Privacy Policy

Background and Objective

Lakshy Inclusion Services Private Limited (“us”, “we”, or “our” or “Lakshyaa”), is a private limited company incorporated under the Companies Act, 2013 with its registered office at 1st Floor, Alfalah Arcade, #24/4 Haudin Road, Halasuru Road Cross, Bangalore – 560042, Karnataka, India. Lakshya provides facility to enable the investors to carry out the online transactions in the units of the mutual funds and is dedicated to protecting the personal and financial information that our users submit to us. Lakshya holds a registration with Association of Mutual Funds in India (“AMFI”) and has obtained ARN Code bearing number [150276Ÿ] to act as an online distributor of mutual fund through its website mobile application/mobile site (hereinafter collectively referred to as (“Platform”). Lakshya is in the business of providing financial technology, including, but not limited to that related to savings and investments.

This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Platform and the choices you have associated with that data (hereinafter referred to as “Privacy Policy”).

We use your data to provide and improve the Platform and endeavour to protect it from any form of unauthorized use. By using the Platform, you agree to the collection and use of information in accordance with this Privacy Policy. The terms which have not been defined in this Privacy Policy shall have the meaning ascribed to them as stated in the Terms of Service.Any user accessing or using the Platform shall be deemed to have read, understood and accepted this Privacy Policy



Personal Data: Personal Data means data about a natural person who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).

Sensitive Personal Data: Sensitive personal data means such personal information which consists of information relating to; (i) password; (ii) financial information such as bank account or credit card or debit card or other payment instrument details; and (iii) any detail relating to the above-mentioned points as provided to us for using the Platform.

Usage Data: Usage Data is data collected automatically either generated by the use of the Platform or from the service infrastructure itself (for example, the duration of a page visit).


Collection of Data

We collect several different types of information for various purposes to provide and improve our Platform to you. The types of data collected by us is:

Personal Data: While using our Platform, we may ask you to provide us with certain Personal Data that can be used to contact or identify you. Personal Data shall be collected at the time of registration and we may collect Personal Data including, but is not limited to email address, first name and last name, phone number, date of birth, etc.We will require you to provide a virtual signature (as applicable), that is, an image of the signature on a plain white paper and we will use this signature only for the limited purpose of completing the registration process and it will not be used for any transactions other than filling forms for registration. We will collect Personal Data from the users only if they voluntarily submit such information to us. Users can always refuse to supply Personal Data, except that it may prevent them from engaging in certain parts of our Platform or availing our services.We may also ask for additional personal information from time to time to meet new regulatory requirements or to provide you with other benefits of our Services. As always, the information that we seek will only be for the stated purpose.

Usage Data: We may also collect information how the Platform is accessed and used. This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), passwords, browser type, browser version, the pages of our Platform that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

Cookies Data: For the purpose of improving the Platform for our users, we use cookies and similar tracking technologies to track the activity on our Platform and we hold certain information. Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyse our Platform. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Platform. The service links to any third party websites, apps or platforms, may lead you such third parties that use their own cookies and hence, we urge you to read the privacy policy of such third parties before transacting or using such third parties’ website, apps or platforms. Examples of Cookies we use are Session Cookies, Preference Cookies (to remember your preferences and various settings), Security Cookies.


Use of Data

 In order to satisfy regulatory requirements, such as Know Your Client (“KYC”) or honour the investment instructions provided by you, you are required to provide us with physical evidence of Personal Data or Sensitive Personal Data. You shall upload such data in soft copy form on our Platform at the time of registration, or in some instances, in hard copy to our authorized representative. Your documents shall also be used to create investment folios with the respective AMCs. Once the regulatory authority and/or mutual fund have verified your information, your account for undertaking the transactions may be opened and become operational. We shall not be responsible, in the event, any discrepancy is found, in any of the information provided by you, such as mismatch of the information provided. Incorrect information may lead to the rejection of account opening.You represent and warrant that any and all information is absolutely correct and complete in all aspects. You further undertake to immediately update us of any change or variation of your information as some of the changes made or proposed by you may require you to provide documentary evidence and re-verification will be carried out for the purpose of KYC.

The Personal Data collected by us shall be used for availing our Platform and utilised for other functions including but not limited to maintaining the Platform, notifying you about changes to our Platform, allowing you to participate in interactive features of our Platform when you choose to do so, providing customer care and support, providing analysis or valuable information so that we can improve the Platform, monitoring the usage of the Platform, detecting, preventing and addressing technical issues, etc. We process this Personal Data for these purposes given our legitimate interest in improving our Platform and your experience while using our Platform.


Sharing your Information with your Consent

Where you have provided consent, we share your information, including Personal Data as described at the time of consent, such as when you participate in promotional activities.

We further share the information for the following purposes:

  1. We may share non-personally-identifiable information (such as anonymous user usage data, referring / exit pages and URLs, platform types, asset views, number of clicks, etc.) with third-parties to better understand usage patterns for certain content, services, advertisements, promotions, and/or functionality of the services. Your account settings would be kept confidential and shall not be shared with any third party. Any Personal Data pertaining to your account shall not be used by us for any website/application other than our platform.
  2. Employees /Agents of Lakshyaa: We follow a strict confidentiality policy with regard to disclosure of confidential information to our employees or other personnel. There may be situations, where we may disclose the confidential information only to those of our employees and other personnel on a need to know basis. Any breach of confidential information by the employees, personnel within Lakshyaa is dealt with stringently by us.
  3. If the Company undertakes or is involved in any merger, acquisition, reorganization, sale of assets, bankruptcy, or insolvency event, then we may sell, transfer or share some or all of our assets, including your information in connection with such transaction or in contemplation of such transaction (e.g., due diligence). In this event, we will notify you before your Personal Data is transferred and becomes subject to a different privacy policy.
  4. Further, we may share your Personal Data with any other third party for providing other financial services.
  5. Finally, we may share information with our subsidiaries and affiliates to help us provide our Platform or conduct data processing on our behalf only after you have provided the consent.

In case you do not provide your consent or later withdraw your consent, we request you not to access the Platform and also reserve the right to not provide you any services on our Platform. In such a scenario, we may delete your information or de-identify it so that it is anonymous and not attributable to you.


Transfer of Data

Your information, including Personal Data, may be transferred to, and maintained on, computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction. If you are located outside India and choose to provide information to us, please note that we transfer the data, including Personal Data, to India and process it in India. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.


Data Retention

Subject to applicable law, Lakshya may continue to hold data till the purpose for providing such data has been fulfilled.  Notwithstanding anything contained herein, Lakshya may retain data including but limited to the following purposes: If there is an unresolved issue or an unresolved claim or dispute; If we are required to by applicable law; and/or in aggregated and/or anonymized form; or if it is necessary for our legitimate business interests, such as fraud prevention and enhancing users’ safety and security.


Disclosure of Data

We may be required to disclose your information to the statutory authorities in connection with any legal process that may be initiated by such authorities in accordance with applicable laws. We may also need to disclose your information when required by law, such as responses to civil or criminal subpoenas, or other requests by law enforcement personnel. We will only disclose your information when we have a good faith belief that it is necessary to comply with a court order, ongoing judicial proceeding, subpoena, or other legal process, or to exercise its legal rights or defend against legal claims. Lakshya may disclose your Personal Data in the good faith belief that such action is necessary to comply with a legal obligation, protect and defend the rights or property of Lakshya , prevent or investigate possible wrongdoing in connection with the Platform, protect the personal safety of users of the Platform or the public, protect against legal liability, etc. 


Security of Data

We have complied with reasonable security practices and procedures, and have a comprehensive information security programme and information security policy that shall contain managerial, technical, operational and physical security control. The measures we undertake may include, where appropriate, the use of firewalls, secure server facilities, implementing proper access rights management systems and processes, careful selection of processors, standard authentication and encryption policies for our servers and other technically and commercially reasonable measures. However, we cannot guarantee in any way with respect to any information that you upload transmit, share or display through the Platform and you do so at your own risk and no method of electronic transmission and storage is 100% secure. We shall not be liable for any loss or damage sustained by reason of any disclosure (inadvertent or otherwise) of any data, if the same is either (a) required under sharing your information for legitimate purposes; or (b) was effected through no fault, act, or omission of the company. 


Children’s Privacy

If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.


Force Majeure

We shall be not be responsible for any loss or wrongful sharing of information resulting from, industry wide shortages of labour or material, acts of war or civil disruption, governmental action, acts of God and other natural disasters which is beyond the reasonable control of us.


Changes to this Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. We will let you know via email and/or a prominent notice on our Platform, prior to the change becoming effective and update the “effective date” at the top of this Privacy Policy. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page. 


Access to Your Information

All information provided by you is yours. You have the right to ask us for a readable copy of all your information stored with us by making a written request. As an added security measure and regulatory requirement, we may require additional proof of identity prior to such disclosure.


Grievance Officer

We have appointed a grievance officer who shall address any discrepancies and grievances of the provider of the data with respect to processing of information in a time-bound manner. You can contact the concerned person by calling on our registered number.

Name: __Gowri_________

Email address:           ______

Contact details: ___080-41222353__________


Your Acceptance of these Terms

By using or visiting this platform, you signify your agreement of this policy. If you do not agree to any of these terms, please do not use this Platform.