Legal
Privacy Policy
This policy explains what personal data Sumit Kumar Singh, a SEBI-registered Investment Adviser (individual), trading as Xumit Capital (“we”, “us”) collects through xumitcapital.com, why, and what rights you have. It is written to meet the Digital Personal Data Protection Act, 2023 and our record-keeping duties under SEBI regulations.
1. What we collect
| Data | When | Why |
|---|---|---|
| Name, email address, mobile number | Sign-up, contact form | To create your subscription, send confirmations, holdings and rebalance updates, and reply to you |
| PAN and date of birth | Sign-up | KYC verification, which SEBI requires before we can advise you |
| Risk profile answers (income, investment experience, goals, risk appetite) | Before your portfolio is shared | Risk profiling and suitability assessment required by SEBI |
| Plan, amount, payment reference | Payment | Billing, GST invoices, refunds and accounting records |
| Basic technical data (browser type, pages visited) | Website visits | Running and securing the website |
We do not collect or store your card numbers, UPI PIN or bank login details. Payments are processed entirely by Razorpay. We never ask for your broker login, password or OTPs.
2. Who we share it with
We do not sell your data or share it for marketing. We share only what is needed with:
- KYC Registration Agencies (such as CVL KRA), to verify your KYC.
- Razorpay, to process payments and refunds.
- Service providers who run parts of our service on our behalf: website hosting (Hostinger), email delivery (Twilio SendGrid) and our contact and CRM system (HubSpot). They may process data outside India under their own security commitments.
- SEBI, BASL and other authorities, when the law requires it.
3. How long we keep it
SEBI requires investment advisers to keep client records, including KYC, risk profiles, agreements and advice given, for at least five years. We keep subscription records for the period required by law and then delete them. Contact-form enquiries that do not lead to a subscription are deleted within 60 months.
4. How we protect it
Data is sent over encrypted (HTTPS) connections and stored on access-restricted servers. Only the adviser and authorised staff can access client records.
5. Your rights
You can ask us to:
- tell you what personal data we hold about you,
- correct or update it,
- delete it, except where the law requires us to keep it (for example, SEBI record-keeping),
- withdraw consent for future processing. This may mean we can no longer provide the service.
Email sumit.singh@xumitcapital.com. We respond within 30 days. If you are not satisfied, you may complain to the Data Protection Board of India.
6. Cookies
The website uses cookies needed for it to work and, where enabled, basic analytics. You can block cookies in your browser settings; some parts of the site may then not work properly.
7. Contact
Registered name: Sumit Kumar Singh · Trading as Xumit Capital
Type of registration: Individual Investment Adviser · SEBI Registration No.: INA100010008 · Validity: Perpetual
BSE Administration & Supervision Ltd (BASL) membership No.: 2015
Address: B5/503, Waterlily, Shantigram, Ahmedabad (INDIA) 382421 · Phone: +91 9971996276 · Email: sumit.singh@xumitcapital.com
Principal Officer: Sumit Kumar Singh · sumit.singh@xumitcapital.com · +91 9971996276
SEBI office: Plot No. C4-A, ‘G’ Block, Bandra Kurla Complex (BKC), Bandra (East), Mumbai (INDIA) 400051
GSTIN: 24AAACX3377J1Z4
We may update this policy. The effective date at the top shows when it last changed.
