Please ensure that this Privacy Policy (“Policy”) is perused by You (defined below) before availing any services from Us (defined below). This Policy shall be updated from time to time and therefore in order to stay abreast with respect to the purpose of using Your (defined below) Information (defined below) and protecting Your privacy, We (defined below) recommend You to please keep reviewing the Policy.

Driv Drisht LLP, a limited liability partnership firm incorporated under the Limited Liability Partnership Act, 2008, having its registered office at Surabhi, 2nd Floor, 8/1/2, Dr. U.N. Brahmachari Street, Kolkata-700017, owns and operates the website www.dhanvesttor.com and is committed to protecting the privacy and security of personal data, belonging to and/or provided by any person who accesses or uses Our (defined below) services.

For the purpose of this Privacy Policy, wherever the context so requires the term “You” ‘’Your” or “User” or “Data Principal” shall mean any natural or legal person and their authorised representative including online and offline clients and the term “We”, “Us”, “Our”, “Dhanvesttor” or “Data Fiduciary” shall mean Driv Drisht LLP, and its employees and authorised representative(s).

We value Your privacy and advise You to carefully read this privacy policy as this Policy describes the types of Personal Data or Personal Information (“PI”) and Sensitive Personal Data or Information (“SPDI”) We collect, how We use the Information, how We process and protect the Information We collect, for how long We store it, with whom We share it, to whom We transfer it and the rights that individuals can exercise regarding Our use of their Information. We also describe how You can contact Us about Our privacy practices and to exercise Your rights.

It is clarified here that for the purposes of this Policy, PI and SPDI shall hereinafter be collectively referred to as “Information”

Driv Drisht LLP respects Your privacy and seeks to comply with all the applicable statutory requirements in India, including the Digital Personal Data Protection Act 2023, Information Technology Act 2000, and rules (collectively referred to as “Law”) made thereunder in respect of data collection, processing, and transfer.

THIS POLICY DOES NOT APPLY TO INFORMATION THAT YOU PROVIDE TO, OR THAT IS COLLECTED BY (i) ANY THIRD PARTY THROUGH OUR PLATFORM AND (ii) ANY THIRD PARTY WEBSITES THAT YOU ACCESS OR USE IN CONNECTION WITH THE SERVICES OFFERED THROUGH OUR PLATFORM. THE COMPANY SHALL NOT BE LIABLE FOR AND HAS NO CONTROL OVER THE PRACTICES AND CONTENT OF ANY SUCH THIRD PARTIES.

1. What Information We collect about You

Driv Drisht LLP for the purpose of rendering its services collect Information such as:

1. a) Contact Information: name, address, contact details like email ID and phone number;

1. b) Demographic information: age, gender, date of birth;

1. c) PAN, KYC Status, signature and photograph;

1. d) Bank account or other payment instrument details;

e) Any other information that is collected or generated in the course of availing the services including information about your computer, mobile device, and Internet connection, specifically your IP address, operating system, browser type, and application version information.

ANY INFORMATION THAT IS FREELY AVAILABLE OR ACCESSIBLE IN PUBLIC DOMAIN OR FURNISHED UNDER THE RIGHT TO INFORMATION ACT, 2005 OR ANY OTHER LAW FOR THE TIME BEING IN FORCE SHALL NOT BE REGARDED AS INFORMATION FOR THE PURPOSE OF THIS POLICY.

When You use Our services through our website, We may collect certain non-personal information such as Your internet protocol address, operating system, browser type, internet service provider, aggregate user data, software and hardware attributes, pages You request, number of click, active seconds or minutes on Our website, frequency of Your visit to Our website, the date and time of Your visit to Our website.

THIS TYPE OF INFORMATION DOES NOT IDENTIFY YOU PERSONALLY.

2. How We collect Your Information

The Information we collect comes from:

• a) Application forms or other materials You or Your authorized representative submits to Us during the course of your relationship with Us;

• b) You or Your authorized representative’s interactions with Us during transactions and use of Our services (including the use of Our website); and

• c) Recording and monitoring tools that We use for compliance or security purposes (e.g. recording of telephone calls, monitoring emails, video calls etc.).

3. How We use Your Information

Our primary purpose in collecting Your Information is to act as financial consultants, financial planners, and investment advisors in various fields including but not limited to conducting financial analysis, data analysis, undertaking risk assessments, and studying market trends in order to help clients meet their financial objectives.

Additionally, We use Information for the following purposes:

• a) Process transactions and to improve the quality of the service that We provide to You;

• b) Notify You about changes to Our service;

• c) Allow You to participate in interactive features of Our Service when You choose to do so;

• d) Provide customer support;

• e) Gather analysis or valuable information so that we can improve Our Service;

• f) Monitor the usage of Our service;

• g) Detect, prevent and address technical issues;

• h) Fulfil any other purpose for which You provide it;

• i) Carry out Our obligations and enforce Our rights arising from any contracts entered into between You and Us, including for billing and collection;

• j) Provide You with news, special offers, and general information about other services and events which We offer that are similar to those that You have already purchased or enquired about unless You have opted not to receive such information;

k) for any other purpose with Your consent.

4. Consent

The consent of the Data principal may be obtained through Our website or mobile application electronically or physically on paper directly or through a consent manager in accordance with the provisions of Law. Where the consent is received physically on paper, then such consent may be converted to electronic form by the consent manager or the Data Fiduciary and vice versa.

By providing Your consent You hereby agree to the collection, storage, processing, disclosure and transfer of Your Information in accordance with the provisions of this Policy. You acknowledge that You are providing Your Information out of Your free will. You also consent that the collection, storage, processing, disclosure and transfer of any Information shall not cause any wrongful loss to You, if it is done in accordance with the provisions of this Policy. However, we shall not be liable for any loss that may happen to you owing to the provision of wrongful personal Information by You.

5. Children under the age of 18

For children under 18 (eighteen) years of age, Our services are provided only upon obtaining the express consent of their parent or guardian. If You are under 18 (eighteen) years of age, We require that Your parent or guardian use Our services on Your behalf to the extent possible. If You are under 18 (eighteen) years of age and do not have parental consent, do not use or provide any Information, including Your name, address, telephone number, email address, or any screen name or username. If We learn We have collected or received Information from a child under 18 (eighteen) years of age without verification of parental consent, We will erase that Information. If You believe that We might have any Information from a child under 18 (eighteen) years of age, please contact Us at ho@dhanvesttor.com

6. Data Sharing

We may share, disclose and in some cases transfer Your Information to such entities as required to provide services to You, improve our services, and to provide value-added services or any other technical services, to the extent permitted by applicable law. These entities may be located outside India, which You hereby consent to. We require such entities to protect Your Information through equivalent security measures as what We would adopt.

An indicative list of entities We may disclose or transfer Information to, as provided below:

• a)

Payment Service Provider:

We may also share the Information including financial information with third-party payment service providers like payment gateways, payment aggregator, and other payment service providers for the purpose of fulfilling services to You.

• b)

Law Enforcement Agencies:

We may disclose Your Information if required to do so by law or when We believe that such disclosure is appropriate to comply with law or in good faith belief that such disclosure is reasonably necessary to respond to subpoenas, court orders, or other legal process. We may disclose Information to law enforcement agencies, pursuant to lawful requests for information, and otherwise as required under any law applicable at the given time, both in India and outside India.

DHANVESTTOR SHALL NOT BE LIABLE FOR ANY LOSS CAUSED TO YOU DUE TO SHARING OF ANY OF YOUR INFORMATION WHICH WAS DONE AFTER TAKING YOUR CONSENT.

7. Data Retention

We shall not retain Your Information for longer than is required for the purposes for which the Information may lawfully be used. However, We may retain data related to You if there is a legal obligation to retain the data; if required to comply with any applicable statutory or regulatory retention requirement by law; if We believe it may be necessary to prevent fraud or future abuse; to enable the Company to exercise its legal rights and/or defend against legal claims; or for other legitimate purposes. Dhanvesttor shall not retain any Information beyond the period necessary to satisfy the purpose for which it is processed and shall erase the information at the end of the processing.

8. Withdrawal of Consent

You may choose to withdraw Your consent provided hereinunder at any point in time. Such withdrawal of the consent must be communicated in writing to ho@dhanvesttor.com. You may also withdraw Your consent through a consent manager. In case You do not provide or later withdraw Your consent, We reserve the option to not allow You to undertake any transaction or access Our service for which the said Information was sought. However, if You are a part of any on-going transaction, We reserve the right to retain all Your Information until completion of the transaction. Further, You acknowledge and agree that in case of such withdrawal of Your consent, We will erase such Information. Dhanvesttor shall complete the erasure of the data within 30 (thirty) days from the date of withdrawal of consent.

9. Rectification of Information collected

You represent and warrant that any and all Information is absolutely correct and complete in all aspects. You further undertake to immediately update any change or variation of Your Information by sending Us a request in writing to ho@dhanvesttor.com to rectify or update Your Information. Once You send an email to Us, You agree to comply with the instructions as may be provided/communicated by Us.

10. Rights of Users

Your rights with respect to data protection and privacy are:

• a) Right to be informed about the processing of Your personal data (i.e. for what purposes, what types, to what recipients it is disclosed, storage periods, any third party sources from it was obtained, etc.);

• b) Right to request access to or a copy of any Information which We hold about You;

• c) Right to rectification of Your Information, if You consider that it is inaccurate;

• d) Right to ask Us to erase Your Information, if You consider that We do not have the right to hold it;

• e) Right to withdraw consent to Our processing of Your Information (to the extent such processing is based on previously obtained consent);

• f) Right to restrict processing of Your Information where, (i) You contest the accuracy of Your Information; (ii) processing is unlawful but You oppose erasure; (iii) We no longer need Your Information for the purposes of Our processing, but You require Your Information for the establishment, exercise or defence of legal claims; and (iv) You have objected to processing, pending the verification of that objection. In the event the processing has been restricted on the above circumstances, We may continue to store Your Information. However, We will only otherwise process it, with Your consent, (i) for the establishment, exercise, or defence of legal claims; (ii) for the protection of the rights of another natural or legal person; or (iii) for reasons of public interest;

• g) Right to object to Your Information data being processed on grounds relating to Your particular situation, provided such objection is not to the extent, as far as practicable, of processing where the legal basis of such processing is necessary for,

• (i) undertaking a transaction carried out in public interest or in the exercise of any official authority vested in Us; or (ii) the purposes of legitimate interests pursued by Us in a bona fide manner;

• h) Right to object to our processing of Your Information for direct marketing purposes, including profiling for direct marketing purposes. If You make such an objection, We will cease to process Your Information for this purpose;

• i) Right to nominate any other individual who shall in the event of Your death or incapacity, exercise the rights that You have; and

j) Right of grievance redressal if there is any breach of obligations from Our side.

11. Use of Cookies

Cookies are files with a small amount of data, which may include an anonymous unique identifier. Cookies are sent to You on the Platform. We may store temporary or permanent ‘cookies’ on Your computer/device to store certain data (that is not SPDI). You can erase or choose to block these cookies from Your computer. You can configure Your computer’s browser to alert You when We attempt to send You a cookie with an option to accept or refuse the cookie. If You have turned cookies off, You may be prevented from using certain features of the Platform. We do not control the use of cookies by third parties.

12. Security of Information

Dhanvesttor uses commercially reasonable physical, managerial, and technical safeguards to preserve the integrity and security of Your Information. We cannot, however, ensure or warrant the security of any information You transmit to Us and You do so at Your own risk. Once We receive your transmission of Information, We make commercially reasonable efforts to ensure the security of Our systems. However, please note that this is not a guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of Our physical, technical, or managerial safeguards. To protect Your privacy and security, We take reasonable steps (such as requesting a unique password) to verify Your identity before granting You access to Your account. You are responsible for maintaining the secrecy of Your unique password and account information, and for controlling access to Your email communications from Us, at all times. Our reasonable security measures shall be audited by an auditor at least once a year. IN CASES WHERE YOUR DATA GETS DISCLOSED, ALTERED OR DESTROYED EVEN AFTER TAKING ALL REASONABLE PHYSICAL, MANAGERIAL AND TECHNICAL SAFEGUARDS, WE SHALL NOT BE LIABLE FOR ANY LOSS THAT MAY ARISE PURSUANT TO SUCH DISCLOSURE, ALTERATION, OR DESTRUCTION.

13. Policy Changes

We reserve the unconditional right to change, modify, add, or remove portions of this Policy at any time, without specifically notifying You of such changes. Any changes or updates will be effective immediately. You should review the privacy notice, published on the Website at www.dhanvesttor.com, regularly for changes. If We make any significant changes, We will endeavor to provide You with reasonable notice of such changes, such as via a prominent notice on the website or to Your email address on record with Us and where required is applicable by an Indian law, We will obtain Your consent. Your acceptance of the amended privacy policy and/ or Your continued use of Our services after We publish or send a notice about Our changes to this Policy shall signify Your consent to such changes and be legally bound by the same. In case of breach of Information, We will notify You via email or a phone call, on record with Us, when We are aware of such breach at the earliest as practicable.

14. Grievance Redressal

Dhanvesttor shall address any discrepancies and grievances of the provider of the information with respect to the processing of information in a time-bound manner.If You have any discrepancies or grievances relating to the processing or usage of Information provided by You in connection with this Policy, please email us at cs@dhanvesttor.com or write to our Data Protection Officer at the following address:
Ms. Beas Moitra (Compliance Officer – Data Protection Officer)
Office for Grievance Redressal, Driv Drisht LLP (Dhanvesttor),
Surabhi Building, 2nd Floor,
8/1/2 Dr. U.N. Brahmachari Street,
Kolkata, West Bengal, 700017 India
(E): beasmoitra@dhanvesttor.com

Your grievances shall be addressed by the Grievance Officer within 1 (one) month from the
date of receipt of grievance.