1. Introduction

SGP &Associates ("SGP", "we", "us") is a firm of Company Secretaries. We value your privacy and are committed to ensuring that the information we collect, including information provided by our users ("you", "your", "yourself") or the information about visitors to our websites is done so in compliance with the applicable data privacy laws. This Privacy Policy explains what information we collect, how we collect and may use information that we obtain about you and how we disclose and share this information.

2. Information we collect:

a. What information do we collect: We may collect personal information that includes your name, identification, contact details, organization, employment, positions held as well as enquiry/complaint details which may be current or historical or both. We may also collect personal information about your dealings with us and other clients.

b. When do we collect information: We collect information about you when you avail of our service, contact us via electronic mail or telephone or when you transact on our website.

c. Who else do we obtain your information from: We may also collect personal information from third parties such as regulatory authorities, your employer, other organizations you are associated with, government agencies, credit reporting agencies, information or service providers and social media platforms. Any unsolicited information shall be treated as stipulated by law, including destroying or de-identifying such information as the law prescribes.

3. Why we collect this information:

As a practice, we would be collecting/ storing/using or transferring your personal information for the following purposes, including but not limited to:

• Personal identification and authentication purposes;
• To provide apt responses to your enquiries and requests;
• Providing our service to you and upgrading the same based on your needs;
• Maintaining and updating your records;
• For research, planning, service development, security or risk management;
• Ensure compliance with the regulatory framework;
• Improve our service delivery;
• To perform administrative and maintenance functions related to our services; and
• Sending you reminders, notices, updates, support and administrative messages, service bulletins, updates about our firm, and any other requested information.

4. Disclosure of information collected

Who may we disclose your information to: Subject to the existing law, your information could be disclosed to the following types of third parties (whether in India or overseas):

• Our agents, service providers, and advisors;
• Our partners;
• Other users of our services;
• Regulatory bodies, government agencies, law enforcement bodies and courts; and
• Any prospective transferee in a scheme of arrangement, amalgamation, merger or sale of shares or sale of business.

Why would we disclose your information: In general, we will not use or disclose information collected about you to a third party otherwise than for the purposes prescribed in this Privacy Policy, unless the disclosure is mandated for compliance of a legal obligation, or where agreed by you contractually, or as otherwise consented. We may exchange the information we collect with third parties (including but not limited to our advisors, consultants and affiliate firms) for the purpose of:

• Providing anonymous statistical information about users of our websites and related usage information, including analytics and search engine providers; or
• Providing services that involve data processing, for example archival, auditing, reference checking, professional advisory, mailing house, delivery, technology, website, research, banking, payment, client contact, data processing, insurance, forensic, litigation, support, marketing and security services.

It is possible that some of the third parties with whom we share your information may be located outside your jurisdiction or the country from which the data were provided (collectively the "Jurisdiction of Origin") including the countries where a firm that we have an association or alliance with has an office. While such third parties will often be subject to privacy and confidentiality obligations, you accept that where lawful such obligations may differ from and be less stringent than the requirements of the privacy laws of the jurisdiction of origin. In those instances, SGP is not responsible for imposing the concerned laws of the jurisdiction of origin and you may not seek redress under those laws.

5. Cookies:

When you view the website, we may store some information on your computer in the form of a "cookie" file. We use cookies to identify members. Most web browsers automatically accept cookies but allow you to modify security settings so that you can approve or reject cookies on a case-by-case basis. Even if you do not use cookies, you can still access all the features on our site by logging in manually with each visit.

6. Security

What security practices we adopt: The security of your information is our priority. We adopt reasonable security practices and procedures to ensure that the information we collect is secure. Access to your information shall be limited to our employees, agents, advisors and third party associates, to the extent necessary. When we share, or transfer your information in accordance with this Privacy Policy, we will undertake reasonable efforts, to the extent practicable, to ensure that the transferee maintains or adopts security practices and procedures, which are similar to the security practices and procedures we follow. While we shall take all reasonable and appropriate measures to secure any information which we hold about you and prevent any unauthorized access, this is not an absolute guarantee of your information's security. To the widest extent permissible by applicable law, we disclaim all liability in relation to any possible breach of security or unintended loss or disclosure of information in relation to your information.

7. Data Retention

Subject to any legal requirements that requires the contrary, it is our policy to retain your data only for as long as we believe it to be necessary for the purposes illustrated in this Privacy Policy.

8. Consent to collect, store and transfer information

By using or continuing to use this website you expressly consent to the aforementioned use of your information in accordance with this Privacy Policy, as may be amended from time to time. This also extends to your consent to us collecting, storing, processing, transferring and sharing information related to you with third parties or service providers for the objectives purported in this Privacy Policy.

Subsequent to us sharing your information with another entity, the information so received by the other entity becomes subject to the concerned entity's privacy practices. However, we will transfer your information to third parties, only as prescribed by this Privacy Policy.

9. Your right to your information

Sharing your information is entirely voluntary. The privacy laws of some jurisdictions also give individuals the right to access and amend their personal information. You may contact us as provided in the succeeding section, if you would like to request a copy of your data or would like to change the information we hold about you. However, to the extent permissible under law, we may refuse or limit access your personal information or grant access subject to conditions.

Upon request, we will remove/block the information you have provided us from our database. However, even after the deletion or termination of your account some of your information may remain stored in our servers for archival purpose only. .

10. Opting-out

You may at any time opt out of receiving newsletters and updates from us by selecting the "unsubscribe" option included in the email or other material.

11. Grievances

If you have any concern in relation to the processing and use of your information or if there are any clarifications you might need with respect to our Privacy Policy, you may contact Mr. R. Sivaram Reddy at sivaram@sgpassociates.com or +91 -9640015500.

If you raise a concern as aforementioned, we shall promptly revert to you with information on how we will handle the grievance and may even seek further details, consult with other parties and maintain record of the interaction.

12. Miscellaneous

Technology and information governance practices are constantly developing and we may therefore need to revise this Privacy Policy in the future. We reserve the right to change or update this Privacy Policy at any time following notice on our website. Such changes shall be effective immediately upon posting and it is advised that you refer the same on a regular basis. Your continued use of our website and services (as defined under the Terms of Use) after these changes will constitute your acceptance of these changes. If you do not agree with such changes to our Privacy Policy, you should immediately cease using our website.

This Privacy Policy only addresses the collection, processing and use (including disclosure) of information by us through your interaction with us. Other websites that may be accessible through links from the website or e-mails may have their own privacy policies and personal information collection, processing, use, and disclosure practices. We encourage you to familiarize yourself with the privacy policies provided by these other parties prior to providing them with information.

This Privacy Policy is to be read along with the Terms of Use. Any undefined term in this Privacy Policy shall have the same meaning assigned to it under the Terms of Use. Clauses 4 (No Warranties); 5 (Limitations and Exclusions of our Liability); 6 (Indemnity) and 7 (Miscellaneous) of the Terms of Use shall apply mutatis mutandis to this Privacy Policy as well.