POLICY ON PRIVACY & SECURITY OF INFORMATION

Your privacy is important to us and maintaining your trust and confidence is one of our highest priorities. We, at Canara Robeco Asset Management Limited (“CRAMC”), respect your right to keep your personal information confidential and understand your desire to avoid unwanted solicitations. When you visit our website - www.canararobeco.com (“Website”) or Mobile Application or Canara Robeco Asset Management Social Media Page/profile or portal for investor education awareness, we may collect, process, retain data through physical or online channels, either directly (where you are asked to provide the data) or indirectly. It is our endeavor to ensure that use of any such personal data stored in electronic format by us shall be in accordance with the purposes set forth in this Privacy Statement. We are committed to safeguarding your personal information as collected and shall ensure appropriate safeguards to comply with our obligations of confidentiality and privacy. In this regard, we request investors/clients/customers to kindly read this “Policy on Privacy & Security of Information” carefully. The terms & conditions used in this document would be in accordance with any law or regulations to retain or process Personal Data for as long as required to exercise or defend legal claims.

Interpretation

  • All references to the masculine shall include the feminine and all reference to the singular shall include the plural and vice-versa. Reference to client/customer/investor whether masculine or feminine include reference to non-individuals also unless repugnant to the context thereof.

  • Reference to any statute or a statutory provision shall be construed as reference to any statutory modifications or re-enactment therein from time to time.

  • References to 'you, 'your' and ‘yours' are references to the person(s) accessing this website. References to 'we', 'us' and 'our' are references to mean individually and collectively, the Trustees of Canara Robeco Mutual Fund, Canara Robeco Asset Management Company Limited, its directors, officers and employees.

  • Headings are for ease of reference only.

The Policy

This policy has been formulated by CRAMC in its capacity as the Investment Manager to the Schemes of Canara Robeco Mutual Fund (“CRMF”). Canara Bank and ORIX Corporation Europe NV (formerly known as Robeco Groep NV) are the Sponsors of CRMF. CRAMC and CRMF are hereinafter collectively referred to as “Canara Robeco”.

Sources of Data

Canara Robeco collects personal data or information about you from a variety of sources, such as:

  • Online and electronic interactions including this website, Canara Robeco’s mobile application, investor education awareness programs, Canara Robeco’s social media page / profile, text messaging programs or through its branded pages or applications on third party networks;

  • Offline interactions, including via direct marketing campaigns, hard copy registration / application forms and the contacts generated by consumer services call centres of Canara Robeco and its Registrar and Transfer Agents (“RTA”); and

  • Your interaction with online targeted content (such as advertisements) that Canara Robeco, or service providers on our behalf, provide to you via third party websites or applications.

However, please note that you are no longer covered by terms of this policy if you enter your sensitive personal data on social media platforms like Twitter, LinkedIn, Facebook, Instagram etc., or any other co-branded and partner websites other than canararobeco.com or Canara Robeco’s mobile application. As these websites have their own policies, we do not accept any responsibility or liability for any such policies.

Sensitive data

CRAMC either directly or through third party service providers engaged by CRAMC such as, the Registrar and Transfer Agents collect, receive, possess, store, deal or handle information received from investors/client/ customers whether existing or prospective. Such information could be personal and sensitive in nature such as:

  • Name, date of birth, mobile number, email ID, address, and country of domicile and/or your nationality, Marital status, gender, occupation;

  • Photographs and signatures;

  • Information relating to your work (if self-employed, the nature of the self-employment);

  • PAN, Bank account details, change of bank account details or registration of multiple bank accounts , IFSC or MICR codes through application forms or otherwise;

  • Payment instrument details at the time of submitting application or at the time of investment or as a proof for carrying out change of bank accounts;

  • Generation and storing of passwords or Personal Identification Number (“PIN”) in encrypted form based on the request from the investor under the online mode of investments;

  • Annual income and savings profile; and/or

  • Device data including computer and mobile device, browsing actions and patterns and online activity for collective analysis;

  • Behavioral details as to how you utilize our products, services, offers, etc.;

  • Social Relationships details such as your father’s name/spouse name, mother’s name, anniversary date; and/or Nominee Name, birthdate, pan card, mobile number or any other proof submitted for KYC registration;

  • Details of your communications and transactions with us;

  • Any other information as may be considered sensitive and personal.

Purpose of data collection

The aforesaid information is collected by CRAMC for the following purposes:

  • to conduct its business.

  • to process the investment applications.

  • to ensure safe subscription/redemption/switch/SWP through points of acceptance in physical form, website, online portals and such other modes.

  • to inform and make available products and services that may be of interest to you and for the development of website statistics.

  • to contact you when necessary, e.g. to notify you about functionality changes to the website and to offer services that you may find helpful (provided you have not opted out to receive such services).

  • to improve investor experience and provide new services.

  • to run target-oriented marketing campaigns.

The aforesaid information is the basis of our ability to provide investors/clients/customers with good, qualitative, timely and efficient service, while also keeping the information and data provided totally secure and confidential. We do not reuse data for any purposes other than those stated herein.

Every marketing email will include instructions on how to unsubscribe from these messages or change your preferences.

We endeavor to have suitable technical, operational and physical security controls and measures to protect personal/ sensitive data or information of the investors/customers/clients that are commensurate with the nature of our business at all times.

Confidentiality and Disclosure of Information

As a general rule, we do not disclose your personal information to anyone. We permit only authorized employees who are trained in the proper handling of customer information to have access to the aforesaid information. We also enter into suitable terms with third party service providers in order to protect client confidentiality and follow a non-disclosure or restricted disclosure policy. Further, the employees who violate the privacy and confidentiality would be rendered liable to appropriate disciplinary action.

We shall reveal only such information to the external /statutory/ judicial authorities as may be found relevant and necessary in order to comply with the applicable laws of the land and to third party service providers such as RTA/ distributors/ agents/intermediaries/banks/sub-brokers/call-centres/custodians/ depositories /subsidiaries /group entities and such other entities/persons/third parties to ensure smooth functioning of the activities or transaction processing as may be prescribed under applicable laws or Regulations.

Consent - By using our website or by agreeing to transact with us, you agree to sharing information during your relationship with us. However, to the extent permitted by law and any applicable Regulations, certain non-public information about you may be disclosed/used in the following situations:

  • To comply with applicable laws including cyber laws and validly issued and enforceable statutory or judicial notice/ summons/orders.

  • In connection with a prospective purchase, sale, or merger of all or part of our business, however, after taking appropriate precautions (through a written confidentiality agreement) so the prospective purchaser or merger partner does not disclose information obtained in the course of the review or due diligence.

  • As a part of any actual or threatened legal proceedings or alternative dispute resolution proceedings either initiated by or against us, provided we disclose only the information necessary to file, pursue, or defend the lawsuit or legal proceedings.

  • To enforce legal rights/provisions of the Scheme related documents of the Mutual Fund viz. Scheme Information Documents (SID), Statement of Additional Information (SAI) and Key Information Memorandum (KIM).

  • To contact investors/clients/customers regarding the products and services offered by us and seek feedback on the services provided.

  • To generate statistics and reports and/or to protect and defend the rights, interest and property of CRMF, CRAMC, Sponsors & its affiliates and trustees/directors.

  • To provide information to affiliates/ associates of CRAMC and non-affiliated third parties who perform services or functions for us in conjunction with our services to you, provided we have a contractual agreement with the other party which prohibits them from disclosing or using the information other than for the purposes for which it was disclosed.

  • To comply with queries from AMFI/SEBI/RBI/Income Tax authorities or Judicial bodies and institutions working for them.

  • To comply with queries from auditors, Lawyers, Tax Authorities, Courts, Accountants, tribunals and arbitrators.

It is to be noted that Internet Protocol (IP) addresses, browser supplied information and site session information may be recorded as part of the normal operations and for security monitoring purposes.

Information Authenticity and Retention

It is our foremost endeavor to ensure that Customer’s privacy is protected at all times. However, any information/data provided/to be provided shall be verified and rechecked by the investors/customers/clients before providing the same to CRAMC or any other person acting on its behalf. Post submission of information/data, if the investor/customer/client finds any such submitted information/data being incorrect or inaccurate, the same shall be immediately informed to CRAMC or any other person acting on its behalf for rectification/ amendment.

CRAMC or any other person/service provider acting on its behalf shall not be responsible for the accuracy and authenticity of the information/data submitted by investors/customers/clients.

CRAMC and its service providers may retain the information/data as may be provided by investors/customers /clients till such time as may be permitted under law and as required to efficiently provide services to the investors/customers/clients.

Cookies

CRAMC may gather and analyse information regarding usage of this website, including domain name, the number of hits, the pages visited, previous/subsequent sites visited and length of user session. This information may be gathered by using a cookie. A cookie is a small text file placed on your hard drive by our web page server which can be used to recognize repeat users, facilitate the user's ongoing access to and use of the site, allow a site to track usage behavior and compile aggregate data that will allow content improvements and targeted advertising, preferences etc. Cookies themselves do not personally identify you, but they do identify your computer, computer resources and devices connected with computer resources including Mobile phones. You can choose whether or not to use a cookie by altering the settings of your browser. A cookie will make the use of this website faster and easier.

Types of Cookies

Canara Robeco uses (1) Functional and (2) Non-Functional Cookies.

  1. Functional Cookies are used to ensure the functionality of its websites or services.

  2. Non-Functional Cookies Cookies are used to collect information on this Website usage and to remember the selections you make such as language preferences, web pages visited or duration of a user session. Canara Robeco uses these cookies to enhance your user experience on this website.

Cookies can further be subdivided into:

  1. Session Cookies: These can be used to track the web pages you visit and the options you use. A session cookie is only stored for the duration of your visit to the internet, i.e., during a single internet session. When you close your internet browser, this session ends, and the cookie is deleted.

  2. Permanent Cookies: These are used to recognize the investors/client/customers on their subsequent visit to this Website or to remember their preferences. Permanent cookies are stored for longer duration than the Session Cookies.

Cookie settings

By using this Website, you agree to the processing of the data collected during your visit in the manner and for the purposes set out above. You have the option to control and/or delete the cookies. You can block certain cookies by selecting the appropriate settings on your Internet Browser. Please note, however, that if you do this, the functionality of this Website may be affected.

Third Party Sites

Please note that this Privacy Statement does not extend to third party sites linked to this Website.

Amendments

CRAMC reserves the right to amend/modify any of the sections of this Privacy Policy at any time. Please check and keep yourselves updated for changes by reading the same from time to time.

Breach of Internet Security

You must ensure that any information or data being provided to us or by you or any person acting on your behalf should be rechecked. In case if any of the data/information is found to be inaccurate or incorrect, you shall be required to intimate us of the same for immediate amendment. Canara Robeco Asset Management Company and any person acting on its behalf shall not be responsible for the authenticity of the personal information or sensitive personal data or information supplied by you.

However, despite our best efforts, if unauthorized persons breach our security control measures resulting in the Site being hacked or presenting inaccurate information etc., Canara Robeco Mutual Fund or its trustees, Canara Robeco Asset Management Company Limited, its directors, officers, employees or associates/ affiliate's will not be responsible.

Grievance Redressal

If investors/customers/clients have any concerns relating to their personal and sensitive information, they may be addressed to Investor Relations Officer at the email address given below. For more details please refer to the Scheme related documents as available on our website.

Investor Relations Officer: Ms. Pallavi Singh

Email: IRO@canararobeco.com

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