Privacy Policy

Introduction

Altcase and the Altcase mobile application are products of Alt-Alpha Broking Private Limited ("Altcase", "Company", "we", "our" or "us"). Altcase is committed to protecting the privacy, confidentiality, and security of the information entrusted to it by its clients, users, visitors, and prospective clients ("Users").

This Privacy Policy sets out the manner in which Altcase collects, receives, stores, processes, uses, shares, discloses, retains, and protects information obtained through its website ("Website"), mobile applications, and services, including research-related services provided in compliance with applicable laws and regulations, including the Securities and Exchange Board of India ("SEBI") (Research Analysts) Regulations, 2014, as amended from time to time.

By accessing or using the Website, mobile application, or services, Users acknowledge that they have read, understood, and agreed to the terms of this Privacy Policy.

Acceptable Use of Website and Services

While accessing or using the Website and/or Services, Users shall comply with all applicable laws and regulations and shall refrain from engaging in any activity that may adversely affect Altcase, its systems, services, users, or any third party.

The User agrees that he/she shall not:

• Reverse engineer, reproduce, modify, distribute, copy, exploit, or commercially utilize any portion of the Website or Services without prior written authorization from Altcase.
• Represent themselves as an agent, representative, partner, or reseller of Altcase without authorization.
• Misrepresent their identity or impersonate any other individual or entity.
• Upload, publish, transmit, share, modify, or store any content or information that: belongs to another person and to which the User has no lawful right; infringes intellectual property rights or proprietary rights of any third party; is false, misleading, deceptive, fraudulent, or intended to mislead recipients regarding its origin; threatens India's sovereignty, integrity, security, defence, public order, or friendly relations with foreign states; promotes unlawful activities or facilitates the commission of any offence; or contains knowingly false information intended to harass, defraud, or cause injury to any person or entity.
• Upload, transmit, or distribute any unlawful, defamatory, obscene, vulgar, abusive, invasive, harmful, or privacy-violating content.
• Use the Website or Services for any illegal purpose, including fraud, money laundering, market manipulation, misrepresentation, or other unlawful activities.
• Engage in activities that may compromise the security, performance, availability, or integrity of the Website or Services, including unauthorized access attempts, cyberattacks, malware distribution, denial-of-service attacks, or similar activities.
• Violate any applicable law, regulation, circular, direction, or guideline issued by any competent authority.

All intellectual property rights, proprietary content, research materials, trademarks, logos, reports, software, and other materials available through the Website or Services shall remain the sole and exclusive property of Altcase or its licensors.

The User represents and warrants that they possess the legal capacity and authority to enter into and comply with the terms of this Privacy Policy and the applicable Terms and Conditions.

User Consent

Consent — By accessing the Website or availing the Services, the User expressly consents to the collection, processing, storage, use, and disclosure of personal information in accordance with this Privacy Policy and the applicable Terms and Conditions.

Withdrawal of Consent — A User may withdraw consent by submitting a written request to support@altcase.com. The User acknowledges that withdrawal of consent may result in suspension, restriction, or discontinuation of certain services where such information is necessary for service delivery, compliance, regulatory obligations, or client onboarding requirements.

Upon receipt of a valid withdrawal request, Altcase may, subject to applicable legal and regulatory requirements, delete, anonymize, or de-identify the information retained by it.

Amendments to the Privacy Policy — Altcase reserves the right to modify, amend, update, or replace this Privacy Policy at any time to reflect changes in applicable laws, regulatory requirements, business practices, or services. Any revised version shall become effective upon publication on the Website or application. Continued use of the Services following such publication shall constitute acceptance of the revised Privacy Policy.

Information Collected from Users

Altcase may collect information directly from Users, including but not limited to:

• Name and contact details, including mobile number and email address.
• Information submitted through enquiries, feedback forms, surveys, complaints, or support requests.
• Demographic information such as age and location.
• Information required during onboarding with brokers, research service providers, investment advisers, or other authorized partners.
• Information submitted for employment applications, internship applications, or other engagement opportunities.
• Financial information, investor profile information, risk appetite, investment preferences, and related information required for service customization and suitability assessments.
• Any additional information voluntarily provided by Users.

Users are responsible for ensuring that all information furnished to Altcase is accurate, complete, and up to date. Altcase shall not be responsible for any loss, liability, or consequence arising from inaccurate, incomplete, or outdated information provided by the User.

Information Collected Through Technology

When Users access the Website, platform, or mobile application, Altcase may automatically collect certain information, including:

• Internet Protocol (IP) address;
• Browser type and version;
• Device information;
• Operating system;
• Date and time of access;
• Website usage patterns and preferences;
• Domain name and related technical information.

Altcase may engage third-party technology service providers, analytics providers, or cloud service providers to assist in analyzing usage patterns, improving functionality, enhancing user experience, and maintaining platform security. Such service providers may use cookies or similar technologies to perform these functions on behalf of Altcase.

Purpose of Collection and Use of Information

Personal Information collected by Altcase may be used for the following purposes:

• Verification of User identity.
• Providing access to products, services, and research-related offerings.
• Account administration and management.
• Compliance with applicable legal, regulatory, contractual, and risk-management requirements.
• Client onboarding and suitability assessment processes.
• Enhancing the quality, functionality, and security of the Website and Services.
• Responding to enquiries, requests, complaints, and support queries.
• Delivering service-related communications, alerts, notifications, and updates.
• Conducting surveys, market research, analytics, and customer feedback initiatives.
• Preventing, detecting, investigating, and addressing fraud, abuse, unauthorized access, cyber threats, or unlawful activities.
• Internal monitoring, audits, and regulatory reporting.
• Marketing communication regarding products and services, where permitted by applicable law.

Disclosure of Information

Altcase may disclose personal information to:

• Regulatory authorities, statutory bodies, government agencies, law enforcement authorities, courts, tribunals, SEBI, stock exchanges, RAASB, or any other authority where disclosure is required under applicable law.
• Affiliates, group entities, and authorized service providers engaged for operational, technological, administrative, communication, compliance, audit, or support functions.
• Professional advisers, auditors, consultants, or legal counsel, where necessary.

Such disclosure shall be made only for legitimate business, legal, regulatory, contractual, or operational purposes and subject to appropriate confidentiality obligations wherever applicable.

Anonymized and Aggregated Information

Altcase may create anonymized, aggregated, or de-identified data derived from personal information after removing identifiers capable of identifying an individual. Such anonymized information may be used for:

• Statistical analysis;
• Service enhancement;
• Product development;
• Business intelligence;
• Research and analytics; and
• Other lawful purposes.

Since such information does not identify any individual, Altcase may use or disclose such information without restriction, subject to applicable laws.

Third-Party Websites

The Website or Services may contain links to third-party websites, applications, or services. Once a User accesses any third-party platform, Altcase shall not be responsible for the privacy practices, content, policies, security measures, or data collection activities of such third parties. Users are advised to review the privacy policies of such third-party websites independently.

Cookies and Similar Technologies

Altcase may use cookies, tags, pixels, web beacons, and similar technologies to:

• Improve Website functionality;
• Enhance user experience;
• Remember user preferences;
• Monitor platform performance;
• Conduct analytics and security monitoring.

Users may manage cookie preferences through their browser settings. However, disabling cookies may affect certain functionalities of the Website or Services.

Information Security

Altcase maintains reasonable administrative, technical, operational, and physical safeguards designed to protect personal information against unauthorized access, disclosure, alteration, misuse, loss, or destruction. Altcase implements security measures that are commensurate with the nature of its business operations, regulatory requirements, and industry practices.

While Altcase endeavors to protect personal information using commercially reasonable safeguards, no system can guarantee absolute security. Accordingly, Altcase shall not be liable for unauthorized access resulting from circumstances beyond its reasonable control, including cyberattacks, force majeure events, or other unlawful acts by third parties.

Retention of Information

Altcase shall retain personal information only for as long as necessary to:

• Fulfil the purposes for which it was collected;
• Provide services to Users;
• Comply with applicable legal, regulatory, tax, accounting, audit, and record-retention requirements; and
• Protect its legal rights and interests.

Information may be retained for such period as may be prescribed under applicable laws, SEBI regulations, circulars, and other regulatory requirements.

Amendments and Updates

This Privacy Policy may be amended, revised, or updated from time to time. The latest version shall always be available on the Website and shall supersede all earlier versions. Users are advised to review this Privacy Policy periodically to remain informed of any updates.

Contact Information

For any questions, concerns, requests, or grievances relating to this Privacy Policy or the processing of personal information, Users may contact:

Alt-Alpha Broking Private Limited — Grievance Redressal Officer (GRO)

• Address: 4th Floor, Innov8, Shubhash Nagar Road, Navpada, Netaji Subhash Nagar, Vile Parle (E), Mumbai, Maharashtra 400057
• Phone: +91 95940 66336
• Email: madhu@altcase.com

Definitions

Anonymous Information means information that does not directly or indirectly identify, and cannot reasonably be used to identify, an individual.

Internet Protocol (IP) Address means a unique numerical identifier assigned to a device connected to a network and used for communication over internet-based networks.

Personal Information means any data or information relating to an identifiable natural person, which either directly or indirectly, alone or in combination with other information available, is capable of identifying such individual.