Welcome to 9Point Capital. This Privacy Policy is applicable to 9Point Capital and all affiliated entities. We value your privacy and are committed to protecting your personal data. This Privacy Policy explains how AlphaQuest Technovations Private Limited and our partner Broker-Dealer known as “VTI IFSC” (“we,” “us,” or “our”) collects, uses, and safeguards your information when you use our platform or services (collectively referred to as ‘Services’), which is owned and operated by AlphaQuest Technovations Private Limited (“ATPL”). VTI IFSC is responsible for opening, approving and monitoring all activities in connection with your account.
Any reference to “ATPL”, “us”, “our”, and “we” in this Agreement shall be construed to be a reference to either VTI IFSC or ATPL depending on the relevant part of the Service in question. By using the platform, you agree to the terms outlined in this Privacy Policy.
Description of Users and Acceptance of Terms
By signing up for, accessing, or using our Services, Customers agree to abide by the terms set forth in this Privacy Policy, the Terms of Use, and any applicable customer agreements. If you do not agree with any of the terms outlined in this Privacy Policy or the Terms of Use, you are not permitted to access or use the Sites or the App.
1. Personal Information
When you register to become a Customer, you will be required to provide certain personal details, including but not limited to your name, date of birth, National ID number and scan, citizenship, home address, telephone number, email address, employer name, employment status, job position, whether you are a “politically exposed person,” whether you are a “controlling person”, annual income range, total net worth range, and any other information necessary for our legitimate business purposes (collectively referred to as “Personal Information”).
2. Non-public Personal Information
During the registration process and throughout your use of our Services, we will also collect Non-public Personal Information. This includes: (i) any information you provide to obtain a financial product or service from us, (ii) any information resulting from transactions involving a financial product or service between us and you, or (iii) any additional information we gather in connection with providing a financial product or service to you (collectively, “Non-public Personal Information”). Non-public Personal Information is a subset of Personal Information and is treated as such under this Privacy Policy.
WE DO NOT SELL YOUR NON-PUBLIC PERSONAL INFORMATION COLLECTED
In conducting our business as described above, we collect (or may collect), for example, the following types of non-public personal information:
1. Information about you: (1) information you provide in connection with securities accounts or any other financial product or service, whether in writing, in person, by telephone, electronically or by any other means, such as your name, address, social security number, if applicable, tax ID number, assets, income, investment objectives, financial situation and debt; and (2) information VTI IFSC obtains (or may obtain) for the purpose of tax reporting to you.
2. Information about your securities and/or other transactions: (1) information we collect and may relate to account balance, payment history, trading activity and any other transactions which we provide brokerage services; (2) information we collect as part of servicing your account(s), as a BD.
3. Information about your transactions with non-affiliated third parties: (1) information from non-affiliated third parties pursuant to law, rules, regulations, standard securities industry practice and/or legal process, including information and/or documents received, shared, produced or provided in connection with a subpoena, discovery request or other legal process compelling production; and (2) information from non-affiliated third parties related to servicing your account for purposes of providing securities BD services.
Confidentiality and Security of Non-Public Personal Information
We are dedicated to implementing and maintaining commercially reasonable and appropriate measures to ensure the security and confidentiality of your non-public personal information. Our information and security procedures include, but are not limited to, the following measures:
Access Controls: We employ access controls on customer information systems to authenticate and restrict access to authorized individuals only.
Physical Access Restrictions: We enforce physical access restrictions at locations where non-public personal information is stored to ensure that only authorized personnel can access such information.
Pre-Employment Screening and Segregation of Duties: We conduct stringent pre-employment screening and thorough background check and enforce segregation of duties for our employees who have responsibilities for or access to non-public information.
Regular Review and Updates: We regularly reviews, revises, and updates its information security program to adapt to changes in technology and emerging security threats.
3. Transaction Information
When Customers initiate a purchase, sale, or any other transaction through the Platform, they are required to provide specific details related to the transaction they wish to execute. This information is collectively referred to as “Transaction Information.” Transaction Information is a subset of Personal Information and is treated as Personal Information under this Privacy Policy.
Information Collected by or Received from Third-Party Sources
We may collect Personal Information and transaction details from various sources, including transactions with us, our affiliates, unaffiliated third parties, banking, and consumer reporting agencies. Additionally, we may obtain information about you from third-party data sources, such as brokers, banks, and government databases. We may combine the data we collect from these third-party sources with the information you provide directly. This combined data will be used and shared in accordance with the terms outlined in this Privacy Policy. All information collected and/or received from such third-party sources is collectively referred to as “Third-Party Information”.
Information Usage and Disclosure
As per privacy policy user allowed us to use the personal information, the third-party information if any, to improve our platform and services. We will use this content for improving functionality and services experience, to inform you about our products and services and those of third parties.
- We will use, access and share the information as require fulfilling our contractual agreement and obligation to you.
- Like many businesses, we occasionally hire other companies to handle specific functions on our behalf. When we engage another company to perform such functions, we only provide them with the information necessary for that specific task. These companies are authorized to use your information only to the extent necessary to provide these services to us.
- To better understand our customers, the products, the Platform, and our services, we may analyse certain information to compile data on customer demographics, interests, and behaviours. This aggregated data does not identify you personally. We may share this aggregate information with our affiliates, agents, business partners, and other third parties. Additionally, we may disclose aggregated user statistics to describe the Platform, the Services, and our products to current and potential business partners, investors, and other third parties for lawful purposes.
- We may disclose your information if required by law or if we believe in good faith that such disclosure is necessary to: (i) comply with legal obligations, (ii) protect and defend our rights or property, (iii) respond to urgent situations to safeguard the financial security of users or the public from fraud or other harm, or (iv) protect against legal liability.
Sharing of Your Information with Non-Affiliated Third Parties
We will not share your information with non-affiliated third parties who may use it for marketing purposes without first obtaining your opt-in consent.
- Exclusions – This Privacy Policy does not apply to Personal Information collected by us outside of the information collected through the Platform and/or Services. It does not cover any unsolicited information you provide to us through the Platform or by other means. This includes, but is not limited to, information posted to any public areas of the Platform (collectively, “Public Areas”), ideas for new products or modifications to existing products, and other unsolicited submissions (collectively, “Unsolicited Information”). All Unsolicited Information will be considered non-confidential, and we may reproduce, use, disclose, distribute, and exploit such Unsolicited Information without any limitation or attribution.
- Suspicious Email – We do not request non-public or account information (such as usernames and passwords) via email or other electronic communications. If you receive an unsolicited email or communication that appears to be from us or pretending to be us including seeming to be suspicious or fraudulent, please contact us at Grievances@9point.capital.
- Links to Other Websites and Integration of Third-Party Content -This Privacy Policy applies solely to the Platform. The Platform may include links to websites or services operated by third parties (the “Third-Party Sites”). The policies and procedures described in this Privacy Policy do not extend to these Third-Party Sites. The presence of links to Third-Party Sites on the Platform does not imply endorsement or review by us. We recommend that you contact these Third-Party Sites directly to learn more about their privacy policies and practices.
- Former customers -We will disclose non-public personal information about former customers only as permitted or required by law or legal process, or with the former customer’s consent.
- Changes to 9Point Capital’s Privacy Policy – We reserve the right to make changes to this policy and continued usage of the platform will mean that such privacy policy including continuous changes, are acceptable.