Privacy · Marathon Trends

Marathontrends Advisory Pvt Ltd (“Marathontrends”, the “Company”, “we”, “us”), a SEBI-registered Portfolio Manager (Registration No. INP000005722), respects the privacy and confidentiality of its clients, prospective clients and website visitors (“you”, “your”). This Client Personal Information Protection Policy (the “Policy”) describes how we collect, use, retain, protect, disclose and dispose of your personal and non-public information when you access www.marathontrends.com (the “Website”) or avail our products and services.

By accessing the Website or availing our services, you consent to the practices described in this Policy. If you do not agree with this Policy, please do not use the Website.

1. Information we collect and retain

1.1 We collect and retain personal and non-public information relating to you, including but not limited to your name, address, mobile number, email address, date of birth, PAN, bank account details, investment profile, risk profile score, transaction history and KYC documentation, to the extent required to:

(a) provide, administer and improve our products and services, and better assist you with your needs;
(b) comply with our obligations under applicable law, including SEBI regulations, the SEBI (Portfolio Managers) Regulations, 1993, the Prevention of Money Laundering Act, 2002 and the rules and guidelines issued thereunder; and
(c) comply with professional, regulatory, record-keeping and audit requirements.

1.2 We retain client records for the periods prescribed under applicable SEBI regulations and other applicable laws, and not longer than is reasonably necessary for the purposes stated above, unless a longer retention period is required or permitted by law.

2. Protection of your information

2.1 We maintain physical, electronic and procedural safeguards designed to protect your non-public personal information, consistent with the requirements of applicable Indian law, including the Digital Personal Data Protection Act, 2023 and SEBI guidelines on cybersecurity and data protection.

2.2 We protect the confidentiality of your name, mobile number, address and email ID, and treat all such information as non-public personal information. We prohibit the unlawful disclosure of your data and limit access to your data in the same manner as we protect all other non-public personal information.

2.3 Documents and records containing your non-public personal information are safeguarded and are not disclosed to any person unless:

(a) you have authorized such disclosure;
(b) disclosure is required by law, regulation, or by SEBI, RBI, the Income Tax authorities, or any court, tribunal or statutory authority; or
(c) disclosure is required to our service providers strictly for the purpose of providing our services to you, subject to Clause 5 below.

2.4 We restrict access to client data to only those employees, officers and representatives who are involved in offering, administering and supporting our products and services, and who require such access in the course of their duties.

2.5 We train our employees and representatives on the importance of maintaining confidentiality, data protection and customer privacy, and we impose strict confidentiality obligations on all persons with access to client data.

2.6 Upon expiry of the applicable retention period, we destroy, erase or render unreadable all documentation and records containing your personal information prior to their disposal, in a secure manner consistent with industry practice.

2.7 We continuously monitor, review and update the safeguards described in this Policy and make adjustments as necessary to maintain the security of your information.

3. How we protect your information (technical safeguards)

3.1 Our Website is scanned on a regular basis for security vulnerabilities and known threats in order to make your visit as safe as possible.

3.2 We use regular malware scanning and updated security software.

3.3 Your personal information is stored behind secured networks and is accessible only by a limited number of authorized persons with special access rights who are required to keep the information strictly confidential. In addition, all sensitive information and payment details you supply are encrypted using Secure Socket Layer (SSL) / transport layer security technology.

3.4 We implement a variety of security measures — including access controls, authentication procedures and activity logging — when a user enters, submits or accesses their information, to maintain the safety of your personal information.

3.5 Notwithstanding the above, no method of transmission over the internet or electronic storage is completely secure. While we strive to use commercially acceptable means to protect your information, we cannot guarantee its absolute security, and you acknowledge and accept this risk.

4. Use of cookies

4.1 We employ the use of cookies. By using the Website, you consent to the use of cookies in accordance with this Policy. Cookies are used in some areas of our site to enable functionality and improve ease of use.

4.2 You are advised that no personally identifiable information (such as your name or address) is gathered or stored in the cookies placed by the Website, and consequently none can be passed on to any third party. Most web browsers automatically accept cookies; you may control or block cookies through your browser settings, though some features of the Website may not function properly if cookies are disabled.

5. Third-party disclosure

5.1 We do not sell, trade, rent or otherwise transfer your Personally Identifiable Information to outside parties unless we provide you with prior notice and, where required by law, obtain your consent.

5.2 The foregoing does not apply to trusted third parties who assist us in operating the Website, conducting our business or serving you — including website hosting partners, technology providers, payment gateways, KYC and verification agencies, SMS and communication vendors, and courier/logistics providers — provided such parties agree to keep your information confidential and use it solely for the purposes for which it was shared.

5.3 We may disclose your information, without prior notice, where such disclosure is required to:

(a) comply with applicable law, regulation, SEBI/RBI directions or a valid order of a court or statutory authority;
(b) enforce our Website policies or agreements with you; or
(c) protect the rights, property or safety of the Company, our users, clients or others.

5.4 Notwithstanding the above, we may share aggregated, anonymized or non-personally identifiable visitor information with third parties for marketing, advertising, analytics or other lawful uses.

5.5 Our Website may contain links to third-party websites. We are not responsible for the privacy practices or content of such third-party websites, and we encourage you to review their respective privacy policies.

6. Communications

By providing your contact details, you consent to receiving calls, SMS messages (including on DND-registered numbers) and emails from us or our vendors for transactional, informational, service-related and promotional purposes, as described in the Terms of Use. You may withdraw this consent at any time by writing to us at the contact details below; however, certain transactional communications necessary for the provision of services may continue.

7. Your rights

Subject to applicable law, you may have the right to:

(a) access, review and correct your personal information held by us;
(b) withdraw consent to the processing of your personal information (without affecting the lawfulness of processing already carried out); and
(c) raise grievances regarding the handling of your personal information.

Requests may be made in writing to the contact details provided below. We will respond within the timelines prescribed under applicable law.

8. Changes to this policy

We reserve the right to modify this Policy at any time. Any changes will be posted on this page with an updated revision date. Continued use of the Website after such changes constitutes your acceptance of the revised Policy. We encourage you to review this page periodically.

9. Governing law and grievance contact

This Policy is governed by the laws of the Republic of India, and any dispute arising herefrom shall be subject to the exclusive jurisdiction of the courts at Mumbai, Maharashtra.

Grievances or requests under this Policy may be addressed to service@marathontrends.com, or by post to the registered office shown alongside.