services quickly and easily;
• to communicate with and better understand the interests of Clients and prospective Clients in order to provide services or targeted information about Torient Services LLP and other Products and Services distributed/provided by Torient Services LLP;
• to effectively manage and strengthen Client and prospective Client relationships, understand Client and prospective Client needs and interests, and learn more about our Clients and prospective Clients in order to develop, improve, and enhance the products and services we can offer;
• for the management and administration of our business;
• in order to comply with and in order to assess compliance with applicable laws, rules, and regulations, and internal policies and procedures; or
• for the administration and maintenance of databases storing your Personal Data.

When we use your Personal Data, we comply with applicable law. The law allows or requires us to use your Personal Data for a variety of reasons. These include instances where:

• we are performing our contractual obligations;
• we have legal and regulatory obligations that we have to discharge;
• we may need to do so in order to establish, exercise, or defend our legal rights or those of our Clients or for the purpose of legal proceedings;
• we have obtained your consent;
• the use of your Personal Data as described is necessary for our legitimate business interests, such as:
  • allowing us to effectively and efficiently manage and administer the operation of our business;
  • maintaining compliance with internal policies and procedures;
  • enabling quick and easy access to information on Products and Services distributed/provided by Torient Services LLP.

Within Torient Services LLP, your Personal Data is accessed only by personnel of Torient Services LLP that have a need to access it for the purposes described in this Privacy Policy.

DISCLOSURE OF YOUR INFORMATION TO THIRD PARTIES

We may share your Personal Data within the Torient Services for the purposes described above.

We may also share your Personal Data outside of the Torient Services as further described below:

• with business partners of ours where they are contractually obliged to comply with appropriate data protection obligations;
• with representatives, agents, custodians, intermediaries, and/or other third-party product providers appointed by the Client or prospective Client;
• with third-party agents and contractors for the purposes of them providing services both to us and/or to Clients or prospective Clients;
• with any other third party where disclosure of your Personal Data is reasonably intended for the purpose of effecting, managing, or reporting transactions or establishing a relationship with a view to such transactions;
• where you are a joint account or portfolio holder (or otherwise one of multiple persons holding an account or portfolio), we may disclose your Personal Data to the other joint account or portfolio holder or other person;
• to the extent required by law or regulation, for example, if we are under a duty to disclose your Personal Data in order to comply with any legal obligation (including, without limitation, in order to comply with tax reporting requirements and disclosures to regulators, auditors, or public authorities), or to establish, exercise, or defend its legal rights; and
• if we sell any part of our business or our assets, in which case we may need to disclose your Personal Data to the prospective buyer for due diligence purposes.

INTERNATIONAL TRANSFERS OF PERSONAL DATA

Torient Services LLP may transfer your Personal Data to locations outside of your country. Where we transfer your Personal Data to another country, we ensure that it will be protected and transferred in a manner consistent with legal requirements.

HOW WE SAFEGUARD YOUR PERSONAL DATA

Data is a critical business asset and must be protected according to its risk as well as its importance or value. We ensure safe processing operations by operating and maintaining physical, electronic, and procedural safeguards to guard your non-public personal information and we restrict access only to authorised personnel. The effectiveness of these safeguards is tested. We have controls and mechanisms in place designed to detect, respond to, and recover data and functionality in case of adverse events that may arise.

HOW LONG WE KEEP YOUR PERSONAL DATA

The length of time for which we hold your Personal Data will vary as determined by the following criteria:

• the purpose for which we are using it (as further described in this Privacy Policy at paragraph – we will need to keep the data for as long as is necessary for that purpose); and
• our legal obligations – laws or regulation may set a minimum period for which we have to keep your Personal Data.

YOUR RIGHTS

In all the above cases in which we collect, use, or store your Personal Data, you may have the following rights and, in most cases, you can exercise them free of charge. These rights include:

• the right to obtain information regarding the processing of your Personal Data and access to the Personal Data which we hold about you;
• the right to withdraw your consent to the processing of your Personal Data at any time. Please note, however, that we may still be entitled to process your Personal Data if we have another legitimate reason for doing so. For example, we may need to retain your Personal Data to comply with a legal or regulatory obligation or to satisfy our internal/external audit requirements;
• in some circumstances, the right to receive some Personal Data in a structured, commonly used, and machine-readable format and/or request that we transmit such data to a third party where this is technically feasible. Please note that this right only applies to Personal Data that you have provided directly to Torient Services LLP;
• the right to request that we rectify your Personal Data if it is inaccurate or incomplete;
• the right to request that we erase your Personal Data in certain circumstances. Please note that there may be circumstances where you ask us to erase your Personal Data but we are required or entitled to retain it;
• the right to object to, or request that we restrict, our processing of your Personal Data in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your Personal Data but we are required or entitled to refuse that request.

TORIENT SERVICES WEBSITE AND OTHER WEBSITES

If you use the Torient Services Website, we may collect technical information through the use of cookies. If you access the Torient Services Website and make your identity known during a secure (logged-on) browsing session on our Website, we will be able to combine the information we collect about your usage of our Website during that session with other information we know about you, such as any searches you conduct on our Website or information you request during your web session. We will use this combined information to assess the appeal and usefulness of the information and tools offered on our Website as well as to identify products and services distributed/provided by Torient Services LLP that may be of interest to you. We also gather anonymous information related to browsing habits of users through other categories of cookies with the purpose of managing and improving our Website. If you use the Torient Services Website and follow a link from it to another website (including a website operated by Torient Services LLP), different privacy policies may apply. Prior to submitting any Personal Data to a website, you should read the privacy policy applicable to that website.

CHANGES TO THIS PRIVACY POLICY

Any changes we make to our Privacy Policy in the future will be posted on this website. Please check back frequently to see any updates or changes to our Privacy Policy.

QUESTIONS AND CONCERNS

If you have any questions or concerns about Torient Services LLP’s handling of your Personal Data, or about this Privacy Policy, or to exercise any of your rights, please contact us at the address below. To exercise your right to withdraw consent to receive electronic marketing communications at any time, please follow the “unsubscribe” instructions found in such marketing materials.

Torient Services LLP – Contact Details

• Address: 301, Orion Business Park, Shimpoli Signal, S. V. Road, Borivali (W), Mumbai – 400092, India.
• Phone: +91-9136156998, +91-2231591192
• Email: charmiparesh@torientservices.com

We are usually able to resolve privacy questions or concerns promptly and effectively.

If you raise a concern, we may:

• request additional details from you regarding your concerns and personal data limited to what is necessary for the purpose of authenticating you;
• engage or consult with other parties in order to investigate and resolve your issue (and these parties will receive and process information about you); and/or
• keep records of your request and any resolution of your issue,

in each case in accordance with our data protection and other legal obligations.