“Policy on Privacy and Security of Information”

Interpretation

The terms as may be used in this document would be in accordance with “The Information Technology Act 2000 as amended till date, Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011” and such other rules/regulations and Circulars as may be applicable.

All references to the masculine shall include the feminine and all references, to the singular shall include the plural and vice-versa. All references to client/customer/investor whether masculine or feminine include references to non-individuals also unless repugnant to the context thereof.

Any reference to any statute or statutory provision shall be construed as including a reference to any statutory modifications or re-enactment therein from time to time.

Headings are for ease of reference only.

UTI Mutual Fund  (“UTI MF”) is a mutual fund set up under the laws of India and registered with Securities Exchange Board of India (SEBI) under the SEBI (Mutual Funds) Regulations 1996 (MF Regulations). UTI Trustee Company Private Limited (“Trustees”) is the trustee of UTI MF. The Trustees have appointed UTI Asset Management Company Limited (“UTI AMC”) to manage and operate the assets of the Schemes of the UTI MF including all future Schemes that may be launched from time to time.

UTI AMC, interalia, launches schemes for the UTI MF as well as invests, manages the funds mobilized under the various schemes in accordance with the investment objective of the concerned scheme, the SEBI Mutual Funds Regulations 1996 and investment management agreement entered into between the Trustees and the UTI AMC.

UTI Mutual Fund understands that its investors and website/mobile application visitors are concerned about the privacy of their information. UTI Mutual Fund has established policies and procedures concerning the collection, use and security of your information that will help protect your privacy.

We appreciate the importance of keeping the information collected confidential.  We take due care to protect your information.

UTI Mutual Fund may collect information and personal data about you from several sources. You may provide information and personal data as part of the usage/application or enrollment process. Additionally we may obtain information or data about you from third parties. We also develop and retain information about you based on our transactions and experience. We may also obtain information through Internet technology, including our website/mobile applications.

UTI Mutual Fund recognises that the lawful and correct treatment of personal data is very important to maintain investor's confidence in ourselves.  It is our endeavor to ensure that any personal data that we collect, process, record or use in any way whether it is held on paper, on computer or other electronic media will have appropriate safeguards in place to comply with our obligations of confidentiality and privacy. This policy, “Policy on Privacy and Security of Information” is applicable to all channels of your communication with UTIAMC that include physical (e.g., paper forms), online platforms (e.g., website www.utimf.com, mobile apps, etc.) and digital conversational platform (e.g., WhatsApp chatbot).

In this regard, investors/clients/customers  should carefully read the “Policy on Privacy and Security of Information” and the Scheme related documents available  on website (www.utimf.com) and through other sources.

In the course of using the UTI MUTUAL FUND (“UTI MF”) website or UTI MF mobile applications or any other online platform (“Online Platform”) for availing the products and services of UTI MF or UTI Trustee Company Pvt. Ltd., UTI Asset Management Company Limited (hereinafter referred as “UTI MF” / “We”/ “Us”) and its affiliates/agents/service providers may become privy to the personal information of its investors, vendors, distributors (hereinafter “Provider of Information/ Provider”), including information that is of a confidential nature.

We are strongly committed to protect the privacy of the provider of Information and have taken necessary and reasonable measures to protect the confidentiality of the customer information. This Policy (as amended from time to time) describes how we handle and deal in personal information that We may collect and retain, vide various avenues including but not limited to usage of the various services both in the physical (offline) and online/electronic mode.

Personal Information collected by us vide the physical (offline) and online/electronic mode may be converted and stored in an electronic form at our sole discretion for the purposes mentioned hereunder.

We may combine the information related to you collected on our website or through our mobile application with information collected from or about you from other sources. This may include information collected online, such as through email, or from offline sources, like information we collect when you establish your account with us or investor service. Such combined information will be treated in accordance with this policy.

This Policy shall be read with and subject to the disclaimer notified on the Website – www.utimf.com. We shall not be held liable, in any manner whatsoever, for disclosure of the confidential information when in accordance with this privacy commitment or in terms of the agreements, if any, with the Provider of Information.

It is hereby clarified that the Provider of Information shall not be covered by this Policy, if he accesses any third party links from the Online Platform of UTI MF, in which case the Provider may be subject to the policy of such third party..

By using the products and/or services provided by us (either through the Online Platform or through the physical means) including but not limited to subscribing, sending of inquiries etc., the Provider of Information expressly agree to this Policy. Further, for utilizing the services provided by us either by accessing the Online Platform or vide physical (offline) means, the Provider shall be treated as expressly giving their consent for the processing, retention and utilization of the Personal Information in accordance with this Policy and the terms hereof.

It is optional to provide the data or information. The Provider of Information shall, at any time also have an option to withdraw its consent given earlier. Such withdrawal of the consent shall be sent in writing to us. In the case of Provider of Information not providing or later on withdrawing the consent, we may not be able to provide the services/shall have the option not to provide the services for which the information was sought.

Personal Information:

The Personal Information that we collect from the Provider of Information may include information that is confidential in nature and shall mean and include any information that relates to a person, which either directly or indirectly, in combination with other information that is available or likely to be available to us, is capable of identifying the Provider of Information (“Personal Information”).

The type of Personal Information collected from the Provider and covered under this Policy shall include the following, relating to:

• Full name
• Address
• Telephone/mobile number(s)
• Permanent Account Number (PAN)
• Date of Birth
• Gender Identity
• Bank Account details, change of bank account details or registration of multiple bank accounts etc. through application forms;
• Payment instrument details at the time of submitting application at the time of investment or as proof for carrying out change of bank account or any other details of debit card obtained (if any);
• Generation and storing password (PIN) in encrypted form based on the request from the investor under the online mode of investments;
• Biometric information obtained, if any;
• Demat Account details like beneficiary account no. etc.;
• Annual Income and savings profile; and
• E-mail address
• Password (in the event of the Investor signing up for the online facilities)
• Financial information (pertaining to the investments/ applications/ transactions and any other related purposes vide which we would be providing the services to the Investors);and
• Any other information as defined under Rule 3 of the Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011, as may be required by Us from time to time in order to provide services to the Provider of Information.

Provided that, any information that is available or accessible in public domain shall not be regarded as sensitive personal data or information for the purposes of this policy. The Provider of Information herein shall have the right to approach and modify the Personal Information that has been retained with Us. Please note, that We shall not be responsible for the accuracy of the Personal Information that is being provided by the Provider of Information.

Collection of Personal Information:

Personal Information is collected and/or obtained by Us from several sources, wherein the Provider of Information has provided for the same. The information provided may include such Personal Information as a part of the application and/or enrolment process (the same maybe vide Online Platform or vide a physical application form). Additionally, We may obtain/collect the Personal Information from third-parties, or though call recordings at our Contact Centers, internet technology or any other mode of information including online portals, Automated Teller Machines etc. Such Personal Information shall also be collected from vendors/ distributors and/or any other service providers for maintenance of our records and for processing of the payments/ commissions etc.  Such information may be collected/retained including for verifying your identity, fraud prevention, or to assist us in identification of products/services that may be of interest to you. 

You provide personal information when you complete an application. If you enter information in an application, we may store the information even if you don't complete or submit the application. You also provide personal information when you request literature or a financial/non-financial transaction.

In addition to personal information you provide to us, we may receive information about you that you authorize third parties to provide to us. We also may obtain personal information from third-party service providers in order to verify your identity, to prevent fraud, or to help us identify products and services that may be of interest to you. 

UTI MF may, also call you to inform the other products or services offered by the UTI MF. The personal information may  also  be collected to be compliant with the Know Your Client (KYC) norms under the Prevention of Money Laundering Act, 2002, (PMLA), the rules issued thereunder, and guidelines and circular on Anti- Money Laundering issued by SEBI and SEBI (Mutual Funds) Regulations, 1996 as amended till date.

The aforesaid information is the basis of our ability to provide investors/clients/customers with good, qualitative, timely and efficient service, while also keeping the information and data provided totally secure and confidential.

The Provider of Information agrees and understands that the Personal Information collected by Us shall be processed, stored and used by Us, and the same may also be passed to, transmitted to and processed by our affiliates and other data processors, agents or service providers acting under a contract with Us for the purposes identified herein. Such affiliates, data processors, agents and service providers are also subject to protection and sharing of the Personal Information only for the purpose for which it was shared or with our/your consent and prohibiting use of Personal Information/data for cross marketing.

We permit the Provider of Information, as and when requested by them, to review the information they had provided and ensure that any personal information or sensitive personal data or information found to be inaccurate or deficient shall be rectified, corrected or amended as feasible, provided We shall not be responsible for the authenticity of the personal information or sensitive personal data or information supplied by the Provider of Information Us or any other person acting on behalf of Us. Further, the following rights are always available to the Provider of the Information:

1. The right to be informed: You are having the right to be informed about the processing of your Personal Information as to how it is processed and whom else the data may be passed to.

2. The right of protection and access: You have the right to the protection of Personal Information and see/access what Personal Information/data is held about you.

3. The right to update/review or rectification: You may ask Us to have your Personal Information/data updated or corrected or amended if what is held has undergone change or is incorrect in any way.

4. The right to withdraw/erasure/forget: Under certain circumstances you can ask for your Personal Information /data to be deleted. This would apply if the Personal Information /data has been unlawfully processed and/or shared.

5. The right to restrict processing: You may request for a temporary halt to processing of Personal Information/data, such as in the case where a legal case has to be concluded, or the data is being corrected.

6. The right to data portability: You have the right to ask for your Personal Information /data supplied directly to be provided to you.

7. The right to object: You have the right to object to further processing of the Personal Information /data which is inconsistent with this policy.

In case you wish to exercise any of your rights as laid down in this Policy, you may approach Us in a manner as mentioned in this Policy.

Please note that any of your rights/requests as mentioned in this Policy shall be subject to applicable obligations including laws, rules and regulations, directions of the statutory authority/regulatory body/law enforcement authorities, courts or for reporting purposes. Kindly note that We may share/report your Personal Information/data or any other information without any restriction where such sharing/reporting is in the aggregate without any specific information relating to an identifiable/you.

Please note that on exercise of such rights/requests, We may not be able to provide you the services or the services may be suspended, interrupted, delayed or may not be error free or may not be to the desired level of satisfaction.

Security Standards and Measures:

We have adopted reasonable security practices and procedures and have implemented such reasonable security practices and safeguards which are appropriate to the sensitivity of the Personal Information. These security practices and standards are consistent with generally accepted standards of commercial business practice, which includes technical, operational and physical security control measures which commensurate with the Personal Information being protected from any unauthorized access and/or disclosures while the same is with Us.

The Provider of Information, especially the investors agree and understand that trusted third parties who act on our behalf for performing of certain functions such as processing of transactions, issuing account statements etc. are under contractual obligations to ensure reasonable security safeguards commensurate to the sensitivity of the Personal Information being handled by them.

UTI MF endeavours to have suitable technical, operational and physical security controls, safeguard and ensure the security of the information provided by the Provider of Information and uses encryption technology wherever applicable, for the storage and transmission of the information, and such encryption technology is currently permitted in India. We would ensure to enter into suitable terms with third party service providers in order to protect client confidentiality and follow a non-disclosure or restricted disclosure policy.

We need to provide access to information about you to those employees/third parties who need to know the information in order to perform their work, such as servicing your accounts, providing you with information you request, or notifying you of new products and services. To protect your personal information, we maintain physical, electronic, and procedural safeguards in keeping with reasonable industry standards and practices, and we review and adjust these safeguards in response to advances in technology.

Use of Personal Information:

The Provider (s) expressly agree and understand that:

1. UTI MF may use the Personal Information of the Provider for the purposes of Processing of commercial and non-commercial transaction  of the Provider, providing him with the services to which he has subscribed and any service- related activities such as processing instructions, responding to service requests, resolve any grievances etc. The same may also be used to contact you whenever required and also to seek your feedback in relation to the offered services.
2. The Contact information (like postal address, e-mail id, mobile /phone number, etc.) may be used to contact/ send periodic information on the services or upcoming events or announcements.
3. The Personal Information may be used to generate statistics and reports for both internal use and for sharing with affiliates, intermediaries, successors, vendors, agents, service providers and advertisers. Such statistics and reports will not contain Personal Information that could identify the Provider of Information, personally.

Disclosure of Personal Information:

You agree that UTI MF may disclose the Provider’s information (other than which cannot be disclosed under applicable Indian laws, rules and regulations),

• In order to Conform to legal and/ or statutory requirements or comply with legal process;
• with statutory/regulatory authorities, Government authorities/bodies/agencies mandated under the law to obtain information including sensitive personal data or information for the purpose of verification of identity, or for prevention, detection, investigation including cyber incidents, prosecution, and punishment of offences,
• In order to protect and defend UTI MF's or its affiliates' rights, interests or property;
• In order to enforce our legal rights, terms and conditions or provisions of the offer documents of Schemes of the Mutual Fund/ Portfolio Management Services/ any other products or services which the Provider avails/intends to avail.

Sharing of Personal Information with Third Parties:

To the extent required or permitted under law, We may share the Investor’s Personal Information for the uses mentioned here with the following third parties:

• Registrar and transfer agent (s), contact centers, Payment Gateways , KYC agencies , Banks, custodians, depositories and/ or authorized external third parties who are involved in transaction processing, dispatches, etc., of investors’ investment with Us and/or who are vendors/ service providers/ distributors to whom commission is paid;
• Distributors or sub-brokers or intermediaries through whom applications are received and whose ARN number is stamped on the application form/ transaction slips;
• Any other organization for verifying the identity of investors for complying with anti-money laundering requirements;
• Any governmental & judicial authority including but not limited to the Reserve Bank of India and/ or the Securities and Exchange Board of India;,
• Certain Personal Information (Address details of the investors, Bank details of the investors, Statement of Account, Unit Holding Details) may be shared with banks, post office, depositories, local & international courier service providers, agents and other intermediaries for correspondence with the Provider of Information and for making payments to the Provider by cheques, drafts, warrants, through electronic clearing services, NEFT etc.

We will  advise the third parties, to take reasonable and appropriate steps to  maintain the required level of data protection in respect of the Personal Information.

The Personal Information so collected shall be communicated to third parties / third persons only for the reasons consistent with the purposes for which such Personal Information was originally collected or such purposes as authorized by law.

Nevertheless, it is our foremost endeavor to ensure that the Provider’s Privacy is protected at all points in time. The investors/customers/clients (whether existing/prospective) must ensure to recheck the information or data being provided to the UTI MF/UTI AMC or any person acting on its behalf. Incase if any of the data/information is found to be inaccurate or incorrect, the same should be informed to the UTI MF /UTI AMC for immediate amendment. The UTI MF/UTI AMC and any person acting on its behalf shall not be responsible for the authenticity of the personal information or sensitive personal data or information supplied by the customers/clients (whether existing/prospective).

Direct Marketing:

Any, non-personally identifiable visitor information may be provided to the third parties for marketing, advertising, or other uses however Personal Information shall not be shared for direct marketing without the express permission of the Provider of Information.

Retention of Personal Information:

We may retain Provider’s Personal Information for as long as required to provide our services to the Provider of Information or otherwise if required under laws, rules or regulations.

Breach of Internet Security:

In addition to the efforts of UTI MF for the protection of the Personal Information, it is important that the Provider of Information should co-operate with UTI MF for the security of the Personal Information. It is recommended that the Providers, especially the investors should necessarily choose their passwords carefully and change them periodically, that no unauthorized access is made by any third party and not to disclose the confidential information, OTP etc. to any one and or keep a record of the same in writing.

The information and cyber security is continuously evolving arena. There are risks involved in availing the online services viz. risks of hacking, fraud, presenting inaccurate information etc. You may, if so required, seek independent advice to assess the various risks involved. By availing the online services, you voluntarily and consciously agree to the risks involved. Despite best efforts, if unauthorized persons breach the security control measures resulting in the website being hacked etc., UTI Mutual Fund, UTI Asset Management Company, UTI Trustee Company Private Limited, it’s directors, officers, employees or affiliates’, agents, service providers etc. will not be responsible in any manner whatsoever.

Incidental Information :

Cookie Policy:

When you visit our Online Platform, We may use cookies, which are small pieces of information that allow Us to maintain your connection to our Website. The Online Platform may use cookies for detecting what kind of device you have in order to present content in the best way, for a language switch and/or for other purposes. These cookies do not contain, collect or store any Personal Information and the visitor including the Provider of Information can refuse the use of cookies. By using our website and agreeing to these terms of use, you consent to our use of cookies in accordance with the terms of our policy.

Website Analytics:

The website (www.utimf.com) and a web analytics service (which may be used by Us) uses cookies to help the Website operators analyse how users use the Website. The information generated by the cookie about the visitors’ use of the Website (including the IP address) will be transmitted to and stored as part of the normal operation of services. Also, information may be supplied to the owners or operators of third party websites from which it is possible to link to our Website with information relating the number of users linking to our Website from such third party websites. The information shared shall be non- personally identifiable information. 

All such incidental information will be used only to assist Us in providing an effective service on the Website.

We shall reveal only such information to external authorities as may be found relevant and necessary in order to comply with the applicable laws of the land and to third party service providers to ensure smooth functioning of the activities as may be prescribed under applicable laws like Registrar and Transfer Agents/distributors/banks/sub-brokers/call-centers/custodians/depositories and such other entities/persons. By using our website or by agreeing to transact with us, you agree to the above sharing of information during your relationship with us. We may also be required from time to time to disclose investors/customers/clients  personal information to governmental or judicial bodies or agencies or our regulators based on their requirement to comply with the applicable laws including cyber laws. In addition to the above, we may also use the information shared by investors/clients/customers to contact investors/clients/customers regarding the products and services offered by us and seek feedback on the services provided. Further, such information may also be used by us to generate statistics and reports and/or to protect and defend the rights, interest and property of the Mutual Fund, AMC, Trustee Company, Sponsors & its affiliates and directors and/or to enforce legal rights or provisions of the Scheme related Documents of the Mutual Fund viz. Scheme Information Document (SID), Statement of Additional Information (SAI) and Key Information Memorandum (KIM). Further, it may be noted that Internet Protocol (IP) addresses, browser supplied information and site session information may be recorded as part of the normal operations and for security monitoring purposes.

Your Safety:

For your protection, you should not provide/share your account information, user-name, or password, OTP or any other sensitive information to anyone. If you become aware of any suspicious activity relating to your account with UTI, or if you wish to exercise any of your rights or any other matter concerning this Policy, you should contact us immediately to assist you.

Mr. Vivek Maheshwari, CRO; Telephone Number: 022 66786686 Email: vivek.maheshwari@uti.co.in

Mr. Sanjivan Shirke, CISO, Telephone Number: 022 66786210; Email: Sanjivan.shirke@uti.co.in

Ms. Madhavi Dicholkar; Telephone Number: 022 66786407; Email : safetyforyou@uti.co.in

If you have any questions or concerns relating to this policy, please do not hesitate to write to  us  at e mail ID <service@uti.co.in>

Grievance Redressal:

Any grievance relating to your Personal Information including any concern/issue regarding this policy concerning you may be addressed to service@uti.co.in

We shall address any requests/discrepancies and grievances of the Provider of the Information including with respect to processing of information in a time bound manner.

The name and contact details of the Grievance Officer are as under:

Name : Madhavi Dicholkar Telephone Number: 022 66786407 Email :  safetyforyou@uti.co.in

The Grievance Officer shall redress the grievances of Provider of Information expeditiously but in any case within one month from the date of receipt of grievance.

Investors/ Customers/ Clients shall not be covered by the terms of this Policy if they access other websites using links from this website.

Further, despite our efforts to protect investors/customers/clients privacy, if unauthorized persons breach security control measures and illegally use such sensitive/personal data or information, the Mutual Fund, AMC, Trustee Company, Sponsors and its affiliates and directors shall not be held responsible/liable.

This Policy is a lawful contract and is supplemental to the terms and conditions agreed to between Us and the Provider and is subject to the applicable Indian laws, rules and regulations that have been enacted in this regard. In case of any conflict, including due to any amendments, the applicable Indian laws, rules and regulations shall prevail. UTI MF/UTI AMC reserves the right to update or amend this Policy from time to time and the Providers of Information are advised to visit this page regularly in order to view the same.  No Provider or any other person shall have any right or benefit under any other laws, rules or regulations other than Indian laws, rules or regulations.

By accessing or availing the services/website or provide any information while transacting with us, the Provider/other persons expressly agree to the terms of this Policy.