PRIVACY POLICY

1. Introduction and Scope

This Privacy Policy (“Policy”) governs the collection, use, storage, sharing, and protection of personal data through this website and related digital platforms (“Platform”).

Under the Digital Personal Data Protection Act, 2023 (“DPDP Act”), Wealth Company Private Limited (WCPL) acts as the Data Fiduciary.

WCPL operates as a distributor of SEBI-regulated financial products including AIFs, PMS, Mutual Funds, and other investment products.

  • Wealth Company Asset Management Private Limited (AIF Investment Manager)
  • Wealth Company Asset Management Holdings Private Limited (AMC of Mutual Fund)

Each entity operates independently within its regulatory capacity. This Policy applies only to WCPL.

2. Data Fiduciary Status

WCPL acts as the Data Fiduciary for personal data collected through this Platform. Data shared with third parties is processed strictly for lawful and regulatory purposes.

3. Regulatory Framework

  • Digital Personal Data Protection Act, 2023
  • Information Technology Act, 2000
  • IT Rules, 2011 (SPDI)
  • SEBI Regulations
  • PMLA and KYC requirements

4. Data Minimisation

We collect only necessary personal data required for lawful purposes, regulatory compliance, and service delivery.

5. Personal Data Collected

  • Identity and contact details
  • PAN, Aadhaar (where permitted), KYC documents
  • Financial information
  • Investment preferences and transaction history
  • Device and technical information
  • Communication records

Publicly available information is not treated as personal data.

6. Purpose of Processing

  • KYC and onboarding
  • Distribution of financial products
  • Regulatory compliance
  • Transaction execution
  • Risk management
  • Investor servicing
  • Fraud prevention

7. Legal Basis

  • Consent
  • Legal and regulatory obligations
  • Contractual necessity
  • Legitimate business purposes

You may withdraw consent at any time, subject to legal and regulatory retention requirements.

8. Sharing of Personal Data

  • AIF Managers
  • Portfolio Managers
  • Asset Management Companies
  • RTAs
  • Depositories and exchanges
  • Banks and payment providers
  • KYC Registration Agencies
  • Regulators
  • Technology service providers

9. Cross-Border Processing

Data is primarily stored in India. Where cross-border processing occurs, appropriate safeguards are implemented.

10. Cookies and Tracking

  • Improve performance
  • Enhance user experience
  • Analytics
  • Session security

11. Security Measures

  • Encryption
  • Secure infrastructure
  • Role-based access
  • Multi-factor authentication
  • Periodic audits

Absolute security cannot be guaranteed.

12. Data Breach

In case of a breach, affected users and authorities will be notified as per applicable laws.

13. Retention of Data

  • As long as required for purpose
  • As per statutory requirements
  • As per SEBI / PMLA / regulatory mandates

14. Your Rights

  • Access your data
  • Correct inaccuracies
  • Request deletion (subject to law)
  • Withdraw consent
  • Nominate a representative
  • Lodge grievances

15. Governing Law

This Policy is governed by Indian law.

16. Third-Party Websites

We are not responsible for third-party privacy practices. Please review their policies separately.

17. Grievance Redressal

Name: Dinkal Shah

Designation: Grievance Officer

Email: Wealth@wealthcompany.in

18. Updates to Policy

This Policy may be updated periodically. Continued use constitutes acceptance of the latest version.