PRIVACY POLICY

Sapphire Broking ("Sapphire", "we", "us", or "our") is committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy describes how we collect, use, disclose, and protect your information when you visit our website, use our mobile applications, or utilize our services, including the Sapphire Terminal trading platform.

By accessing our website, using our applications, or availing our services, you consent to the practices described in this Privacy Policy. We encourage you to read this policy carefully to understand our practices regarding your personal information.

Sapphire Broking is a partnership firm registered in India and regulated by the Securities and Exchange Board of India (SEBI). We are a stockbroker and depository participant providing trading and investment services across various market segments.

Sapphire Broking is registered with the following authorities:

• Securities and Exchange Board of India (SEBI)
• National Stock Exchange of India Limited (NSE)
• BSE Limited (BSE)
• Multi Commodity Exchange of India Limited (MCX)
• National Securities Depository Limited (NSDL)
• Central Depository Services (India) Limited (CDSL)

We collect information about you through various sources to provide our services, improve user experience, and comply with regulatory requirements. The information we collect includes:

3.1. Personal Information

• Identity Information: Name, date of birth, gender, photographs, signatures, PAN, Aadhaar, and other government-issued identification details
• Contact Information: Email address, phone number, residential address, and correspondence address
• Financial Information: Bank account details, income information, tax status, investment objectives, and risk tolerance
• Employment Information: Occupation, employer name, business address, and industry
• Educational Information: Educational qualifications and professional certifications

3.2. Information Collected Automatically

• Device Information: IP address, device type, operating system, browser type, and mobile device identifiers
• Usage Information: Pages visited, features used, trading behavior, time spent on the platform, and interactions with our content
• Location Information: General location derived from IP address or more precise location when permitted by you
• Cookies and Similar Technologies: Information collected through cookies, web beacons, and similar technologies (see our Cookie Policy for more details)

3.3. Information from Third Parties

• Credit Information: Credit reports and scores from credit bureaus
• KYC Information: Verification data from KYC Registration Agencies (KRAs)
• Bank Information: Account details and transaction information from banking partners
• Market Data: Trading and market information from exchanges and data providers
• Social Media: Information shared when you connect your social media accounts to our services

We use your personal information for the following purposes:

4.1. Providing and Improving Our Services

• Processing your account applications and opening trading accounts
• Facilitating securities transactions and order execution
• Providing access to market data and research
• Maintaining your demat account and custody of your securities
• Enhancing and personalizing your experience with our platform
• Developing new features, products, and services
• Performing analytics to improve our services

4.2. Communication and Support

• Sending transaction confirmations, contract notes, and account statements
• Communicating important updates about our services
• Providing customer support and resolving disputes
• Responding to your inquiries and requests
• Sending newsletters, market updates, and promotional offers (subject to your preferences)

4.3. Compliance and Security

• Verifying your identity and preventing fraud
• Complying with legal and regulatory requirements
• Conducting risk assessments and due diligence
• Monitoring for suspicious or illegal activities
• Protecting our rights, property, and safety
• Enforcing our terms and conditions

4.4. Business Operations

• Processing payments and managing billing
• Conducting market research and analytics
• Maintaining internal records
• Performing audits and quality control
• Managing business operations and expansion

We process your personal information based on one or more of the following legal bases:

• Contract Performance: Processing necessary to provide our services and fulfill our contractual obligations to you
• Legal Obligations: Processing required to comply with applicable laws, regulations, and directives
• Legitimate Interests: Processing necessary for our legitimate business interests, provided these interests are not overridden by your rights and freedoms
• Consent: Processing based on your explicit consent, which you can withdraw at any time

We may share your personal information with the following categories of recipients:

6.1. Regulatory Authorities and Exchanges

• Securities and Exchange Board of India (SEBI)
• Stock exchanges (NSE, BSE, MCX, etc.)
• Depositories (NSDL, CDSL)
• Tax authorities and other government agencies
• Law enforcement agencies when legally required

6.2. Service Providers

• KYC Registration Agencies (KRAs)
• Payment processors and banking partners
• Cloud hosting and data storage providers
• Software and technology service providers
• Professional advisors (legal, accounting, audit)
• Customer support services

6.3. Business Partners

• Authorized research providers
• Marketing and advertising partners
• Financial product issuers
• Other financial institutions (with your consent)

6.4. Corporate Affiliates

We may share information with our corporate affiliates and subsidiaries for the purposes described in this Privacy Policy.

6.5. Legal Proceedings

We may disclose your information in response to:

• Court orders and legal process
• Regulatory inquiries and investigations
• To establish, exercise, or defend legal claims
• To protect our rights, property, or safety, or that of our users or others

6.6. Business Transfers

In the event of a merger, acquisition, reorganization, sale of assets, or bankruptcy, your personal information may be transferred as part of the transaction.

We retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. The criteria used to determine our retention periods include:

• The duration of our ongoing relationship with you
• Legal obligations to retain data for certain periods
• Statutes of limitations for legal claims
• Regulatory requirements for record-keeping
• Recommendations from data protection authorities

When we no longer need your personal information, we will securely delete or anonymize it.

Depending on your location and applicable laws, you may have certain rights regarding your personal information:

8.1. Access and Portability

You have the right to request access to the personal information we hold about you and obtain a copy of certain information in a structured, commonly used, and machine-readable format.

8.2. Correction and Update

You have the right to request correction of inaccurate information or completion of incomplete information we hold about you.

8.3. Deletion and Restriction

You may request deletion of your personal information in certain circumstances or restrict our processing of your information.

8.4. Objection

You have the right to object to our processing of your personal information in certain circumstances.

8.5. Marketing Preferences

You can opt out of receiving marketing communications from us at any time by:

• Clicking the "unsubscribe" link in our emails
• Adjusting your communication preferences in your account settings
• Contacting our customer support team

8.6. Exercise Your Rights

To exercise any of these rights, please contact us using the information provided in the "Contact Us" section below. We will respond to your request within the timeframe prescribed by applicable law.

We implement appropriate technical and organizational measures to protect your personal information against unauthorized or unlawful processing, accidental loss, destruction, or damage. These measures include:

• Encryption of sensitive information
• Secure sockets layer (SSL) technology for data transmission
• Firewalls and intrusion detection systems
• Access controls and authentication procedures
• Regular security assessments and testing
• Staff training on data protection and security
• Physical security measures for our facilities

While we strive to protect your personal information, no method of transmission over the Internet or electronic storage is 100% secure. We cannot guarantee absolute security of your information.

Sapphire Broking primarily operates in India, and your information is generally stored and processed in India. However, we may transfer your information to service providers and business partners located outside India for the purposes described in this Privacy Policy.

When we transfer personal information outside India, we take steps to ensure that such transfers are conducted in accordance with applicable data protection laws. These steps may include:

• Implementing standard contractual clauses
• Ensuring the recipient is in a country with adequate data protection laws
• Obtaining your explicit consent for the transfer

Our services are not directed to individuals under the age of 18. We do not knowingly collect personal information from children. If you are a parent or guardian and believe that your child has provided us with personal information, please contact us, and we will take steps to delete such information.

We use cookies, web beacons, and similar technologies to collect information about your interactions with our website and applications. Cookies are small text files stored on your device that help us provide and improve our services.

Types of cookies we use:

• Essential Cookies: Necessary for the operation of our website and services
• Analytical Cookies: Help us understand how users interact with our platform
• Functional Cookies: Enable enhanced functionality and personalization
• Targeting Cookies: Used to deliver relevant advertisements and marketing

You can manage your cookie preferences through your browser settings. However, blocking certain cookies may affect your experience and the services we offer.

For more information about how we use cookies, please see our Cookie Policy.

Our website and applications may contain links to third-party websites, products, and services. These third parties have their own privacy policies, and we do not have control over and are not responsible for their privacy practices. We encourage you to read the privacy policies of any third-party websites you visit.

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. We will notify you of any material changes by posting the updated policy on our website and applications with a new "Last Updated" date. Your continued use of our services after such modifications will constitute your acknowledgment and acceptance of the modified policy.

In accordance with the Information Technology Act, 2000 and the rules made thereunder, the contact details of the Grievance Officer are provided below:

• Name: [Grievance Officer Name]
• Designation: Grievance Officer
• Email: grievance@sapphirebroking.com
• Phone: [Grievance Officer Phone Number]
• Address: [Sapphire Broking Address]

If you have any questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us at:

• Sapphire Broking
• Email: privacy@sapphirebroking.com
• Phone: [Customer Support Phone Number]
• Address: [Sapphire Broking Address]

We will respond to your inquiry as soon as reasonably possible.