We would like to make one thing very clear: We will never rent or sell your personal information.
Starseed Investment and its affiliates, including Starseed Investment (“we” or “us”), are committed to protecting and respecting your privacy. This privacy policy (“Privacy Policy”) sets out our policies and procedures for collecting, using, maintaining, protecting and disclosing information provided to us by you when you access or browse www.starseedinvest.com (“Starseed Investment”), This Privacy Policy applies to information we collect:
- On our Website www.starseedinvest.com.
- In e-mail, text and other electronic messages between you and us that are related to the services that we are providing to you.
Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. This Privacy Policy governs your use of our services and by accessing or using our Sites you agree to this Privacy Policy and your consent to the collection, transfer, processing, storage, disclosure and other uses described in this Privacy Policy. If you do not agree with our policies and practices, your choice is to not use our Website.
If you have any questions or concerns regarding this statement, you should contact us at bo@starseedinvest.com.
Data Collection
The types of information we collect depend on whether you are a User or Client. We collect Personal Data from you when you voluntarily provide information to us. Examples of instances when we collect Personal Data include when you answer questions on our website or in physical documents provided by you to determine what kind of portfolio we might recommend if you were to become a Client, when you register to open an account, when you contact our client service organization with questions or when you become a Client. Wherever Starseed Investment collects Personal Data, we make an effort to link to this Privacy Policy.
We collect user-submitted account information by which you may be personally identified, such as name, email address, and other personal details by which you may be contacted online or offline with notifications related to the use of the services offered by the Site (“personal data”). We maintain information submitted by you while registering with us. We also collect information from you when you send us feedback as well.
Additional Information Collected for Operations for the Paid Service
We may collect additional information provided by users in relation to our services in order to give Portfolio Rebalancing Advise in Tax-efficient way to users.
We may collect other information from you during your use of the paid service. The information we collect may include but is not limited to your name, age, salary, financial account information, contributions, investment holdings and preferences, and contact information.
We keep records of our advisory service, which may include but are not limited to records of the advice that we provide to you, your use of our services, and your communications to us about our services.
Communication through Website
The Website may provide you with periodic summaries of your Account Information and send email / SMS alerts. The Website also allows you to subscribe to email content, newsletters, research information, notifications and from time to time may transmit emails / SMS promoting the Website or third-party products or services. Opting out in this manner will not end transmission of service-related emails / SMS – such transactional alerts that shall continue till you avail the services of The Website.
From time to time, the Website may offer you the opportunity to participate in surveys, contests, giveaways and other promotions. Any information submitted in connection with such activities will be treated in accordance with this Privacy Policy, except as specifically set forth in the rules for those surveys, contests, giveaways or promotions.
Blogs or Forums
If you use a blog or other publicly published content product on our Sites, you should be aware that any personal information you submit there can be read, collected, or used by other users of the blog, and could be used to send you unsolicited messages. We are not responsible for the personal information you choose to submit in the blog.
Paid Service
Your personal, investment and forecast information is maintained by us in order to provide you with customized investment services and to fulfill our legal and regulatory requirements. By having more information about you, we are able to customize our services to your particular investment preferences.
Service-related Announcements
We will send you service-related announcements on the rare occasions when it is necessary to do so. For instance, if our service is temporarily suspended for maintenance, we might send you an email. Generally, you may not opt-out of these communications, which are not promotional in nature. If you do not wish to receive them, you have the option to deactivate your account.
Updating/Accessing Personal Information
If your personal information changes, or if you no longer desire our service, you may Deactivate your Account by emailing our Customer Support team at bo@starseedinvest.com. We will respond to your request within 30 days. Please note that even if we close your account, we may retain and use your information as necessary to comply with our legal obligations, resolve disputes and enforce our agreements. Please also note that there might be latency in deleting information from our servers and backed-up versions might exist after deletion.
Use of Cookies and IP Addresses
As you navigate through and interact with our Sites, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including browser-type related information, IP address, requested URL, referring URL, timestamp data, and other information help us diagnose problems with our servers, administer the Sites, and otherwise provide the highest possible level of service to you. In addition, we use this non-personal information to perform statistical analyses of user behaviour and characteristics in order to measure interest in and use of the various areas of the site.
Like most websites, the Site require cookies to function properly. Cookies are small text files that reside on a user’s computer and identify you as a unique user. We use cookies to refine our services and simplify the user experience.
We use a tracking utility company that uses cookies and Web beacons on our Sites. We have no access to or control over these third party tracking utilities. We also use cookies in conjunction with Google Analytics Demographics and other tools in order to better understand our visitors. Google Analytics collects information such as how often users visit our Sites, what pages they visit when they do so, and what other sites they used prior to coming to our Sites. We use the information we get from Google Analytics only to maintain and improve our Sites. Google Analytics does not collect your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personal information.
Disclosure/Transfer of Information
Some of the information you provide on our Sites is publicly exposed in an aggregated manner unless otherwise noted. However, except as set forth in this Privacy Policy, we do not sell, rent, share, trade or give away any of your personal information. We do not share your personal information for a third parties’ promotional use. We may disclose personal information that we collect or you provide as described in this Privacy Policy:
- To our subsidiaries and affiliates.
- To contractors, service providers and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
- We will disclose information about individual users to governmental or judicial authorities or law enforcement. Further, we may share information in order to investigate, prevent, or take action regarding illegal activities or suspected fraud, or to enforce or apply the terms and conditions of this Privacy Policy.
- To fulfil the purpose for which you provide it.
- For any other purpose disclosed by us when you provide the information.
- With your consent.
- To enforce or apply our Terms of Use.
- If we believe disclosure is necessary or appropriate to protect our rights, property, or safety or the rights, property or safety of our customers or others.
We reserve the right to transfer your personal information in the event of a transfer of ownership of Starseed Investment such as a restructuring, an acquisition by or merger with another company. In such an event, we will notify you before information about you is transferred and becomes subject to a different privacy policy.
We will notify you when information about you may be provided to third parties in ways other than explained above, and you will have the option to prevent such information sharing.
Conflict of Interest Policy
Starseed Investments Private Limited SEBI Registration No: INA000018771
1. Introduction and Objectives
1.1 Primacy of Client Interest (First, Do No Harm)
Starseed Investments Pvt. Ltd. (hereinafter referred to as “Starseed” or “the RIA”) is registered with the Securities and Exchange Board of India (SEBI) as an Investment Adviser and adheres to the highest standards of integrity and
fairness, prioritizing the client’s interest above all other considerations, including its own.
This policy is established in compliance with Regulation 19 and 22 of the SEBI (Investment Advisers) Regulations, 2013 (“IA Regulations”) and the SEBI
Circulars/Guidelines issued thereunder.
1.2 Policy Objectives
The core objectives of this policy are:
- Identification: To systematically identify circumstances that constitute or could potentially lead to a conflict of interest, posing a material risk of harm to our clients’ interests.
- Elimination/Avoidance: To eliminate or avoid conflicts of interest
wherever possible, especially those related to compensation from third parties.
- Management and Mitigation: To establish and implement effective procedures and organizational arrangements to manage and mitigate unavoidable conflicts.
- Disclosure: To ensure full, fair, and timely disclosure of residual conflicts so clients can provide informed consent.
2. Scope and Applicability
This Policy applies to Starseed, its Directors, Partners, Principal Officer,
Employees, and all individuals/entities associated with the RIA’s investment advisory activities (collectively referred to as “Associated Persons”).
3. Guiding Principles: Fiduciary Duty
Starseed and its Associated Persons shall, at all times, adhere to the following principles, ensuring that personal and corporate interests do not conflict with the duty owed to the client:
- Primacy of Client Interest: The interests of the client shall always take primacy in any investment advice, decision, or transaction.
- High Standards of Integrity: Maintain high standards of integrity, due skill, care, and diligence in all business conduct.
- Fair Treatment: Ensure fair and non-discriminatory treatment among all
- Confidentiality: Preserve client confidentiality unless disclosure is required by law.
4. Identification of Potential Conflicts of Interest
Conflicts of interest can arise in various forms. Starseed has identified, but is not limited to, the following key areas of potential conflicts:
| Category of Conflict | Specific Scenario | Impact on Client |
| I. Compensation & Incentives | The RIA or its Associated Persons receiving any consideration(commission, referral fee, etc.)from product issuers (e.g., AMC, brokerage firm). | Conflict is Eliminated: This is strictly prohibited by SEBI IA Regulations (Regulation 22(1)) and must be avoided entirely. |
|
II. Affiliations & Group Structure |
Starseed’s group, family, or associates offeringexecution/distribution services (e.g., a group entity is astockbroker or mutual fund distributor). | May incentivize the RIA to recommend products that generate revenue for the group/affiliates rather than the best product for the client. |
| III. Proprietary Products | Recommending products (funds, services) developed, managed, or | May lead to biased advice in favor of proprietaryproducts, regardless of |
| sponsored by Starseed or its group entities. | their suitability for the client. | |
| IV. Personal Trading of Associated Persons | An Associated Person conducting personal trades in securities that are also being recommended to or traded for clients. | Risk of “Front-Running” (trading before a client to benefit from the price movement caused by the client’s trade) or Insider Trading. |
|
V. Differential Treatment |
Allocating limited investment opportunities or beneficial IPO/NFO allotmentsdisproportionately to one client over others (e.g., favoring larger clients). | Unfair treatment and discrimination among clients. |
5. Management and Mitigation Strategies
Starseed employs the following robust organizational and administrative arrangements to manage and mitigate conflicts of interest:
5.1 Elimination and Avoidance (Structural Measures)
- No Product-Based Consideration (Zero Commission): Starseed confirms that it shall not receive any consideration (remuneration, commission, referral fee, etc.) by any name whatsoever, from any person other than the client being advised, in respect of the underlying products or
securities for which advice is provided.
2. Segregation of Advisory and Distribution Activities:
- Starseed maintains a strict “client-level segregation.” A client or the client’s family who avails advisory services from Starseed cannot be provided with distribution/execution services by any entity in the Starseed group/family.
- The Permanent Account Number (PAN) of the client and their family members is used as the control record to enforce this
- Financial Planning vs. Product Sales: The incentive and remuneration structure for Associated Persons is based on factors related to the quality of financial planning, compliance adherence, client service metrics, and professional certifications, not on the volume or value of recommended
5.2 Internal Controls and Procedural Measures
- Information Barriers (Chinese Walls): Physical and electronic barriers are maintained to restrict the flow of price-sensitive or confidential client information between the advisory function and any other affiliated
2. Employee Personal Trading Policy:
- Associated Persons are required to seek prior approval from the Compliance Officer for any personal trades in securities
recommended to or held by clients.
- A minimum holding period of 30 days is imposed on all personal investments by Associated Persons to discourage short-term gain
- No personal transactions are permitted for two days preceding and two days succeeding any client recommendation in the same or related security.
- Fair Allocation: Any limited investment opportunity shall be allocated
fairly and equitably among all eligible clients in line with their investment objectives and risk profile, as documented by the Principal
Officer/Compliance Officer.
6. Disclosure Requirements
Where a potential conflict of interest is unavoidable and deemed manageable, Starseed shall make clear, accurate, and specific disclosure to the client prior to the advice being executed.
The disclosure shall cover:
- Nature of the Conflict: Detailed explanation of the conflict and how it could potentially impair the RIA’s objective advice.
- Mitigation: The steps taken by Starseed to mitigate the
- Financial Interest: Any financial or commercial interest that Starseed or its affiliates have in the recommended product or service.
7. Compliance and Monitoring
- Responsibility: The Compliance Officer is responsible for the overall implementation, monitoring, and enforcement of this policy.
- Reporting: Associated Persons must promptly report any actual or potential conflict of interest to the Compliance Officer.
- Review: This Policy shall be reviewed by the management of Starseed at least annually and whenever there is a material change in the business model or regulatory requirements.
- Record Keeping: Starseed shall maintain adequate records for a minimum period of five years documenting:
- Identification and assessment of potential
- The decision-making process for managing or mitigating a
- All disclosures made to clients regarding
This policy is subject to amendment by Starseed in accordance with SEBI Regulations and is made available to all clients and Associated Persons.
Security
To keep you and your data safe we have also implemented a number of security procedures, we have built in a number of safeguards into our software, including:
- Automatic Logout. If you are inactive for an extended period of time we automatically log you out so unauthorized people cannot access your account.
- Contact Information Confirmation. All changes to your contact information are verified with you before we make any changes.
- Personalized Email. Emails coming from Starseed Investment will generally address you by name, so you can be confident we know who you are and the email is coming from us.
- Account Ownership Verification. We verify that you have proper access to any external checking account that we electronically link to. This helps prevent people from opening an account in your name and moving money out of your external account.
- Identity Verification. We run thorough identity verification checks on new customers to determine if the identity information provided is accurate and not suspicious or on any government watch lists.
Customer Preferences and Opt-out Choices
We may also use your information to contact you about our services that may be of interest to you. If you do not want us to use your information in this way, please provide notice to us through one of the following ways:
To opt-out of receiving promotional or marketing communications from us at a specific address, you may:
- Use the unsubscribe instructions sent by us.
- Or Contact us by email at: bo@starseedinvest.com
*Note: It may take up to 10 business days to process your request post receipt of the request.
Links
Our Site may contain links to third party websites to which we have no affiliation. The links are provided on our Sites solely for your convenience and may assist you in locating other useful information on the Internet. Unless you expressly authorize us to do so, we will not share your personal information with such third party websites. These third party websites are not under our control. In using such third party websites please be aware that each third party website is subject to its own privacy policies and is not covered by our Privacy Policy. We make no representation or warranty regarding the accuracy of the information contained on such third party websites, and we disclaims all responsibility relating to or resulting from your use of such third party websites.
Modifications to the Privacy Policy
This Privacy Policy may change from time to time. If we make a change to this Privacy Policy that we believe materially reduces your rights, we will provide you with prominent notice on our Site’s home page. By continuing to use our services after those changes have become effective, you agree to be bound by the revised Privacy Policy. You are responsible for periodically visiting our Sites and this Privacy Policy to check for any changes.
Contact
If you have questions, comments, concerns or feedback regarding this Privacy Policy or any other privacy or security concern, please send an e-mail to bo@starseedinvest.com.