Privacy Policy

This Privacy Policy explains how Avdesh Mishra Capitals Private Limited collects, uses, shares, stores, and protects your information when you visit our website https://amcapitals.in/ (the “Website”) or avail of our investment advisory services. We are committed to safeguarding your privacy and handling your personal data in accordance with applicable Indian law, including the Digital Personal Data Protection Act, 2023 (“DPDP Act”), the Information Technology Act, 2000 and the rules framed thereunder, and the SEBI (Investment Advisers) Regulations, 2013.

By accessing or using the Website or our services, you acknowledge that you have read and understood this
Privacy Policy.

1. Who We Are

Avdesh Mishra Capitals Private Limited is a company incorporated under the Companies Act, 2013 and is registered with the Securities and Exchange Board of India (SEBI) as a Non-Individual Investment Adviser under the SEBI (Investment Advisers) Regulations, 2013. The relevant particulars are set out below:

• Name: Avdesh Mishra Capitals Private Limited
• Registered Office: Flat No. PSQC1-F02-07 Palm Square, Sec-66 Bhondsi Gurgaon, Gurugram, Haryana, 122102
• SEBI Registration No.: INA000022941
• BSE Enlistment No.: 2547
• Type of Registration: Investment Adviser
• Principal Officer : Vikas Yadav
• Email: vikas.nsit07@gmail.com
• Phone: +91 9911306931

2. Scope of This Policy

This Policy applies to personal data we collect through the Website, online forms, email, telephone, messaging, and during the course of providing investment advisory services. It does not apply to third-party websites or services that may be linked from our Website; those are governed by their own privacy policies.

3. Information We Collect

3.1 Information You Provide to Us

• Identity and contact details such as your name, address, email address, telephone number, and date of birth.
• KYC and onboarding information required under SEBI and PMLA regulations, such as PAN, Aadhaar (where legally permitted), bank account details, and identity/address proof documents.
• Financial information such as income range, net worth, investment objectives, risk tolerance, existing investments, and other details necessary to perform suitability and risk profiling.
• Communications you send to us, including queries, feedback, and correspondence.

3.2 Information We Collect Automatically

• Technical data such as your IP address, browser type, device information, operating system, and referring URLs.
• Usage data such as the pages you view, time spent on the Website, and navigation patterns, collected through cookies and similar technologies (see Section 8).

4. How We Use Your Information

We process your personal data for the following purposes:

• To provide investment advice and render advisory services in accordance with the SEBI (Investment Advisers) Regulations, 2013.
• To carry out KYC, client onboarding, suitability assessment, and risk profiling as required by law.
• To communicate with you regarding your account, advice, service updates, and responses to your queries.
• To comply with our legal, regulatory, and statutory obligations, including record-keeping and reporting to
  SEBI and other authorities.
• To maintain, secure, and improve the Website and our services.
• To detect, prevent, and address fraud, security incidents, and other prohibited or illegal activities.

5. Legal Basis for Processing

We process your personal data on the basis of your consent, and/or for certain legitimate uses and legal obligations permitted under the DPDP Act and other applicable laws. Where processing is based on consent, you may withdraw it at any time Please note that certain data is collected to comply with mandatory statutory and regulatory requirements; withdrawal of consent in such cases may prevent us continuing to provide our
services.

6. Sharing and Disclosure of Information

We do not sell or rent your personal data. We may share your information only in the following circumstances:

• With regulatory and statutory authorities, including SEBI, BSE, income-tax authorities, and law-enforcement
  agencies, where required by law or legal process.
• With KYC Registration Agencies (KRAs) and other intermediaries as required for client onboarding and
  verification.
• With service providers and professional advisers (such as IT, hosting, audit, and compliance support) who act on our instructions and are bound by confidentiality obligations.
• Where you have provided specific consent for such sharing.

Any third party with whom data is shared is expected to maintain confidentiality and adequate security
safeguards.

7. Data Retention

We retain your personal data for as long as necessary to fulfil the purposes described in this Policy and to comply with our legal and regulatory obligations. SEBI regulations require investment advisers to maintain certain records (including KYC documents, risk profiles and advice rendered) for a minimum period of five years
(or longer where mandated). When data is no longer required, we will erase or anonymise it in a secure manner.

8. Cookies and Tracking Technologies

Our Website may use cookies and similar technologies to enable core functionality, remember your preferences, and understand how the Website is used. You can control or disable cookies through your browser settings however, disabling certain cookies may affect the functionality of the Website. Where required, we will obtain your consent before placing non-essential cookies.

9. Your Rights

Subject to applicable law, you have the following rights in relation to your personal data:

• The right to access a summary of the personal data we process about you.
• The right to correction, completion, or updating of inaccurate or incomplete data.
• The right to erasure of your personal data, subject to our legal and regulatory retention obligations.
• The right to withdraw consent previously given, without affecting the lawfulness of processing carried out
  before withdrawal.
• The right to grievance redressal and the right to nominate another individual to exercise your rights in the
  event of death or incapacity.

To exercise any of these rights, please contact us at
vikas.nsit07@gmail.com. We may need to verify your identity before
acting on your request.

10. Data Security

We implement reasonable technical and organisational security measures designed to protect your personal data against unauthorised access alteration, disclosure, or destruction. These measures are aligned with the reasonable security practices contemplated under the Information Technology Act, 2000 and the DPDP Act. However, no method of transmission over the internet or electronic storage is secure, and we cannot guarantee
absolute security.

11. Children’s Data

Our services are intended for individuals who are 18 years of age or older. We do not knowingly collect personal data of children where permitted by law and with verifiable parental or guardian consent. If you believe we have inadvertently collected a child’s data, please contact us so we can take appropriate action.

12. Links to Third-Party Websites

Our Website may contain links to external websites. We are not responsible for the privacy practices or content of such websites. We encourage you to review the privacy policies of any third-party sites you visit.

13. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or in applicable law. The revised version will posted on this Website with an updated “Last Updated” date. We encourage you to review this Policy periodically.

14. Grievance Redressal and Contact

Mr. : Vikas Yadav, in his capacity, serves as the Principal Officer of Avdesh Mishra Capitals Private Limited and is responsible for addressing privacy-related queries and grievances. If you have any questions, concerns, or complaints regarding this Policy or our handling of your personal data, please contact:

Vikas Yadav

Principal Officer

Avdesh Mishra Capitals Private Limited

Flat No. PSQC1-F02-07 Palm Square, Sec-66 Bhondsi Gurgaon, Gurugram, Haryana, 122102

Email: vikas.nsit07@gmail.com

Phone: +91 9911306931

If your grievance is not satisfactorily resolved, you may escalate the matter to the Data Protection Board of India in accordance with DPDP Act, or to SEBI through the SCORES platform for matters relating to investment advisory services.