Privacy Policy

Smart Share & Securities Ltd.

Smart Share & Securities Ltd. (“Smart Share”, “we”, “us”, or “our”) respects the privacy of our clients, investors, website visitors, applicants, and other individuals who interact with us.

This Privacy Policy explains how we collect, use, process, store, protect, and disclose personal information when you visit our website, open or maintain a BO or trading account, use our trading platforms and digital services, communicate with us, or otherwise use our services.

By using our website, digital platforms, applications, or services, you acknowledge that you have read and understood this Privacy Policy.

We are committed to handling personal information responsibly and in accordance with applicable laws, regulations, regulatory requirements, and our internal policies.

1. About Smart Share & Securities Ltd.

Smart Share & Securities Ltd. is a stock brokerage firm providing brokerage and investment-related services in Bangladesh.

We provide services including, where applicable:

• BO and trading account opening and maintenance;
• Stock and securities trading;
• Order placement and order management;
• Government securities;
• Corporate bonds;
• Mutual funds and other exchange-traded securities;
• Online and digital trading services;
• Market information and investor education and
• Customer support and related brokerage services.

Smart Share is a member of the Dhaka Stock Exchange (DSE) DSE TREC-290 and Chittagong Stock Exchange (CSE) CSE TREC-127 and operates under the applicable regulatory framework governing capital market intermediaries in Bangladesh.

2. Contact Information

If you have questions, concerns, complaints, or requests regarding this Privacy Policy or the way we handle your personal information, you may contact us at:

Smart Share & Securities Ltd.
76/77, KM Tower (4th Floor)
Agrabad C/A, Chattogram, Bangladesh

Phone: 01958237923, 01958237924, 01958237925
Email: info@smartsharebd.com
Website: smartsharebd.com

3. Scope of This Privacy Policy

This Privacy Policy applies to personal information collected through:

• Our official website;
• Online BO and trading account applications;
• Smart Share digital platforms and portals;
• Smart OMS and related trading services;
• Our mobile applications;
• Customer service and support channels;
• Email, telephone, SMS, and other communications;
• Physical or electronic account-opening documentation;
• Marketing and investor communication activities; and
• Other interactions between you and Smart Share.

This policy does not necessarily apply to websites, applications, products, or services operated by third parties. Such third parties may have their own privacy policies, and we encourage you to review them before providing information to them.

4. What Personal Information We May Collect

Depending on the services you use and the nature of our relationship with you, we may collect and process different categories of information.

4.1 Identification and KYC Information

This may include:

• Full name;
• Date of birth;
• Nationality;
• National Identification Number (NID);
• Passport or other identification information, where applicable;
• Photograph;
• Signature;
• Tax Identification Number (TIN);
• Occupation and professional information;
• Residential and mailing address;
• Nominee and related information;
• Beneficial ownership information;
• Source of funds or source of wealth information, where required;
• KYC and customer due diligence information; and
• Other information required under applicable laws and regulatory requirements.

4.2 Contact Information

This may include:

• Mobile number;
• Telephone number;
• Email address;
• Mailing address;
• Emergency or authorized contact information; and
• Other contact details provided by you.

4.3 Financial and Account Information

Where necessary for providing our services, we may collect:

• Bank account information;
• BO account information;
• Trading account information;
• Payment and settlement information;
• Portfolio information;
• Dividend and corporate-action related information;
• Tax-related information; and
• Other information necessary to administer your account.

4.4 Trading and Transaction Information

We may collect information relating to:

• Buy and sell orders;
• Order dates and times;
• Order quantities and prices;
• Executed transactions;
• Trade confirmations;
• Settlement information;
• Portfolio activity;
• Deposits and withdrawals;
• Corporate actions; and
• Other activities performed through our brokerage services or digital platforms.

4.5 Technical and Electronic Information

When you access our website, applications, or digital platforms, we may automatically collect certain technical information, including:

• IP address;
• Browser type and version;
• Operating system;
• Device information;
• Device identifiers;
• Login information;
• Session information;
• Date and time of access;
• Pages or services accessed;
• Application activity;
• Network information;
• Cookies and similar technologies; and
• Security and activity logs.

We may use this information to maintain the security, functionality, performance, and reliability of our digital services.

5. How We Collect Personal Information

We may collect personal information directly from you when you:

• Apply to open a BO or trading account;
• Complete KYC or account-opening documentation;
• Use our website or online portals;
• Use Smart OMS or other trading platforms;
• Use our mobile application;
• Place or manage orders;
• Make payments or transfers;
• Contact our customer service team;
• Submit a complaint or enquiry;
• Subscribe to communications;
• Participate in seminars, events, surveys, or campaigns; or
• Otherwise communicate or interact with us.

We may also obtain information from authorized third parties or publicly available sources where permitted or required by applicable law.

Such sources may include financial institutions, market infrastructure institutions, regulatory authorities, government agencies, exchanges, depositories, payment service providers, and other service providers, where applicable.

6. Why We Use Your Personal Information

We may process your personal information for the following purposes:

6.1 Account Opening and Account Administration

To:

• Process your BO and trading account application;
• Conduct KYC and customer due diligence;
• Verify your identity;
• Maintain your account;
• Update your account information;
• Provide account-related services; and
• Fulfil your instructions and requests.

6.2 Trading and Brokerage Services

To:

• Receive, process, transmit, and execute orders;
• Provide trading services;
• Maintain transaction records;
• Process settlements;
• Provide trade confirmations and statements and
• Provide other brokerage-related services.

6.3 Regulatory and Legal Compliance

We may process your information to comply with applicable laws, rules, regulations, directives, and requirements, including requirements relating to:

• Bangladesh Securities and Exchange Commission (BSEC);
• Dhaka Stock Exchange (DSE);
• Chittagong Stock Exchange (CSE);
• Central Depository Bangladesh Limited (CDBL);
• Anti-Money Laundering (AML);
• Counter-Terrorist Financing (CFT);
• Know Your Customer (KYC);
• Taxation and reporting;
• Fraud prevention;
• Regulatory reporting; and
• Other lawful obligations.

BSEC’s regulatory framework requires market intermediaries to maintain appropriate verification and KYC-related processes, among other regulatory obligations.

6.4 Security and Fraud Prevention

We may use personal and technical information to:

• Detect and prevent unauthorized activity;
• Protect accounts and digital platforms;
• Detect suspicious transactions;
• Investigate fraud or security incidents;
• Protect our systems and infrastructure; and
• Maintain the security and integrity of our services.

6.5 Customer Support

We may use your information to:

• Respond to enquiries;
• Resolve complaints;
• Provide technical assistance;
• Verify your identity before providing account information; and
• Communicate with you regarding your account or services.

6.6 Service Improvement

We may use information to:

• Improve our website and digital platforms;
• Improve our trading services;
• Analyze service performance;
• Understand how users interact with our platforms;
• Identify technical problems; and
• Develop new products and services.

Where appropriate, we may use aggregated or anonymized information for analytical purposes.

7. Cookies and Similar Technologies

Our website and digital services may use cookies, pixels, analytics tools, and similar technologies.

These technologies may help us:

• Remember user preferences;
• Maintain sessions;
• Improve website functionality;
• Understand website traffic;
• Analyze usage patterns;
• Improve user experience;
• Detect security threats; and
• Measure the effectiveness of our communications.

You may be able to control or disable cookies through your browser settings. However, disabling certain cookies may affect the functionality of some website features or services.

8. Do We Use Automated Processing?

We may use automated systems, statistical analysis, security tools, and other technologies to support activities such as:

• Security monitoring;
• Fraud detection;
• Risk management;
• Compliance monitoring;
• Transaction monitoring;
• System performance analysis; and
• Service improvement.

Where required by applicable law, appropriate human review or other safeguards may be applied to decisions involving significant effects on an individual.

9. Who May Receive or Access Your Information?

We may disclose or provide access to personal information where reasonably necessary for legitimate business, contractual, regulatory, or legal purposes.

Depending on the circumstances, recipients may include:

• Bangladesh Securities and Exchange Commission (BSEC);
• Dhaka Stock Exchange (DSE);
• Chittagong Stock Exchange (CSE);
• Central Depository Bangladesh Limited (CDBL);
• Government authorities and regulatory bodies;
• Law enforcement agencies;
• Tax authorities;
• Banks and authorized financial institutions and
• Other service providers or entities where disclosure is permitted, required, or necessary under applicable law.

We require third-party service providers handling information on our behalf to maintain appropriate safeguards and use information only for authorized purposes, subject to applicable agreements and requirements.

10. Third-Party Websites and Services

Our website, applications, or communications may contain links to third-party websites, applications, platforms, or services.

These third parties may have separate privacy policies and practices.

Smart Share is not responsible for the privacy practices, security, content, or policies of third-party websites or services that we do not control.

We recommend reviewing the applicable privacy policy of any third-party service before providing personal information.

11. Data Security

We take reasonable technical, administrative, and organizational measures to protect personal information against:

• Unauthorized access;
• Unauthorized disclosure;
• Accidental loss;
• Destruction;
• Alteration;
• Misuse;
• Fraud; and
• Other unlawful or unauthorized processing.

Security measures may include access controls, authentication mechanisms, monitoring, logging, system safeguards, and other appropriate controls.

However, no electronic transmission, storage system, or online service can be guaranteed to be completely secure.

You are responsible for maintaining the confidentiality of your account credentials, passwords, PINs, OTPs, and other authentication information and should never share such information with unauthorized persons.

12. Data Retention

We retain personal information only for as long as reasonably necessary to:

• Provide our services;
• Maintain and administer your account;
• Complete transactions and settlements;
• Fulfil regulatory and legal obligations;
• Meet record keeping requirements;
• Resolve disputes and complaints;
• Prevent fraud and misuse; or
• Protect our legitimate business interests.

Certain information may need to be retained for a specific period under applicable securities, tax, AML/CFT, accounting, or other regulatory requirements.

When information is no longer required, we may securely delete, destroy, anonymize, or archive it in accordance with applicable requirements and our internal retention policies.

13. Where Your Information Is Stored

Personal information may be stored and processed on systems operated by Smart Share or by authorized third-party technology, hosting, infrastructure, or service providers.

We take reasonable steps to ensure that information stored or processed by our service providers is subject to appropriate security and confidentiality measures.

Where applicable law imposes requirements concerning the location or transfer of personal information, we will handle such information in accordance with those requirements.

14. Direct Marketing and Communications

Subject to applicable law and your preferences, Smart Share may communicate with you regarding:

• Brokerage services;
• Trading services;
• Market updates;
• Investor education;
• New services or features;
• Notices and announcements;
• Seminars and events;
• Research or market information; and
• Other information that may be relevant to you.

Service-related and regulatory communications may continue even if you opt out of promotional communications where such communications are necessary for your account or required by law.

15. Your Communication Preferences

Where promotional communications are sent through channels that provide an opt-out or unsubscribe mechanism, you may use that mechanism to manage your preferences.

You may also contact Smart Share using the contact details provided in this Privacy Policy to request changes to your communication preferences.

Please note that opting out of marketing communications does not necessarily prevent us from sending important account, transaction, security, regulatory, or service-related communications.

16. Your Rights and Responsibilities

Subject to applicable law and regulatory requirements, you may have rights relating to your personal information, including the right to:

• Request access to certain personal information held by us;
• Request correction of inaccurate or incomplete information;
• Update your personal information;
• Ask questions about how your information is processed;
• Withdraw consent where processing is based on consent, where applicable; and
• Raise a complaint or concern regarding our handling of personal information.

Certain requests may be restricted or refused where we are legally required to retain or disclose information, where the request would interfere with regulatory obligations, or where other legal exceptions apply.

You should promptly notify Smart Share if any information provided to us becomes inaccurate or changes.

17. Complaints and Privacy Concerns

If you have a concern regarding the way Smart Share handles your personal information, we encourage you to contact us first so that we can investigate and address the matter.

You may contact:

Smart Share & Securities Ltd.
76/77, KM Tower (4th Floor)
Agrabad C/A, Chattogram, Bangladesh

Phone: 01958237923, 01958237924, 01958237925
Email: info@smartsharebd.com

We will review and respond to privacy-related enquiries or complaints in accordance with our applicable procedures and legal obligations.

18. Children’s Privacy

Our services are intended for persons who are legally eligible to open and operate the relevant investment or brokerage accounts.

We do not knowingly collect personal information from individuals who are not legally eligible to use our services.

If we become aware that personal information has been collected from an individual who is not eligible to use the relevant service, we may take appropriate steps in accordance with applicable law.

19. Changes to This Privacy Policy

Smart Share may update this Privacy Policy from time to time to reflect:

• Changes to our services;
• Changes to technology;
• Changes in regulatory or legal requirements;
• Changes in our data-processing practices; or
• Other operational requirements.

When material changes are made, we may update the policy on our website and, where appropriate, provide additional notice.

The updated version will become effective from the date stated at the beginning of the revised Privacy Policy.

We encourage you to review this page periodically to remain informed about how we protect your information.

20. Contact Us

For questions, requests, complaints, or concerns regarding this Privacy Policy, please contact Us.