We really value our users and by extension, we value your trust and privacy. That’s why we’ve developed this privacy policy; to be transparent about the personal data we collect, how it’s used, who it’s shared with and what choices our users have over their data.
This privacy policy applies to the personal data that Rosy Blue Securities Private Limited (“RBSPL”) processes in connection with the platform and applications, web Services, products and services.

Privacy Policy
RBSPL’s Privacy Policy aims at handling of or dealing in personal information of an individual or entity, including sensitive personal data or information - collected, received, possessed or stored during the course of its business under lawful contract.
We capture personal information about the proposed user while registering with RBSPL for Opening of account for Online Trading and Accounts Access.

Disclosure of Information
We will hold your personal information confidentially and will preserve it. We will not sell or rent the information to anyone. We consider our relationship with you as invaluable and strive to respect and safeguard your right to privacy.
In case of a compulsion to share your information, we shall obtain your prior consent and the information shall be shared with only those people or companies who are authorized by you to do so.

Security
Do help us protect your privacy by maintaining the secrecy of the username and password you use for any of our services. . 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

Policy Statement:
RBSPL or any person acting on its behalf (together referred to as “RBSPL”) shall obtain consent in writing through letter or fax or email from the provider of the sensitive personal data or information regarding purpose of usage before collection of such information. The provider of information shall, at any time while availing the services or otherwise, also have an option to withdraw its consent. Such withdrawal of the consent shall be sent in writing to RBSPL. In the case of provider of information not providing or later on withdrawing his consent, RBSPL shall have the option not to provide its services for which the said information was sought.

RBSPL shall not collect sensitive personal data or information unless:-
i.   the information is collected for a lawful purpose connected with a function or activity of; and
ii.  the collection of the sensitive personal data or information is considered necessary for that purpose.
While collecting information directly from the person concerned, RBSPL shall take such steps as are, in the circumstances, reasonable to ensure that the person concerned is having the knowledge of
a.  the fact that the information is being collected;
b.  the purpose for which the information is being collected;
c.  the intended recipients of the information; and
d.  the name and address of
i.    the agency that is collecting the information; and
ii.    the agency that will retain the information.
RBSPL shall not retain that information for longer than is required for the purposes for which the information may lawfully be used or is otherwise required under any other law for the time being in force.
RBSPL only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including satisfying any legal, accounting or reporting requirements.
RBSPL permit the providers of information, as and when requested by them, to review the information they had provided, and ensure that any personal information or sensitive personal data or information found to be inaccurate or deficient shall be corrected or amended as feasible.
However, RBSPL shall not be responsible for the authenticity of the personal information or sensitive personal data or information so provided.
RBSPL shall, prior to the collection of information including sensitive personal data or information, provide an option to the provider of the information to not to provide the data or information sought to be collected.       
In some circumstances, we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes. In this case, we may use this information indefinitely without giving you further notice.                              

Personal or sensitive personal data or information:
RBSPL, during the course of its business, may collect personal or sensitive personal information/data or documents (together referred to as “Information”).
1.Personal data/Information -Any information/document that relates to a natural person, which either directly or indirectly, in combination with other information available or likely to be available with RBSPL, is capable of identifying such person like name, residential address, Guardian's name (if minor), Email address, Domain address, Telephone/mobile number, Date of birth, Job position/Occupation etc.
2. Sensitive Personal data/Information: Sensitive personal data or information of a person means such personal information which consists of information relating to:
i. passwords;
ii. financial information such as Bank account or credit card or debit card or other payment instrument details, income, assets, investment strategy, investment background etc;
iii. any document provided for identity verification like copies of passport, utility bills, and/or bank statement or your company incorporation details etc
iv. physical, physiological and mental health condition;
v.  sexual orientation;
vi. medical records and history;
vii. Biometric information;
viii. any detail relating to the above clauses as provided to RBSPL for providing service; and
ix. any of the information received under above clauses by RBSPL for processing, stored or processed under lawful contract or otherwise:
Provided that, 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 sensitive personal data or information for the purpose of this policy.
Further, RBSPL may collect some information automatically such as IP address, information about web browser software and version, general geographic location indicated by your IP address, website that referred the person to RBSPL, and similar information.
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 Customer Service and we shall ensure that your information is updated and protected from any misuse or unauthorised revelation.

Failure in providing data      
Sometimes, we need to collect personal data by law. Sometimes, we need to collect personal data under the terms of a contract we have with you. Should you fail to provide this data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our Services).
In this case, we may have to cancel a product or service you have with us, but we will notify you in advance.

Use of collected Information:
RBSPL may use the personal information for the following purposes:
•for processing business related transactions, providing, improving, and marketing services, including site content and performance;
•Responding to requests for information
•To personalize user experience
•To improve the functionality of RBSPL’s website
•To send business/marketing communications, periodic marketing emails, newsletters, and exclusive promotions offering special deals
•To participate in sweepstakes, contests, promotions, surveys, and similar promotions and to administer these activities
•Monitoring compliance with any terms and conditions associated with RBSPL’s services, including to confirm identity
•Performing such other functions as described to the provider of information, at the time of collection or pursuant to their consent.
In addition, certain information collected by RBSPL such as the IP address of any computer or other device that the information provider use to access RBSPL’s website and any other domains that may be operated by RBSPL, will be used to monitor and investigate possible violations of, and enforce any terms and conditions associated with RBSPL’s products and services or other applicable agreements between the information provider and RBSPL.

Disclosure / Sharing / Transfer of information:

We may share personal data with entities within the RBSPL Group.

•Disclosure of information by RBSPL to any third party shall require prior permission from the provider unless such disclosure has been agreed to in the contract between RBSPL and the provider of information, or where the disclosure is necessary for compliance of a legal obligation.

•RBSPL shares the sensitive personal information to any third party without obtaining the prior consent of the User in the following limited circumstances
a) When it is requested or required by law or by any court or governmental agency or authority to disclose, for the purpose of verification of identity, or for the prevention, detection, investigation including cyber incidents, or for prosecution and punishment of offences. These disclosures are made in good faith and belief that such disclosure is reasonably necessary for enforcing these Terms; for complying with the applicable laws and regulations.
b) RBSPL proposes to share such information within its group companies and officers and employees of such group companies for the purpose of processing personal information on its behalf. We also ensure that these recipients of such information agree to process such information based on our instructions and in compliance with this Privacy Policy and any other appropriate confidentiality and security measures.
•RBSPL may transfer information to any other body corporate or a person in India, or located in any other country, that ensures the same level of data protection that is adhered to by RBSPL as provided for under this policy. The transfer may be allowed only if it is necessary for the performance of the lawful contract between RBSPL and provider of information or where such person has consented to data transfer.

•If RBSPL choose to sell, transfer or merge parts of our business or our assets, we’ll share your personal data with the new owners of our business, who may use your personal data in the same way set out in this privacy policy.

Disclaimer: RBSPL cannot control the privacy practices of the third parties and thus is not responsible for any non-compliance with respect to disclosure of information done by such third parties.

Grievance Officer:
•RBSPL shall address any discrepancies and grievances, with respect to processing of information, of the information provider in a time bound manner, through its designated Grievance Officer.
•Name and contact details of the Grievance Officer are published on the website of RBSPL at https://www.rosybluesecurities.co.in/
•The grievances of the information provider shall be redressed expeditiously but within one month from the date of receipt of grievance.


Security / Safeguard Practices and Procedures:
Among others, following RBSPL IT security access policies shall be adhered to for the purpose of security and safeguarding the information of the provider:
• Data disposal & Data Retention Policy
• Information Security policy
• Cryptographic and Encryption Policy
• IT Access Control Policy
• Physical Security Policy
• Network Security Policy
• Internet Access Policy

Review/Amendments to this policy:
This policy has been adopted by the Board of Directors of RBSPL. Board may review and amend the terms of this policy as and when required due to regulatory changes or under any other circumstances necessitating revision to this policy.