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Privacy & Data Protection Policy

How Sunrise Associates collects, safeguards, and processes investor information in compliance with SEBI, AMFI, and the Digital Personal Data Protection Act.

Effective Date: March 2025 · Last Updated: March 2026

1. Introduction & Commitment to Privacy

Sunrise Associates ("we", "us", "our") is an AMFI-Registered Mutual Fund Distributor (ARN-92388) operating from Surat, Gujarat, India. We respect your personal privacy and are committed to protecting your sensitive financial and personal data in strict compliance with the Information Technology Act, 2000, the Digital Personal Data Protection Act (DPDP), 2023, and regulatory directives issued by the Securities and Exchange Board of India (SEBI) and the Association of Mutual Funds in India (AMFI).

2. Information We Collect

To facilitate mutual fund transactions, CVL/KRA KYC verification, and mandate registrations through official exchange platforms (such as NSE NMF II), we collect the following categories of information:

  • Identity & Demographic Data: Full name, Permanent Account Number (PAN), Date of Birth, gender, father's/spouse's name, Aadhaar number (only as processed through UIDAI-compliant DigiLocker/e-KYC workflows).
  • Contact Details: Residential address, registered email address, mobile number, and correspondence details.
  • Banking & Financial Information: Bank account number, IFSC code, account type (Savings/Current/NRE/NRO), cancelled cheque leaf copies, and NPCI e-Mandate authorization credentials.
  • KYC & FATCA/CRS Declarations: Tax residency status, occupation, annual income slab, country of birth, politically exposed person (PEP) status.
  • Technical & Log Data: IP address, device identifiers, browser type, and transaction timestamp logs for cybersecurity audit trails.

3. Purpose & Lawful Basis of Processing

We process your personal information strictly for legitimate regulatory and transactional purposes:

  • To perform statutory Know Your Client (KYC) and In-Person Verification (IPV) with licensed KRAs (CVL, CAMS, Karvy, NDML, NSE).
  • To register your Unique Client Code (UCC) on the National Stock Exchange of India (NSE NMF II platform).
  • To process purchase, redemption, SIP, STP, and SWP instructions with respective Asset Management Companies (AMCs) and RTAs (CAMS, KFintech).
  • To register bank account e-mandates via NPCI for automated SIP installments.
  • To communicate transaction confirmations, account statements, regulatory notices, and folio valuation summaries.
  • To comply with statutory anti-money laundering (PMLA) and tax reporting obligations.

4. Disclosure & Data Sharing

Sunrise Associates maintains a strict non-disclosure policy. We do not sell, rent, or trade your personal data to any third-party marketing companies. Data is shared strictly on a need-to-know basis with regulated entities essential for transaction execution:

  • Asset Management Companies (AMCs): Mutual fund fund houses where your folios are maintained.
  • Registrars & Transfer Agents (RTAs): CAMS and KFin Technologies for folio administration.
  • Exchange Infrastructure: National Stock Exchange of India (NSE NMF II).
  • Payment Aggregators & NPCI: For NetBanking, UPI, and NACH e-mandate processing.
  • Statutory Authorities: SEBI, AMFI, FIU-India, Income Tax Department, or law enforcement bodies when required by judicial summons or statutory mandate.

5. Data Security & Encryption

We implement bank-grade administrative, technical, and physical security safeguards to protect your personal data against unauthorized access, alteration, loss, or misuse. All digital transmissions are secured via TLS 1.3 encryption. Internal access to client files is restricted strictly to authorized compliance and operations personnel bound by non-disclosure agreements.

6. Data Retention Period

In accordance with SEBI (Mutual Funds) Regulations, 1996 and the Prevention of Money Laundering Act (PMLA), client identity documents, transaction feeds, and communication logs are retained for a statutory minimum period of eight (8) years following the termination of the business relationship or completion of the last financial transaction.

7. Your Legal Rights

Subject to statutory retention constraints, you are entitled to:

  • Review the personal information held in our records.
  • Request correction of inaccurate or incomplete KYC records.
  • Opt-out of non-regulatory promotional newsletters or market insights at any time.

8. Contact Our Data Protection Desk

If you have any questions or concerns regarding this Privacy Policy or our data handling practices, please contact us:

Sunrise Associates (ARN-92388)
1st Floor, Raj Victoria, Opp. Pal Gam Circle, L P Savani–Pal Road, Adajan, Surat, Gujarat – 394510
Email: info@sunconnectmfd.in
Phone: +91 9687387891