Qovar Advisors Private Limited, (hereinafter referred to as “Company”, “Qovar”, “us”, “our,” or “we” and other terms of similar meaning) is registered as an ‘Investment Advisor’ with the Securities and Exchange Board of India in accordance with the SEBI (Investment Advisers) Regulations, 2013 and is engaged in the business of providing portfolio advisory services in direct equities and other advisory solutions to investors in Indian capital markets.
USER REPRESENTATIONS AND WARRANTIES
By using and accessing our and our authorised partners’ products, services, websites and other platforms and by providing your information in relation thereof, you represent and warrant as follows:
- You are at least 18 (eighteen) years of age or have attained the legal age under the laws applicable in the jurisdiction from where you access the above-mentioned;
- You will comply with all laws, rules and regulations of India, in so far as applicable to you; and
- You shall provide accurate, current and complete information as may be prompted (i.e., registration, user account, portfolio building related details including financial information) and maintain and undertake to update us in respect of any changes thereof.
- Qovar’s website available at [www.qovar.in] (“site” or “website”);
- our portfolio advisory products (“products”);
- our portfolio advisory services (“services”); and
- our authorised partner’s platform addressed as [www.qovar.smallcase.com] (“platform”).
We hold no liability for any attempt to gather information through our website, platform, products and services once it is out of our jurisdiction.
INFORMATION THAT WE GATHER
We collect certain personal, non-personal and other information from you, as indicated below, that we consider necessary for you to access the website, platform, products and services (hereinafter collectively referred to as “information”):
Any personal information we collect from users helps us customize and improve our website, products and services. Personal information means information that is about any individual, or from which any individual is directly or indirectly identifiable. Personal information shall include all information that can be linked to a specific individual or used to identify any individual, such as (i) contact data (i.e., your e-mail address, phone number, account details and passwords); (ii) demographic data (i.e., your gender, your date of birth, nationality, zip code); (iii) details of consents (records of consents given with the date and time and other relevant information); (iv) billing and payment information (as applicable); (v) other information (i.e., your permanent account number, credit score, income, assets, etc.); and (v) any and all details that may be identifiable in nature (“personal information”). Please note that the above list is not an exhaustive list and is only an illustrative list.
We do not collect or otherwise process personal information about race, religion, sexual orientation and/ or health or any other information that may be deemed to be sensitive under the applicable laws of India in the ordinary course of our business.
When browsing our site or the platform, you are not required to provide any personal information unless and until you choose to use and access our products and services.
Any content on public platforms shared by you via reviews, comments, blogs, discussion boards, forums, user testimonials, scribbles, etc., becomes published content, are not considered as personal information and is not protected by us.
When you visit our site or the platform, relevant non-personal information may be collected such as domain and host from which you access the internet, your internet protocol (IP) address, operating system, browser type and internet service provider. This type of information does not identify you personally.
In the course of providing our products and services, we collect your information (personal or otherwise) for the following sources:
- Portfolio applications and other standard forms related to your accounts and information that you disclose to us through offline methods (if any) or the platform. Examples of information collected include your name, address, permanent account number, date of birth, investments in different asset classes, and any know your customer information.
- Your transactions with us and any entity associated with us i.e. authorized partners, including those that work closely with us to provide you with diverse financial advisory products and services. Examples of information collected include your account balance, payment history, parties to transactions, types and amounts of investments and transactions.
- Associated entities, primarily our authorized partners that are affiliated with us.
- Our customer support team or communications team.
When you send emails or other communications to us, we may retain those communications in order to process your inquiries, respond to your requests and improve the website, platform, products and other services. Further, the email address and contact number you provide for on-going correspondences may be used to send you information and updates pertaining to the products and services sought by you, in addition to receiving occasional company news, updates, related product or service information, etc., and you provide your express consent thereof.
We endeavour to provide you with choices and obtain your clear, decipherable and indistinguishable consent regarding the information and personal information you provide to us and our authorised partners. Please note that your consent shall be as easy to withdraw as it is to give it, provided your use and access to our products and services and its associated/ linked services (including the platform) may be disabled or non-usable at your own cost, risk and responsibility.
We restrict access to your personal information and other information to our employees, our affiliates/ partners, associated persons and companies with which we have contractual arrangements that have a need to know such information to assist us in providing products and services to you. We maintain physical, electronic and procedural safeguards that comply with applicable laws to protect your personal information. When we use other entities to help provide our products and services to you, we require them to protect the confidentiality of any personal information they receive.
INFORMATION COLLECTED WHEN YOU USE, ACCESS AND ADOPT OUR PRODUCTS AND SERVICES
Analytics Information/ Data
Certain information is collected and processed with users’ usage of the site and the platform, such as log files, number of visitors on the site and/ or platform, site traffic and other non-identifying statistics. When you visit our site or the platform we may collect and analyse details including but not limited to IP address, operating system, browser type and internet service provider. Qovar uses this information to analyse the use, viewership and access of the site, to improve user experience and interaction with the site and provide you with best possible information about our products and services.
In case you are accessing our site or the platform on your mobile or other electronic device including, but not limited to, smartphones or tablets, then certain information might be accessed such as your location. You can choose to not share the details in which case certain functionalities will be disabled.
PERSONAL INFORMATION COLLECTED FROM OTHER SOURCES
Third Party Website Links and Services
In summation, you can freely visit and browse our site and the platform and share personal information as and when you choose based on your express consent. We may also, from time to time, opt to send you updates regarding products and services, special offers and/ or any other information we think might be of interest to you. If you wish to not receive such updates, you can always opt and unsubscribe from the mailer list.
HOW IS THE INFORMATION USED?
The sole purpose of the use of your personal information shared by you is to provide you with a better product experience, continually improve the services offered by us and our site/ the platform and customize your experience as a user. We may use your personal information shared to us for following purposes:
- we will use the information to communicate with you to personalize and improve product and service experience and process and fulfil your requests (if any);
- for providing products and services and access thereto, we may disclose your personal information to the Company’s and/or our authorised partners (as applicable and if required for the purposes of our legitimate business interest);
- to improve our products and services, provide customizations and other associated services;
- for analytics purpose to understand how our products and services are being used,
- for the purposes of customer support to take continuous feedback in order to improve our existing products and services or provide our users with any specific customized products and services;
- to send marketing communications, updates or special offers;
- as and when required by applicable laws or any governmental authority or judiciary process extending claim or jurisdiction over the Company or our authorised partners;
- to contact you and to customise our communication with you and the marketing material/ advertisement we and our partners share with you;
- to avoid fraud, misappropriation and other prohibited or illegal activities;
- for any other specific purpose in which case your consent will be asked prior to using your personal information, and
- for any other purpose to give effect to the abovementioned.
HOW IS THE INFORMATION SHARED?
We do not share, disclose, sell or otherwise trade in any personal or other information provided by you with other persons/ entities or any third-party affiliates except for the purposes of our legitimate business interests and to facilitate your requested products and services based on any information shared by you voluntarily.
Further, we may share, release or transfer information about you, in respect of the following:
- for legitimate business purposes (including but not limited to providing our products and services, access to the platform or conducting our business), in accordance with applicable law, with our authorised partners having a contractual arrangement with us;
- for expertise, services and advise of professional advisors (such as accountants, auditors, or lawyers), subject to binding contractual obligations of strict confidentiality and non-disclosure,
- if we believe it is necessary to share any personal information in order to control, investigate or take appropriate action regarding any illegal activity, fraud or any situation involving or causing any potential threat to the safety of any person(s), entity(ies) or group(s), as and when required by law and judicial process, or in case of violation of our policy statement or terms of service;
- to the extent necessary for the establishment, exercise or defense of legal rights and remedies, we shall disclose information to any relevant party, law enforcement agency or competent court of applicable jurisdiction(s);
- our authorised partners for our marketing, promotional, advertising processes and additionally analyse and suggest any other related product(s)/ service(s) in order to further improve and customize your experience with us as a user;
- in any other situation in which case we will seek prior consent before sharing, releasing or transferring your information to any third party.
LAWFUL BASIS FOR PROCESSING INFORMATION
Further, we may also process certain personal information on the basis of the following legitimate business interests, provided that such interests are not overridden by your data protection and privacy rights and interests: (i) providing products and services or other associated/ linked services as requested by you; (ii) analyse and suggest if any other related product/ service shall be suitable for you; and (iii) develop and continue to develop, upgrade and improve our products and services, our site and the platform.
RETENTION OF INFORMATION
Notwithstanding the above, we may choose to delete the personal information shared by user(s) in case the information is no longer required to carry out our legitimate business interests and the purposes for which we were processing the information for unless we are required by applicable laws of India or any other binding action to retain the information for further processing. In case of data deletion or purging, backups shall be made in our systems/ servers/ networks, at our sole discretion only. We may choose to keep the information in a form which does not permit identifying you personally.
PROTECTION OF INFORMATION
Qovar ensures proper safeguards to protect the personal information entrusted to us. We use reasonable security measures to protect information from unauthorized access, maintain data accuracy, and help ensure the appropriate use/ disclosure of information. These safeguards take into account the sensitivity of the information that we collect, process and store and the current state of technology.
We take proper, adequate, efficient and best industry standards related technical, physical, administrative and managerial measures to protect your personal information against accidental loss or unlawful acquiring or unauthorised access and misuse or any other unlawful way of information processing of the shared information trusted to us by the users. We share, execute and sign duly stamped and properly drafted contractual agreements with our service providers (third party or otherwise) to safeguard any information from being misused or unlawfully accessed, that is in our possession. Even with our best efforts we cannot promise 100% security in certain cases owing to the associated risks of sharing and receiving information via internet as the internet is not 100% secure. We encourage you to use your own discretion while sharing any personal information voluntarily.
We host our site and the platform in a protected manner by utilizing a secure server environment that uses firewalls and other advanced technology to prevent interference or access from outside intruders.
CAN USERS ACCESS THE INFORMATION?
You have the right to request access to receive details about the personal information we collect, retain and maintain about you in order to correct or update any inaccuracies in your shared personal information, to have your shared details deleted or blocked. You can also exercise your right to data portability to ensure seamless transfer of your shared information with any third party at your own discretion and subject to applicable laws.
CAN CHILDREN ACCESS PRODUCTS AND SERVICES?
Please note that our products, services, site and the platform are meant to be used by adults above 18 (eighteen) years of age. Any discrepancies arising out of any usage of our products or services by children will not be our responsibility and consequently any imposition of obligations or liability thereof shall not be attributable to us.
INTERNATIONAL TRANSFER OF DATA
To facilitate the provision of our products and services to you, we may store and send your personal information outside the country where you reside or are a national of, including countries which may have privacy protection laws that are less stringent than the ones at the country you reside in. We are committed to protect your personal information during such transfers. However, by using and accessing our products and services and thereby giving your consent thereof, you agree and consent to the transfer to and processing of personal information on servers located outside of the country you reside in and that the protection of such information may be different than required under the laws of your residence or nation. For the sake of clarity, we shall only be responsible or liable to the extent of any breach of the applicable laws of India.
HOW TO CONTACT US?
GRIEVANCE REDRESSAL MECHANISM
- A504, Esteem Enclave, Near Arekere gate, Bannerghatta road, Bangalore – 560076
© Qovar Advisors Private Limited 2019. All Rights reserved.
Latest update: August 5th, 2019