The objective of this Data Protection and Privacy Statement is to inform you of how IKIGAI Asset Managers Holdings Pvt. Ltd. (IKIGAI ) which provides or will provide services and/or products to you, as well as its representatives, affiliates and/or agents, (collectively referred to herein as “IKIGAI ”, “us”, “we” or “our”) manages Personal Data (as defined below). We ask that you read this Data Protection and Privacy Statement carefully as it contains important information about what to expect when we collect Personal Data about you or from you and how we will use and/or disclose such Personal Data.
This Personal Data Protection Policy Statement supplements but does not supersede or replace any other consent you may have previously provided to IKIGAI in respect of your Personal Data, and your consents herein are additional to any rights to which IKIGAI may have at law to collect, use or disclose your Personal Data.
In this Data Protection Policy Statement, “Personal Data” refers to any data about you or a Relevant Person, such that you or such natural person (as the case may be) can be identified (a) from that data; or (b) from that data and other information to which we have or are likely to have access, including data in our records as may be updated from time to time.
Examples of such Personal Data you may provide us include your name, company name, title, passport or other identification number, telephone number(s), mailing address, email address, account number, assets, income and financial situation and any other information relating to any Relevant Person which you have provided us in any forms you may have submitted to us in taking steps to enter or entering into a contact to provide you with services. When we process such Personal Data IKIGAI will rely on Contract as its lawful basis for processing.
We may also collect personal information about you from applications, forms or questionnaires you may complete or agreements you enter into with us or in the course of your establishing or maintaining a customer relationship with us, including information about your credit history or financial situation, and your transactions with us or others who provide services to us. Again, when processing such Personal Data IKIGAI will be relying on Contract as its lawful basis for processing.
We may also collect personal information about you as a result of us recording certain telephone calls which our employees may have with you, and storing these recordings, in order to satisfy our legal and regulatory obligations or for IKIGAI business purposes. Apart from Personal Data, we may collect other types of information which is not linked to a natural person and which is anonymous. For example, the number of website visitors and the number of website users using a particular service. In this way, we hope to improve our customer services.
Generally, IKIGAI collects, uses and discloses Personal Data for the following purposes:
IKIGAI may also use this information to provide you with information about other services we offer that are similar to those that you have already engaged us to provide or enquired about or to provide information about IKIGAI by way of news letters or emails.
In such instances IKIGAI will only do so where we have either received consent from you or we have assessed that there is a legitimate interest for us to send you the communication. When assessing legitimate interest, we will balance our interests with your rights and will only send communications where you would reasonably expect to hear from us. You may opt out of receiving this information when we collect details or at any time by contacting us using the contact details below;
If you do not wish for us to continue to use your Personal Data or the Personal Data provided by you to us for any of the Purposes at any time in the future, you must notify us in writing to withdraw your consent. Depending on the circumstances, your withdrawal of consent may result in IKIGAI ’s inability to provide you with the services and/or products that we have been offering to you, and consequently, may result in the termination of your relationship and/or accounts with us.
Where the personal data protection laws of the relevant jurisdictions permit us to collect, use or disclose the Personal Data without your or the Relevant Person’s consent, such permission granted by law will continue to apply.
Subject to the provisions of any applicable law, Personal Data may be disclosed or transferred to, shared with or kept by the following entities, wherever located, for any of the Purposes or for processing for any of the Purposes:
To the extent that we may need to transfer personal data outside the relevant jurisdiction, we shall do so in accordance with the personal data protection law of that jurisdiction to ensure that we provide a standard of protection to the Personal Data so transferred that is comparable to the protection under that jurisdiction.
If you would like to obtain access to check for accuracy and make corrections to your Personal Data, you may contact us in writing at the address set out in Section 15 below referencing ‘Data Protection & Privacy Statement’. In exceptional circumstances, we reserve the right to deny you access to your Personal Data and may provide an explanation as required by applicable laws.
IKIGAI are committed to only keeping your personal data for as long as we need to in order to fulfil the relevant purpose(s) it was collected for, as set out above in this notice, and for as long as we are required or permitted to keep it by law.
We shall cease to retain Personal Data, or remove the means by which the Personal Data can be associated with particular individuals, as soon as it is reasonable to conclude that the purpose for which that Personal Data was collected is no longer being served by retention of the Personal Data and retention is no longer necessary for legal or business purposes.
We retain copies of our customer contracts in order to enable us to deal with any legal issues and the information provided to us for identification verification checks, financial crime and anti-money laundering checks (as required by law) for up to 7 years after termination or expiry of our contract with you. We retain details of complaints for up to 7 years from the date of receipt.
We shall keep records of the following for up to 7 years:
IKIGAI has taken and will continue to take reasonable efforts to protect Personal Data in our possession or control by making reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks.
While we strive to protect your Personal Data, we cannot ensure the security of any Personal Datawhich you may have transmitted to us, via the Internet, and we urge you to take every precaution to protect your Personal Data and use a secure browser.
IKIGAI may from time to time update this Personal Data Protection & Privacy Statement to ensure that it is consistent with our future developments, industry trends and/or any changes in legal or regulatory requirements. Such changes will be posted on our website.
Such changes to our Data Protection & Privacy Statement shall apply from the time that we post the same on this website.
When we receive such a request we will endeavour to provide you with these details without delay and at the latest within one month of receipt. We may extend the period of compliance by a further two months where requests are complex or numerous. In such instances IKIGAI will inform you within one month of the receipt of the request and explain why the extension is necessary.
When IKIGAI receives a subject access request we will provide a copy of the information held free of charge. IKIGAI may charge a reasonable fee to comply with requests for further copies of the same information. This does not mean that we will charge for all subsequent access requests rather that the IKIGAI reserves the right to charge a fee based on the administrative cost of providing the information.
If the after reviewing a request the Data Protection Officer believes a request is manifestly unfounded or excessive, particularly if it is repetitive, then IKIGAI may charge a ‘reasonable fee’ which will be decided on a case by case basis. In certain circumstances IKIGAI may even refuse to respond to such requests.
You also have the following rights (unless exemptions apply), which can be exercised by contacting us using the details provided below:
When you contact us to exercise any of the rights above, we may ask you to provide some additional information in order to verify your identity, such as your name, your address and proof of identity. If you would like to lodge a complaint or exercise any of your rights set out above, you can contact us at compliance@ikigaiasset.com
A cookie is an alphanumeric identifier which we transfer to your hard drive through your web browser when you visit our website. It enables our own system to recognise you when you visit our website again and improve our service to you.
The information is used to track visitor use of the website and to compile statistical reports on website activity. Cookies may also be used to compile aggregate information about areas of our website that are visited most frequently. This traffic information can be used to enhance the content of our website and make your use of it easier.
For further information about cookies visit www.aboutcookies.org. If you wish to reject our cookie, you can configure your browser to do so. However, in a few cases some of our website features may not function if you remove cookies from your browser.
Our website may contain links to other websites. Please note that we are not responsible for the privacy practices of such other websites and you are advised to read the privacy statement of each website you visit which may collect your Personal Data.
If you provide personal data to us about someone else (such as one of your directors or employees, or someone with whom you have business dealings) you must ensure that you are entitled to disclose that personal data to us and that, without our taking any further steps, we may collect, use and disclose that personal data as described in this Privacy Notice.
In particular, you must ensure the individual concerned is aware of the various matters detailed in this Privacy Notice, as those matters relate to that individual, including our identity, how to contact us, our purposes of collection, our personal data disclosure practices (including disclosure to overseas recipients), the individual’s right to obtain access to the personal data and make complaints about the handling of the personal data, and the consequences if the personal data is not provided (such as our inability to provide services).
If you have any comments or questions about the collection, use or disclosure of your Personal Data or this Data Protection and Privacy Statement, please contact us in writing at the address below referencing ‘Data Protection and Privacy Statement’:
IKIGAI Asset Managers Holdings Pvt. Ltd.
Email: compliance@ikigaiasset.com