Privacy policy
What personal data we collect, why, how long we keep it, and the rights you have over it.
Not yet issued
This document is a draft. It has not been reviewed by a lawyer, it is not yet in force, and it should not be relied on. Ask us for the current terms before engaging any service.
This policy needs drafting against the Digital Personal Data Protection Act, 2023 and the rules made under it.
What we collect
When you use this website. Pages visited, approximate location derived from IP address, device and browser type, and referring site. Collected through analytics cookies only where you have consented.
When you submit an enquiry. Your name, email address, phone number, the service you asked about, the investment range you selected, and anything you wrote in the message field.
When you become a client. Identity and address documents, PAN, bank account details, income and net worth information, risk profile responses, nominee details, and transaction records — collected because KYC and AML obligations require it.
Why we use it
- To respond to your enquiry and arrange a consultation.
- To meet KYC, AML and record-keeping obligations under the Prevention of Money Laundering Act, 2002 and applicable SEBI and FIU-IND requirements.
- To provide, administer and report on the services you have engaged.
- To send the market note, where you have subscribed. You can unsubscribe from every one of those emails.
We do not sell your personal data. We do not share it for third-party marketing.
Who we share it with
(to be confirmed)
We also disclose data where required by law, to a regulator, or to a court.
How long we keep it
Client and transaction records are retained for the period required by law, which for records maintained under the Prevention of Money Laundering Act is generally five years from the end of the relationship or the transaction. Enquiries that do not become client relationships are deleted after (to be confirmed). Newsletter subscriptions are kept until you unsubscribe.
How we protect it
Data is encrypted in transit using TLS and at rest. Access is restricted to staff who need it. KYC documents are stored separately from general business data with additional access controls. (to be confirmed)
Your rights
Under the Digital Personal Data Protection Act, 2023 you may request access to your personal data, correction of inaccurate data, erasure where retention is not legally required, and withdrawal of consent where processing relies on it. You may also nominate someone to exercise these rights on your behalf.
To exercise any of these, contact our Data Protection Officer at (to be confirmed). We will respond within (to be confirmed).
Cookies
Strictly necessary cookies are set to make the site work. These keep you signed in, protect forms against cross-site request forgery, and enforce rate limits. They cannot be switched off without breaking the site, and they are not used to profile you.
Analytics cookies are set only with your consent. On your first visit a band appears at the foot of the page asking whether we may count your visit, with the option to refuse presented as plainly as the option to accept. Until you answer, no analytics script is loaded and no analytics cookie is set — a visitor who scrolls past the band and never answers is treated as having refused.
Your answer is recorded in your browser's local storage rather than sent to us. To change it, use the analytics link in the footer of any page: it clears your answer and shows the band again. Withdrawing consent also deletes the analytics cookies already set and reloads the page, so the script stops running immediately rather than at your next visit.
Where analytics is enabled, it is Google Analytics 4 with IP anonymisation on, which shortens your IP address before it is stored.
Complaints
If you are not satisfied with how we have handled your data, you may complain to the Data Protection Board of India.
Parts of this document are marked (to be confirmed). Those are details the firm has not settled yet, not terms being withheld. Ask us for anything you need before engaging a service, and treat nothing here as final until this notice is gone.