Direct Onboarding

PRIVACY POLICY

Vallum Capital Advisors Private Limited is a SEBI registered Portfolio Manager. This Privacy Policy explains how we collect, use, disclose and protect information received from visitors to our website and from clients who engage our Portfolio Management Services.

The policy is aligned with applicable Indian laws including SEBI PMS Regulations, KYC and AML requirements and the Digital Personal Data Protection framework.

1. Information We Collect

We may collect the following categories of information:

a) Personal and KYC Information

Name, address, email, phone number, PAN, Aadhaar, date of birth, bank details, photographs, signatures and other documents required for KYC and AML compliance.

b) Financial Information

Net worth details, investment experience, risk profiling data, source of funds and portfolio related information necessary for providing PMS.

c) Website Information

IP address, browser type, device details and information submitted through website forms for inquiry and onboarding purposes.

d) Communication Records

Emails, call recordings, meeting notes and instructions received from clients for service delivery and compliance.

2. Purpose of Collection

  • Client onboarding and KYC verification
  • Risk profiling and suitability assessment
  • Portfolio management and reporting
  • Compliance with SEBI, FIU and AML requirements
  • Communication of statements and disclosures
  • Grievance handling and audit
  • Improvement of website experience

3. Legal Basis

  • Consent provided by the client
  • Statutory obligations under SEBI PMS Regulations and PMLA
  • Contractual necessity for providing services
  • Legitimate business interests consistent with law

4. Sharing of Information

  • Custodians, brokers, RTAs and banks for transaction processing
  • KYC Registration Agencies
  • Auditors, compliance and technology partners
  • Regulators such as SEBI, FIU and other authorities when required

We do not sell or trade personal data to any third party.

5. Data Security

  • Access limited to authorized personnel
  • Encryption and secure systems
  • Periodic security assessments
  • Confidential handling by partners
  • Retention as per regulatory norms

6. Cookies

The website may use essential cookies for functionality. No tracking for advertising is undertaken without consent.

7. Client Rights

  • Access to their data
  • Correction or updation
  • Withdrawal of consent where permitted
  • Details of data usage
  • Grievance redressal

8. Retention

Records are retained for the period mandated under SEBI and AML regulations or as required by law.

9. Third-Party Links

Vallum is not responsible for privacy practices of external websites linked on this site.

10. Changes to Policy

This policy may be updated from time to time. The latest version will be available on the website.

11. Grievance Officer

  • Name: Madhavi Gore
  • Email: pms.grievances@vallum.in
  • Phone: +91 8655664538
  • Address: B-403, Kanakia Wall Street, Mumbai – 400093

12. Consent

By using this website or availing services, you consent to the collection and processing of information as described above.

Regulatory Disclosures:
Vallum Capital Advisors Private Limited is a SEBI Registered Portfolio Manager. Investments are subject to market risks. Data collected is used strictly for PMS and regulatory purposes.