Privacy Policy

We collect your personal data when you use our Platform, services or otherwise interact with us during the course of our relationship, and related information provided from time to time.

• 2.1 Information We Collect

◦ Personal Information

• ▪ Identity Information: Name, PAN, Aadhaar, date of birth, gender, photograph
• ▪ Contact Details: Address, email, phone number
• ▪ Demographic Information: Age, income, occupation, marital status
• ▪ KYC Documents: PAN card, Aadhaar card, address proof, income proof

◦ Financial Information

• ▪ Bank Account Details: Account number, IFSC code, bank name
• ▪ Investment Details: Portfolio holdings, transaction history
• ▪ Risk Profile: Risk appetite, investment objectives, time horizon
• ▪ Financial Goals: Retirement, education, wealth creation targets

◦ Technical Information

• ▪ Device Information: IP address, browser type, device type
• ▪ Usage Data: Pages visited, time spent, features used
• ▪ Cookies: Session cookies, authentication tokens
• ▪ Location Data: Approximate location based on IP address

• 2.2 How We Collect Information

◦ Direct Collection

• ▪ Account opening forms and applications
• ▪ Risk profiling questionnaires
• ▪ Client meetings and consultations
• ▪ Email and phone communications
• ▪ Document submissions

◦ Automated Collection

• ▪ Website and application usage analytics
• ▪ Cookies and similar technologies
• ▪ Server logs and error reports
• ▪ Security monitoring systems

◦ Third-Party Sources

• ▪ KYC registration agencies (KRAs)
• ▪ Credit bureaus (with consent)
• ▪ Brokers and depository participants
• ▪ Public databases and regulatory sources

• Voluntary Disclosure: You always have the option to not provide information, by choosing not to use a particular service or feature on the Platform.

• Third-Party Partner Policies: Users are governed by a third-party business partner's privacy policy when they collect data directly.

• Fraud Warning: Instructions to never provide sensitive data like PINs or passwords via email/call and to report any such requests.

We use personal data for the following purposes:

• 3.1 Purpose of Data Collection

◦ Service Delivery

• ▪ Providing investment advisory services
• ▪ Portfolio analysis and recommendations
• ▪ Risk profiling and asset allocation
• ▪ Client communication and support

◦ Regulatory Compliance

• ▪ KYC and AML compliance
• ▪ SEBI reporting requirements
• ▪ Tax compliance and reporting
• ▪ Audit and inspection requirements

◦ Business Operations

• ▪ Service improvement and development
• ▪ Client relationship management
• ▪ Marketing and communication (with consent)
• ▪ Research and analytics

• Note: Not providing permission may affect access to products/services.

We process your personal data based on:

• • Contractual Necessity: To provide advisory services as per agreement
• • Legal Obligations: Compliance with SEBI, PMLA, and other regulations
• • Legitimate Interests: Business operations and service improvement
• • Consent: For marketing communications and specific processing activities.

• Internal Sharing: Shared within group entities, other corporate entities, and affiliates to provide access to services and products (with opt-out for marketing).

• Sharing with Third Parties: Disclosed to sellers, business partners, service providers (logistics, payment issuers), and third-party reward programs.

• Legal & Fraud Prevention Disclosures:

• ◦ Required to comply with legal obligations, enforce user agreements, and facilitate marketing.
• ◦ To prevent, detect, mitigate, and investigate fraudulent or illegal activities.
• ◦ Disclosed to government/authorized law enforcement agencies if required by law (subpoenas, court orders).
• ◦ Disclosed to enforce Terms of Use/Privacy Policy, respond to claims of third-party rights violations, or protect the rights, property, or personal safety of users or the public.

• Security Measures: Adoption of reasonable security practices and procedures (including the use of a secure server) to protect personal data from unauthorized access, disclosure, loss, or misuse.

• User Responsibility: Users accept inherent security risks of data transmission over the internet and are responsible for protecting their login and password records.

• Deletion Option: Users can delete their account via profile/settings or by writing to the contact email.

• Refusal/Delay of Deletion: Deletion may be refused or delayed in the event of pending grievances, claims, shipments, or other services.

• Retention Period: Data is retained no longer than necessary for the purpose collected or as required by applicable law, though data may be retained to prevent fraud, for legitimate purposes, or in anonymized form for research.

• 8.1 Access and Correction

• ◦ Right to access your personal information
• ◦ Right to correct inaccurate or incomplete data
• ◦ Right to request data portability in machine-readable format
• ◦ Note: Users may access, rectify, and update their personal data directly through the Platform's functionalities.

• 8.2 Consent Management

• ◦ Right to withdraw consent for marketing communications
• ◦ Right to object to certain processing activities
• ◦ Right to restrict processing in specific circumstances

• 8.3 Erasure and Complaints

• ◦ Right to request erasure of personal data (subject to regulatory requirements)
• ◦ Right to file complaints with the Data Protection Board
• ◦ Right to grievance redressal through our internal mechanism

• 9.1 Types of Cookies

• ◦ Essential Cookies: Required for website functionality
• ◦ Analytical Cookies: Help us understand website usage
• ◦ Preference Cookies: Remember your settings and preferences
• ◦ Marketing Cookies: Used for targeted advertising (with consent)

• 9.2 Cookie Management

• ◦ You can manage cookie preferences through browser settings
• ◦ You can opt-out of non-essential cookies through our cookie banner
• ◦ Disabling essential cookies may affect website functionality

• Consent to Processing: By using the Platform, you consent to the collection, use, storage, disclosure, and processing of your information.

• Consent to Contact: Consent is given to the company, affiliates, and partners to contact the user via SMS, instant messaging, call, and/or e-mail.

• Withdrawal of Consent: Users have the option to withdraw consent by writing to the Grievance Officer, noting:

• ◦ The request is subject to verification.
• ◦ Withdrawal is not retrospective and is subject to Terms of Use, Privacy Policy, and applicable laws.
• ◦ The company reserves the right to restrict or deny services for which the information is considered necessary.

• Updates: The policy may be updated to reflect changes to information practices or to reflect regulatory changes.

• Notification: Significant or material changes may be alerted/notified as required under applicable laws, typically 30 days in advance.

• Acceptance & Archiving: Continued use constitutes acceptance of the updated policy. Previous versions are archived for reference.

• Name: Jayadrath Suresh Gunjal

• Contact us: support@kevalainvest.com

• Phone Time: Monday - Friday (9:00 - 18:00)