# Privacy Policy (I) Confidential Relationship The terms and conditions of this contract, and all information and recommendations furnished by Manifesting Millennials Private Limited (“Sure Sampatti”) to the User and/or its Trustee/Trustees, shall be treated as confidential by the parties, and shall not be disclosed to third parties except as provided for in herein and except as required by applicable laws, Rules or Regulations, and in response to appropriate requests of regulatory authorities, or as otherwise expressly agreed to in writing by the parties. However, Sure Sampatti shall be entitled to disclose the information relating to the financial asset of the User to the Trustee/Trustees. Sure Sampatti shall be entitled to disclose the information relating to the financial asset of the User to the legal heirs of the User upon the demise of the User at its sole discretion. (II) Personal and third party data, confidentiality and credit reference and Fraud Prevention Agencies 1.1 Sure Sampatti will treat all information of the User and/or its Trustee/Trustees as private and confidential (even when he/she/it is no longer the User). 1.2 Nothing about Sure Sampatti, the User and/or its Trustee/Trustees relationship or the User and/or its Trustee/Trustees’ name and address will be disclosed to any third party without the User and/or its Trustee/Trustees’ permission, unless: Sure Sampatti is legally compelled or it is the public interest to do so; or it is in Sure Sampatti ’s interests to do so (e.g. to protect Sure Sampatti from or to recover loss); or it is for any of the purposes specified elsewhere of in this Agreement or otherwise in connection with this Agreement, or with any of its group companies to enhance the service level to cross sell any of its products and/or services. 1.3 Members of Sure Sampatti and other companies may use the record of credit searches and any other information held by the agencies if credit decisions are made about the User and/or its Trustee/Trustees, or other members of his/her household or any associate. Any of this information may also be used for identification purposes, debt tracing and the prevention of money laundering as well as the management of the User and/or its Trustee/Trustees account. 1.4 To prevent or detect fraud and to assist in verifying the User and/or its Trustee/Trustees identity, Sure Sampatti may exchange information with other members of Sure Sampatti and make searches of records held at fraud prevention agencies who will supply such information. Sure Sampatti may also pass information to financial and other organizations involved in fraud prevention to protect itself and its customers from theft and fraud. If false or inaccurate information is provided and Sure Sampatti suspects fraud, Sure Sampatti will record this. 1.5 Members of Sure Sampatti may record, use, exchange, analyse and assess relevant information held about the User and/or its Trustee/Trustees and his/her/its relationships with other members of Sure Sampatti, including nature of the transactions, for credit assessment, market research, insurance claims and underwriting purposes and in servicing the User and/or its Trustee/Trustees relationships with Sure Sampatti. This may include any information provided by the User and/or its Trustee/Trustees or someone acting on his/her/its behalf about the User and/or its Trustee/Trustees, which is relevant to the relationship with Sure Sampatti. Relevant information may be used or disclosed as part of the disposal or reorganization or the granting of security interests or encumbrances over the whole or any part of Sure Sampatti/an associate’s business or assets or the transfer or securitization of any rights or obligations. Relevant information may also be exchanged with Sure Sampatti if required by appropriate governmental and non-governmental regulators or ombudsmen. Sure Sampatti may also be obliged to disclose information to other third parties outside Sure Sampatti where any part of Sure Sampatti is required to disclose to any governmental or judicial bodies or agencies or regulators in any jurisdiction throughout the world including the SEBI. Sure Sampatti aims to keep the User and/or its Trustee/Trustees information up-to-date. Wherever it is processed, the User and/or its Trustee/Trustees information will be protected by a strict code of secrecy and security, which all members of Sure Sampatti, their staff and any third parties are subject to and will only be used in accordance with Sure Sampatti instructions. 1.6 To ensure that the User and/or its Trustee/Trustees instructions are carried out accurately, to help Sure Sampatti improve its services continually and in the interests of security, Sure Sampatti may monitor and/or record telephone calls and e-mail communications between the Parties. 1.7 To ensure compliance with the guidelines in respect of prevention of money laundering and in furtherance of the Know Your Customer policy Sure Sampatti may require the User and/or its Trustee/Trustees to submit appropriate proofs of identification, provide other information relating to the User and/or its Trustee/Trustees funds and may also need to make and retain photocopies of such proofs including of passports, driving licenses, other identification evidence or any information provided by the User and/or its Trustee/Trustees. 1.8 If Sure Sampatti receives a request from another financial services institution to verify the User and/or its Trustee/Trustees identity for money laundering prevention purposes, such information may be provided without reference to the User and/or its Trustee/Trustees. 1.9 The User and/or its Trustee/Trustees confirms that he/she/it has read and understands and agrees to the processing of information as described above. Subject to applicable law, individuals may have the right to request access to personal data and require personal data to be corrected if inaccurate in certain circumstances. The User and/or its Trustee/Trustees acknowledges and agrees (on his/her/its own behalf and duly authorized on behalf on any third party whose details have been supplied) that the processing (including disclosure) of information described above is necessary or desirable for the provision of relevant services and the operation of Sure Sampatti business or performance of its rights and obligations owed to the User and/or its Trustee/Trustees or a third party. 1.10 Sure Sampatti will treat all information of the User and/or its Trustee/Trustees as private and confidential (even when he/she/it is no longer the User The User and/or its Trustee/Trustees further agrees and understands that Sure Sampatti shall not be responsible for the misuse or exploitation of the information/ data/ confidential information which he/ she/ it has provided to Sure Sampatti under this Agreement. 1.11 Parties are subject to and will only be used in accordance with Sure Sampatti instructions. 1.16 The User and/or its Trustee/Trustees further agrees and understands that Sure Sampatti shall not be responsible for the misuse or exploitation of the information/ data/ confidential information which he/ she/ it has provided to Sure Sampatti under this Agreement.