Privacy Policy

1. Scope & Applicability

This Privacy Policy applies to the EazySip website and mobile application (the "Platform") operated by Dzambala Financial Services LLP ("Dzambala", "we", "us"), and governs the collection, use, storage, sharing and protection of personal data of users, prospects, investors and their nominees/representatives ("you") who access the Platform. It supplements, and must be read with, the EazySip Website Disclaimer and Terms & Conditions.

2. Legal Framework

We currently process personal data in accordance with the Information Technology Act, 2000 and the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 ("SPDI Rules"). We are also aligning our practices with the Digital Personal Data Protection Act, 2023 ("DPDP Act"), whose substantive compliance obligations are being phased in under the Digital Personal Data Protection Rules, 2025; where a DPDP Act obligation is not yet in force, we follow it as a voluntary best practice pending statutory applicability.

3. Information We Collect

We collect: (a) identity/KYC information (name, PAN, Aadhaar masked/reference number, photograph, signature, address proof); (b) contact details (mobile, email, postal address); (c) financial information (bank details, income/tax status, investment and transaction history, portfolio holdings), which is Sensitive Personal Data or Information under the SPDI Rules; (d) technical data (IP address, device ID, cookies, log files); and (e) your communications with our Sahayogis/support team.

4. Purpose & Lawful Basis

Data is collected with your consent and/or as necessary to perform KYC/onboarding and distribution services, comply with SEBI/AMFI/PMLA/KRA obligations, process transactions, prevent fraud, and improve the Platform. Sensitive personal data is collected only where necessary for a lawful purpose connected with our functions.

5. Sharing & Disclosure

Your data may be shared with AMCs, Registrars & Transfer Agents (CAMS, KFin Technologies), KYC Registration Agencies, payment gateways/UPI/banking partners, SEBI/AMFI/FIU-IND and other regulators/statutory authorities, and our auditors, cloud-hosting and IT service providers, strictly for the purposes stated in this Policy and under confidentiality obligations. We do not sell personal data to third parties for their independent marketing use.

6. Cross-Border Transfer

Personal data may be processed on servers located in India or, where our cloud service providers so require, outside India, except to any country restricted by the Central Government under the DPDP Act.

7. Data Retention

Records, including KYC and transaction data, are retained for the periods mandated under the Prevention of Money Laundering (Maintenance of Records) Rules, 2005 and applicable SEBI/AMFI recordkeeping norms (currently a minimum of five years from the end of the business relationship, or longer if directed by a regulator/court), and are erased or anonymised thereafter in line with the DPDP Act's purpose-limitation principle.

8. Security

We maintain reasonable security practices and procedures, including encryption, access controls and a documented information-security policy, as required under the SPDI Rules and Section 43A of the IT Act. Cyber-security incidents are handled and reported to CERT-In within the timelines prescribed under the CERT-In Cyber Security Directions, 2022 (currently within 6 hours of notice, for reportable incidents). No system is completely secure; see also Limitation of Liability in the Website Disclaimer.

9. Your Rights

Subject to applicable law, you may request access to, correction of, or erasure of your personal data, withdraw consent prospectively, nominate a representative to exercise your rights in the event of death/incapacity, and raise a grievance with our contact below; unresolved grievances may, once the relevant DPDP Act provisions are in force, be escalated to the Data Protection Board of India.

10. Cookies

We use cookies and similar technologies to operate the Platform, remember preferences, and for analytics; you may control cookies through your browser settings, though some features may not function without them.

11. Children's Data

The Platform is intended for use by persons aged 18 years or older who are KYC-compliant; we do not knowingly collect personal data of children, and where processing on behalf of a minor investor is unavoidable (e.g., guardian-operated folios), it is undertaken with verifiable consent of the parent/lawful guardian.

12. Marketing Communications

We may send service, transactional and (with consent, where required) promotional communications by SMS, email, push notification or WhatsApp; you may opt out of promotional communications at any time.

13. Third-Party Links

This Policy does not apply to third-party websites or apps linked from the Platform; please review their respective privacy policies.

14. Grievance Officer / Data Protection Contact

For any privacy-related query, complaint or rights request, contact our Grievance Officer BINAY PRADHAN (Email: binay@eazysip.com | Phone: +91 75570 51930). We aim to acknowledge queries within 24 hours and resolve them within the timelines prescribed under applicable law.

15. Changes to This Policy

We may update this Privacy Policy from time to time; the "last updated" date above reflects the most recent revision, and material changes will be notified through the Platform.

16. Governing Law

This Policy is governed by the laws of India, subject to the jurisdiction clause in the Website Disclaimer and Terms & Conditions.