1. Introduction
This Privacy Policy ("Policy") explains how we collect, use, store, share, and protect information when you visit or use https://samarcapital.in/ and any associated web pages, forms, chat tools, WhatsApp channels, email, phone, and other communication channels linked to the website (collectively, the "Platform").
We value your trust and are committed to handling your information responsibly and in line with applicable laws including the Information Technology Act, 2000 and rules thereunder (including the SPDI Rules), and the Digital Personal Data Protection Act, 2023 (to the extent applicable), as well as other applicable regulatory requirements.
2. Who we are (Data Fiduciary / Controller)
The Platform is owned and operated by:
Samar Capital Private Limited ("SCPL")
- CIN: U64990DL2026PTC461299
- Registered office: D-26 Basement, Jangpura Extension, Jungpura, South Delhi, New Delhi, Delhi, India – 110014
Group entities & roles
For the purposes of this Policy, references to "Samar", "we", "us", "our" may include our group entities where relevant for service delivery, support, or operations:
- Samar Applications Private Limited ("SAPL") (Technology / platform support entity) – CIN: U62013DL2025PTC459291; Registered office: D-26 Basement, Jungpura Extension, Jungpura, South Delhi, New Delhi – 110014;
- Samar Asset Management Private Limited ("SAMC") (Proposed PMS entity) – CIN: U64990DL2026PTC461301; Registered office: D-26 Basement, Jangpura Extension, Jungpura, South Delhi, New Delhi – 110014.
Regulatory status note: Certain registrations/licenses (e.g., SEBI PMS registration, AMFI ARN, APMI registration) may be applied for / obtained in future. Until then, the Platform may provide information, intake enquiries, enable relationship management, and facilitate permissible onboarding readiness; regulated services (if any) will be offered only after the relevant approvals are obtained and applicable documentation is executed.
3. Scope of this Policy
This Policy applies to: website visitors; individuals who submit details on forms; individuals who contact us through phone/email/WhatsApp/chat; prospective customers and customers (as applicable).
This Policy does not apply to third-party websites or platforms linked from our site which have their own policies.
4. Information we collect
4.1 Information you provide to us
- Identity & contact: name, mobile number, email address, city/state, and communication preferences.
- Service-related: investment preferences, risk preferences (if shared), product interest (PMS/MF/bonds/other), meeting notes, and query details.
- Documents you share voluntarily: may include identification or financial documents if you choose to share them; however, we encourage sharing such documents only through secure channels when requested and appropriate.
4.2 Information collected automatically (website)
- Device and usage data: IP address, browser type, device identifiers, pages visited, time spent, referral URLs, and interaction logs.
- Cookies & similar technologies: to enable site functionality, analytics, and user experience improvements.
4.3 Sensitive personal data / financial data
If/when you proceed for onboarding into regulated offerings (after relevant approvals/licenses), we (or our authorised service providers) may collect or verify information such as PAN, bank/demat details, address, date of birth, and KYC records only as required for compliance and service delivery.
5. How we use your information (Purposes)
We use collected information to:
- Respond to enquiries and provide information you request.
- Provide and improve services, including website operations and user experience.
- Verify identity / prevent fraud and maintain security of our Platform.
- Relationship management (CRM), follow-ups, and service communications.
- Compliance and recordkeeping, including handling legal/regulatory requirements and maintaining audit trails (as applicable).
- Marketing communications where permitted by law and subject to your preferences (you can opt out).
- Analytics and performance monitoring, to improve our products, communications, and internal processes.
6. Legal basis / grounds for processing
We process personal data based on one or more of: consent (where required); steps taken at your request prior to entering a contract; performance of a contract; compliance with applicable law; and legitimate uses such as security, fraud prevention, service improvement, and internal operations (as permitted).
7. Cookies
We may use cookies and similar tools. You can control cookies through your browser settings. Disabling cookies may limit some features.
8. Sharing of information
We do not sell your personal data. We may share information only as necessary with:
- Group entities (SCPL, SAPL, SAMC) for operational support, technology enablement, and service delivery, subject to appropriate access controls.
- Service providers / processors (hosting, CRM, analytics, communications, KYC/verification, auditors, legal advisors) under confidentiality and data protection terms.
- Regulators / authorities / law enforcement where required under law or valid legal process.
- Business transfers in case of merger/acquisition/restructuring, subject to lawful safeguards and confidentiality.
9. Security measures
We implement reasonable technical and organisational measures to protect information (access controls, role-based access, vendor due diligence, and security practices). However, no system is completely secure and you should also take precautions (e.g., do not share passwords/OTPs).
10. Data retention
We retain your information only for as long as necessary for the purposes described in this Policy, or as required under applicable law/regulatory recordkeeping obligations. Retention may be longer where needed for dispute resolution, legal claims, or compliance.
11. Your rights and choices
Subject to applicable law, you may request access and correction of your data; withdraw consent (where processing is based on consent); request deletion/erasure (where not required for legal/regulatory retention); and opt out of marketing communications. To exercise rights, contact us at the details in Section 14.
12. Children’s privacy
The Platform is not intended for persons under 18 years. We do not knowingly collect personal data of minors. If you believe a minor has provided personal data, please contact us.
13. Cross-border transfers
We may use service providers that store/process data in India or other jurisdictions. Where cross-border transfers occur, we take reasonable measures to ensure appropriate safeguards consistent with applicable law.
14. Updates to this Policy
We may update this Policy periodically as and when required.

