1. BACKGROUND
PGP either directly (through website, web app or other applications) and its related social media accounts (collectively, the “Sites”) or through third party service providers engaged by us such as the Registrar and Transfer agents, Fund Admin collects, receives, possesses, stores, deals or handles information received from investors/client/customers whether existing or prospective.
This Privacy Policy governs the collection of information including
Further, the policy specifies the uses, maintains, stores, shares and discloses regarding the information collected from each User.
2. INFORMATION COVERED UNDER THE POLICY
a. Personal Information
Personal Information refers to any data about an individual who is identifiable by or in relation to such data. Such information that can be personal and sensitive in nature. At times, and to allow PGP to do its job, PGP may receive identifiable personal information for those purposes outlined in its agreements with customers. An indicative list given below:
b. User Data
User data is a data collected from visitors to this website, web app and any other application.
This includes browser-supplied information (including computer and technical information, site session information such as the sequence of pages visited during a visit to the Service, the average time spent, information searched for, access times etc.) and may be recorded for usage analysis and security monitoring.
When you visit our website, we may use “cookies” and similar technologies to enhance your user experience. Cookies are small pieces of information that allows PGP to place files on your device to store preferences and track activity. By using our website and agreeing to the terms of use, you consent to our use of cookies in accordance with the terms of our privacy policy. The visitor, including the Information Provider can refuse the use of cookies. The information generated by the cookie of the visitor’s use of the Website, may be stored with us for operational purposes.
Further, it may 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. Should you wish to disable these cookies you may do so by changing the setting on your browser. However, you will be unable to access certain part(s) of our Site.
PGP will collect personal data, which is adequate, relevant and limited to the stated purpose, and will annually review application/web forms to eliminate fields no longer required.
3. PURPOSE AND USE OF COLLECTING THE INFORMATION
a. Collection of Personal Information
PGP may collect/receive your Personal Information from several sources. You may provide Personal Information as part of the application or enrolment process. (whether in writing or electronically). You agree and understand that your Personal Information shall be collected, processed, stored and used by us, and passed to, transmitted to and processed by our affiliates and other data processor, agents or service providers acting under a contract with us for the purposes identified in this Privacy Policy.
Personal Information is being collected by PGP to respond to your requests and the Personal Information enables us to provide the Users with good, qualitative, timely and efficient service such as to be able to manage your portfolios, provide you information and/or statements regarding our portfolio(s), manage queries and complaints from the Users.
The Personal Information
To carry out an assessment of the applications and requests you place with us, and carry out an anti-fraud, suspicious activity check, or any other regulatory check which the PGP may be directed to do or is bound to do under applicable law.
To share your information with our service providers and vendors.
b. KYC documents
To be compliant with the Know Your Client (“KYC”) norms, the rules issued thereunder, and guidelines and circular on Anti- Money Laundering issued by Regulators and as amended till date.
We may also use the information shared by Users to contact them regarding the products and services offered by us and seek feedback on the services provided.
User data collected by PGP can be used for the following purposes:
4. PROCESSING THE INFORMATION
PGP is permitted to collect, process and retain the Personal Information basis the following grounds:
PGP further declares that the Personal Information may be disclosed if the same is necessary to protect the legitimate interests and rights of the company and/or any other affiliate, to enforce our legal rights and be in compliance with any applicable law or under the directions of any court, tribunal, judicial/quasi-judicial and/or statutory authority.
5. CONNECTING WITH PGP VIA SOCIAL MEDIA
PGP will provide experiences on social media platforms that enable online sharing, communication and collaboration among users who have registered to use such platforms. PGP may collect information you provide by interacting with us via social media, such as images, pictures, videos or other information. Any content you post, such as pictures, videos, information, opinions, or any personal information that you make available to other participants on these social platforms, is also subject to the terms of use and privacy policies of those platforms. Please refer to the respective platform policies to better understand your rights and obligations regarding such content.
6. SHARING OF PERSONAL INFORMATION
PGP may share the Personal Information for the uses mentioned with the following third parties: affiliates, Registrar and Transfer Agents, Fund Admins,, banks, custodians, depositories, vendors, service providers, distributors or Sub-Brokers including application of investors received for investment, attorneys, accountants, auditors, call centres, external third parties who are involved in clearing the transactions, any other organization for verifying the identity of investors for complying with anti-money laundering requirements, with intermediaries, Government authorities, whose ARN stamp appears on the application forms/ transaction slips, post office, couriers and other intermediaries involved in any electronic transfer of information or monies, court, tribunal, judicial/quasi-judicial and/or statutory authority, arbitrators.
PGP may share certain Personal Information with third parties such as post office, local and international courier and other intermediaries for correspondence with the investor and for making payments to the investor through Electronic Clearing Services (ECS), NEFT etc.
Personal Information shall be communicated to third persons only for reasons consistent with the purposes for which the data are originally collected or other purposes authorised by law.
The Information Provider expressly and unequivocally, gives their consent that the Personal Information may be used to produce statistics reports for internal as well external use, which may be forwarded to affiliates, intermediaries, successors, vendors, advertisers and also gives their consent for sharing of the Personal Information as highlighted above.
Additionally, we shall reveal only such information to external authorities as may be found relevant and necessary in order to comply with the applicable laws and to third party service providers to ensure smooth functioning of the activities as may be prescribed under applicable laws and the use of the Personal Information will be communicated with the third parties for the reasons consistent with the purpose for which the Personal Information was originally taken.
By using our website or by agreeing to transact with us or sending inquiries, you expressly agree to terms of the privacy policy and give your explicit consent and above sharing of information.
We may also be required from time to time to disclose the Personal Information to governmental or judicial bodies or agencies or our regulators based on their requirement to comply with the applicable laws including cyber laws.
7. SECURITY MEASURES
PGP limits access to personal information to authorized firm employees or agents and, as described above in Sharing Personal Information, our service providers are held to stringent standards of privacy. We maintain physical, electronic and procedural safeguards to protect the information against loss, misuse, damage or modification and unauthorized access or disclosure.
We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of your personal information, username, password, transaction information and data stored on our Site.
a. Breach of Internet Security
Despite our efforts to protect the Personal Information, if any unauthorized person(s) breaches security and control measures (including site being hacked, presenting inaccurate information, loss of data etc), and illegally use such sensitive/personal data or information the PGP will strive to put in place corrective measures. However, PGP and/or and its affiliates, directors, or employees shall not be held responsible/ liable for the same.
b. Third Party data provided by the Users
You might sometimes provide us personal information of others. Common scenarios include providing nominee or beneficiary details, giving details of a joint account holder, or providing referee/contact information. If you give us personal data about another person, you must do so only with proper authority or consent from that person. By submitting such information, you confirm that you have the right to do so PGP will use and protect that third-party’s information in accordance with this Policy just as we do for your own data.
Further, users are advised to share the guardian details in case the third-party user is a minor.
c. Third Party Websites
Our website may contain links to third party websites or services that may collect personally identifiable information about you. The data protection practices of those websites linked to this Website are not covered by this Privacy Policy. Third-party sites are governed by their own privacy policies, and we do not have control over their content or practices. We encourage you to review the privacy policies of any external sites you visit. We will not be responsible for misuse of your information by any third-party website that you access via our site.
d. Retention of Information:
PGP may retain the Personal Information of the Information Provider for as long as required to provide the services or as otherwise required under law or establishment, exercise or defence of legal claims.
8. CHANGES TO THIS PRIVACY POLICY
PGP reserves the right to amend/modify any sections of this policy from time to time to reflect changes in our practices, legal or regulatory requirements or any other purpose we may deem necessary. The Policy, as amended from time to time, will be available on the Website.
We encourage you to periodically review this Privacy Policy to stay informed about how we are protecting your information. Your continued relationship with us after any changes to this Policy will be deemed as acceptance of the updated terms, except in scenarios where explicit consent is required. If you do not agree with the changes, you retain the choice to discontinue use of our services.
1. YOUR ACCEPTANCE OF THE TERMS OF THE POLICY AND RIGHTS THEREOF
Investors/clients/customers / Website Users and other Users shall have expressly consented to the terms of this Policy if they enter and use this website or provide any information while transacting with us.
You have the right to request a copy of the personal data about you, which we hold, to have any inaccurate personal data corrected and to object to or restrict our using your personal data. You may also make a complaint if you have a concern about our handling of your personal data.
22. CONTACTING US/GRIEVANCE REDRESSAL
We do not send or condone unsolicited email, or “spam”. We send email only to people who have requested our newsletter or asked information about us or raised an enquiry. If you feel you’ve received unsolicited email from us, please send a message to investor@pantheragp.com. We shall deal with the issue promptly. Email addresses found on this page do not accept consent to receive promotional email messages.
Any question, concern or complaint concerning our Privacy Policy, or any grievances relating to use or handling of your sensitive personal data may be brought to our notice by writing our email at investor@pantheragp.com Please include your name, contact information, and a clear description of your issue. We will acknowledge receipt of your complaint/request and seek to resolve it as soon as possible.
Investors/clients/customers/ Website Users and Other Users shall have expressly consented to the terms of this Policy if they enter and use this website or provide any information while transacting with us.