Privacy Principles & Policy

This client privacy policy guides our conduct in collection, use, security and disclosure of client's financial information. It outlines the responsibilities we assume as representatives of Just Invest Online, and our expectations of business partners. They also guide the development of Just Invest Online's other policies and procedures.

1. Privacy Principles

1. Only relevant client information that is necessary for our business purpose is collected from the Client. Further, the Client is duly informed on how the Company uses the information so collected.
   We limit the collection of information about our clients solely to what we need to know to administer their relationship with us, to provide better client services, to offer investment products, and to satisfy any legal, statutory and regulatory requirements. We also inform our clients about the general usage of information we collect about them, and we will provide additional explanation if clients so request. A written consent is also obtained from the client before collection of such information.

2. We give clients choices about how their information will be used.
   In order to most effectively deliver the services relating to investment products to our clients, it is sometimes necessary to share information about our clients with carefully selected investment product manufacturers, vendors and business partners who offer additional value to Just Invest Online's clients.Just Invest Online will, prior to the collection of information, provide an option to the clients to not provide the data or information sought to be collected. The clients shall, at any time while availing the services or otherwise, also have an option to withdraw its consent given earlier to Just Invest Online. Such withdrawal of the consent shall be sent in writing to Just Invest Online.

3. We use prudent information security safeguards.
   We limit access to client information systems to those who specifically need it to conduct their business responsibilities, and to meet our client servicing commitments. We employ safeguards designed to protect the confidentiality and security of our client information.

4. We limit the disclosure of client information.
   We do not disclose client information unless we have been authorized by the client or where the disclosure is necessary for compliance of a legal obligation, or we do so in connection with our efforts to reduce fraud or criminal activity and to comply with regulatory requirements and guidelines. Any client information shall be disclosed to any third party by an order under the law for the time being in force, but the same shall be routed through the Compliance function. Just Invest Online may transfer client information to any other body corporate or a person that ensures the same level of data protection that is adhered to by Just Invest Online as provided for under these policy and it is necessary for the performance of the lawful contract between Just Invest Online and client or where such client has consented to data transfer.

5. We hold ourselves responsible for our privacy principles.
   Each of Just Invest Online's employees and advisors are responsible for maintaining consumer confidence in the company. We provide training and communications programs designed to educate Just Invest Online's representatives about the meaning and requirements of this Client Privacy Policy. Those who violate this Policy are subject to disciplinary action, up to and including dismissal. Employees and advisors are expected to report violations, and may do so confidentially, to their manager or to the Compliance Officer. We also conduct internal assessments of our privacy practices to ensure compliance with our Privacy Policy and the specific guidelines that support this Policy.

6. We extend this privacy policy to our business relationships.
   We obligate companies we prudently select as our business partners to agree to keep our client information confidential and secure, to protect the information against unauthorized access, use, or re-disclosure by the recipient company, and limit its use to the purposes for which it was provided to them.

2. Display of the Policy

This policy shall be published on the website of the Company.

3. Review of Information

Just Invest Online shall permit the clients, as and when requested by them, to review the information they had provided and ensure that any information found to be inaccurate or deficient shall be corrected or amended as feasible. However, Just Invest Online shall not be responsible for authenticity of such information.