PRIVACY POLICY

This document is an electronic record in terms of the Information Technology Act, 2000 and rules framed thereunder as applicable. This electronic record is generated by a computer system and does not require any physical or digital signatures.

TM Investment Technologies Pvt Ltd, a private limited company, incorporated under the Indian Companies Act, 2013, allotted Corporate Identification Number (CIN) U65990MH2020PTC342552 and having its registered office at Motilal Oswal Tower, Rahimtullah Sayani Road, Opp. Parel ST Depot, Prabhadevi, Mumbai – 400 025, Maharashtra, India and operating under its trade name ‘Teji Mandi’, (hereinafter referred to as ‘Teji Mandi’) is the owner of the website with domain name www.tejimandi.com and Teji Mandi application (hereinafter referred to as the ‘Teji Mandi Platforms’).

Teji Mandi is concerned about the privacy of individuals who visit our websites, use our mobile applications, access campaign landing pages, submit enquiries, register their interest, subscribe to our services, contact us or apply for employment opportunities.

This Privacy Policy explains how we collect, use, disclose, store and protect personal data in connection with our digital platforms and business activities.

This Policy applies to the following categories of individuals, as relevant:

Website and mobile application visitors.
Individuals who submit campaign, registration or enquiry forms.
Individuals who verify their mobile number through OTP.
Existing and prospective subscribers of our services.
Individuals who contact our customer support or submit grievances.
Individuals who subscribe to our newsletter or promotional communications.
Job applicants and prospective employees.

Different services or forms may require additional information or notices specific to the relevant purpose.

2. Personal Data We May Collect

The personal data we collect depends on the platform, form, service or interaction involved. We seek to collect information relevant to the purpose for which it is required.

2.1 Website Visitors and Technical Information

When you visit our digital platforms, we may collect technical and usage information to the extent enabled by our systems and tools, such as:

IP address and general device or browser information.
Operating system and technical identifiers.
Pages visited, referring pages and interaction information.
Date, time and technical logs relating to access.
Cookie identifiers and similar technology information, where used.

The specific technical information collected will depend on our actual configuration and the tools deployed on the relevant platform.

2.2 Enquiry and Campaign Forms

When you submit a campaign form, register your interest or request information, we may collect:

Name
Mobile number.
Email address, where requested.
Information about the product or service you are interested in.
Details included in your enquiry.

Relevant consent, preference and submission records.

2.3 Mobile Number and OTP Verification

Where mobile verification is offered, we may process your mobile number, OTP verification status, verification timestamps and related technical or security records.

The OTP itself is used to complete the relevant verification process. We do not treat OTP verification alone as consent to receive all promotional communications.

2.4 Account and Subscription Information

If you register for or purchase a service, we may process information such as:

Account and contact details.
Selected product, portfolio or subscription plan.
Subscription start and end dates.
Payment status, transaction references and billing records.
Service access and account administration records.
Applicable declarations, acknowledgements and acceptance records.
KYC documents and regulatory information, where required.

Payment card, banking or other payment credentials may be collected and processed directly by the relevant payment provider. We will handle any payment-related information available to us in accordance with applicable law and the relevant service arrangements.

2.5 Customer Support and Grievances

If you contact us, we may process your name, contact details, enquiry, correspondence, complaint details, supporting documents and records necessary to investigate and resolve the matter.

Where a grievance relates to a regulated service, we may also process information necessary to comply with applicable regulatory, audit, reporting or dispute-resolution requirements.

2.6 Careers and Recruitment

If you apply for a job or submit your details through our Careers page, we may collect:

Name and contact details.
Resume or curriculum vitae.
Job title or role of interest.
Educational and professional qualifications.
Work experience and employment-related information.
Current or expected compensation details, if requested.
Other information you voluntarily submit in connection with your application.

We use this information for recruitment, assessing suitability for a role, communicating with candidates and managing the hiring process.

Please avoid submitting personal information that is not relevant to the recruitment process.

2.7 Newsletter and Promotional Preferences

If you subscribe to a newsletter or choose to receive promotional communications, we may collect your email address or mobile number, your communication preferences and records of consent, subscription, withdrawal or unsubscribe requests.

2.8 Information from Other Sources

Where permitted by applicable law, we may receive relevant information from service providers, verification providers, payment providers or other sources in connection with a transaction, service, fraud prevention, security or regulatory requirement.

We will handle such information in accordance with the applicable legal requirements and the purpose for which it is obtained.

3. How We Use Personal Data

We may use personal data, as relevant, for the following purposes:

To respond to enquiries and requests for information.
To process registrations and requests to access our services.
To verify mobile numbers and protect the security of accounts and forms.
To administer subscriptions, billing, payments and service access.
To complete KYC and other regulatory formalities where applicable.
To provide customer support and resolve complaints or grievances.
To send service-related notices and important account or subscription communications.
To send promotional communications where permitted by law and supported by the applicable consent or communication preferences.
To process job applications and communicate with candidates.
To maintain records required for legal, regulatory, audit, tax, accounting or dispute-resolution purposes.
To monitor, maintain and improve the security and functioning of our platforms.
To detect, prevent and investigate fraud, misuse, unauthorised access and technical issues.
To comply with applicable laws, regulations, lawful directions and requests from competent authorities.

We will not use personal data for an unrelated purpose merely because it has been collected through a Teji Mandi platform. Where required, we will provide additional information or obtain consent before using personal data for a new purpose.

4. Legal Basis, Notice and Consent

We process personal data in accordance with applicable law.

Depending on the purpose and the legal framework applicable at the relevant time, processing may be based on consent, a legally recognised permitted use, a contractual or service-related necessity where legally recognised, or a legal or regulatory obligation.

Where consent is required, we will seek consent through an appropriate process and explain the relevant purpose. You may withdraw consent where permitted by applicable law. Withdrawal does not affect processing already lawfully undertaken before withdrawal, and it does not require us to erase information that we are legally required or otherwise permitted to retain.

Submitting a mobile number, completing OTP verification or submitting an enquiry does not, by itself, mean that you have consented to all promotional communications or unrelated processing.

5. Promotional Communications and Preferences

We may send service-related communications necessary to respond to your enquiry, complete verification, administer your account or subscription, communicate service changes or meet legal and regulatory obligations.

We will send marketing or promotional communications through the channels and on the basis permitted by applicable law and the relevant consent or preference requirements.

Where a separate marketing opt-in is required, it should be presented separately from service access or enquiry submission and should not be pre-selected.

You may unsubscribe from promotional emails through the unsubscribe mechanism provided in the communication, where available, or contact us at support@tejimandi.com to update your preferences.

Where available, you may also use the relevant communication channel’s preference or opt-out mechanisms. We will process requests in accordance with applicable law and the technical requirements of the relevant service providers.

Withdrawing marketing consent does not prevent us from sending essential service, transaction, security or legally required communications.

6. Sharing and Disclosure of Personal Data

We may share personal data with the following categories of recipients, where relevant and necessary for the purposes described in this Policy:

6.1 Service Providers

Technology and hosting providers, website and application service providers, OTP and SMS providers, email or communication platforms, customer support providers, analytics providers and other vendors engaged to support our operations.

6.2 Payment and Verification Providers

Payment gateways, banks, payment service providers, KYC or verification providers and other entities involved in processing transactions or completing required verification.

6.3 Professional Advisers and Auditors

Legal advisers, auditors, consultants and professional service providers where access is necessary for the relevant work and permitted by law.

6.4 Regulators and Public Authorities

SEBI, BSE, courts, law enforcement agencies, government departments and other competent authorities where disclosure is required or permitted by applicable law, regulation, lawful direction or legal process.

6.5 Business Transfers

If the Company undergoes a merger, restructuring, acquisition or transfer of business or assets, relevant information may be disclosed or transferred as permitted by law, subject to appropriate safeguards and applicable obligations.

We do not authorise service providers to use personal data for purposes unrelated to the services they perform for us, except where independently permitted or required by law.

The actual providers used for each platform may differ. We will not identify a particular vendor as a recipient unless that vendor is actually used for the relevant processing.

7. Cross-Border Processing

Where personal data is processed or stored outside India by us or by our service providers, such processing will be subject to applicable legal requirements, restrictions and safeguards.

The location of processing may depend on the technology infrastructure and vendors used for the relevant platform. Further information may be provided where required by applicable law.

8. Data Retention

We retain personal data only for as long as reasonably necessary for the purpose for which it was collected, subject to applicable legal, regulatory, accounting, audit, contractual and dispute-resolution requirements.

Retention periods may vary depending on the type of information and the nature of the interaction. For example:

Enquiry information may be retained for responding to requests, follow-up, records and related business requirements.
Account, subscription, transaction and KYC records may be retained for applicable regulatory, audit, accounting or legal periods.
Customer support and grievance records may be retained for resolution, audit, regulatory and dispute-related purposes.
Recruitment information may be retained for the hiring process and any further period disclosed to the candidate or permitted by applicable law.
Security logs and technical records may be retained for a period appropriate to security, troubleshooting and compliance needs.

When personal data is no longer required and no legal or other permitted retention ground applies, we will take appropriate steps to erase it or render it unusable in accordance with applicable law and our retention practices.

9. Cookies and Similar Technologies

Our websites or digital platforms may use cookies and similar technologies to support essential functionality, maintain security, remember preferences, analyse platform performance or measure campaign activity, depending on the tools deployed.

Where required by applicable law, we will provide appropriate notice and obtain consent for non-essential cookies or tracking technologies.

You may be able to manage cookies through your browser settings or through a cookie preference mechanism made available on the relevant platform. Disabling certain cookies may affect website functionality.

Third-party tools may operate under their own privacy policies and technical practices. Our use of a particular analytics, advertising or tracking tool will depend on whether it is actually deployed on the relevant platform.

10. Careers and Recruitment Privacy

Personal data submitted through our Careers page will be used to evaluate applications, contact candidates, conduct the hiring process and maintain recruitment records.

Access to candidate information will be limited to personnel and service providers who need the information for recruitment or related administrative purposes.

If we intend to retain a candidate’s information for consideration for future vacancies beyond the current recruitment process, we will provide appropriate information about that purpose and obtain consent where required.

You may contact support@tejimandi.com regarding a privacy request relating to your application. Requests will be handled subject to applicable law and any legitimate record-retention requirements

11. Personal Data Security

We take reasonable steps, appropriate to the nature of the information and our operations, to protect personal data against unauthorised access, disclosure, alteration, loss or misuse.

These measures may include access controls, restricted permissions, technical safeguards, monitoring and vendor-management procedures, as appropriate to the relevant systems.

No method of transmission or electronic storage can be guaranteed to be completely secure. However, this does not exclude any security obligation or liability that applies to us under law.

If a personal data breach occurs, we will take appropriate steps to investigate, contain and address it and provide notifications to affected individuals or authorities where and to the extent required by applicable law.

12. Your Requests and Privacy Rights

Subject to applicable law and the legal framework in force at the relevant time, you may request information or action relating to your personal data, including:

Access to relevant information about processing.
Correction or updating of inaccurate personal data.
Erasure of personal data where applicable and where continued retention is not legally required.
Withdrawal of consent where processing is based on consent.
Updating or withdrawing promotional communication preferences.
Assistance or redress in relation to a privacy concern.

To submit a request, please email support@tejimandi.com with sufficient information to identify the relevant interaction and describe your request.

We may request reasonable verification to protect your information and prevent unauthorised disclosure. We will respond within the period required by applicable law. We may decline or limit a request where permitted or required by law, including where information must be retained for regulatory, legal, audit or dispute-resolution purposes.

Where applicable law provides for a grievance or appeal mechanism, you may use the relevant mechanism in accordance with the prescribed procedure.

13. Children’s Personal Data

Our services are intended for individuals who are legally eligible to use the relevant service. We do not knowingly seek to collect children’s personal data in connection with services that are not intended for children.

Where a service or interaction may involve a child, we will handle the relevant personal data in accordance with applicable law, including any requirements relating to parental or guardian consent and restrictions on processing.

If you believe that a child has submitted personal data to us inappropriately, please contact support@tejimandi.com so that we can review the matter and take appropriate action.

14. Third-Party Websites and Platforms

Our platforms may link to third-party websites, applications, payment pages or other external services.

When you access a third-party platform, its own privacy policy, terms and data-handling practices may apply. We do not control independent third-party platforms and encourage you to review their policies before providing personal data.

This section does not exclude any responsibility that may apply to TMITPL under applicable law.

15. External Communications and Integrated Services

If you interact with us through email, messaging applications, telephone, social media or another communication channel, we may process the information you provide and records necessary to respond to you or administer the relevant interaction.

Where a third-party service processes information independently, its own terms and privacy policy may apply. We will handle any personal data processed by us in accordance with this Policy and applicable law.

16. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes in our services, data practices, technology, legal requirements or regulatory obligations.

The updated Policy will be published with a revised “Last Updated” date.

Where a change requires additional notice or fresh consent under applicable law, we will take the required steps. Continued use of a website or platform alone will not constitute consent where fresh consent is legally required.

We encourage you to review this Policy periodically.

17. Privacy Contact and Grievances

For questions, requests or concerns relating to this Privacy Policy or the handling of your personal data, please contact:

TM Investment Technologies Private Limited
Trade Name: Teji Mandi
Registered Office: Motilal Oswal Tower, Rahimtullah Sayani Road, Opp. Parel ST Depot, Prabhadevi, Mumbai – 400025, Maharashtra, India
Email: support@tejimandi.com

Please include “Privacy Request” or “Privacy Grievance” in the subject line and describe your concern. We may request reasonable information to verify your identity and process the request securely.

If the Company designates a separate privacy contact or grievance officer for data protection matters, the relevant details will be published on the applicable platform and this Policy will be updated accordingly.

18. Applicable Law

This Privacy Policy shall be governed by and construed in accordance with the laws of India, including, where applicable, the Information Technology Act, 2000, as amended from time to time, the rules and regulations made thereunder, and applicable data protection and privacy laws, including the Digital Personal Data Protection Act, 2023, and the rules and provisions thereof as and when applicable and brought into force.

Nothing in this Privacy Policy shall limit or exclude any rights, obligations or remedies available under applicable law.