Privacy Policy

Introduction

SPVH AMC Private Limited ("SPVH AMC," "we," "our," or "us") is committed to protecting the privacy of individuals who visit our website, engage with our services, or otherwise interact with us. This Privacy Policy explains our practices regarding the collection, use, disclosure, and protection of personal information in accordance with the Information Technology Act, 2000 and the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011.

Information We Collect

We may collect the following categories of information:

• Personal Identifiers: Full name, email address, phone number, mailing address, date of birth, PAN, and Aadhaar number (as required for KYC purposes).
• Financial Information: Bank account details, investment history, risk profile, net worth declarations, and income details — collected solely for the purpose of providing investment management services.
• Technical Data: IP address, browser type and version, device information, operating system, and browsing behaviour on our website through cookies and similar technologies.
• Communication Records: Correspondence exchanged via email, telephone, or written form, including inquiries and consultation requests submitted through our website.

Purpose of Collection

Your personal information is collected and processed for the following purposes:

• To comply with Know Your Client (KYC) and Anti-Money Laundering (AML) regulatory obligations.
• To administer, manage, and service your investment accounts and portfolios.
• To communicate investment updates, reports, account statements, and relevant market insights.
• To respond to your inquiries, consultation requests, and service-related communications.
• To comply with applicable laws, regulations, court orders, and directives from regulatory bodies including SEBI, RBI, and other authorities.
• To improve our website functionality, user experience, and service offerings.

Disclosure of Information

We do not sell, rent, or trade your personal information. Disclosure may occur under the following circumstances:

• Regulatory Authorities: To SEBI, stock exchanges, depositories, RBI, tax authorities, and other statutory bodies as required by law.
• Service Providers: To custodians, registrars, transfer agents, fund administrators, auditors, and legal advisors engaged by us, subject to confidentiality obligations.
• Legal Requirements: Where disclosure is necessary to comply with legal processes, enforce our terms, or protect the rights, safety, and property of SPVH AMC, our clients, or the public.

Data Security

We implement reasonable security practices and procedures commensurate with the sensitivity of the information collected. These include:

• Encryption of sensitive data in transit and at rest.
• Access controls restricting personal data to authorised personnel on a need-to-know basis.
• Regular security assessments and audits of our information systems.
• Secure disposal of records containing personal information when no longer required.

Data Retention

Personal information is retained for the duration of the client relationship and thereafter for such period as may be required under applicable laws and regulations, including SEBI (Intermediaries) Regulations, the Prevention of Money Laundering Act (PMLA), and Income Tax Act requirements. Once the retention period expires, data is securely destroyed or anonymised.

Cookies & Tracking Technologies

Our website may use cookies and similar technologies to enhance user experience, analyse traffic, and facilitate website functionality. You may control cookie settings through your browser preferences. Disabling cookies may affect certain features of our website.

Third-Party Links

Our website may contain links to external websites operated by third parties. We are not responsible for the privacy practices or content of such third-party sites and encourage you to review their respective privacy policies.

Your Rights

Subject to applicable law, you have the right to:

• Access the personal information we hold about you.
• Request correction of inaccurate or incomplete personal data.
• Withdraw consent for non-essential communications at any time.
• Request deletion of your personal data, subject to regulatory retention requirements.

Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable legal requirements. The revised policy will be posted on this page with an updated effective date. We encourage you to review this page periodically.

Contact Us

For any questions, concerns, or requests relating to this Privacy Policy or your personal data, please contact us at:

SPVH AMC Private Limited
Registered Office Address, Mumbai — 400051
Email: info@spvhamc.com
Phone: +91 22 4000 0000

Last updated: July 2026