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1. Introduction
Manoj Prabhu & Associates (“the Firm”, “we”, “us” or “our”) recognises the importance of privacy and the responsible handling of personal information received in connection with its website, professional engagements and related communications.
This Privacy Policy describes the categories of personal information that may be collected, the purposes for which such information may be processed, the circumstances in which it may be disclosed, and the practices governing its retention and protection.
This Policy applies to www.manojprabhu.com (“Website”) and, where applicable, electronic enquiries, recruitment submissions, authorised online accounts, document exchanges and digital facilities operated by the Firm.
Processing of personal information is subject to applicable Indian law, including relevant provisions of the Information Technology Act, 2000, the Digital Personal Data Protection Act, 2023, rules made thereunder as and when applicable, and other legal and professional obligations.
2. Scope and Application
This Policy applies to personal information collected or processed in connection with:
- Visits to and interactions with the Website.
- Enquiries submitted through online forms, email or other communication channels.
- Applications for employment, articleship or other professional opportunities.
- Proposed, existing or completed professional engagements.
- Client onboarding, identification and engagement administration.
- Documents and information submitted for taxation, audit, accounting, regulatory compliance or advisory assignments.
- Access to authorised client portals, document-sharing facilities or other digital services, where made available.
Information processed by the Firm solely on behalf of another organisation may also be governed by relevant engagement terms or contractual arrangements.
This Policy does not override applicable statutory obligations, professional duties or specific engagement terms imposing additional confidentiality, retention or disclosure requirements.
3. Categories of Information Collected
Depending on the nature of the interaction or professional engagement, the Firm may collect or receive the following information.
3.1 Contact and Identification Information
Names, email addresses, telephone numbers, correspondence addresses, designations, organisation names and information supplied when contacting the Firm.
3.2 Business and Professional Information
Business particulars, entity details, statutory registrations, authorised representative information and records relevant to a proposed or existing assignment.
3.3 Financial, Taxation and Regulatory Records
Where required for an agreed professional engagement, information may include financial statements, accounting records, tax computations, statutory filings, transaction details, identification documents, supporting schedules and records supplied by clients or authorised representatives.
3.4 Recruitment Information
Educational qualifications, employment history, professional experience, curriculum vitae, contact details and other information provided during recruitment processes.
3.5 Website and Technical Information
Depending on the technologies actually deployed, technical information may include IP addresses, browser and device information, access logs, session information, security events, cookies and similar technologies required for website operation, security or permitted analytics.
3.6 Client Account and Document Information
Where secure client accounts or document facilities are available, information may include account identifiers, access permissions, uploaded documents, document histories, assignment communications and authorised user activity.
The Firm seeks to limit collection to information relevant and reasonably necessary for the specified purpose.
4. Sources of Information
Personal information may be obtained:
- Directly from individuals contacting the Firm.
- From clients, their employees, directors or authorised representatives.
- Through enquiry and recruitment forms.
- Through documents submitted for professional engagements.
- From public records, statutory databases or official sources where access and use are legally permitted.
- From authorised professional advisers, service providers or other third parties.
Persons submitting information relating to another individual should have the appropriate legal basis or authority to disclose it.
5. Purposes of Processing
Personal information may be processed for the following purposes:
Professional Enquiries: To receive, evaluate, respond to and maintain records of enquiries concerning the Firm's services.
Engagement Administration: To assess assignments, establish engagement terms, maintain correspondence and administer professional relationships.
Professional Services: To undertake taxation, audit, accounting, regulatory compliance, corporate, financial advisory and other engagements within the Firm's professional scope.
Statutory and Professional Compliance: To comply with applicable laws, regulatory requirements, professional standards, recordkeeping obligations and lawful requests from competent authorities.
Recruitment: To evaluate applications, communicate with candidates and administer recruitment procedures.
Website Operation and Security: To maintain website functionality, manage authorised access, investigate technical issues and protect systems against misuse.
Document and Workflow Management: To facilitate authorised document exchange, assignment management, reporting and communications where digital facilities are made available.
Legal and Administrative Purposes: To establish, exercise or defend legal rights, resolve disputes and maintain records required for legitimate professional or statutory purposes.
Information will not be processed for unrelated purposes without an appropriate legal basis or authority under applicable law.
6. Consent and Other Lawful Grounds
Where consent is required under applicable law, the Firm will seek and process personal information on a basis satisfying the relevant legal requirements.
In other circumstances, information may be processed where permitted or required under applicable law, including for specified professional, statutory, regulatory or other lawful purposes.
The applicable basis for processing depends on the nature of the information, the relationship with the individual, the purpose of processing and the legal provisions in force at the relevant time.
Where legally available, individuals may withdraw consent by contacting the Firm.
Withdrawal will not necessarily affect processing undertaken before withdrawal or information that the Firm is required or permitted to retain or process under applicable law.
7. Professional Confidentiality
Information received in connection with professional engagements is subject to applicable duties of confidentiality, professional standards, legal requirements and engagement terms.
Access to engagement-related records is intended to be limited to persons requiring such access for authorised professional, administrative, technical or compliance purposes.
Information may be disclosed where required or permitted by law, professional requirements, competent authorities or appropriately authorised instructions.
Confidentiality obligations applicable to specific professional engagements may extend beyond this general Website Privacy Policy.
8. Disclosure and Sharing of Information
Personal information may be disclosed, to the extent appropriate and legally permissible, to the following categories of recipients.
8.1 Authorised Personnel
Partners, employees, professional staff and other authorised personnel involved in the relevant engagement, administration or support function.
8.2 Professional Advisers and Service Providers
External professional advisers, technology providers, hosting providers, document-storage providers or other service providers where their involvement is necessary and appropriately authorised.
8.3 Government and Statutory Authorities
Tax authorities, regulatory bodies, courts, tribunals, law-enforcement agencies or other competent authorities where disclosure is required or permitted under applicable law or authorised procedures.
8.4 Client-Authorised Recipients
Banks, financial institutions, professional advisers, business counterparties or other recipients where disclosure forms part of an authorised engagement and is legally permissible.
The Firm does not sell personal information to advertisers or data brokers.
Information is not disclosed to third parties for their independent promotional purposes without an appropriate lawful basis.
10. Information Security
The Firm seeks to apply reasonable technical and organisational safeguards appropriate to the nature of information processed and associated risks.
Such safeguards may include, where implemented:
- Access restrictions and user authentication.
- Role-based permissions for confidential records.
- Secure transmission and storage mechanisms.
- Controls for document uploads and downloads.
- Administrative and technical monitoring.
- Backup, recovery and incident-response arrangements.
- Restrictions on unauthorised access.
No electronic transmission, information system or storage environment can be guaranteed to be completely secure.
Individuals should exercise reasonable care when submitting information electronically and avoid sending unnecessary sensitive documents through ordinary enquiry forms or unsecured communications.
11. Document Uploads and Client Portals
Where the Firm provides an authorised client portal or document-sharing facility, access may be restricted to registered or approved users.
Documents uploaded through such facilities may be used to carry out the relevant engagement, review records, prepare working papers, maintain correspondence or deliver agreed outputs.
Access to client records should be governed by applicable permissions and professional responsibilities.
Users should ensure that documents are relevant to the intended assignment and that they are authorised to submit the information contained in them.
The availability of a document-upload facility does not, by itself, establish a professional engagement or constitute acceptance of an assignment.
Additional conditions or engagement-specific requirements may apply.
12. Data Retention
Personal information is retained for periods reasonably necessary for the purposes for which it is processed, subject to applicable legal, regulatory, professional and contractual requirements.
Retention periods may vary according to information category and purpose.
For example:
- Enquiry records may be retained for correspondence and administrative follow-up.
- Recruitment records may be retained for recruitment administration and applicable legal purposes.
- Client identification and engagement records may be subject to statutory or professional retention obligations.
- Accounting, taxation, audit and regulatory records may require retention for prescribed periods.
- Technical and security records may be retained for administration, investigation and security purposes.
Where information is no longer required and no applicable retention obligation or lawful reason for continued processing exists, appropriate deletion, anonymisation or other lawful disposal procedures should be followed.
Deletion requests may be subject to applicable legal and professional retention requirements.
13. Rights Relating to Personal Data
Subject to applicable law, its commencement provisions and relevant statutory conditions, individuals may have rights concerning personal information processed by the Firm.
These may include rights to:
- Obtain prescribed information concerning personal data processing.
- Request correction, completion or updating of inaccurate or incomplete information.
- Request erasure where applicable conditions are satisfied.
- Withdraw consent where processing is based on consent.
- Seek grievance redressal through the applicable mechanism.
- Exercise other rights available under applicable law.
Requests may require reasonable verification of identity or authority before disclosure, correction or deletion is undertaken.
The Firm may decline, limit or defer a request where permitted or required by law, including where information must be retained for statutory compliance, professional obligations or legal proceedings.
14. Personal Data of Other Individuals
Clients and other persons submitting information concerning employees, directors, shareholders, business counterparties, family members or other individuals should ensure the information is supplied in accordance with applicable law and relevant authority.
The Firm may request confirmation of authority where necessary.
Individuals should avoid submitting unrelated personal information or documents not required for the relevant professional purpose.
15. Third-Party Websites and External Platforms
The Website may contain links to external websites, statutory portals, professional resources or social media platforms.
External platforms operate under their own privacy policies, terms and security practices.
The Firm is not responsible for independent data-processing practices of third-party websites merely because links appear on this Website.
Users should review the relevant privacy notices before submitting personal information to external services.
16. International Processing and Service Providers
Where technology, hosting or professional service providers have systems or personnel located outside India, personal information may be processed or accessed across jurisdictions, subject to applicable law and appropriate contractual and security arrangements.
Such processing should be assessed with reference to applicable restrictions, confidentiality obligations, client arrangements and the nature of the information involved.
This provision does not represent that any particular international transfer currently takes place.
17. Personal Data Breaches and Incidents
Where a suspected or confirmed personal data breach or security incident occurs, the Firm will assess the incident and undertake appropriate containment, investigation and remedial measures.
Notifications to affected individuals, regulators or other authorities will be made where required under applicable law.
Individuals who believe information submitted through the Website has been accessed or used without authorisation may contact the Firm using the designated enquiry channel.
18. Changes to This Policy
The Firm may revise this Privacy Policy to reflect changes in applicable law, professional requirements, technology, website functionality or information-processing practices.
The revised Policy will be published on the Website with an updated effective or revision date.
Where applicable law requires additional notice or consent in connection with a material change, the relevant requirements will be addressed separately.
19. Privacy Enquiries and Grievance Redressal
Individuals seeking information regarding the processing of their personal data, or wishing to submit a request concerning access, correction, updating, erasure, withdrawal of consent or any other privacy-related matter, may contact the Firm through its designated enquiry facility.
Privacy-related requests will be reviewed in accordance with applicable law and the nature of the request. The Firm may require reasonable verification of identity or authority before processing requests involving personal information.
Where applicable, statutory grievance redressal procedures and timelines shall be followed.
The Firm's general correspondence details are available on the Contact Us page.
20. Interpretation
This Privacy Policy explains the Firm's information-handling practices and does not limit rights or obligations arising under applicable law.
In the event of inconsistency between this Policy and a mandatory legal requirement, the applicable legal requirement shall prevail.
Nothing in this Policy is intended to waive professional confidentiality obligations, statutory rights or duties imposed by law.