Privacy Policy

Monarch Networth Asset Management Private Limited

1. Background

Monarch Networth Asset Management Private Limited (“Monarch AMC” or the “AMC”), a company incorporated under the Companies Act, 2013, has been appointed as the Investment Manager to the schemes of Monarch Mutual Fund (the “Mutual Fund”), a mutual fund registered with the Securities and Exchange Board of India (“SEBI”) under Registration No. MF/092/26/18. Monarch Networth Trustee Private Limited (the “Trustee Company” or “Trustee”) is the Trustee to the Mutual Fund. Monarch Networth Capital Limited is the sponsor of the Mutual Fund (the “Sponsor”).

Monarch AMC, either directly (through the monarchamc.in website, its investor and distributor portals, web applications and other applications) and its related social media accounts (collectively, the “Sites”), or through third party service providers engaged by the AMC (“Service Providers”) such as the Registrar and Transfer Agent, collects, receives, possesses, stores, deals with or handles information received from investors, clients, customers and distributors, whether existing or prospective.

This Privacy Policy governs the collection of information including (a) personal information or sensitive personal data of current or prospective investors, clients, customers and distributors; (b) visitors to the website (https://monarchamc.in) and to the products, services and software made available through it; and (c) such other persons who intend to enter into any kind of relationship with the AMC (each such person referred to as “Information Provider”, “User”, “You” or “Your”).

The Policy further specifies how the information collected from each User is used, maintained, stored, shared and disclosed.

2. Information covered under the policy

2.1. Personal Information

Personal Information means any data about an individual who is identifiable by or in relation to such data. Such information may be personal or sensitive in nature. In the course of carrying on its business, Monarch AMC may receive identifiable personal information for the purposes set out in its agreements with customers. An indicative list is given below:

Name, residential address, office address, age, gender, mobile or telephone number, email address, fax number and similar contact particulars
Bank account details, including changes to bank account details or registration of multiple bank accounts through application forms
Permanent Account Number (PAN) details
Payment instrument details furnished at the time of submitting an application for investment, or as proof for carrying out a change of bank account, and any other debit card particulars obtained (if any)
Generation and storage of a password (PIN) in encrypted form, based on a request from the investor under the online mode of investment
Know Your Customer (KYC) documents
Biometric information obtained, if any
Demat account details such as beneficiary account number
Annual income and savings profile
Third party data provided by the User, including nominee and beneficiary details
Any other information collected that may be regarded as sensitive and personal

2.2. User Data

(That is, data collected from visitors to the Monarch AMC website, web application and any other application)

This includes browser-supplied information — computer and technical information, and site session information such as the sequence of pages visited during a visit, the average time spent, information searched for and access times — which may be recorded for usage analysis and security monitoring.

When you visit our website or use our mobile application, we may use cookies and similar technologies to enhance your experience. Cookies are small pieces of information that allow the AMC to place files on your device to store preferences and track activity. These technologies include Google Tag Manager and Google Analytics. By using the AMC website and agreeing to the terms of use, you consent to our use of cookies in accordance with the terms of this Privacy Policy. A visitor, including an Information Provider, may refuse the use of cookies. Information generated by cookies about a visitor’s use of the website may be stored by the AMC for operational purposes.

Internet Protocol (IP) addresses, browser-supplied information and site session information may also be recorded as part of normal operations and for security monitoring purposes. Should you wish to disable these cookies you may do so by changing the settings on your browser; however, you will then be unable to access certain parts of our Site.

The AMC will collect personal data which is adequate, relevant and limited to the stated purpose.

3. Purpose and use of collecting the information

Collection of Personal Information: The AMC may collect or receive your Personal Information from several sources. You may provide Personal Information as part of the application or enrolment process, whether in writing or electronically. You agree and understand that your Personal Information shall be collected, processed, stored and used by us, and passed to, transmitted to and processed by our subsidiaries and affiliates, and other data processors, agents or service providers acting under contract with us, for the purposes identified in this Privacy Policy:

To respond to your requests, to process investment applications, and to ensure safe subscriptions and redemptions through points of acceptance in physical form, the website, online portals and such other modes.
To provide investors, clients and customers with good, qualitative, timely and efficient service, including management of portfolios, provision of information and statements regarding portfolios, and handling of queries and complaints.
To carry out an assessment of the applications and requests you place with us, and to carry out anti-fraud, suspicious activity or any other regulatory checks which the AMC may be directed to carry out or is bound to carry out under applicable law.
To share your information with our service providers and vendors for the stated purpose.
To maintain KYC documents.
To comply with Know Your Client (“KYC”) norms under the Prevention of Money Laundering Act, 2002 (“PMLA”), the rules issued thereunder, the guidelines and circulars on anti-money laundering issued by SEBI, and the SEBI (Mutual Funds) Regulations, 1996 read with applicable master circulars, as amended from time to time.
To contact Users regarding the products and services offered by us and to seek feedback on the services provided.

User Data collected by Monarch AMC may be used for the following purposes:

To run and operate our Site, where your information is needed to display content on the Site correctly.
To improve customer service, where the information you provide helps us respond to your service requests and support needs more efficiently.
To personalise user experience, where we may use information in the aggregate to understand how our Users as a group use the services and resources provided on our Site.
To run a promotion, contest, survey or other Site feature.
To send Users information they have agreed to receive about topics we think will be of interest to them.
To send periodic emails.
To respond to enquiries, questions and other requests.
For regulatory or legal purposes.

4. Processing the Information

The AMC is permitted to collect, process and retain Personal Information on the following grounds:

You have given your explicit consent to the processing of your Personal Information by us;
The processing of the data provided by you is integral to the AMC performing its duties and obligations under the contractual arrangements which it has entered into with you, or the same is necessary in respect of any legal obligation that is applicable to us;
Processing the data is required for a legitimate purpose pursued by us or by a third party;
Such information may also be used by us to generate statistics and reports, and to protect and defend the rights, interests and property of the Mutual Fund, the AMC, the Trustee Company, the Sponsor and their affiliates and directors, and to enforce legal rights or the provisions of the scheme related documents of the Mutual Fund, namely the Scheme Information Document (SID), Statement of Additional Information (SAI) and Key Information Memorandum (KIM);
To continue to provide and improve our services to you;
Where the same is necessary for compliance with any applicable law;
To prevent, detect or investigate any fraud or alleged fraud, instances of money laundering, or any other such activity which is punishable under applicable law.

The AMC further declares that Personal Information may be disclosed where the same is necessary to protect the legitimate interests and rights of the AMC, the Mutual Fund, the Trustee Company, the Sponsor and any other affiliate, to enforce our legal rights, and to be in compliance with any applicable law or under the directions of any court, tribunal, judicial or quasi-judicial and/or statutory authority.

6. Sharing of Personal Information

The AMC may share the Personal Information for the uses mentioned above with the following third parties: affiliates; Registrar and Transfer Agents (as defined under the relevant SEBI guidelines); banks; custodians; depositories; vendors; service providers; distributors or sub-brokers through whom applications of investors are received for investment; attorneys; accountants; auditors; call centres; external third parties who are involved in clearing the transactions; any other organisation for verifying the identity of investors for complying with anti-money laundering requirements; intermediaries whose ARN stamp appears on the application forms or transaction slips; government authorities including but not limited to the Reserve Bank of India and SEBI; post offices, couriers and other intermediaries involved in any electronic transfer of information or monies; and any court, tribunal, judicial or quasi-judicial and/or statutory authority, and arbitrators.

The AMC may share certain Personal Information with third parties such as post offices, local and international couriers and other intermediaries for correspondence with the investor and for making payments to the investor through Electronic Clearing Services (ECS), NEFT and similar mechanisms.

Personal Information shall be communicated to third persons only for reasons consistent with the purposes for which the data was originally collected, or for other purposes authorised by law.

The Information Provider expressly and unequivocally gives their consent that the Personal Information may be used to produce statistics reports for internal as well as external use, which may be forwarded to affiliates, intermediaries, successors, vendors and advertisers, and also gives their consent for the sharing of the Personal Information as highlighted above. Additionally, we shall reveal only such information to external authorities as may be found relevant and necessary in order to comply with the applicable laws, and to third party service providers to ensure smooth functioning of the activities as may be prescribed under applicable laws; the use of the Personal Information will be communicated to the third parties for reasons consistent with the purpose for which the Personal Information was originally taken.

By using our website, or by agreeing to transact with us, or by sending enquiries, you expressly agree to the terms of this Privacy Policy and to the above sharing of information. If Users do not agree with this Privacy Policy, Users are not granted permission to access or otherwise use this website.

We may also be required from time to time to disclose the Personal Information to governmental or judicial bodies or agencies, or to our regulators, based on their requirement to comply with the applicable laws including cyber laws.

Electronic Newsletters: If a User decides to opt in to our mailing list, they will receive emails that may include company news, updates, and related product or service information. If at any time the User would like to unsubscribe from receiving future emails, we include detailed unsubscribe instructions at the bottom of each email, and the User may also contact us via our Site. We may use third party service providers to help us operate our business and the Site, or administer activities on our behalf, such as sending out newsletters or surveys. We may share your information with these third parties for those limited purposes provided that you have given us your permission.

The AMC and its service providers and agents shall share data with any entity based on explicit unitholder consent as follows:

Through the Account Aggregator* ecosystem as and when notified by SEBI.
Through any similar consent artefact as and when notified by SEBI.

* An Account Aggregator is a consent manager for financial data: a class of non-banking financial company approved by the Reserve Bank of India to manage consent for financial data sharing. It was created through an inter-regulatory decision by the Reserve Bank of India, the Securities and Exchange Board of India, the Insurance Regulatory and Development Authority of India and the Pension Fund Regulatory and Development Authority, through the Financial Stability and Development Council. Account Aggregators are licensed by the Reserve Bank of India.

7. Security Measures

The AMC limits access to personal information to authorised employees or agents of the firm and, as described above under Sharing of Personal Information, our service providers are held to stringent standards of privacy. We maintain physical, electronic and procedural safeguards to protect the information against loss, misuse, damage or modification and unauthorised access or disclosure.

We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorised access, alteration, disclosure or destruction of your personal information, username, password, transaction information and data stored on our Site.

7.1. Breach of Internet Security

Despite our efforts to protect the Personal Information, if any unauthorised person or persons breaches security and control measures (including the Site being hacked, presenting inaccurate information, loss of data and the like), and illegally uses such sensitive or personal data or information, the AMC will strive to put in place corrective measures. However, the Mutual Fund, the AMC, the Trustee Company, the Sponsor and their affiliates, directors or employees shall not be held responsible or liable for the same.

7.2. Third Party data provided by the user

You might sometimes provide us personal information of others. Common scenarios include providing nominee or beneficiary details for your investments, giving details of a joint account holder, or providing referee or contact information. If you give us personal data about another person, you must do so only with proper authority or consent from that person. By submitting such information, you confirm that you have the right to do so. The AMC will use and protect that third party’s information in accordance with this Policy just as we do for your own data. Further, users are advised to share the guardian details in case the third party user is a minor.

7.3. Third Party Websites

Our website may contain links to third party websites or services that may collect personally identifiable information about you. The data protection practices of those websites linked to this website are not covered by this Privacy Policy. Third party sites are governed by their own privacy policies, and we do not have control over their content or practices. We encourage you to review the privacy policies of any external sites you visit. We will not be responsible for misuse of your information by any third party website that you access via our Site.

7.4. Retention of Information

The AMC may retain the Personal Information of the Information Provider for as long as required to provide the services, or as otherwise required under law, or for the establishment, exercise or defence of legal claims.

8. Changes To This Privacy Policy

Monarch AMC reserves the right to amend or modify any sections of this Policy from time to time to reflect changes in our practices, legal or regulatory requirements, or any other purpose we may deem necessary. The Policy, as amended from time to time, will be available on the AMC website.

We encourage you to periodically review this Privacy Policy to stay informed about how we are protecting your information. Your continued relationship with us after any changes to this Policy will be deemed as acceptance of the updated terms, except in scenarios where explicit consent is required. If you do not agree with the changes, you retain the choice to discontinue use of our services.

9. Your Acceptance of the terms of the policy and Rights thereof

Investors, clients and customers shall have expressly consented to the terms of this Policy if they enter and use this website or provide any information while transacting with us.

You have the right to request a copy of the personal data about you which we hold, to have any inaccurate personal data corrected, and to object to or restrict our using your personal data. You may also make a complaint if you have a concern about our handling of your personal data.

10. Contacting Us / Grievance Redressal

Any question, concern or complaint concerning our Privacy Policy, or any grievances relating to the use or handling of your sensitive personal data, may be brought to our notice by writing to us at iro@monarchamc.in. Please include your name, contact information, and a clear description of your issue. We will acknowledge receipt of your complaint or request and seek to resolve it as soon as possible.

Correspondence may be addressed to:

Ms. Nayana Parab, Investor Relations Officer