Last Updated: June 5, 2025

1. Introduction

ANS Private Limited (“ANS,” “we,” “us,” or “our”) is committed to protecting the privacy and security of your personal data. This Privacy Policy explains how we collect, use, store, disclose, and safeguard information when you visit or use our website www.ansplshares.com (the “Platform”) and related services (collectively, the “Services”). By accessing or using the Platform, you agree to the terms of this Privacy Policy.

2. Regulatory Compliance and Legal Framework

ANS operates under the following legal and regulatory requirements:

• Applicable Laws & Regulatory Bodies
  • ANS is a SEBI-registered stockbroker and follows guidelines issued by SEBI, NSE, BSE, MCX, and NCDEX.
  • For mutual fund services, we comply with SEBI’s Mutual Fund Regulations.
  • We adhere to the Information Technology Act, 2000 (IT Act) and Section 43A requirements for data protection.
  • Where relevant, RBI guidelines on NRI investments in Indian capital markets apply.
• Service Eligibility & Geographic Restrictions
  • Our Services are available exclusively to residents of India. NRIs and foreign residents may have additional compliance steps.
  • ANS reserves the right to determine customer eligibility based on SEBI/KRA/KYC norms.

3. Information We Collect

We collect various types of information to deliver, improve, and secure our Services. Below is a non-exhaustive list:

• Personal Information (Collected at Registration/KYC)
  • Name, date of birth, gender, marital status, nationality
  • Contact details: address, e-mail, telephone/mobile number
  • Government-issued identifiers: PAN, Aadhaar (as required by KYC), signature, photograph
  • Bank account details, IFSC, bank statements (for linking trading/demat accounts)
  • KYC & CKYC identification information (via KRA/KYCs)
• Financial & Transaction Data
  • Trading history (equity, derivatives, commodities), order details, settlement instructions
  • Mutual fund investment details: SIP registrations, redemptions, folio numbers
  • Loan applications and MTF data: loan amounts, security pledged, outstanding balances
  • Allotment status, bid quantities, application amounts (for IPO/ASBA)
  • Demat holdings, transaction codes, contract notes
• Technical & Usage Data
  • IP address, browser type/version, operating system
  • Device identifiers (mobile device ID, device model)
  • Usage logs: pages visited, features accessed, clickstreams, time stamps, error logs
  • Cookies, web beacons, tracking pixels, and similar technologies (see Section 8)
• Non-Personal & Aggregated Data
  • Anonymized or aggregated usage patterns (e.g., demographic trends, feature adoption)
  • Website analytics: pages per session, bounce rates, time on page, referral sources
• Optional Information
  • Survey responses, feedback, customer support interactions
  • Social media profile information (if you choose to link accounts for marketing or referrals)
  • Email integration data (with explicit consent, used only to consolidate your investment history)

4. How We Use Your Information

ANS processes your information for lawful, necessary, and relevant purposes, including but not limited to:

• Account Creation & Verification
  • Verify identity and eligibility (KYC/KRA verification) per SEBI/NSE/BSE/MCX/NCDEX rules.
  • Establish and maintain trading and demat accounts, e-wallet or UPI linkage.
• Service Delivery & Transaction Processing
  • Execute buy/sell orders, settle trades, generate contract notes.
  • Process mutual fund transactions—SIPs, redemptions, and generate consolidated statements.
  • Facilitate Margin Trading Facility (MTF), Loans Against Shares (LAS), SLBM.
  • Provide IPO/ASBA application services, calculate bid quantities, generate ASBA/UPI mandates, update allotment status.
• Regulatory Reporting & Compliance
  • Share data with SEBI, stock exchanges (NSE, BSE), commodity exchanges (MCX, NCDEX), CDSL, NSDL, KRA (CKYC), CERSAI, RBI, and other statutory bodies as required by law.
  • Maintain records of transactions and communications for statutory retention requirements.
• Customer Support & Communication
  • Respond to inquiries, resolve disputes, and provide support via phone, e-mail, WhatsApp Backoffice, or live chat.
  • Send transactional alerts (order confirmations, payment receipts, margin calls) via SMS, e-mail, or WhatsApp.
  • Provide periodic account statements, billing information, tax invoices, Form 10DB (STT), CDSL holding statements.
• Service Improvement & Personalization
  • Analyze usage patterns and feedback to enhance platform features and UI/UX.
  • Tailor content, recommendations, and marketing communications to your interests (e.g., mutual fund offers, IPO alerts, Algo Trading suggestions).
  • Detect and prevent fraud, anomalies, or unauthorized activity.
• Marketing & Promotions
  • With explicit consent, send promotional e-mails, SMS, or WhatsApp messages about new products, offers, and updates.
  • Provide targeted advertisements (within legal boundaries), including third-party advertising (non-PII usage).
  • Conduct surveys and market research to improve products and services.

5. Information Sharing & Disclosure

We do not sell your personal information. We may share it only in these cases:

• With Regulators & Exchanges
  • SEBI, NSE, BSE, MCX, NCDEX, RBI, CDSL, NSDL, KRA, CERSAI, and other statutory bodies for compliance, audit, investigations, or regulatory reporting.
• With Service Providers & Business Partners
  • Third-party providers (IT hosting, payment gateways, UPI/ASBA processors, SMS/e-mail vendors, cloud services, data analytics) under confidentiality agreements.
  • AMCs, RTAs, custodians, clearing corporations for mutual fund transactions and demat operations.
  • Banks, payment processors, UPI aggregators, and financial institutions for settlements and KYC/AML checks.
  • CRM, marketing, and analytics partners to tailor promotions or manage customer relationships (only with consent for marketing).
• With Affiliates & Subsidiaries
  • ANS group companies, subsidiaries, and affiliates for providing integrated services (e.g., ANS Money Mutual Fund App, ANS Trade Trading App, ANSPL Backoffice App).
• With Government or Law Enforcement Agencies
  • When required by law, court order, or regulatory authority, or to protect ANS’s rights, property, or safety of others.
• During a Corporate Transaction
  • In connection with a merger, acquisition, demerger, sale of assets, reorganization, or insolvency proceedings, we may transfer your information to a successor entity (subject to confidentiality and legal safeguards).

6. Data Retention & Storage

• We retain personal and transaction data as long as required for the purpose collected or to meet legal, regulatory, accounting, or reporting obligations (generally 8 years per SEBI/NSE/BSE).
• Non-personal or aggregated data may be retained indefinitely for analytical purposes.
• Upon request for deletion, we will de-identify or delete your personal data unless retention is required by law or for legitimate business purposes (e.g., outstanding dues, disputes).

7. Data Security Measures

• Encryption & Secure Protocols
  • All sensitive data (passwords, payment details, KYC documents) are encrypted in transit (TLS/SSL) and at rest on secure servers.
  • HTTPS is enforced across the Platform.
• Access Controls & Authentication
  • Role-based access controls: Only authorized personnel have data access on a strict “need-to-know” basis.
  • Multi-factor authentication (MFA) for internal systems and critical operations.
  • Password protection and regular credential rotation for employees with data access.
• Network & Server Security
  • Firewalls, intrusion detection/prevention (IDS/IPS), anti-malware, and regular vulnerability assessments.
  • Physical security at Indian data centers (restricted access, biometric entry).
  • Regular security audits and penetration testing by third parties.
• Incident Response & Breach Notification
  • Established incident response plan to promptly investigate and mitigate security incidents.
  • In case of a data breach compromising personal data, we will notify affected users and relevant authorities (e.g., CERT-IN, SEBI) within legal timelines.

8. Cookies & Tracking Technologies

• Cookies & Similar Technologies
  • We use cookies, web beacons, pixels, and local storage to personalize experience, maintain session state, track preferences, and analyze usage patterns.
  • Types of cookies: essential (login, security), performance (analytics, load times), functional (remembering preferences), and advertising (targeted promotions).
• Managing Cookies
  • You can modify browser settings to block or delete cookies; certain features (automatic login, personalized recommendations) may not work properly if cookies are disabled.
  • We may use Google Analytics and other third-party providers; they use non-identifiable data and have their own privacy policies.

9. User Rights & Choices

Under applicable laws, you have the following rights regarding your personal data:

• Right to Access: Request a copy of personal data held by us.
• Right to Rectification: Request correction of inaccurate or incomplete data.
• Right to Erasure (Right to be Forgotten): Request deletion of personal data, subject to legal retention obligations.
• Right to Restrict Processing: Request limitation on processing certain categories of personal data.
• Right to Data Portability: Request data in a structured, commonly used, machine-readable format (e.g., transaction history).
• Right to Withdraw Consent: If processing is based on consent (e.g., marketing emails), you can withdraw consent at any time.
• Right to Object: Object to processing for direct marketing or profiling.

To exercise these rights, contact us at customercare@anspl.net. We will respond within 30 days as required by law. If you’re dissatisfied with our response, you may lodge a complaint with the Data Protection Authority or relevant regulator.

10. Third-Party Links & Embedded Content

The Platform may contain links to third-party websites, APIs (e.g., TradingView, payment gateways, registrar websites such as CAMS & KFintech), or embedded widgets (e.g., live charts, calculators). We do not control such sites and are not responsible for their privacy practices or content. Please review their privacy policies before providing any personal information.

11. Changes to This Privacy Policy

• We may update this Privacy Policy to reflect changes in legal, regulatory, or business requirements. The “Last Updated” date at the top indicates the revision date.
• We may notify you of material changes via in-app notifications, e-mail, or a prominent notice on our Platform. Continuing to use the Services implies acceptance of the updated Privacy Policy.

For grievances specific to SEBI/NSE compliance (e.g., unauthorized disclosure, KYC concerns), you may also contact:
SEBI Investor Grievance Redressal
Toll-Free: 1800-22-7575
E-mail: investor@sebi.gov.in

12. Effective Date

This Privacy Policy is effective as of June 5, 2025. All prior versions are superseded.