1. Introduction

DHAN KIRTI INVESTOR SERVICES PRIVATE LIMITED (“Company”, “we”, “our”, or “us”) is committed to protecting the privacy and confidentiality of personal and financial information of its clients, investors, website visitors, and other stakeholders.

This Privacy Policy describes how we collect, use, process, store, disclose, and safeguard information when you visit our website, mobile interface, digital platforms, or interact with us in connection with our services relating to investment facilitation, unlisted securities transactions, and pre-IPO investment opportunities (collectively referred to as the “Platform”).

By accessing or using our Platform or services, you consent to the practices described in this Privacy Policy. If you do not agree, you should refrain from using our Platform.

This Privacy Policy is framed in accordance with applicable Indian laws including:

  • Information Technology Act, 2000

  • Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011

  • Applicable SEBI regulations and financial compliance standards

  • Any amendments or statutory re-enactments thereof

We reserve the right to modify this Policy at any time. Changes shall become effective upon publication on the Platform.

2. Information We Collect

We may collect information in the following categories:

2.1 Personal Information

We may collect personally identifiable information voluntarily provided by you, including but not limited to:

  • Name

  • Address and contact details

  • Email address and mobile number

  • Date of birth, PAN, Aadhaar (where required for KYC)

  • Bank account details and investment preferences

  • Occupation, income category, risk profile

  • Any information provided during onboarding, due diligence, or compliance processes

Such information is collected when you:

  • Register on our Platform

  • Submit KYC documents

  • Request information on unlisted shares or investment opportunities

  • Execute transactions

  • Contact customer support

  • Subscribe to newsletters or updates

You may refuse to provide certain information; however, this may restrict your ability to use our services.

2.2 Sensitive Personal Data / Financial Information

In order to comply with regulatory requirements and facilitate transactions, we may collect:

  • PAN / KYC documentation

  • Bank details and payment confirmations

  • Demat account details

  • Transaction history

  • Investment records

  • Source of funds declarations

Such information is treated as Sensitive Personal Data and handled in accordance with Indian law.

2.3 Automatically Collected Information

When you access our Platform, our systems may automatically collect:

  • IP address

  • Browser type and device information

  • Access time and duration

  • Pages visited and navigation patterns

  • Cookies and analytics data

This data is used only for system security, analytics, and service improvement.

2.4 Third-Party Information

We may receive information from:

  • KYC verification agencies

  • Payment gateways and banks

  • Depositories, brokers, intermediaries

  • Compliance verification vendors

  • Public regulatory databases

3. Purpose of Collection and Use

We use collected information for legitimate business and regulatory purposes including:

  • Investor onboarding and KYC verification

  • Processing transactions in unlisted securities

  • Compliance with anti-money laundering laws

  • Maintaining transaction and investor records

  • Communication regarding investment opportunities

  • Customer service and dispute resolution

  • Improving our Platform functionality

  • Internal analytics and risk monitoring

  • Prevention of fraud, misuse, or unlawful activity

  • Compliance with legal, regulatory, and audit requirements

We do not sell personal data to third parties.

4. Disclosure of Information

We may disclose your information in the following circumstances:

4.1 Regulatory and Legal Compliance

  • SEBI or stock exchange authorities

  • Courts or law enforcement agencies

  • Government departments

  • Statutory auditors or regulators

4.2 Service Providers

  • KYC verification

  • Payment processing

  • Hosting and IT infrastructure

  • Data storage and security

  • Legal, compliance, and audit services

Such parties are contractually obligated to maintain confidentiality.

4.3 Business Transfers

In case of merger, acquisition, restructuring, or sale of assets, information may be transferred subject to applicable confidentiality safeguards.

5. Cookies and Tracking Technologies

  • Improve website performance

  • Analyse user behaviour

  • Enhance user experience

  • Maintain session security

You may disable cookies via browser settings, though this may affect certain features.

6. Data Security

  • Secure servers and encryption practices

  • Access control systems

  • Confidentiality agreements with employees and vendors

  • Periodic security review and monitoring

While we follow industry standards, no digital transmission can be guaranteed completely secure.

7. Data Retention

  • For as long as required to provide services

  • To comply with legal and regulatory requirements

  • For record-keeping, audit, and dispute resolution purposes

Data may be retained even after account closure where required by law.

8. Third-Party Links

Our Platform may contain links to external websites. We are not responsible for their privacy practices and encourage users to review their policies separately.

9. Children’s Privacy

Our services are intended only for persons legally eligible to enter into financial transactions. We do not knowingly collect information from minors.

10. Your Rights

  • Request access to your personal information

  • Request correction or update of inaccurate data

  • Withdraw consent where applicable

  • Request deletion of information (subject to legal retention obligations)

  • Opt-out of marketing communications

Requests may be made via the contact details below.

11. Contact Details

For any questions, requests, or grievances regarding this Privacy Policy or handling of your personal information, please contact:

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