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Privacy

Last Update: 10 July 2025

1. BACKGROUND AND APPLICABILITY

Capworks Investment Manager India Private Limited (“Company” or “We” or “Our” or “Us”) maintains the website https://www.rmb.co.in/. This privacy notice (“Privacy Notice”) applies in respect of all Personal Information collected by Us from users, visitors and others (hereinafter referred to as “User” and also indicated by “you” or “your”) who access or use the website, submit any information to Us or who avail the services from Us, including through any third-party application. We respect your privacy and therefore limit the collection, processing, storage and sharing of Personal Information (as defined hereinafter) to that which is required and appropriate for the purposes approved by you, or for Our legitimate interest or any legal requirement.

We have developed this Privacy Notice to enable Our customers to understand how We collect, use, disclose, share, safeguard and otherwise process their Personal Information.

This Privacy Notice is in addition to the applicable law and in case of any contradiction between this Privacy Notice and applicable law, the provisions of applicable law will prevail at all times.

Access to and the use of the website and availing of the services is subject to this Privacy Notice. It is important that you read the Privacy Notice carefully because by accessing the website or availing the services, you shall be deemed to have agreed to all the terms and conditions of this Privacy Notice and have authorized us to collect, process and share the Personal Information as provided in this Privacy Notice, subject to any applicable law. However, We endeavour, as and when practicable or required by applicable law, to seek specific and explicit consent for collection, processing, storage and sharing of your Personal Information.

We collect Personal Information about Our customers. This includes what customers tell Us about themselves, what We learn by having a customer or when a customer makes use of a solution, as well as the choices customers makes about the advice provided.

In terms of general data privacy and protection principles, this Privacy Notice may also apply on behalf of other third parties (such as authorised agents and contractors), acting on Our behalf when providing You with solutions. If We process Personal Information for another party under a contract or a mandate, the other party’s privacy policy or notice will be applicable on You.

 

This Privacy Notice helps you to understand:

 

  • The type of data or information which relates to an identified or identifiable person, including sensitive personal data, (“Personal Information”) collected by us;

  • The purpose of collection, the manner of collection, storage, and processing of such Personal Information;

  • The person with whom such Personal Information is shared and the manner in which they may process such Personal Information;

  • Your rights and obligations in respect of such Personal Information.

 

The Company may combine customers’ Personal Information and use the combined Personal Information for any of the purposes stated in this notice.

 

In the course of availing the services or accessing the platforms, you may also be accessing or may be redirected to the websites, or apps of third parties, who may collect Personal Information for their own purposes or for providing you other services. This Privacy Notice does not govern Personal Information collected by any such third-party, even though their website, may be linked to Our website. While We restrict the manner and extent to which We share your Personal Information with third parties and provide appropriate safeguards in Our contractual arrangements with such third parties, We will not be liable or responsible in any manner for any Personal Information collected and processed by such third parties. We advise that you understand and comply with privacy policies applicable to such third-party websites.

 

NOTE: We may change this Privacy Notice from time to time if required under applicable law or Our business practices. Where the change is material, the Company will notify you and will provide you with a reasonable time period to raise any objections before the change is made. Please note that We may not be able to continue a relationship with you or provide you with certain solutions if you do not agree to the changes made or proposed by Us. 

 

The latest version of the Privacy Notice would be displayed on Our website and will apply to all the interactions made with you.

 

Further, any information that is freely available or accessible in public domain or shared by you in interactions with the third parties in public platforms, or furnished under the Right to Information Act, 2005 or any other law for the time being in force will not be subject to this Privacy Notice.

2. RESPONSIBLE PARTIES

The Company would be considered as a responsible party that is responsible for determining why and how the Company will use customers’ Personal Information.  

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When a customer engages with a solution offered by the Company, the Company assumes the role of the responsible party for handling the customer's personal data. This responsibility is clearly outlined in the documentation provided to customers when they utilize or subscribe to a solution, specifying who is accountable and whom to contact for any privacy-related inquiries.

3. WHAT IS PERSONAL INFORMATION?

We may collect, store and use Personal Information about you when you visit or use Our website or query on, apply for, or avail any services or submit any Personal Information to Us, including through third party website or application. Subject to applicable laws, the Personal Information provided by you may be utilized to procure such further information through independent or third-party sources, as may be needed by Us for providing any services. Accordingly, the Personal Information in this context includes, but is not limited to, the following information:

 

  • marital status (married, single, divorced), national origin, age, language, birth, education;

  • financial history (e.g., income, expenses, obligations, assets and liabilities or buying, investing, lending, insurance, banking and money management behaviour or goals and needs based on, amongst others, account transactions);

  • employment history and current employment status (for example when a customer applies for credit);

  • gender or sex (for statistical purposes as required by the law);

  • identifying number (e.g., an account number, identity number or passport number);

  • e-mail address; physical address (e.g., residential address, work address or physical location); telephone number;

  • information about a customer’s location (e.g., geolocation or GPS location);

  • online identifiers; social media profiles;

  • biometric information (e.g., fingerprints, signature or voice);

  • race (for statistical purposes as required by the law);

  • physical health; mental health; wellbeing; disability; religion; belief; conscience; culture;

  • medical history, criminal history, employment history;

  • personal views, preferences and opinions;

  • confidential correspondence, or

  • another’s views or opinions about a customer and a customer’s name also constitute Personal Information.

 

There is also a category of Personal Information called Special Personal Information, which includes the following Personal Information about a customer:

 

  • religious and philosophical beliefs (for example where a customer enters a competition and is requested to express a philosophical view);

  • race (e.g., where a customer applies for a solution where the statistical information must be recorded);

  • ethnic origin

  • trade union membership

  • political beliefs

  • health including physical or mental health, disability and medical history (e.g., where a customer applies for an insurance policy)

  • biometric information (e.g., to verify a customer’s identity), or

  • criminal behaviour where it relates to the alleged commission of any offence or the proceedings relating to that offence.

 

Further, to the extent possible and as required by applicable law, We may give you the option to not provide or agree to the collection of specific Personal Information. However, if you choose not to accept the Privacy Policy or not to provide any or all Personal Information as requested, We reserve the right to not provide certain features on the website or services or offer them on terms which may be different (including more onerous or less beneficial) than the terms on which the services may have otherwise been provided.

4. WHEN WILL WE PROCESS YOUR PERSONAL INFORMATION?

We may process your Personal Information for lawful purposes relating to our business and services if the following cases:

 

  • it is necessary to conclude or perform under a contract with you or to provide you with optimum the solution;

  • applicable law requires or permits it;

  • to provide the services requested by you;

  • curate and optimise Our services for you and provide customized offers or rewards to you;

  • improve Our services and your experience in respect of the same;

  • undertake market, advertise and promote activities to bring you products and services which may be appropriate or of interest to you;

  • however, We do not sell or transfer your personal data to any third party for their marketing or promotional purposes, without your explicit and specific consent;

  • send you communications, including through SMS, voice call, IVR or any third-party messaging platform in relation to your use of the services;

  • comply with laws and regulations or requests from government authorities;

  • the customer is a child and a competent person (such as a parent or guardian) has consented thereto on their behalf; or

  • otherwise with your consent.

5. WHEN WILL WE PROCESS YOUR SPECIAL PERSONAL INFORMATION?

We may process your Special Personal Information in the following circumstances, among others:

 

  • if the processing is needed to create, use or protect a right or obligation in law;

  • if the processing is for statistical or research purposes, and all legal conditions are met;

  • if the special Personal Information was made public by the customer;

  • if the processing is required under applicable law;

  • if health information is processed, and the processing is to determine a customer’s insurance risk, or to comply with an insurance policy, or to enforce an insurance right or obligation, or

  • if the customer has consented to the processing.

6. WHEN AND HOW WILL WE PROCESS THE PERSONAL INFORMATION OF CHILDREN?

We process the Personal Information of children if the applicable law permits and if any one or more of the following situations applies:

 

  • a person with the ability to sign legal agreements has consented to the processing, being the parent or guardian of the child; or

  • the processing is needed to create, use or protect a right or obligation in law, such as where the child is an heir in a will, a beneficiary of a trust, a beneficiary of an insurance policy or an insured person in terms of an insurance policy; or

  • the child’s Personal Information was made public by the child, with the consent of a person who can sign legal agreements; or

  • the processing is for statistical or research purposes and all legal conditions are met.

7. WHEN, AND FROM WHERE, DO WE OBTAIN PERSONAL INFORMATION?

We collect information:

  • directly from you;

  • based on your use of Our solutions or service channels as applicable;

  • based on how you engage or interact on the website, such as on social media, and through emails, letters, telephone calls and surveys;

  • based on a mutual relationship amongst the parties;

  • from public sources (such as newspapers, company registers, online search engines, deed registries, public posts on social media);

  • from technology, such as your access and use including both assisted and unassisted interactions to access and engage with the group’s platform; or

  • from third parties that We interact with for the purposes of conducting Our business.

 

We collect and process your Personal Information at the start of, and for the duration of our relationship.

8. DATA RETENTION

We will retain your Personal Information only to the extent and for the period required by Us for the purposes set out in this Privacy Policy or as may be required for compliance with applicable laws, regulatory requirements, or to protect, enforce or establish Our legal rights.

 

You may request Us to delete your Personal Information by submitting a request in writing to the contact details provided below (Contact Information and Grievance Redressal). Subject to any compliance with applicable laws, regulatory requirements, or except as required to protect, enforce or establish Our legal rights, We will delete such Personal Information pursuant to receipt of such request. You understand that in case of any such request, your account may be permanently deleted, and you will not be able to reactivate your account. In such case, We may also not undertake any further communication with you. We also reserve the right to cease providing any services to you and any such discontinuation will be without any liabilities or obligations on Us on account of such discontinuance / deactivation.

9. WHY DO WE USE OR PROCESS YOUR PERSONAL INFORMATION?

At the time that We collect your Personal Information, We have a reason or purpose to collect that Personal Information. In certain circumstances, however, We may use that same Personal Information for other lawful purposes. We may also need to request a customer’s specific consent for the further processing in limited circumstances.

 

Should you wish to exercise your privacy rights in terms of Personal Information provided to Us or enquire about the centralised processing procedure, enquiries can be made through the contact details of the grievance redressal officer, as set out below.

10. WHEN, HOW, AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In general, We only share your Personal Information if any one or more of the following apply:

 

  • if you have consented to sharing your Personal Information with Us;

  • if it is necessary to conclude or perform under a contract;

  • if there is applicable law that requires it or makes it mandatory to share such a Personal Information, or

  • if it is necessary to protect or pursue or a third party’s legitimate interest.

11.UNDER WHAT CIRCUMSTANCES WILL WE SHARE YOUR PERSONAL INFORMATION TO OTHER COUNTRIES?

We will only share your Personal Information to third parties in another country if any one or more of the following circumstances arise:

 

  • where the transfer is necessary to enter into, or perform, under a contract with the third party that is in your interest;

  • where the customer has consented to the transfer; and/or

  • where it is not reasonably practical to obtain the customer’s consent, but the transfer is in the customer’s interest.

 

This transfer will happen within the requirements and safeguards of applicable laws or privacy rules that bind us.

 

Where possible, the party processing a customer’s Personal Information in another country will agree to apply the same level of protection as available by law in the customer’s country, or if the other country’s laws provide better protection, the other country’s laws would be agreed to and applied.

12. YOUR DUTIES AND RIGHTS REGARDING THE PERSONAL INFORMATION

You must provide Us with a proof of identity when enforcing the rights as mentioned in this Privacy Policy. You must inform Us when your Personal Information changes or as soon as possible after the change has been made.

 

You agree and warrant that when you provide Us with your Personal Information, your spouse, dependants or any other person, they have permission from you to share your Personal Information with Us.

 

12. 1. Right to access

 

You have the right to request access to the Personal Information provided to Us by contacting Us. This includes requesting:

  • a confirmation that We hold your Personal Information;

  • a copy or description of the record containing your Personal Information; and

  • the identity or categories of third parties who have had access to your Personal Information.

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We will endeavour to attend to requests for access to Personal Information within a reasonable time period once submitted to Us. You may be required to pay a reasonable fee to receive copies or descriptions of records, or information about, third parties. We will inform you of the fee before attending to your request.

 

You should note that the law may limit your right to access information.

 

12.2. Right to correction, deletion or destruction

 

You have the right to request Us to correct, delete or destroy your Personal Information if it is inaccurate, irrelevant, excessive, out of date, incomplete, misleading, obtained unlawfully, or if We are no longer authorised to keep it. You must inform Us of your request in the prescribed form that would be available on request.

 

We will take reasonable steps to determine if the Personal Information is correct and make any correction, if required. It may take a reasonable time for the change to reflect on the group’s platform/systems. However, we may request documents from you to verify the change in Personal Information, already provided to us.

 

Where the law requires the Company to keep the Personal Information, it will not be deleted or destroyed upon the customer’s request. The deletion or destruction of certain Personal Information may lead to the termination of a customer’s business relationship with the Company.

 

12.3. Right to objection

 

You may object on reasonable grounds to the processing of your Personal Information where the processing is in their legitimate interest, Company’s legitimate interest or in the legitimate interest of another party.

 

You must inform the Company of your objection in the prescribed form that would be available upon request.

 

The Company will not be able to give effect to your objection if the processing of your Personal Information was and is permitted by law, you have provided consent to the processing and the group’s processing was conducted in line with your consent, or the processing is necessary to conclude or perform the services under a contract with you.

 

The Company will also not be able to give effect to your objection if the objection is not based upon reasonable grounds and substantiated with appropriate evidence.

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12.4. Right to withdraw consent

 

Where you have provided your consent for the processing of your Personal Information, you may withdraw your consent. If you decide to withdraw your consent, Company will explain the consequences of such withdrawal. If your still wish to withdraw your consent, the Company may not be able to provide certain solutions to you. The Company will inform you if this is the case. The Company may proceed to process your Personal Information, even if you have withdrawn your consent, if the law permits or requires it. It may a reasonable time for the change to reflect on the groups’ systems. During this time, the Company may still process your Personal Information.

 

You can give effect to this right by making use of the Company’s unassisted service channels, e.g., using a Company website, or through an assisted interaction to update your consent preferences.

 

12.5. Right to complain

 

You have a right to file a complaint with the Company or any regulator with about an alleged contravention of the protection of your Personal Information. The Company will address your complaints as far as possible.

You may raise their complaints with the Grievance Officer, whose name and contact details are available on the website. The right to approach the Grievance Officer will lapse if you submit the complaint to a regulatory body established under applicable law.

13. HOW LONG DO WE KEEP CUSTOMERS’ PERSONAL INFORMATION?

We will keep your Personal Information for as long as:

 

  • the law requires the us to keep it;

  • a contract between the you and the Company requires it to keep it;

  • the you have consented to keeping it;

  • the Company is required to keep it to achieve the purposes listed in this notice;

  • the Company requires it for statistical or research purposes;

  • a code of conduct requires the Company to keep it; and/or

  • the Company requires it for lawful business purposes.

 

TAKE NOTE: The Company may keep your Personal Information even if you no longer have a relationship with the Company or if you request the group to delete or destroy it, if the law permits or requires.

14. HOW THE COMPANY PROCESSES PERSONAL INFORMATION ABOUT PERSONS RELATED TO A JURIDICAL PERSON

If a customer is a juristic person, such as a company or close corporation, the Company may collect and use Personal Information relating to the juristic person’s directors, officers, employees, beneficial owners, partners, shareholders, members, authorised signatories, representatives, agents, payers, payees, customers, guarantors, spouses of guarantors, sureties, spouses of sureties, other security providers and other persons related to the juristic person. These are related persons.

 

If customers provide the Personal Information of a related person to the Company, they warrant that the related person is aware that they are sharing their Personal Information with the Company, and that the related person has consented thereto.

 

The Company will process the Personal Information of related persons as stated in this notice, thus references to “customer/s” in this notice will include related persons with the necessary amendments.

15. PERSONAL INFORMATION THE COMPANY MAY SHARE WITH OTHER BANKS OR REQUEST FROM OTHER FINANCIAL INSTITUTIONS

  • Another financial institution may ask the Company, at the request of their customers or for the financial institution itself, to provide personal information about a customer’s financial position. This is done by issuing what is known as a banker’s reference and code. These banker’s references and codes are usually requested when a customer wishes to establish a relationship with the other bank or when a customer is applying for a trade account with another bank’s customer or if a customer is responding to a government tender.

  • This relates to personal information about the customer’s financial position. The banker’s references and codes will only be provided with a customer’s express, implied, or tacit consent.

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