Welcome To GULAQ, a portal operated by Estee Financial Services Pvt. Ltd. (hereinafter referred to as “EFSPL”) Formerly Estee Commodities Pvt. Ltd ( hereinafter referred to as “ECPL”), referred to as the “Company”, incorporated in India under the Companies Act, 2013. Company presently has its registered office at 7th Floor, A- block, Sohna Road, Vatika Business Park, Sector 49, Gurgaon -122 001, Haryana, India .
Estee Advisors Pvt Limited (hereinafter referred to as “EAPL”) is registered with the Securities and Exchange Board of India as Stock Broker with registration number INZ000170130 and registered with BSE Star with code 24408 for mutual fund transaction facility, offers services related to investments such as tracking and investing in mutual funds, stocks, etc. The User agrees and understands that the execution service in respect of mutual funds provided on the Website/App are only with respect of select mutual fund schemes as determined by EAPL from time to time.
The EFSPL and EAPL are group companies and EAPL is authorized to provide its services to the Users on the Website/App under a Sub-distribution agreement with EFSPL.
- Section 43A of the Information Technology Act, 2000; and
- Regulation 4 of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information) Rules, 2011 (the “SPI Rules”) “Personal Information” and “Sensitive personal data or information” shall be as defined under the SPI Rules. The information about the Users as collected by Company is:
- information supplied by Users and
- information automatically tracked while navigation (Information).
By using Company’s Website or its services, you consent to collection, storage, and use of the Personal Information you provide (including any changes thereto as provided by you) for any of the services that we offer. To avail certain sites/ services on our Websites, Users may be required to provide certain information for the registration process that may include but not limited to:-
- your name,
- email address,
- PIN code,
- Bank Detail,
- password etc., and / or your occupation, interests, and the like.
Company presumes adequate and lawful parental consent in case the Personal Information is shared by a User under the age of 18 years. The information as supplied by the Users enables us to improve our Website and provide you the most user-friendly experience. All required information is service dependent, and Company may use the above said User information to, maintain, protect, and improve its services (including advertising services) and for developing new services. Such information will not be considered as sensitive if it is freely available and accessible in the public domain or is furnished under the Right to Information Act, 2005, any rules made there under or any other law for the time being in force. The primary reason for gathering information is to improve our products, deals, services, website content and navigation.
To improve the responsiveness for our Users, we may use “cookies”, or similar electronic tools to collect information to assign each User a unique, random number as a User Identification (User ID) to understand the User’s individual interests using the identified computer. Unless you voluntarily identify yourself (through registration, for example), we will have no way of knowing who you are, even if we assign a cookie to your computer. The only Personal Information a cookie can contain is information you supply. A cookie cannot read data off your hard drive. Our advertisers may also assign their own cookies to your browser (if you click on their ads), a process that we do not control. We receive and store certain types of information whenever you interact with us via Website, application or service though your computer/laptop/netbook or mobile/tablet/pad/handheld device etc.
If a User opts out using the Ads Settings, the unique Double Click cookie ID on the User’s browser is overwritten with the phrase “OPT_OUT”. Because there is no longer a unique cookie ID, the opt-out cookie can’t be associated with a particular browser.
Log File Information
We automatically collect limited information about your computer’s connection to the Internet, mobile number, including your IP address, when you visit our Website, application or service. Your IP address is a number that lets computers attached to the Internet know where to send you data — such as the pages you view. We automatically receive and log information from your browser, including your IP address, your computer’s name, your operating system, browser type and version, CPU speed and connection speed. We may also collect log information from your device, including your location, IP address, your device’s name, device’s serial number or unique identification number (e.g. UDiD on your iOS device), your device operating system, browser type and version, CPU speed, and connection speed etc.
Information from other Sources
Demographic and User Behaviour
We may refer other sources of demographic and other information in order to provide you with more targeted communications and promotions. We use Google Analytics among others, to track the User Behaviour and derive product related insight for our Website/Mobile application in order to facilitate better services to the respective User. Google Analytics specifically has been enable to support display advertising towards helping us gain understanding of our Users’ Demographics and Interests. If you don’t want Analytics to be used in your browser, you can install the Google Analytics browser add-on.
Links to Third Party Sites / AD-Servers
We take utmost care our user’s Personal Information and/or Sensitive Personal information and we share user’s personal information with our employees and third-party facilities providers on strictly on a “need to know” basis hence we take all such steps to ensure that electronic records are valid under the Information Technology Act, 2000 as amended from time to time and notifications and rules framed thereunder.
Company may share the sensitive Personal Information to any third party/Service Provider/Alliance Partner without obtaining the prior consent of the User in the following limited circumstances:
- When it is requested or required by law or by any court or governmental agency or authority to disclose, for the purpose of verification of identity, or for the prevention, detection, investigation including cyber incidents, or for prosecution and punishment of offences. These disclosures are made in good faith and belief that such disclosure is reasonably necessary for enforcing these Terms and Conditions; for complying with the applicable laws and regulations.
- Company may use third-party advertising companies and/or within group companies to serve ads when the User’s visits the Website. These companies may use Personal Information about the User’s visit to the Website and other websites in order to provide advertisements about goods and services of interest to the User.
- Company shall transfer information about the User in case Company is acquired by or merged with another company.
- Company may share the personal information with the Service Provider, in case the User shows interest in applying for User.
Accessing and Updating Personal Information
When you use Company’s Websites, we make good faith efforts to provide you, as and when requested by you, with access to your Personal Information and shall further ensure that any Personal Information or sensitive personal data or information found to be inaccurate or deficient shall be corrected or amended as feasible, subject to any requirement for such Personal Information or sensitive personal data or information to be retained by law or for legitimate business purposes. We ask individual Users to identify themselves and the information requested to be accessed, corrected or removed before processing such requests, and we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backup tapes), or for which access is not otherwise required. In any case where we provide information access and correction, we perform this service free of charge, except if doing so would require a disproportionate effort. Because of the way we maintain certain services, after you delete your information, residual copies may take a period of time before they are deleted from our active servers and may remain in our backup systems.
Retention of Data
As Per PMLA (Prevention of Money Laundering Act 2002) guidelines and Securities and Exchange Board of India (Investment Advisers) Regulations, 2013 records need to be maintained for a period of up to 10 years from the closer / deletion of account. In the event of any legal / regulatory proceeding is the pending we can retain records for a longer period as may be asked by regulatory / statutory authorities.
EFSPL and EAPL may keep its records of the Electronic Instructions/transactions in any form as permitted under applicable Laws. In this regard, all records, whether in electronic form, magnetic form, documents or any other form with respect to Electronic Instructions/online transactions shall be conclusive evidence of such instructions/transactions and shall be binding on the User (jointly and severally, in case the mode of holding is ‘Anyone or Survivor’). The User shall not request/demand any evidence or proof for the transactions undertaken through the internet and the audit trail of the log-in would be conclusive proof to establish the bona fides of the transactions. In the event of any dispute, EAPL/BSE Star/ AMC’s records shall be binding as conclusive evidence of the transactions carried out through the electronic mode.
Redressal Mechanism: Any complaints, abuse or concerns with regards to content and or comment or breach of these terms shall be immediately informed to the designated Grievance Officer as mentioned below via in writing or through email signed with the electronic signature to.
Mr. Rishabh Garg (Director Marketing)
Address: Estee Financial Services Pvt. Ltd. ,
7 th Floor, A Block, Vatika Business Park,
Sohna Road, Sector 49, Gurgaon-122001
We request you to please provide the following information in your complaint:-
- A physical or electronic signature of a person authorized to act on behalf of the copyright owner for the purposes of the complaint.
- Identification of the copyrighted work claimed to have been infringed.
- Identification of the material on our Website that is claimed to be infringing or to be the subject of infringing activity.
- The address, telephone number or e-mail address of the complaining party.
- A statement that the complaining party has a good-faith belief that use of the material in the manner complained of is not authorized by the copyright owner, its agent or the law.
- A statement, under penalty of perjury, that the information in the notice of copyright infringement is accurate, and that the complaining party is authorized to act on behalf of the owner of the right that is allegedly infringed.