Privacy Policy

SUKHMAL PRIVACY POLICY

At Sukhmal Mutual Fund Distributors Private Limited, we understand that when you entrust us with your personal and financial data, you're placing immense faith in our ability to protect it. That trust forms the foundation of everything we do. As a platform dedicated exclusively to mutual fund investments, we are committed to ensuring your information is handled with the highest standards of privacy, transparency, and integrity.

This Privacy Policy explains how we collect, use, store, protect, and share your information when you interact with our services. It also outlines the rights you have over your data and the choices you can make.

In the course of using our platform—whether to explore our services, register, submit forms, provide online consents, or initiate transactions—you may be required to share personal details which may include sensitive and confidential information. We understand the importance of this data and have taken all necessary and reasonable measures to ensure its security.

For the purpose of this Policy, terms such as "You," "Your," "Client," "Investor," or "User" shall refer to any individual or legal entity who visits our website or mobile application, initiates the process of account registration, submits investment instructions, or inquires about our offerings. These individuals shall collectively be referred to as "Covered Persons." The terms "We," "Us," "Our," or "Team Sukhmal" refer to Sukhmal Mutual Fund Distributors Private Limited, a company incorporated under the Companies Act, 2013 with CIN U66190GJ2025PTC158580, having its registered office at Office No. 815, Office Tower, Homeland City, Business Park, Piplod, Surat, Gujarat 395007 and engaged exclusively in the distribution and facilitation of mutual fund transactions.

Sukhmal is registered as an Association of Mutual Funds in India (AMFI) under ARN-279960 as a mutual fund distributor and provides a digital platform that facilitates transactions in mutual funds through recognized exchange infrastructure such as BSE StAR MF and NSE NMF II. We are not involved in stock broking, margin trading, or any other capital market activities. Users may freely browse or access our website without registration; however, transactions and certain features will require you to create an account and comply with Know Your Customer (KYC) norms in accordance with applicable SEBI and AMFI guidelines.

Your use of Sukhmal's platform and services constitutes acceptance of this Privacy Policy, along with our Terms and Conditions, client agreements, application forms, declarations, and any other associated documents or policies as made available on our website revenumf.com. Continued use of the platform, including placing transactions or modifying account details, shall be considered your ongoing acceptance of all applicable terms.

This Privacy Policy may be updated from time to time, and we encourage you to review it periodically. Your continued use of our platform after such changes implies your consent to the revised terms.

Collection of Sensitive Personal Data or Information

Sukhmal may collect certain personal and sensitive personal data or information (as defined under applicable data protection laws) from you as part of our investor onboarding and transaction facilitation process. This information is necessary to offer our services through the mutual fund distribution platform integrated with recognized exchanges and systems like BSE StAR MF.

The types of personal data collected may include:

• Full name, gender, date of birth or incorporation, marital status, and contact details (such as residential address, mobile number, and email ID);
• Permanent Account Number (PAN), Aadhaar Number, signature, photograph, and KYC status;
• Bank account details including account number, IFSC code, and account type;
• FATCA-related declarations, source of income, income range, occupation or profession;
• Nominee details and proof documents, including a cancelled cheque (especially in case of NRIs).

To streamline the process, we employ a government-authorized third-party API provider to fetch basic details directly from your PAN, thereby reducing manual input and ensuring accuracy. Similarly, Aadhaar-based eKYC and address validation may also be utilized for regulatory compliance.

All mutual fund transactions facilitated through our platform are performed via the BSE StAR MF platform, which employs two-factor authentication and robust backend checks. As per SEBI regulations, Sukhmal does not handle any user funds directly. All payments are redirected to the exchange's secure payment gateway, ensuring that funds flow directly from your bank account to the exchange. Withdrawals are also processed via the BSE system, ensuring transparency and security.

Your personal and sensitive data may be shared only with regulated third-party entities such as SEBI, AMCs, KRAs, BSE/NSE, RTAs, and payment intermediaries, and solely for the purpose of processing your investment transactions and fulfilling compliance requirements. We impose strict confidentiality obligations on all such entities and require them to handle your data only as long as necessary for the intended purpose.

We may also disclose your information to government authorities, courts, or regulatory bodies when required under applicable law.

By using our platform and services, you consent to the collection, processing, and sharing of your personal data in accordance with this Privacy Policy. You may choose to withdraw your consent at any time by contacting our support team. However, please note that withdrawal of consent may result in the discontinuation of services offered through our platform.

We do not collect or store any funds—all payments and redemptions are processed directly through BSE's secure payment gateways, ensuring that the flow of money is directly between the user and the exchange, in line with SEBI regulations. Similarly, we do not perform any unauthorized advisory activities and comply fully with AMFI's Code of Conduct for Mutual Fund Distributors. Therefore, Sukhmal will not be liable in case of breach of any data.

Under Regulation 5 of the IT Rules, 2011, every registered user has the right to receive a readable copy of the personal information they have submitted. Users may also request updates, corrections, or the deletion of personal data subject to compliance and operational constraints.

We retain such data only as long as necessary for regulatory, legal, audit, or business purposes, in line with SEBI-mandated record-keeping requirements (for minimum four financial years). We also maintain appropriate technical and procedural safeguards, including AES 256 CBC encryption, HTTPS-secured APIs, and access-controlled environments to protect your information from unauthorized access or disclosure.

By using Sukhmal's platform, you consent to the collection, storage, and use of your data as outlined in this Privacy Policy. If you choose to withdraw your consent, certain services may no longer be accessible.

Scope of this Privacy Policy

This Privacy Policy applies to every individual or legal entity who visits, accesses, or interacts with the official website or mobile application of Sukhmal Fin Consultancy Private Limited ("Sukhmal", "we", "our", or "us"), regardless of whether they proceed to create an account or complete the KYC process. Any such visitor or user is deemed to fall within the scope of this Policy.

Sukhmal is a SEBI-compliant mutual fund distributor (ARN-279960) registered with the Association of Mutual Funds in India (AMFI), operating under applicable regulatory frameworks. We strictly adhere to the provisions of the Information Technology Act, 2000, including the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, as well as all applicable SEBI, AMFI, and related regulatory guidelines. Our policies are designed to ensure full compliance with data privacy and security obligations governing digital investment platforms in India.

Aadhaar User Consent Policy

Voluntary Disclosure of Aadhaar

At Sukhmal Fin Consultancy Private Limited ("Sukhmal"), the submission of your Aadhaar number or Aadhaar-related details is completely voluntary. Aadhaar is requested only for the purpose of completing your KYC verification and account opening process, in compliance with regulatory requirements laid down by SEBI and AMFI.

You may also use Aadhaar as a proof of address, but this is an optional alternative to other valid identity documents such as a passport or driver's license.

If you do not wish to share your Aadhaar, you may choose to complete the account opening process offline, either by visiting our office or meeting a Sukhmal representative, where your account details will be entered directly into the BSE StAR MF system.

How Aadhaar Details Are Collected

Sukhmal does not require users to manually upload their Aadhaar card. During the online onboarding process, once you provide your PAN, we use a government-authorized KYC API partner, Surepass Technologies (surepass.io), to retrieve KYC-linked details. If your Aadhaar is already linked to your PAN, the system fetches the Aadhaar number automatically—without displaying or storing it on Sukhmal's platform.

In cases where Aadhaar is not pre-linked or where Aadhaar is voluntarily provided by the user, the details may be entered manually to complete the KYC.

During offline registrations conducted at our office or through a scheduled meeting, our team will collect required details and input them directly into the BSE StAR MF portal to complete your onboarding process.

Use and Protection of Aadhaar Information

Sukhmal does not store or retain your Aadhaar number or Aadhaar documents on its servers. Any Aadhaar-linked information obtained is used only once to complete the KYC and registration process and is not retained beyond the requirement of that transaction.

We are fully committed to protecting your personal data in accordance with the:

• Information Technology Act, 2000
• Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011
• Applicable SEBI and AMFI guidelines

Any information obtained through APIs or submitted manually is handled with strict access controls, encryption protocols, and internal security safeguards.

User Consent

By proceeding with online onboarding or by submitting your documents to our representative for offline processing, you:

• Expressly consent to the use of Aadhaar-linked data for the limited purpose of KYC verification;
• Acknowledge that submission of Aadhaar is voluntary and not mandatory;
• Confirm your understanding that you may opt out by choosing offline KYC through physical identity documents;
• Accept that any Aadhaar-related data, if fetched or submitted, will be handled strictly in accordance with applicable privacy regulations and not stored by Sukhmal.

Minor's Data

To protect children's data, special emphasis is taken by Sukhmal to safeguard the data and measures such as parental consent is required.

Lawful Basis for Processing Your Personal Data

At Sukhmal, we are permitted to process your personal and non-personal information in accordance with the applicable data protection laws and regulatory frameworks. Such processing is conducted only when supported by one or more of the following lawful bases:

• Consent: You have explicitly provided your consent for your personal data to be collected and used for one or more specified purposes.
• Contractual Necessity: The processing is necessary for the performance of a contract to which you are a party, or in order to take steps at your request prior to entering into such a contract.
• Legal Compliance: The processing is necessary to comply with legal obligations applicable to us, including but not limited to SEBI, AMFI, PMLA, and IT Act requirements.
• Legitimate Interest: The processing is necessary for our legitimate business interests, which may include:
  • Delivering and maintaining seamless access to mutual fund investment services;
  • Ensuring the security, integrity, and performance of user accounts;
  • Preventing, detecting, and investigating fraud, financial crime, identity theft, and violations of regulatory norms;
  • Addressing investor grievances and managing service quality;
  • Evaluating, improving, or customizing our services and user experience;
  • Communicating with you regarding our services or updates, unless you have opted out of such communication.

Advertisement Identifier

Our mobile app may collect advertisement identifiers for app usage analytics and, if you consent, for showing relevant promotional content. These identifiers do not directly identify you and can be reset or limited via your device settings.

Grievance Settlement

To exercise any of the above rights or to initiate a request for data portability or deletion, users may write to us at:

Email: [email protected]

Please include your full name, registered email address, and the nature of your request for proper verification and timely handling.

The Designated Data Protection Officer (DPO) for GDPR-related matters at Sukhmal is:

Name: Omkar Khalipe
Designation: Data Protection Officer
Email: [email protected]

We aim to respond to such requests within 30 days, subject to verification of identity and applicable exemptions under data protection laws.

Cookies and Browser Controls

Our website and mobile application may use cookies to distinguish you from other users, track preferences, improve performance, and enhance the user experience. Cookies may also be used for analytics and functional personalization.

You have the option to refuse cookies by adjusting your browser settings. However, if you disable cookies, some parts of the website or platform features may not function as intended.

Unless disabled, cookies will be automatically issued when you access and interact with our platform.

Security, Data Protection & User Privacy

Data Security Measures

At Sukhmal, the security of your data is of paramount importance. We have implemented multiple layers of technical and procedural safeguards to ensure that your personal and financial information remains protected at all times.

• All data transmitted between your device and our platform is encrypted using the HTTPS protocol.
• Our systems and third-party APIs are secured with authentication tokens and compliant with industry standards.
• Any data temporarily stored during the onboarding or KYC process is encrypted using AES-256 CBC encryption, ensuring that even in the rare event of unauthorized access, the information cannot be deciphered.
• We rely on BSE StAR MF's secure infrastructure for all mutual fund transaction processing and do not store or transmit user funds.

While we take all reasonable precautions, it is important to note that no online system is completely immune to threats, and users are encouraged to take appropriate security measures, such as safeguarding login credentials.

Data Storage

Our servers are located within India, in full compliance with Indian data protection regulations. While Sukhmal does not permanently store all user data on its servers, any limited data that may be stored temporarily (such as for failed KYC follow-up) is encrypted and purged once the purpose is fulfilled.

Handling of Sensitive Financial Information

Sukhmal may collect sensitive financial information—such as bank account details or UPI IDs—during KYC and investment processing. However, this information is:

• Not stored permanently in our database;
• Retained only temporarily (if required to resolve KYC discrepancies), and
• Deleted immediately once the process is complete or the issue is resolved.

Data Sharing Policy

Sukhmal does not share user data with third-party marketing or analytics platforms beyond basic, anonymized insights for platform improvement.

• BSE, as the mutual fund transaction platform, directly handles and shares KYC and investment data with relevant AMCs and RTAs.
• We use tools like Google Analytics and Meta/Facebook Pixel to collect non-personally identifiable data for the sole purpose of measuring website/app performance and optimizing user experience.
• We do not sell or share personal data with any other third parties.

Data Breach Notification

In the unlikely event of a data breach:

• Since minimal personal data is stored on our servers, the risk of any significant data leak is extremely low.
• Any limited data we hold is encrypted and protected by strong access controls.
• Nonetheless, should such an incident occur, Sukhmal will promptly notify affected users via email and publish an update on our official website, in compliance with applicable legal obligations within 72 hours.

User Control and Account Deletion

Users have full control over their account and personal data.

• You may request modification, correction, or deletion of your account by reaching out to us at: [email protected]
• Upon such a request, your data will be removed from our systems to the extent permissible under applicable SEBI and BSE data retention rules.

App Permissions (For Mobile Users)

To provide a seamless experience, our mobile application may request the following permissions:

• Location access – for usage analytics (optional)
• Camera and file access – to upload KYC documents or photographs
• Notification access – for sending service-related or personalized updates
• Device identifiers – for login tracking, fraud detection, and authentication

You can manage these permissions from your mobile device settings at any time.

Two-Factor Authentication (2FA)

For all sensitive operations such as login and transaction authorization, two-factor authentication (2FA) is enabled by default through the BSE Star MF platform. This ensures that only authorized users can access or perform actions on their investment accounts.

Marketing Preferences and Opt-Out

We respect your communication preferences. If you receive marketing emails or promotional messages from Sukhmal and wish to unsubscribe, simply use the "Unsubscribe" link included in the email. You may also update your preferences directly within the app or by contacting support.

Disclaimer on Data Breach and Limitation of Liability

While Sukhmal employs industry-standard encryption protocols, access controls, and secure infrastructure to protect user data, it is important to acknowledge that no digital platform can guarantee absolute security.

Despite our best efforts, if there is a data breach, cyberattack, system compromise, or any other unauthorized access—whether due to external threats, not limited to cyber fraud, hacking, or force majeure events—Sukhmal shall not be held liable for any loss, damage, or harm, including but not limited to:

• Financial loss,
• Identity theft,
• Unauthorized transactions,
• Reputational damage, or
• Any consequential or incidental damages arising therefrom.

By using our services, you acknowledge and accept that you do so at your own risk, and agree that Sukhmal shall not be responsible for any claims or liabilities arising out of such incidents, except to the extent required under applicable law.

Users are also advised to take all necessary precautions to protect their login credentials, avoid sharing OTPs, and secure their personal devices from unauthorized access. In the event you suspect your account or data may have been compromised, please notify us immediately at: [email protected]

Contact Us

If you have any questions about this Privacy Policy, please contact us.