Privacy Policy

Client First Wealth Management Private Limited ("CLIENT FIRST ALPHA", "we", "our" or "us") recognises that privacy, confidentiality and responsible handling of Personal Data are fundamental to maintaining the trust and confidence of Users of the CLIENT FIRST ALPHA Portal (CLIENTFIRSTALPHA.COM).

This Privacy Policy ("Policy") describes the manner in which Personal Data is collected, received, used, processed, stored, shared, retained, protected and otherwise handled by CLIENT FIRST ALPHA in connection with the operation of the CLIENT FIRST ALPHA Portal and the services made available through it.

Where a User voluntarily chooses to avail distribution-related services offered through CLIENT FIRST WEALTH MANAGEMENT PRIVATE LIMITED ("CFWM"), certain Personal Data may also be processed by CFWM for the specific purposes described in this Policy and in accordance with applicable law.

This Policy forms an integral part of the governance framework adopted by CLIENT FIRST ALPHA and CFWM and should be read together with the following documents, each as amended from time to time:

• Website Terms & Conditions (TERMS AND CONDITIONS GOVERNING REGISTRATION, ACCESS TO AND USE OF THE CLIENTFIRSTALPHA.COM (PORTAL) AND RELATED SERVICES);
• Regulatory Disclosures, Investor Information & Important Notices;
• Cookie Policy;
• Client Consent for Retrieval and Use of Consolidated Account Statement (CAS);
• Consent-cum-Authorisation Form;
• such other policies, disclosures and notices as may be published by CLIENT FIRST ALPHA and/or CFWM from time to time.

The objectives of this Policy are to:

• explain the categories of Personal Data collected by CLIENT FIRST ALPHA and, where applicable, by CFWM;
• explain the purposes for which such Personal Data is collected, processed and used;
• inform Users regarding their rights under applicable data protection laws;
• describe the safeguards adopted for protecting Personal Data;
• explain the circumstances in which Personal Data may be shared with third parties;
• explain the manner in which Personal Data relating to Portfolio Summary Services and other services is handled; and
• demonstrate CLIENT FIRST ALPHA's and CFWM's commitment to responsible, lawful and transparent processing of Personal Data.

This Policy applies to:

• every visitor accessing the CLIENT FIRST ALPHA Portal;
• every registered User;
• persons making enquiries through the Portal;
• persons requesting Portfolio Summary Services;
• persons providing consent for retrieval of their Consolidated Account Statement (CAS);
• persons interacting with Relationship Managers of CFWM;
• existing and prospective investors;
• users accessing the Portal through websites, mobile devices or other digital platforms operated by CLIENT FIRST ALPHA.

This Policy applies irrespective of the device or technology used for accessing the Portal.

This Policy has been prepared having regard to applicable laws governing privacy, data protection, information technology and financial services in India, including the Digital Personal Data Protection Act, 2023 and other applicable laws, rules, regulations and governmental or regulatory directions as may be amended, modified or replaced from time to time.

Nothing contained in this Policy shall limit or restrict any obligation imposed upon CLIENT FIRST ALPHA or CFWM under any applicable law or regulatory requirement.

CLIENT FIRST ALPHA and CFWM are committed to ensuring that Personal Data is handled responsibly, ethically and lawfully.

Accordingly, Personal Data shall be collected and processed only for legitimate business purposes connected with the operation of the CLIENT FIRST ALPHA Portal, the provision of services requested by Users, compliance with applicable legal and regulatory obligations, and such other purposes as are communicated to the User at or before the time of collection.

CLIENT FIRST ALPHA and CFWM endeavour to adopt appropriate organisational, administrative and technical measures to safeguard Personal Data against unauthorised access, disclosure, alteration, misuse, loss or destruction.

Privacy protection forms an integral part of the governance, risk management and compliance framework adopted by CLIENT FIRST ALPHA and CFWM.

Client First Wealth Management Private Limited and CLIENT FIRST WEALTH MANAGEMENT PRIVATE LIMITED are committed to embedding privacy considerations into the design, development, implementation and operation of the Portal, Portfolio Summary Services and associated business processes. Appropriate technical, organisational and administrative measures shall be adopted to ensure that Personal Data is processed in accordance with applicable law, legitimate business purposes and sound governance principles. Privacy considerations shall be integrated into new systems, products, services and processes, having regard to the nature, scope, context and purposes of processing, as well as the risks to the rights and interests of individuals.

For the purposes of this Policy:

Client First Wealth Management Private Limited owns, operates and manages the CLIENT FIRST ALPHA Portal and is responsible for the collection and processing of Personal Data relating to the operation of the Portal and the services provided through it.

CLIENT FIRST WEALTH MANAGEMENT PRIVATE LIMITED functions independently in its capacity as an AMFI-registered Mutual Fund Distributor, an APMI-registered PMS Distributor and a distributor of Alternative Investment Funds (AIFs), (XXXX - Insurance) in accordance with applicable laws. CFWM may process Personal Data only in connection with the distribution-related services requested by the User or otherwise authorised under applicable law.

Nothing contained in this Policy shall be construed as implying that CLIENT FIRST ALPHA possesses any registration, licence or authorisation as a regulated intermediary unless expressly disclosed.

Users are requested not to infer the existence of any regulatory registration, approval or authorisation other than those specifically disclosed in the Regulatory Disclosures, Investor Information & Important Notices.

CLIENT FIRST ALPHA and CFWM shall endeavour to process Personal Data in accordance with the following principles:

7.1 Lawfulness and Fair Processing

Personal Data shall be collected and processed only where permitted under applicable law or with the consent of the User where such consent is required.

7.2 Purpose Limitation

Personal Data shall be collected only for specified, lawful and legitimate purposes communicated to the User and shall not be processed in a manner incompatible with those purposes except where permitted by law.

7.3 Data Minimisation

Only such Personal Data as is reasonably necessary for the relevant purpose shall ordinarily be collected.

7.4 Accuracy

Reasonable efforts shall be made to maintain Personal Data that is accurate, complete and, where necessary, updated.

7.5 Security Safeguards

Reasonable technical, organisational and administrative safeguards shall be implemented to protect Personal Data.

7.6 Need-to-Know Access

Access to Personal Data shall ordinarily be restricted to authorised personnel, service providers and other persons who require such access for legitimate business, legal or regulatory purposes.

7.7 Accountability

CLIENT FIRST ALPHA and CFWM shall endeavour to maintain appropriate governance processes relating to the handling, protection and management of Personal Data.

Unless the context otherwise requires:

• CLIENT FIRST ALPHA Portal means the website (CLIENTFIRSTALPHA.COM), portal, applications and digital platforms operated by CLIENT FIRST ALPHA.
• Alternative Investment Fund (AIF) shall have the meaning assigned under applicable law.
• Consolidated Account Statement (CAS) means the statement issued through authorised depositories reflecting investments and holdings, as applicable.
• Cookie Policy means the Cookie Policy published by CLIENT FIRST ALPHA.
• Personal Data shall have the meaning assigned under applicable data protection laws.
• Portfolio Summary Services mean the complimentary analytical and summary services provided by CFWM, upon the client's request and consent, based on information including the Consolidated Account Statement (CAS), for informational purposes only. Portfolio Summary Services do not constitute investment advice, investment recommendations or portfolio management services.
• Relationship Manager means an authorised representative of CFWM responsible for interacting with Users regarding distribution-related services.
• User means any person accessing, visiting, registering on or otherwise using the CLIENT FIRST ALPHA Portal.

Depending upon the nature of the interaction with the CLIENT FIRST ALPHA Portal or the services requested, CLIENT FIRST ALPHA and, where applicable, CFWM may collect or receive categories of Personal Data including:

• identification information;
• contact information;
• account registration details;
• communication preferences;
• KYC-related information where applicable;
• information voluntarily submitted by the User;
• information relating to Portfolio Summary Services;
• information contained in a Consolidated Account Statement (CAS), where expressly authorised by the User;
• technical, device and usage information;
• cookie and analytics information;
• correspondence and customer support records; and
• such other information as may be reasonably required for lawful purposes communicated to the User.

CLIENT FIRST ALPHA shall endeavour to collect Personal Data directly from the User wherever reasonably practicable. Where information is received from authorised third parties, such collection shall be subject to applicable law and appropriate authorisations.

CLIENT FIRST ALPHA and, where applicable, CFWM may collect, receive, use, process and otherwise handle Personal Data only for one or more of the following legitimate purposes:

• facilitating access to and operation of the CLIENT FIRST ALPHA Portal;
• creating, maintaining and administering User accounts;
• providing analytics, research, educational content and other information available on the Portal;
• responding to enquiries, requests, feedback or communications initiated by Users;
• verifying the identity of Users where necessary;
• complying with applicable legal, regulatory, audit, risk management and internal governance requirements;
• improving the functionality, security, performance and user experience of the Portal;
• preventing fraud, abuse, unauthorised access and other unlawful activities;
• providing Portfolio Summary Services upon the User's request and consent;
• facilitating distribution-related services through CFWM where expressly requested by the User;
• maintaining records required under applicable law;
• such other purposes as may be communicated to the User at or before the time of collection or as otherwise permitted under applicable law.

Personal Data shall not ordinarily be processed for purposes incompatible with those stated above except where permitted under applicable law.

Where a User voluntarily requests Portfolio Summary Services, CLIENT FIRST ALPHA and/or CFWM may process such Personal Data as is reasonably necessary for preparing and delivering the requested Portfolio Summary.

Portfolio Summary Services are provided solely as complimentary informational and analytical services intended to assist Users in understanding their existing investment portfolios.

Portfolio Summary Services:

• do not constitute investment advice;
• do not constitute investment recommendations;
• do not constitute financial planning services;
• do not constitute discretionary or non-discretionary portfolio management services;
• do not constitute investment advisory services;
• shall not be construed as a recommendation to purchase, redeem, switch or retain any investment.

Preparation of Portfolio Summary Services shall be undertaken only after obtaining the appropriate consent and authorisation from the User wherever required.

Where a User requests Portfolio Summary Services or any other service requiring analysis of investment holdings, CFWM may, subject to the User's express consent and authorisation, retrieve or obtain the User's Consolidated Account Statement (CAS).

CLIENT FIRST ALPHA and CFWM shall endeavour to ensure that:

• retrieval of the CAS takes place only after obtaining the User's explicit consent and authorisation;
• the purpose of retrieving the CAS is clearly communicated to the User;
• the CAS is used only for the authorised purpose;
• access to the CAS is restricted to authorised personnel who require such access for legitimate business, legal or regulatory purposes;
• the CAS is protected through appropriate organisational and technical safeguards; and
• the CAS is retained only for such period as may be required under applicable law, regulatory requirements or the applicable data retention policy.

CAS information shall not ordinarily be processed for unrelated commercial purposes without obtaining such further consent as may be required under applicable law.

Where a User voluntarily expresses interest in Mutual Funds, Portfolio Management Services (PMS) or Alternative Investment Funds (AIFs), CFWM may process the Personal Data necessary for:

• understanding the User's request;
• communicating with the User;
• explaining products and services;
• facilitating investment transactions where applicable;
• complying with applicable regulatory requirements;
• maintaining statutory records; and
• providing post-transaction support.

Nothing contained in this Policy shall be construed as requiring any User to invest in any product or service.

Users remain solely responsible for evaluating the suitability, appropriateness and eligibility of any investment and are encouraged to seek independent professional advice wherever appropriate.

Authorised Relationship Managers of CFWM may contact Users who have:

• registered on the CLIENT FIRST ALPHA Portal;
• requested information;
• requested Portfolio Summary Services;
• expressed interest in investment products; or
• otherwise consented to such communications.

Relationship Managers shall endeavour to use Personal Data only for legitimate business purposes connected with the services requested by the User.

CLIENT FIRST ALPHA and CFWM expect Relationship Managers to maintain appropriate standards of confidentiality while handling Personal Data.

Personal Data may be shared only where reasonably necessary and only with persons or entities having a legitimate need to receive such information.

Subject to applicable law, Personal Data may be shared with:

• CFWM for providing requested distribution-related services;
• authorised technology service providers;
• cloud hosting providers;
• document management service providers;
• communication service providers;
• professional advisers;
• auditors;
• legal counsel;
• regulatory authorities;
• governmental authorities;
• law enforcement agencies;
• courts and tribunals;
• other persons where disclosure is required or permitted by applicable law.

CLIENT FIRST ALPHA does not ordinarily sell Personal Data to third parties.

CLIENT FIRST ALPHA or CFWM may disclose Personal Data where such disclosure is:

• required under applicable law;
• directed by a court or tribunal;
• required by a statutory authority;
• necessary for regulatory compliance;
• necessary for the establishment, exercise or defence of legal rights;
• otherwise permitted under applicable law.

Reasonable efforts shall be made to ensure that such disclosure is limited to the extent necessary.

The CLIENT FIRST ALPHA Portal may utilise cookies, web beacons, pixels, session identifiers and similar technologies for purposes including:

• authentication;
• maintaining user sessions;
• security;
• fraud prevention;
• performance monitoring;
• analytics;
• improving user experience;
• enhancing Portal functionality.

The use of cookies and similar technologies shall be governed by the Cookie Policy published by CLIENT FIRST ALPHA.

Users may manage cookie preferences through their browser settings, subject to the limitations described in the Cookie Policy.

CLIENT FIRST ALPHA and CFWM may communicate with Users through email, SMS, telephone, messaging applications, postal correspondence or other appropriate communication channels for purposes including:

• responding to enquiries;
• account administration;
• security notifications;
• service-related communications;
• regulatory communications;
• Portfolio Summary Services;
• distribution-related communications requested by the User;
• other legitimate business communications.

Users may opt out of promotional communications wherever such option is available, provided that operational, transactional, legal or regulatory communications may continue where necessary.

CLIENT FIRST ALPHA and CFWM endeavour to implement appropriate administrative, organisational, contractual and technical safeguards designed to protect Personal Data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or unauthorised access.

Such safeguards may include, where appropriate:

• access controls;
• authentication mechanisms;
• encryption;
• secure transmission protocols;
• audit logs;
• monitoring systems;
• periodic security reviews;
• employee confidentiality obligations;
• incident response procedures.

While reasonable efforts are made to safeguard Personal Data, no system can guarantee absolute security. Users are encouraged to exercise appropriate care while transmitting information electronically.

Personal Data shall be retained only for so long as is reasonably necessary to fulfil the purposes for which it was collected, to comply with applicable legal or regulatory requirements, to resolve disputes, to establish or defend legal claims, or to enforce contractual rights.

The retention, archival, anonymisation and deletion of Personal Data shall be governed by the applicable Data Retention Policy and Record Preservation Policy adopted by CLIENT FIRST ALPHA and/or CFWM.

Upon expiry of the applicable retention period, Personal Data shall ordinarily be deleted, anonymised or securely destroyed, unless continued retention is required or permitted under applicable law.

Subject to applicable law, Users may be entitled to exercise certain rights in relation to their Personal Data.

Subject to the provisions of applicable law, a User may:

• seek confirmation regarding the processing of Personal Data;
• request access to Personal Data maintained by CLIENT FIRST ALPHA or, where applicable, by CFWM;
• request correction, updating or completion of inaccurate or incomplete Personal Data;
• request erasure of Personal Data where such retention is no longer necessary or where deletion is otherwise permitted under applicable law;
• withdraw consent for the processing of Personal Data where processing is based on consent, provided that such withdrawal shall not affect the lawfulness of processing undertaken prior to such withdrawal nor processing permitted under applicable law;
• nominate another person to exercise such rights in the circumstances permitted under applicable law;
• exercise such other rights as may be available under applicable data protection laws.

Requests received from Users shall be processed in accordance with applicable law and the internal policies of CLIENT FIRST ALPHA and/or CFWM.

Nothing contained herein shall require deletion of records which CLIENT FIRST ALPHA or CFWM are required to preserve under applicable law, regulatory requirements, contractual obligations or legitimate legal interests.

Where the processing of Personal Data is based upon the User's consent, such consent may ordinarily be withdrawn by the User at any time by following the process communicated by CLIENT FIRST ALPHA or CFWM.

Withdrawal of consent shall not:

• invalidate processing undertaken prior to such withdrawal;
• affect processing permitted or required under applicable law;
• require deletion of records that must be retained under applicable legal or regulatory requirements; or
• affect the validity of transactions or services already completed.

Withdrawal of consent may result in certain services, including Portfolio Summary Services or other requested services, becoming unavailable.

CLIENT FIRST ALPHA and CFWM endeavour to maintain appropriate systems and procedures for identifying, assessing, managing and responding to actual or suspected Personal Data breaches.

Where required under applicable law, appropriate notifications shall be made to the competent authorities and affected individuals within the prescribed timeframes.

Appropriate corrective, preventive and remedial measures shall be implemented to minimise the likelihood of recurrence.

CLIENT FIRST ALPHA has established an appropriate mechanism for addressing grievances relating to this Policy and the processing of Personal Data.

Any request, complaint, grievance or query relating to this Policy may be addressed to:

CLIENT FIRST ALPHA shall endeavour to acknowledge and address grievances within the timelines prescribed under applicable law.

Grievances relating specifically to distribution-related activities undertaken by CFWM may also be addressed to the designated officer of CFWM through the contact details published by CFWM from time to time.

Nothing contained herein shall prejudice any statutory remedy available to the User under applicable law.

Where Personal Data is transferred, stored or processed outside India, such transfer or processing shall be undertaken only in accordance with applicable law and subject to such safeguards as may be considered appropriate by CLIENT FIRST ALPHA and/or CFWM.

Users accessing the Portal from jurisdictions outside India remain responsible for ensuring that access to the Portal and use of its services are lawful in their respective jurisdictions.

Nothing contained in this Policy shall constitute any representation that services described on the Portal are available in every jurisdiction.

CLIENT FIRST ALPHA and/or CFWM reserve the right, from time to time, to amend, modify, supplement, update or replace this Policy, to the extent applicable to their respective activities, in order to reflect changes in:

• applicable law;
• regulatory requirements;
• judicial decisions;
• technology;
• operational practices;
• business requirements;
• governance standards;
• any other legitimate operational, legal or regulatory requirement.

The revised Policy shall become effective from the Effective Date specified therein.

Continued access to or use of the CLIENT FIRST ALPHA Portal following publication of the revised Policy shall constitute acceptance of the revised Policy, unless otherwise required by applicable law.

This Policy shall be governed by and construed in accordance with the laws of India.

Subject to applicable law, the courts having jurisdiction at Raipur, Chhattisgarh, India, shall have exclusive jurisdiction over disputes arising out of or relating to this Policy.

If any provision of this Policy is held to be invalid, unlawful or unenforceable by any court or competent authority, such provision shall, to the extent of such invalidity or unenforceability, be deemed severable without affecting the validity or enforceability of the remaining provisions of this Policy.

Any communication relating to this Policy, privacy practices or Personal Data may be addressed to Client First Alpha and/or CLIENT FIRST WEALTH MANAGEMENT PRIVATE LIMITED, as applicable, through the contact details published on the Portal from time to time, depending upon the nature of the request, service or processing activity.

Communications relating specifically to distribution-related services provided by CFWM may also be addressed through the contact details published by CFWM.

This Policy constitutes the privacy framework governing the collection, receipt, use, processing, storage, disclosure, retention, protection and disposal of Personal Data in connection with the CLIENT FIRST ALPHA Portal and the related services described herein.

Nothing contained in this Policy shall:

• constitute investment advice;
• constitute investment recommendations;
• constitute Portfolio Management Services;
• create any fiduciary relationship between CLIENT FIRST ALPHA and any User;
• create any partnership, joint venture or agency between CLIENT FIRST ALPHA and CFWM;
• confer upon any person any rights other than those expressly provided under applicable law.

In the event of any inconsistency between this Policy and any mandatory requirement under applicable law, the latter shall prevail to the extent of such inconsistency.

By accessing or using the CLIENT FIRST ALPHA Portal, registering as a User, submitting Personal Data, requesting Portfolio Summary Services, providing consent for retrieval of the Consolidated Account Statement (CAS), communicating with CLIENT FIRST ALPHA or CFWM, or otherwise interacting with the Portal, the User acknowledges that:

• the User has read this Privacy Policy;
• the User has understood this Privacy Policy;
• the User agrees to the collection, use and processing of Personal Data in accordance with this Privacy Policy and applicable law;
• the User understands that continued access to or use of the Portal constitutes acknowledgement and acceptance of the governance framework applicable to the Portal, including the Website Terms & Conditions, Regulatory Disclosures, Investor Information & Important Notices, this Privacy Policy, the Cookie Policy, and such other applicable policies, disclosures, notices and documents as may be published, amended, supplemented, updated or replaced by Client First Alpha and/or CLIENT FIRST WEALTH MANAGEMENT PRIVATE LIMITED from time to time.