This page is used to inform website visitors regarding our privacy policy (“Privacy Policy”) with the collection, use, and disclosure of personal information if anyone decided to use our services (“Services”). Kotak Alternate Asset Managers Limited (formerly known as Kotak Investment Advisors Limited) (“KAAML”)( (hereinafter referred to as “Company”, “We”, “Us” or “Our”) owns and operates this website and/or the mobile application. “You” and “Your” shall mean anyone who visits, accesses, or uses the Platform or obtains Services from Us through the Platform. We are committed to protecting Your privacy and the information You share with Us while using and operating the Platform. We value the trust You place in Us and thus We maintain the highest security standards for securing the transactions and Your information.

This Privacy Policy specifies the manner in which personal data and other information are collected, received, stored, processed, disclosed, transferred, dealt with or otherwise handled by the Company. This Privacy Policy does not apply to information that You provide to, or that is collected by, any third-party through the Platform, and any third-party sites that You access or use in connection with the Services offered on the Platform. If you choose to use our Service, then you agree to the collection and use of information in relation to this Privacy Policy. The personal information that we collect is used for providing and improving the Services. We will not use or share your information with anyone except as described in this Privacy Policy.

We, at KAAML, acknowledge and accept that the personal details that you impart to us, is to be kept in strict confidentiality and to use the information only in the manner which would be beneficial to our customers. We consider our relationship with you as invaluable and strive to respect and safeguard your right to privacy. We shall protect the personal details received from you with the same degree of care, but no less than a reasonable degree of care, to prevent the unauthorized use, dissemination, or publication of these information as we protect our own confidential information of a like nature. We shall use the personal information to improve our service to you and to keep you updated about our new product or information that may be of interest to you. The information collected from you would be used in the right spirit and context in which it is intended to be used. Your information would be used by us to provide the Services availed from Us. We would ensure that we collect personal information only to the extent it is necessary to administer our services in the best possible manner and what is required under the various regulations of Indian laws. To ensure high quality services and high degree of value addition to you, we may combine the information given by you on the web or through other channels. We would also impart your personal information wherever it is required to be disclosed under law to any of the governmental agency or regulatory bodies. We ensure that the personal information given to us by you on the web is placed in the secured portion of our web-site/ Applications. We use the most advanced encryption technology, Secure Socket Layer (“SSL”), to ensure that the information transmitted between you and us across the Internet is safe and cannot be accessed by any outsider. SSL has been universally accepted on the World Wide Web for authenticated and encrypted communication between clients and servers.

To ensure security of access to the personal information and transaction details, the access to the secured zone of our website is restricted by the unique login ID and Password selected by you. You should be very careful in handling the ID and password and you should ensure that you do not reveal it to anybody, nor do you keep it in writing. You should keep changing your password periodically. To enable us serve you better, it is necessary that your personal information available with us is updated and accurate. Our web-site enables you to update your personal information. You can also send us an e-mail at Contact Us and we shall ensure that your information is updated and protected from any misuse or unauthorized revelation.

You agree that we may use your information for the purpose of statistical analysis and for creation of data ("Statistical Information"), which does not contain individual customer information. In addition to the information that KAAML elicits from you, you are free to volunteer any other information that you feel that KAAML needs to know, but the security and confidentiality as per this Privacy Policy is guaranteed only to the information that KAAML directly asks from you.

This Policy holds true for a non-customer who has provided information to KAAML, by any means, with the intentions of establishing a relationship, of whatsoever nature, with KAAML. By divulging any information to us you agree to the terms and conditions of this Privacy Policy.

1. Information Collection:

We may collect personal information, transaction information and non-personal information from You when You register or set up an account with Us on the Platform or when You avail the Services. For a better experience, while using our Service, we may collect your personal information to provide services on its Platform. While opening our app, you may be asked for certain Sensitive Personal Data or Information (as defined under the Information Technology Act, 2000) to complete your KYC (as per the ‘Know Your Client’ requirements set by SEBI) and as per the Prevention of Money Laundering Act, 2002. We would save such information as required by the law, and as directed by the regulators or by any appropriate authority, for the purpose of offering You our services, and for such further regulatory, audit, and business purposes. We collect personal information from You only when You voluntarily use the services provided by KAAML.

You may provide to Us voluntarily while registering on Our Platform for using Services, such as mobile number, email address, password, date of birth, gender, Permanent Account Number (PAN), signature, marital status, nominee details, We may also ask You for certain financial information, including Your billing address, bank account details, credit card number, expiration date and/or other payment related details or other payment method data, and debit instructions or other standing instructions to process payments for the Services. We may ask You to provide certain additional information about yourself on a case to case basis. All information disclosed by You shall be deemed to be disclosed willingly and without any coercion. KAAML is not liable for any issues concerning the authenticity, genuineness, misrepresentation, fraud, or negligence of the information that has been disclosed, nor is it responsible in any way to verify any information that has been obtained from You.

KAAML may from time to time collect information, i.e. non-personal information which cannot be used to identify you personally, while You are using the Platform. KAAML may from time to time collect information such as non-personal information such as IP (internet protocol) addresses, browser types, the name of your ISP (internet service provider), information about a third party link/URL from where You arrive to our website/mobile application, which pages/URLs do You click on the KAAML website / mobile application, and the amount of time spent on each.

KAAML may disclose your information, to the extent necessary: (i) to comply with directions from the regulator or by an appropriate authority, (ii) to protect the rights and property of KAAML, and (iii) in an emergency to protect the personal safety and assets of the KAAML, the users, or any person. In such an event KAAML is in no manner responsible for informing you or seeking your approval or consent.

We may collect following information from you, as you have disclosed to us:

• Personal details (e.g. name, contact details including, residential address, date of birth, documents such as PAN card or education details) provided by You to Us to avail various services from Us;
• Your details including transaction history, balances and payment details, for effecting transfer of monies through various payment channels facilitated by Us;
• Financial details (e.g. income / salary) needed as a part of request for some of our products / services;
• Images of documents / photos required to avail any of our products / services;
• Voice recordings of conversations of You with our customer care agent, to address Your queries / grievances;
• Employment details (e.g. occupation, positions held, employment history, salary and / or benefits) as part of our record retention for various product evaluations or as required under Applicable Laws including Prevention of Money Laundering (Maintenance of Records) Rules, 2005;
• Specimen signature(s) or consent for processing of your instructions received by us through Our various payment and delivery channels;
• Opinions provided by You to Us by way of feedback or responses to surveys;
• Information obtained from your mobile device by way of using our app like device location, communication information including contacts and call logs, device information (including storage, model, mobile network, device id including MAC Address, IMEI).

We may retrieve from your records available with third party including from Know Your Customer (KYC) Registration Agency (KRA)or CKYC such as name, KYC details, KYC status, father’s name, occupation, address details and related documents.You hereby agree that, we may fetch or update your personal details from government agencies or regulated authorities like KYC Registration Agency’s, Central Registry of Securitization Asset Reconstruction and Security Interest, Asset Management Company’s, Registrar and Transfer Agency’s, etc.

2. Use of your information:

We use the personal information, non-personal information, transactional information and user communications and such other information provided by You for the following:

• to provide and improve the Services on the Platform that You request;
• to resolve disputes and troubleshoot problems;
• to help promote a safe service on the Platform and protect the security and integrity of the Platform, the Services and the users;
• collect money from You in relation to the Services,
• inform You about online and offline offers, products, services, and updates;
• customize Your experience on the Platform or share marketing material with You;
• to detect, prevent and protect Us from any errors, fraud and other criminal or prohibited activity on the Platform;
• enforce and inform about our terms and conditions;
• to process and fulfil Your request for Services or respond to Your comments, and queries on the Platform;
• to contact You;
• to allow Our business partners and/or associates to present customised messages to You;
• to communicate important notices or changes in the Services, use of the Platform and the terms/policies which govern the relationship between You and the Company and with Our affiliates for providing Services to You; and
• for any other purpose after obtaining Your consent at the time of collection.

You hereby specifically agree and provide Your consent thereby enabling Us and/or our group companies, subsidiaries, affiliates to collect, store, transfer, process and share information (including personal information) related to You with third parties such as Banks, financial institutions, credit information companies, entities registered under applicable laws with Securities Exchange Board of India, National Stock Exchange of India Limited/BSE Limited/Central Registry of Securitisation Asset Reconstruction and Security Interest of India (CERSAI)/payment gateways/ collecting banks/KRAs etc. solely for the purpose of reviewing your profile and processing your transaction requests for the Services or for other products/services offered by us or our group companies, affiliates and subsidiary companies

We may automatically track certain information about You based upon Your behaviour on the Platform.

We use this information to do internal research on Your demographics, interests, and behaviour to better understand, protect and serve You. This information is compiled and analysed by the Company on an aggregated basis and not individually, in a manner that does not specifically identify You.

In addition to the above, We identify and use Your IP address to help diagnose problems with Our server, resolve such problems and administer the Platform. Your IP address is also used to help identify you and to gather broad demographic information.

Unless and until, You explicitly give Your consent to Us, to do so, We will not share Your personal information with another user of the Platform and vice versa.

Use of information received by the Company and/or its affiliates or subsidiary companies from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.

We may use the customer information for, among other things, customer verification, provision of products and services, for personalization of products or services, marketing or promotion of our financial services or related products or that of our associates and affiliates; for creation of Statistical Information, statistical analysis or credit scoring, enforcement of your obligations, any other purpose that will help us in providing you with optimal and high-quality services.

At all time, we will comply with Information Technology (Reasonable Security and Procedures and Sensitive Personal Data or Information) Rules, 2011, The Digital Personal Data Protection Act, 2023 or any other amendments from time to time while processing the personal data of yours while availing the Services.

3. Log Data:

We want to inform you that whenever you use our Service, in a case of an error in the app we collect data and information (through third party products) on your phone called Log Data. This Log Data may include information such as your device Internet Protocol (“IP”) address, device name, operating system version, the configuration of the app when utilizing our Service, the time and date of your use of the Service, and other statistics.

4. Security:

We have taken reasonable measures to protect security and confidentiality of the customer information and its transmission through the World Wide Web. You are required to follow the terms and conditions while using this Platform including the instructions stated therein in respect of security and confidentiality of your Log-in and Password.

Our Platform has reasonable security measures and safeguards in place to protect Your privacy and personal information from loss, misuse, unauthorized access, disclosure, destruction, and alteration of the information in compliance with applicable laws. Further, whenever You access Your account on the Platform or any information relating to it, We offer the use of a secure server. We cannot however ensure or warrant the security of any information You transmit to the Company or guarantee that Your personal information and/or other non-personal information provided for availing the Services or accessing the Platform will not be accessed, disclosed, altered or destroyed by a breach of any of Our security measures and safeguards. It is further clarified that You have, so long as You access and/or use the Platform (directly or indirectly), the obligation to ensure that You shall, at all times, take adequate physical, managerial, and technical safeguards, at Your end, to preserve the integrity and security of Your data which shall include and not be limited to Your personal information.

When Transaction Information is being transmitted on or through the Platform, it will be protected by encryption technology. You expressly consent to the sharing of Your information with third party service providers, including payment gateways, to process payments and manage your payment-related information. We take various steps and measures to protect the security of your information from misuse, loss, unauthorised access, modification or disclosure. We use latest secure server layers encryption and access control on our systems. Please do not share your Account’s login, password, OTP details or credentials with anybody.

While We observe reasonable security measures to protect Your personal information on all our digital platforms, security risks may still arise for reasons outside of our control such as hacking, virus dissemination, force majeure events, breach of firewall etc. Please note that the above mentioned measures do not guarantee absolute protection to the personal information. The Company assumes no liability or responsibility for disclosure of Your information due to errors in transmission, unauthorized third-party access, or other causes beyond its control. You play an important role in keeping Your personal information secure. You shall not share Your personal information or other security information for Your account with anyone. The Company has undertaken reasonable measures to protect Your rights of privacy with respect to Your usage of the Platform controlled by Us and Our Services. However, We shall not be liable for any unauthorized or unlawful disclosures of Your personal information made by any third parties who are not subject to Our control.

You agree to notify us immediately in case of any unauthorized or illegal access/ use of your account or any breach of security arising due to your action/ inaction. We shall notify you and/or the appropriate authority in case of any breach of security, data at our end and in accordance with such timelines as may be prescribed under applicable law(s)

This Privacy Policy and the security controls and practices implemented by Us to Protect Your personal information shall be the reasonable security practices and procedures under section 43A of the Information Technology Act, 2000.

You shall not host, display, upload, modify, publish, transmit, store, update or share any Information that:

• belongs to another person and to which You do not have any right.
• Is obscene, pornographic, paedophilic, invasive of another’s privacy including bodily privacy, insulting or harassing on the basis of gender, racially or ethnically objectionable, relating or encouraging money laundering or gambling, or promoting enmity between different groups on the grounds of religion or caste with the intent to incite violence.
• Is harmful to child.
• infringes any patent, trademark, copyright or other proprietary rights.
• deceives or misleads the addressee about the origin of the message or knowingly and intentionally communicates any misinformation or information which is patently false and untrue or misleading in nature.
• threatens the unity, integrity, defence, security or sovereignty of India, friendly relations with foreign States, or public order, or causes incitement to the commission of any cognizable offence, or prevents investigation of any offence, or is insulting other nation.
• contains software virus or any other computer code, file or program designed to interrupt, destroy or limit the functionality of any computer resource.
• violates any law for the time being in force.

KAAML will give access to customer information to only authorised employees. Employees who violate this Privacy Policy shall be subject to disciplinary process as per the byelaws of KAAML. Any employee who withdraws from the employment of KAAML will have to undertake to abide by this Privacy Policy and keep all customer information secure and confidential.

5. Disclosure:

• We shall not be held liable for disclosure of the customer information or Statistical Information in accordance with this Privacy Policy or in terms of any other agreements with you.
• We may disclose the Statistical Information to any person, without any limitation and you hereby give your irrevocable consent for the same.
• We may disclose customer information to any of our associates and affiliates, without any limitation and you hereby give your consent for the same.
• We may disclose the customer information, to third parties, without limitation, for the following reasons and you hereby give your irrevocable consent for the same:-
  • To comply with legal requirements, legal process, legal or regulatory directive/ instruction. or
  • To enforce the Terms and Conditions of the products or services. or
  • To protect or defend our rights, interests and property or that of our associates and affiliates, or that of our or our Affiliate's employees, consultants etc. or
  • For fraud prevention purposes. or
  • As permitted or required by law.
• We may disclose the customer information to third parties for following, among other purposes, and will make reasonable efforts to bind them to obligation to keep the same secure and confidential and an obligation to use the information for the purpose for which the same is disclosed, and you hereby give your irrevocable consent for the same: -
  • For participation in any telecommunication or electronic clearing network. or
  • For credit rating by a credit rating agency. or
  • For advertising. or
  • For facilitating joint product promotion campaigns. or
  • For the purposes of credit reporting, verification and risk management to/ with clearing house centers or credit information bureau and the like. or
  • For availing of the support services from third parties e.g. collecting subscription fees, and notifying or contacting you regarding any problem with, or the expiration of, any services availed by you.
• For sharing with third-parties information obtained with your consent, from your mobile device like device location, device information (including storage, model, installed apps, wifi, mobile network) transactional and promotional SMS, communication information including contacts and call logs, for statistical modelling, credit scoring and any other purpose that will help us in providing you with optimal and high quality services.

6. Cookie Policy:

To continually enhance your online experience, We use cookies that store your preferences and give us data about your browsing behaviour, such as the pages you visited on our Platform how much time you spent on our Platform etc. This information helps us understand customer interests and helps us improve our services. By visiting the Platform you acknowledge, accept and expressly authorize us for the placement of cookies on your computer or hand held device.

7. What are Cookies?

A cookie is a simple text file that is stored on your computer or mobile device by a website’s server and only that server will be able to retrieve or read the contents of that cookie. Every cookie is unique to your particular web browser. It will contain some anonymous information such as a unique identifier and the site name with some digits and numbers. It allows the website to remember your browsing behaviour & show you relevant ads based on the browsing pattern. The cookies also allow the website to limit the number of ads shown.

How does this Platforms / website use Cookies?

This website uses cookies to capture following information –

• Source of visit to the website/platform
• Time spent on the website/platform
• Pages viewed on the website/platform
• Ad clicks

Please note that the scope of this tracking is limited to this website domain. User activity on other third-party websites is not tracked by this website's cookies.

Further information about cookies

If you’d like to learn more about cookies in general and how to manage them, visit www.aboutcookies.org (opens in a new window - please note that we can’t be responsible for the content of external websites).

8. Changes to this policy:

This Privacy Policy is subject to change and may be updated or revised from time to time, without any prior notification to the user, at the sole discretion of KAAML. Thus, you are advised to review this page periodically for any changes. These changes are effective immediately after they are posted on this page. We will endeavour to notify you of any major changes but you may wish to check it each time you visit our platform. We deem necessary to keep You updated about this Privacy Policy. Any changes or updates will be effective immediately. You should review this Privacy Policy regularly for changes. Your continued usage of the Platform shall signify Your consent to such changes and You shall be legally bound by the same. If you do not agree with the terms of this Privacy Policy or any changes made to this Policy, please stop using all products and services provided by KAAML immediately and write to us at email ID stated below in Contact Us section.

Your Consent: By visiting the Platform or setting up/creating an account on the Platform for availing the Services on the Platform at such time, You signify Your acceptance to the provisions of the Privacy Policy.

Withdrawal of consent:

You may choose to withdraw Your consent provided hereunder at any point in time. Such withdrawal of consent must be sent in writing to the email id mentioned in Contact Us. In case You do not provide Your consent or later withdraw Your consent, We may request you not to access the Platform and/or use the Services and also reserve the right to not provide You any Services through the Platform. In such a scenario, the Company may delete Your information (personal or otherwise) or de-identify it so that it is anonymous and not attributable to You. Notwithstanding anything contained herein, the Company may retain some or all of Your information in accordance with our policies and/or any applicable law(s).

9. Link to third-party sites:

The Platform may contain links to other third-party websites or apps. While we try to link only to platforms that share our high standards and respect for privacy, we are not responsible for the content or the privacy practices employed by other platforms. Note that these external sites are not operated by Us. Therefore, we strongly advise You to review the Privacy Policy of these websites. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or Services.

The Company is not in any manner responsible for the security of such information or their privacy practices or content of those third – party sites/apps. Additionally, You may also encounter “cookies” or other similar devices on certain pages of the third – party sites/apps and it is hereby clarified by the Company that the Platform does not control the use of cookies by these third – party sites/apps. You agree and acknowledge that We are not liable for the information published in search results or by any third-party sites/apps.

10. Purging of your Personal Data:

You may disable or delete your account at any point of time by writing to us at say [email protected] subject to the applicable terms and conditions. With this, we will no longer share your data with any new partners. However, we retain your Personal Data as long as the purpose for its usage exists, after which the same is disposed of by us except for any record retention required by Applicable Laws.

11. Children’s Privacy:

These Services do not address anyone under the age of 13. We do not knowingly collect personally identifiable information from children under 13. In the case we discover that a child under 13 has provided us with personal information, we immediately delete this from our servers. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us so that we will be able to do necessary actions.

12. Contact Us:

You may contact us on any aspect of this Privacy Policy or for any discrepancies with respect to your personal data, by writing to us at say [email protected].

13. Governing Law & Jurisdiction:

This Privacy Policy will be governed by and construed in accordance with the laws of India and subjected to the exclusive jurisdiction of Courts at Mumbai.