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With effect from 14th July 2011, both Benchmark Asset Management Company Private Limited (BAMC)
and Benchmark Trustee Company Private Limited (BTC) are a part of the Goldman Sachs group. Goldman Sachs is
a leading global investment banking, securities and investment management firm that provides a wide range of services
worldwide to a substantial and diversified client base that includes corporations, financial institutions,
governments and high-net-worth individuals. Founded in 1869, Goldman Sachs is one of the oldest and largest
investment banking firms. The entire share capital of BAMC is held by Goldman Sachs Asset Management (India)
Private Limited (the asset management company of Goldman Sachs Mutual Fund) and another Goldman Sachs group
company, whereas the entire share capital of BTC is held by Goldman Sachs Trustee Company (India) Private Limited
(the trustee company of Goldman Sachs Mutual Fund) and another Goldman Sachs group company.
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Privacy and Security
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Goldman Sachs Mutual Fund ("GSMF") was registered with the Securities and Exchange
Board of India ("SEBI") on August 26, 2008 under registration code MF- MF/058/08/03.
GSMF in India has been set up as a trust by Goldman Sachs Asset Management L.P.
(liability restricted to the seed corpus of INR 100,000) (the "Sponsor") with Goldman
Sachs Trustee Company (India) Pvt. Ltd. as the Trustee (the "Trustee") under the
Indian Trust Act, 1882 and with Goldman Sachs Asset Management (India) Private Limited
("GSAM") as the Investment Manager. SEBI approved GSAM to act as the investment
manager of GSMF pursuant to its letter bearing number IMD/AT/136521/2008, dated
September 1, 2008. All references to GSAM hereinafter shall mean and include its
affiliates, and their officers, directors, managing directors, partners, and employees.
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Your Privacy is Important to Goldman Sachs
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In the course of serving you as an individual client or as someone associated with
a corporate or institutional client, GSAM may obtain personal information about
you. Obtaining this information is important to our ability to deliver the highest
level of service to you, but we also recognize that you expect us to treat this
information appropriately.
This policy describes the types of personal information we may collect about you,
the purposes for which we use the information, the circumstances in which we may
share the information and the steps that we take to safeguard the information to
protect your privacy.
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The Sources of Information
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The personal information we collect about you comes primarily from the account applications
or other forms and materials you submit to GSAM during the course of your relationship
with us. We may also collect information about your transactions and experiences
with GSAM relating to the products and services GSAM provides. In addition, depending
on the products or services you require, GSAM may obtain additional information
about you, such as your credit history, from consumer reporting agencies.
Finally, in the provision of financial services to you and subject to strict compliance
with all applicable laws and regulations, information may be collected about you
indirectly from monitoring or other means (e.g. recording of telephone calls and
monitoring e-mails). In these circumstances, the information is not accessed on
a continuous or routine basis, but it may be used for compliance or security purposes.
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The Information We Have about You
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If you deal with GSAM in your individual capacity (e.g. as a private client), or
as a settlor/trustee/beneficiary of a trust, or as an owner or principal of a company
or other investment vehicle established to invest on your behalf or on behalf of
your family, etc., the typical information we collect about you, directly or indirectly,
may include:
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Your name, address and other contact details;
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Your age, occupation and marital status;
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Extensive financial information, including source of wealth, investment experience
and objectives, risk tolerance and, in certain jurisdictions, representations required
under applicable law or regulation concerning your financial resources;
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A head and shoulders photograph from, as applicable, your passport, national identity
card or driver's license, as required by laws and regulations addressing due diligence
and related matters; and
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A personal identifier such as, depending on your country of residence, your passport,
driving license, permanent account number card, etc.
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If you are an employee/officer/director/principal, etc. of one of our corporate
or institutional clients, the typical information we collect about you personally
would include:
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Your name, contact details;
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Your role/position/title and area of responsibility; and
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Certain identifying information (e.g. passport photo, etc.) as required by laws
and regulations addressing money laundering and related matters.
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The information requested from you may vary depending on the product you choose
to invest in. For further details please refer to the relevant product documents
available on this Web Site or contact GSAM at the details provided under “Additional
Information” below.
Of course, you are not required to supply any of the personal information that we
may request. However, failure to do so may result in our being unable to open or
maintain your account or to provide services to you. While we make every effort
to ensure that all information we hold about you is accurate, complete and up to
date, you can help us considerably in this regard by promptly notifying us if there
are any changes to your personal information.
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Our Use of Your Personal Information
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We may use your personal information to:
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maintaining the register of unitholders.
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process subscriptions, redemptions and payments of dividends to unitholders.
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perform controls on excessive trading, market timing and unfair or suspicious practices.
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comply with applicable anti-money laundering rules.
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Administer, operate, facilitate and manage your relationship and/or account with
GSAM. This may include sharing such information internally as well as disclosing
it to third parties, as described in the following two sections, respectively;
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Contact you or, if applicable, your designated representative(s) by post, telephone,
electronic mail, facsimile, etc., in connection with your relationship and/or account;
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Provide you with information (such as investment research), recommendations, or
advice concerning products and services offered by GSAM; and
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Facilitate our internal business operations, including assessing and managing risk
and fulfilling our legal and regulatory requirements.
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If your relationship with GSAM ends, GSAM will continue to treat your personal information,
to the extent we retain it, as described in this policy.
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Disclosures of Your Personal Information within GSAM
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In order to provide efficient and reliable services and to improve product and service
options available to you, more than one entity affiliated with GSAM may be given,
or given access to, your personal information. For example, one GSAM affiliate entity
might share your information with another in order to facilitate settlement of your
transactions or the maintenance of your accounts, or as part of its arranging for
the performance of specialized services. When so sharing your personal information,
we adhere to applicable legal and industry standards regarding the protection of
personal information. Additional information on how your personal information is
protected while within GSAM is provided below, under Information Security: How We
Protect Your Privacy.
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Disclosures of Your Personal Information to Third Parties
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GSAM does not disclose your personal information to third parties, except as described
in this policy, the Statement of Additional Information, other documents provided
by GSAM, this Web Site or otherwise. GSAM may share your personal information with
(a) the Sponsor or its associates, Trustee, registrar, banks and / or authorised
external third parties who are involved in transaction processing, dispatches, etc.
of the schemes or who have been appointed by the Trustee/GSAM to provide services
to the schemes, support services for your account, facilitate your transactions
with GSAM, and includes those that provide professional, legal or accounting advice
to GSAM; (b) distributors or sub-brokers through whom applications of investors
are received for the schemes; or (c) any other persons for compliance with any legal
or regulatory requirements or to verify the identity of investors for complying
with anti-money laundering requirements. Non-affiliated companies that assist GSAM
in providing services to you are required to maintain the confidentiality of such
information to the extent they receive it and to use your personal information only
in the course of providing such services and only for the purposes that GSAM dictates.
We may also disclose your personal information to fulfill your instructions, to
protect our rights and interests and those of our business partners or pursuant
to your express consent. Finally, under limited circumstances, your personal information
may be disclosed to third parties as permitted by, or to comply with, applicable
laws and regulations; for instance, when responding to a notice of demand or similar
legal process, to protect against fraud and to otherwise cooperate with law enforcement
or regulatory authorities or with organizations such as exchanges and clearinghouses.
Under certain circumstances, it may become necessary for GSAM to disclose the user's
personal information or to adhere to the bona fide requests of the government, court,
tribunal, authority or other regulatory agency and/or required by any law. In either
case GSAM shall be bound by and shall at all times have the legal right to disclose
any or all personal information given by the user to it and GSAM shall not be held
responsible or liable for any eventuality, loss and or damage that may arise from
its actions to the user.
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You should know that GSAM will not sell your personal information.
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Information Security: How We Protect Your Privacy
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GSAM is committed to protecting the privacy and confidentiality of your personal
information. We limit access to your personal information to authorized GSAM employees
or agents and, as described above in Disclosures of Your Personal Information to
Third Parties, our service providers are held to stringent standards of privacy.
We also maintain physical, electronic and procedural safeguards to protect the information
against loss, misuse, damage or modification and unauthorized access or disclosure.
Some of the other central features of our information security program are:
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A dedicated group – the Information Security Department – that designs, implements
and provides oversight to our information security program;
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The use of specialized technology such as firewalls;
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Testing of the security and operability of products and services before they are
introduced to the Internet, as well as ongoing scanning for publicly known vulnerabilities
in the technology;
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Internal and external reviews of our Internet sites and services
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Monitoring of our systems infrastructure to detect weaknesses and potential intrusions;
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Implementing controls to identify, authenticate and authorize access to various
systems or sites;
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Protecting information during transmission through various means including, where
appropriate, encryption; and
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Providing GSAM personnel with relevant training and continually updating our security
practices in light of new risks and developments in technology.
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Privacy and the Internet
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The following additional information will be of interest to you as a visitor to
this site:
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The private GSAM Web Sites are built upon a secure infrastructure with multiple
layers of protection, including measures ranging from proper physical security of
our machines to system intrusion detection capabilities. Within such private sites,
GSAM uses industry standard encryption technologies to protect your information
from external compromise.
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"Cookies" are small text files that may be placed on your Web browser when you visit
our Web Sites or when you view advertisements we have placed on other Web sites.
The information derived from cookies is used for administrative purposes, to help
us gauge the effectiveness of advertising efforts, and to improve your experience
with our Web Sites. For example, this information may help authenticate you (i.e.,
verify that you are who you say you are), an essential component of site security.
Cookies also make it easier for you to navigate a GSAM Web Site by, among other
things, “remembering” your identity so that you do not have to input your password
multiple times as you move between pages or services. Cookies also may be used to
serve you GSAM advertisements when you visit Web Sites of third parties with whom
we have marketing relationships. You can set your Web browser to inform you when
cookies are set, or to prevent cookies from being set. However, if you decline to
use cookies, you may experience reduced functionality and, for sites serving authentication-related
cookies, declining cookies will prevent you from using the Web Site altogether.
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"Clickstream" data (e.g., information regarding which of our Web pages you access,
the frequency of such access, and your product and service preferences) may be collected
by GSAM itself, or by our service providers, using cookies, Web beacons, page tags,
or similar tools that are set when you visit our Web Site or when you view an advertisement
we have placed on another Web site. Clickstream data and similar information may
be shared internally within GSAM and its affiliates and used: for administrative
purposes; to assess the usage, value and performance of our online products and
services; to improve your experience with our Web Sites; and as otherwise permitted
by applicable law or regulation. If you are a GSAM client, this information helps
us suggest products or service offerings that may be of interest to you. This information
may be processed by us for the purposes described above, or on our behalf by third
parties, solely in accordance with our instructions.
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When you visit this site, your browser may be momentarily directed to the Web Site
of an ad server or other third party service provider. This re-direction process
will not be apparent to you. These third party Web sites automatically receive your
IP address when this happens, and they may also collect information from your interaction
with our Web Sites including computer and connection information, standard Web log
information, and ad information. Such information does not identify you individually.
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GSAM may make available on this Web Site third party applications such as content
linking or sharing facilities. Information collected by providers of such applications
is governed by their privacy policies.
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Other Privacy Policies or Statements; Changes to Policy
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This policy provides a general statement of the ways in which GSAM protects your
personal information. You may, however, in connection with specific products or
services offered by GSAM, be provided with privacy policies or statements that supplement
this policy. This policy may be changed from time to time to reflect changes in
our practices concerning the collection and use of personal information. The revised
policy will be effective immediately upon posting to our Web Site. This version
of the Policy is effective August 14th 2011.
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Additional Information:
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GSAM may occasionally contact you by post, telephone, electronic mail, facsimile,
etc., with details of products and services that we believe may be of interest to
you. If you do not wish to be contacted in this way, if you wish to exercise your
rights of correction and access, or if you require further information regarding
our privacy policies and practices, please contact:
Goldman Sachs Asset Management (India) Private Limited
405,Raheja Chambers,
Free Press Journal Marg,
213,Nariman Point,
Mumbai - 400 021.
Tel No. : 022-66512727(B)
Fax No : 022 -2200 3412 / 6651 2740
This agreement is governed by the laws of India. Use of this Web Site is unauthorized
in any jurisdiction that does not give effect to all provisions of these terms and
conditions, including without limitation this paragraph. If any part of this agreement
is determined to be invalid or unenforceable pursuant to applicable law including,
but not limited to the warranty disclaimers and liability limitations set forth
above, then the invalid or unenforceable provision will be deemed superseded by
a valid, enforceable provision that most closely matches the intent of the original
provision and the remainder of the agreement shall continue in effect.
Issued by Goldman Sachs Asset Management Company (India) Private Limited, an asset
management company registered with the Securities and Exchange Board of India.
I confirm that I have read the Privacy and Security Policy and agree to abide by
same
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