Information We Collect

We are committed to protecting your online privacy. We further recognize your need for appropriate protection and management of any Personal Information you share with us. We may collect the following information:

• Personal Information: When you register, we collect your email address, date of birth, and any other information you provide in your profile.
• User Content: We collect the content you create, including your chat messages and shared media.
• Automated Information: We automatically collect information about your device (IP address, device ID, browser type) and your usage of our Services (features you use, time spent).
• Cookies and Tracking Technologies: We use cookies and similar technologies to track activity on our Service. For more details, see the "Cookie Policy" section below.
• International Data Transfers: Your information may be transferred to and processed in countries other than your own. We will ensure appropriate safeguards are in place to protect your data.

This privacy policy also applies to data we collect from users who are not registered as members of this Platform, including browsing behavior, pages viewed, etc.

We only collect and use such information that we consider necessary for achieving a seamless, efficient, and safe experience, customized to your needs including:

• To enable the provision of services opted for by you.
• To enable the viewing of content in your interest.
• To communicate the necessary account and service-related information from time to time.
• To allow you to receive quality customer care services and data collection.
• To comply with applicable laws, rules and regulations.
• Where any service requested by you involves a third party, such information as is reasonably necessary may be shared with such third party.

We also use your contact information to send you offers based on your interests and prior activity. We shall immediately delete all such information upon withdrawal of your consent through the 'unsubscribe' button or through an email to compliance@digirm.com.

To the extent possible, we provide you with an option of not divulging any specific information that you wish for us not to collect, store, or use. You may also choose not to use a particular service or feature on the Platform and opt-out of any non-essential communications.

Our Use of Your Information

The information provided by you shall be used to provide and improve the service for you and all users:

• To provide you with services on your request.
• For maintaining an internal record.
• For enhancing the Services provided.
• For maintaining record under the legal and statutory provisions.

We use your tracking information such as IP addresses and/or Device ID to help identify you and to gather broad demographic information, and make further services available to you.

We will not sell, license or trade your personal information. We will not share your personal information with others unless they are acting under our instructions or we are required to do so by law.

Information collected via our server logs includes users' IP addresses and the pages visited, which will be used to manage the web system and troubleshoot problems. We also use third-party analytics, tracking, optimization and targeting tools to understand how users engage with our Platform so that we can improve it and cater personalized content according to their preferences.

How Information Is Collected

Before or at the time of collecting personal information, we will identify the purposes for which information is being collected. If the same is not identified to you, you have the right to request the Company to explain the purpose of collection, pending the fulfillment of which you shall not be mandated to disclose any information.

We will collect and use your personal information solely to fulfill those purposes specified by us, within the scope of consent or as required by law. We will only retain personal information as long as necessary for the fulfillment of those purposes. We will collect personal information by lawful and fair means and with the knowledge and consent of the individual concerned.

Personal data should be relevant to the purposes for which it is to be used, and should be accurate, complete, and up-to-date.

External Links on the Platform

The Platform may include advertisements, hyperlinks to other platforms or resources. We have no control over any other platform or resources or contents available on these other platforms. You acknowledge and agree that we are not responsible for the availability of any such external sites or resources, and do not endorse any advertising, services or other materials on or available from such platforms.

You acknowledge and agree that we are not liable for any loss or damage which may be incurred as a result of the availability of those external sites or resources. These external third-party platforms may have their own privacy policies governing the collection, storage, retention and disclosure of your personal information. We recommend that you review their privacy policies.

Cookies

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. By continuing to browse the site, you are agreeing to our use of cookies. You can set your browser to refuse all or some browser cookies. If you disable or refuse cookies, some parts of this Platform may become inaccessible or not function properly.

The types of cookies we use:

• Strictly Necessary Cookies: Required for the operation of our Platform, including cookies that enable you to log into secure areas.
• Analytical/Performance Cookies: Allow us to recognize and count visitors and to see how visitors move around our Platform. This helps us improve functionality.
• Functionality Cookies: Used to recognize you when you return to our Platform. This enables us to personalize our content and remember your preferences.
• Targeting Cookies: Record your visit, pages visited and links followed. We use this information to make our Platform and advertising more relevant to your interests.

Third-parties (including advertising networks and external service providers) may also use cookies, over which we have no control. You can block cookies by activating the appropriate setting on your browser; however, blocking all cookies may limit access to the Platform.

Your Rights

Unless subject to an exemption, you have the following rights concerning your data:

• The right to request a copy of your data which we hold about you.
• The right to request correction to any personal data if it is found to be inaccurate or out of date.
• The right to withdraw your consent to the processing at any time.
• The right to object to the processing of personal data.
• The right to complain to a supervisory authority.
• The right to obtain information as to whether personal data are transferred to a third country or an international organization.

Where you hold an account with any of our services, you are entitled to a copy of all personal data which we hold concerning you. You are also entitled to request that we restrict how we use your data in your account when you log in.

Depending on your jurisdiction, you may have the right to access, correct, or delete your personal data. You can manage much of your information directly within the Platform. For other requests, please contact us at compliance@digirm.com.

Regulatory Compliances

The Platform operates as a technology-enabled interface for facilitating access to mutual fund–related information, tools and transaction support. Any regulated activities, where applicable, are undertaken strictly in accordance with applicable law and within the scope of valid licenses or registrations held.

The Platform operates and maintains compliance with applicable laws and regulatory frameworks, including but not limited to:

• The Securities and Exchange Board of India Act, 1992.
• The Association of Mutual Funds in India (AMFI) Code of Conduct.
• The Securities Contracts (Regulation) Act, 1956.
• The Information Technology Act, 2000.
• The Digital Personal Data Protection Act, 2023.
• The Consumer Protection Act, 2019.
• The Reserve Bank of India payment and gateway guidelines (to the extent applicable).
• FATCA and CRS requirements.
• Such circulars, guidelines and directions issued by SEBI, AMFI, RBI or other competent authorities from time to time.

The Platform does not provide personalized investment advice or discretionary portfolio management and does not assume custody or control of investor funds or securities, except as may be permitted under applicable law.

Users agree to comply with all applicable laws and regulatory requirements while accessing and using the Platform, and acknowledge that any violation may result in suspension or termination of access.

Confidentiality

You further acknowledge that the Platform may contain information that is designated confidential by us and that you shall not disclose such information without our prior written consent. Your information is regarded as confidential and will not be divulged to any third party, unless legally required to do so to the appropriate authorities.

We will not sell, share, or rent your personal information to any third party or use your e-mail address for unsolicited mail. Any emails sent by us will only be in connection with the provision of agreed services, and you retain sole discretion to seek discontinuation of such communications at any point in time.

Other Information Collectors

Except as otherwise expressly included in this Privacy Policy, this document only addresses the use and disclosure of information we collect from you. To the extent that you disclose your information to other parties, whether they are on our Platform or other sites, different rules may apply to their use or disclosure of the information you disclose to them.

To the extent that we use third party advertisers, they adhere to their own privacy policies. Since we do not control the privacy policies of third parties, you are subject to ask questions before you disclose your personal information to others.

Our Disclosure of Your Information

Due to the existing regulatory environment, we cannot ensure that all of your private communications and other personally identifiable information will never be disclosed in ways not otherwise described in this Privacy Policy. We may be forced to disclose information to the government, law enforcement agencies or third parties. Although we use industry-standard practices to protect your privacy, we do not promise that your personally identifiable information would always remain private.

We do however assure you that any disclosure of your personally identifiable information shall be personally intimated to you through an email sent to your provided email address.

As a matter of policy, we do not sell or rent any personally identifiable information about you to any third party. However, your information may be disclosed in the following ways:

• External Service Providers: If you choose to use optional services offered by external service providers, their use of your information is governed by their own privacy policy.
• Law and Order: We cooperate with law enforcement inquiries and can disclose any information about you to law enforcement and government officials as we believe necessary or appropriate, in connection with an investigation of fraud, intellectual property infringements, or other illegal activity.

Accessing, Reviewing & Changing Your Profile

You can review and change the information you submitted except Email ID. An option for facilitating such change shall be present on the Platform. If you change any information, we may or may not keep track of your old information.

We will not retain in our files information you have requested to remove for certain circumstances, such as to resolve disputes, troubleshoot problems, and enforce our terms and conditions. Such prior information shall be completely removed from our databases, including stored backup systems.

If you believe that any information we are holding on to you is incorrect or incomplete, or to remove your profile so that others cannot view it, the User needs to remediate and promptly correct any such incorrect information.

Security

We treat data as an asset that must be protected against loss and unauthorized access. We employ many different security techniques to protect such data from unauthorized access by members inside and outside the Firm. We follow generally accepted industry standards to protect the Personal Information submitted to us.

However, as effective as encryption technology is, no security system is impenetrable. Our Firm cannot guarantee the security of our database, nor can we guarantee that information you provide won't be intercepted while being transmitted to the Firm over the Internet.

Severability

Each paragraph of this Privacy Policy shall be and remain separate from and independent of and severable from all and any other paragraphs herein except where otherwise expressly indicated or indicated by the context of the agreement. The decision or declaration that one or more of the paragraphs are null and void shall not affect the remaining paragraphs of this Privacy Policy.

Amendment

Our Privacy Policy may change from time to time. The most current version of the policy will govern our use of your information and will always be on the Platform. Any amendments to this Policy shall be deemed as accepted by the User on their continued use of the Platform.

Consent Withdrawal, Data Download & Data Removal

To withdraw your consent, or to request the download or deletion of your data with us for any or all our services at any time, please email to compliance@digirm.com.

Disclaimer

We do not store any account-related information or any credit/debit card details. We shall not be liable for any loss or damage sustained by Users as a result of any disclosure (inadvertent or otherwise) of any information concerning the User's account, credit cards or debit cards in the course of any online transactions or payments made for any products and/or services offered through the Platform.

In case any Personal Information is shared by you with us, which is not requested by us during registration (whether mandatorily or optionally), we will not be liable for any information security breach or disclosure in relation to such information.