Privacy Policy
Last Updated: 15/10/2026
Welcome to True Wealth Co., the brand of TWFP Finserv LLP, an AMFI-Registered Mutual Fund Distributor (ARN: 308 424) having its registered office in Mumbai, Maharashtra, India. The Company facilitates the distribution of mutual fund schemes and other eligible financial products in accordance with applicable laws and regulations, including the Securities and Exchange Board of India (SEBI) regulations, the AMFI Code of Conduct, and the Digital Personal Data Protection Act, 2023 (DPDP Act).
True Wealth Co. is committed to protecting the privacy and personal data of its clients, investors, website visitors, and other users ("Users"). This Privacy Policy describes how the Company collects, receives, uses, processes, stores, discloses, shares, retains, and safeguards personal data obtained through its website, digital platforms, authorised third-party applications, and the services provided by the Company.
This Privacy Policy applies to all users who access or use the Company's website, digital platforms, authorised third-party applications, or services, or otherwise provide personal data to the Company. By accessing or using the Company's website or services, you acknowledge that you have read, understood, and consent to the collection, use, processing, storage, disclosure, and protection of your personal data in accordance with this Privacy Policy.
This Privacy Policy shall be read together with the Company's Terms & Conditions and forms an integral part thereof. In the event of any inconsistency between this Privacy Policy and the Terms & Conditions concerning the processing of personal data, the provisions of this Privacy Policy shall prevail to the extent of such inconsistency.
This Privacy Policy has been formulated in accordance with the Digital Personal Data Protection Act, 2023 (DPDP Act), the applicable regulations issued by the Securities and Exchange Board of India (SEBI), the AMFI Code of Conduct, and other applicable laws governing the collection, processing, storage, use, and protection of personal data.
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Definitions
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“data” means a representation of information, facts, concepts, opinions or instructions in a manner suitable for communication, interpretation or processing by human beings or by automated means.
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“personal data” means any data about an individual who is identifiable by or in relation to such data
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“Data Principal” means the individual to whom the personal data relates and where such individual is—
i) a child, includes the parents or lawful guardian of such a child;
(ii) a person with disability, includes her lawful guardian, acting on her behalf
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“processing” in relation to personal data, means a wholly or partly automated operation or set of operations performed on digital personal data, and includes operations such as collection, recording, organisation, structuring, storage, adaptation, retrieval, use, alignment or combination, indexing, sharing, disclosure by transmission, dissemination or otherwise making available, restriction, erasure or destruction
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"Third-Party Application" means any software application, platform, portal, or digital interface owned or operated by a third party and authorised by the Company for the purpose of enabling users to access, facilitate, or avail the Company's services.
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"Third-Party Service Provider" means any individual, organisation, institution, intermediary, or entity engaged by or associated with the Company for the purpose of facilitating, supporting, enabling, or providing services in connection with the Company's business operations or the services offered to its clients, including but not limited to Asset Management Companies (AMCs), Registrars and Transfer Agents (RTAs), banks, payment gateways, depositories, technology service providers, cloud service providers, analytics providers, and other authorised business partners.
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Consent and Acceptance of Privacy Policy:
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This Privacy Policy shall be read together with, and forms an integral part of, the Company's Terms & Conditions.
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By accessing, browsing, or using the Company's website, digital platforms, authorised third-party applications, or services, you acknowledge that you have read, understood, and accepted both the Terms & Conditions and this Privacy Policy.
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You further provide your consent, to the extent required under applicable law, to the Company's collection, receipt, storage, processing, use, disclosure, sharing, retention, and protection of your personal data in accordance with this Privacy Policy and applicable laws, including the Digital Personal Data Protection Act, 2023 (DPDP Act).
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Privacy Policy
This Privacy Policy applies to all interactions with the Company involving the collection or processing of personal data, including but not limited to the Company's official website (desktop and mobile versions), authorised third-party applications (desktop and mobile versions), contact forms, enquiry forms, email communications, telephone communications, social media platforms, messaging services, and any other digital or offline communication channels used by the Company.
A. Introduction:
The information we collect may vary depending on the nature of your relationship with us and the services you seek or receive. Different categories of individuals or entities, including prospective clients, existing clients, representatives of companies or other organisations, service providers, and other persons interacting with us, may be required to provide different types of information.Accordingly, we do not necessarily collect all of the information listed below from every individual or entity. The information collected will depend on the applicable onboarding process, services requested, regulatory or legal requirements, and the nature of our interaction with you.The categories of personal and other information that we may collect include, where applicable:
1. Individual Clients:
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Full name
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Mobile/telephone number
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Email address
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Date of birth
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Occupation
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Photograph
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Aadhaar Card details
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Birth Certificate, where required
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Permanent Account Number (PAN)
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Bank account statements
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Know Your Customer (KYC) status and related KYC information
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Other information or documents required for verification and onboarding
2. Non-Resident Indian (NRI) Clients:
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Full name and contact details
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Date of birth and occupation
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Passport and passport-related details
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Overseas Citizen of India (OCI) Card, where applicable
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Permanent Account Number (PAN)
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Bank account statements
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Driving Licence
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Utility bills or other address proof
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Photograph
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Know Your Customer (KYC) information and status
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Other documents required for identity, address, residency and regulatory verification
3. Corporate Clients / Companies:
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Company name and contact details
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Company Permanent Account Number (PAN)
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Company bank account statements
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Certificate of Incorporation (COI)
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Memorandum of Association (MOA)
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Articles of Association (AOA)
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Board Resolution (BR)
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Authorised Signatory List (ASL)
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Details and identification documents of authorised signatories
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Details of directors, beneficial owners and other relevant representatives, where applicable
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Balance Sheet and other financial statements
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Know Your Customer (KYC) and other due diligence information
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Other corporate, financial and regulatory documents required for onboarding and verification
B. Additional Information for Regulatory Compliance:
We may request additional information, documents or details from you where required to comply with applicable laws, regulations, regulatory requirements, Know Your Customer (KYC) obligations, anti-money laundering requirements, tax requirements, or directions issued by competent regulatory or governmental authorities. Such information may be requested from time to time depending on the circumstances and requirements applicable to the relevant client or entity.
C. Technical and Usage Information:
When you visit or interact with our website, we may automatically collect certain technical and usage information, either directly or through service providers and third-party technologies used by us. This may include, where applicable:
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Internet Protocol (IP) address
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Browser type and version
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Device type and information
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Operating System
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Cookies and similar technologies
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Website activity, including pages visited, interactions and access times
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Referring website or source
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General location information derived from technical data, where applicable
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Other technical, diagnostic and usage information generated through your interaction with our website
The information collected may vary depending on the technologies, analytics tools, security services and other third-party services integrated with our website.
D. Third-Party Platforms and Applications:
We may use authorised third-party applications, platforms and service providers to support certain services, including portfolio tracking, client servicing, reporting, communication, verification and other operational or regulatory requirements.
Where you use or interact with such third-party platforms, the relevant information may be collected, processed or stored by the applicable third-party service provider in accordance with the services provided and their applicable privacy policies and terms.
The nature and extent of information processed through such platforms may vary depending on the service, your relationship with us and the applicable legal, regulatory and contractual requirements.
E. Communication and Enquiry Information:
When you contact us, request a call, submit an enquiry, schedule a consultation, or otherwise communicate with us, we may collect and process information provided by you through the relevant communication or enquiry channel.
This may include:
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Name
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Mobile or telephone number
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Email address
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Type or category of client
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Purpose or nature of the enquiry
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Details provided in your enquiry, request or communication
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Appointment or consultation details, where applicable
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Feedback, comments or responses provided by you
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Information exchanged through email, telephone calls, WhatsApp or other communication channels used by us
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Records of communications and correspondence, where required for business, service, security, compliance or record-keeping purposes
We may use website forms and workflow automation tools, including Wix-based forms and workflows, to receive, organise and manage call requests, enquiries and consultation requests submitted by visitors.
F. Risk Profiling and Assessment:
We may, where applicable, provide questionnaires, assessments or other tools designed to understand your financial objectives, investment preferences, risk tolerance, investment experience and related requirements.
Such assessments may require you to provide information relevant to your financial circumstances, preferences, objectives and other factors necessary for the assessment. The information collected through such tools will depend on the questions and assessment applicable at the time.
We may use the information obtained through these assessments for purposes including understanding your requirements, conducting suitability or risk assessments where applicable, providing relevant services, and meeting applicable regulatory or compliance requirements.
We may introduce or modify such assessment tools from time to time, and the categories of information collected may therefore vary depending on the applicable assessment.
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A. Introduction:
We may collect information through various sources and channels, depending on the nature of our relationship with you, the services requested, and the applicable legal and regulatory requirements.
B.Information may be collected:
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Directly from you, when you provide information to us during onboarding, consultations, communications, applications or other interactions.
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Through website forms, including contact forms, enquiry forms, request-a-call forms and appointment or consultation booking forms available on our website.
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Through Know Your Customer (KYC) documentation, identity and address verification documents, and other documents provided for client onboarding and verification.
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Through Mutual Fund application forms and other investment-related forms or documentation submitted by you.
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From Asset Management Companies (AMCs) and other financial product providers, where information is shared with us in connection with your investments, transactions or servicing requirements.
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From Registrar and Transfer Agents (RTAs) in connection with mutual fund holdings, transactions, account servicing and related activities, where applicable.
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From banks and other financial institutions, where information is required or made available in connection with investment transactions, verification or servicing.
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Through authorised third-party platforms and service providers used by us for purposes such as portfolio tracking, client servicing, communication, verification, reporting, appointment management and other operational or regulatory requirements.
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Through communications and interactions, including email, telephone, WhatsApp and other communication channels used by us.
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From publicly available or legally accessible sources, where permitted under applicable law and where relevant to our services, verification or compliance requirements.
The source and type of information collected may vary depending on whether you are an individual client, Non-Resident Indian (NRI), company or other entity, and the nature of the services or transactions involved.
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We may collect, use and process personal, financial and other information for the following purposes, as applicable to the nature of our relationship with you and the services requested:
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KYC and Identity Verification:
To conduct, verify and maintain Know Your Customer (KYC) requirements, identity verification and other due diligence processes in accordance with applicable laws, regulations and regulatory requirements.
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Opening and Maintaining Investment Accounts:
To facilitate the opening, maintenance and servicing of investment accounts, folios and other accounts or arrangements requested by you.
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Processing and Executing Transactions:
To process and execute investment instructions and transactions requested or authorised by you, including purchases, redemptions, switches and other permitted investment-related transactions.
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Financial and Investment Services:
To understand your financial circumstances, investment objectives, preferences, existing investments and requirements in order to provide relevant services and, where applicable, facilitate or provide investment-related information, recommendations or product-related assistance within the scope of our services and applicable regulations.
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Client Communication:
To communicate with you regarding your investments, transactions, accounts, appointments, enquiries, service updates, documentation, requests and other matters relating to our services through channels such as email, telephone, WhatsApp or other communication methods.
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Customer Support and Assistance:
To provide customer support, guidance and assistance throughout the onboarding, investment and servicing process, including responding to enquiries, resolving requests and providing necessary hand-holding where required.
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Risk Profiling and Assessment:
To conduct risk profiling and related assessments, where required by applicable regulations, where necessary for our services, or where requested by you, in order to understand your risk tolerance, investment objectives, preferences and related requirements and support informed investment decision-making.
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Compliance and Regulatory Obligations:
To conduct compliance checks, due diligence, monitoring and reporting and to fulfil obligations imposed by applicable laws, regulations, regulatory authorities and other competent governmental authorities.
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Fraud Prevention and Security:
To detect, prevent, investigate and take appropriate action in relation to suspected or actual fraud, illegal activities, unauthorised activities, misuse of our website or authorised third-party applications, security incidents or violations of applicable terms, policies or laws.
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Record Keeping and Internal Administration:
To maintain accurate records relating to clients, transactions, communications, investments, KYC documentation, compliance activities and other business and regulatory requirements.
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Service Improvement:
To understand client requirements, preferences and interactions and to improve the quality, efficiency and relevance of our services, processes, website and client experience.
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Legal and Regulatory Requests:
To respond to lawful requests, notices, investigations, proceedings or directions from courts, regulators, governmental authorities, law-enforcement agencies or other competent authorities, where required or permitted by applicable law.
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Protection of Rights and Interests:
To establish, exercise or defend our legal rights, protect our business, clients and service providers, and address disputes, complaints or claims where necessary.
The purposes for which information is processed may vary depending on the nature of the client, the services or products involved, the applicable regulatory requirements and the circumstances of the particular interaction.
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We process personal and financial information on one or more lawful bases, depending on the nature of the information, the purpose of processing and the circumstances in which the information is collected. These may include:
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Consent:
Where required or appropriate, we may process your information based on your consent. You may have the right to withdraw your consent where applicable, subject to any legal or regulatory obligations that require us to continue processing certain information.
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Legal and Regulatory Obligations:
We may process information where necessary to comply with applicable laws, regulations, regulatory requirements, directions, orders or obligations imposed by competent authorities, including requirements relating to Know Your Customer (KYC), anti-money laundering, taxation, reporting and other applicable compliance obligations.
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Contractual and Service-Related Purposes:
We may process information where necessary to establish, perform or manage our relationship with you, provide the services requested by you, facilitate onboarding, process transactions, maintain accounts or otherwise fulfil our obligations in connection with the services provided.
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Regulatory and Compliance Requirements:
We may process information to fulfil requirements applicable to our business as a financial services provider, including compliance, verification, monitoring, record keeping, reporting and audit requirements.
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Legitimate or Other Lawful Purposes, Where Applicable:
We may process information where permitted by applicable law for purposes such as preventing fraud, maintaining the security of our systems and services, protecting our legal rights and interests, investigating misuse or unauthorised activity, and responding to lawful requests from competent authorities.
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A. Introduction:
We may share personal, financial and other information with authorised third parties where such sharing is necessary to provide our services, facilitate transactions, fulfil contractual or service-related requirements, comply with applicable laws and regulations, meet regulatory obligations, protect our rights and interests, or prevent fraud and misuse.
The information shared and the parties with whom it is shared will depend on the nature of the service, transaction, client relationship and applicable legal or regulatory requirements.
B. Where we share information, wherever applicable:
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Asset Management Companies (AMCs):
We may share relevant client and investment information with Asset Management Companies (AMCs) to facilitate mutual fund investments, transactions, account servicing and other financial services.
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Registrar and Transfer Agents (RTAs):
Information may be shared with Registrar and Transfer Agents (RTAs) for purposes including transaction processing, maintaining investment records, servicing folios, processing requests and other activities related to mutual fund investments.
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Banks and Payment Service Providers:
We may share relevant information with banks, payment gateways and other authorised payment service providers where necessary to facilitate investment-related payments, transactions, verification and settlement.
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Association of Mutual Funds in India (AMFI):
Information may be shared with the Association of Mutual Funds in India (AMFI) where required for applicable compliance, reporting, verification or regulatory purposes.
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Securities and Exchange Board of India (SEBI):
We may provide information to the Securities and Exchange Board of India (SEBI) where required by applicable laws, regulations, directions, orders or regulatory requirements.
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Government, Regulatory and Legal Authorities:
We may disclose information to courts, law-enforcement agencies, government authorities, regulators or other competent authorities where required or permitted by applicable law, including in connection with legal proceedings, investigations, fraud prevention, compliance or enforcement matters.
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Technology and Service Providers:
We may share relevant information with authorised technology vendors and service providers that support our operations, including platforms used for portfolio tracking, client servicing, communication, website hosting, appointment scheduling, data processing, security, reporting and other business functions. Such parties may process information only to the extent necessary for the services they provide to us and subject to applicable contractual and legal requirements.
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Professional and Other Service Providers:
Where necessary, we may share relevant information with professional advisers, auditors, consultants, legal advisers and other authorised service providers for legitimate business, legal, regulatory, compliance or operational purposes.
C. Your Information Is Not Sold:
We do not sell or commercially trade your personal information to third parties for their independent marketing or commercial purposes.
D. Disclosure When Required or Permitted:
We may disclose information where we have a genuine and legitimate requirement to do so, including where necessary to provide or facilitate services, process transactions, fulfil legal or regulatory obligations, respond to lawful requests, protect our rights and interests, prevent fraud or misuse, or otherwise as permitted under applicable law.
Where applicable, information may also be shared based on your consent or authorisation, subject to the terms of such consent and applicable law.
E. Violation of Intellectual Property Rights:
Any unauthorised use of the Company's intellectual property may result in the suspension or termination of access to the Company's website or services and may attract appropriate civil or criminal remedies available under applicable law.
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If you do not wish to provide or share your personal information, or if you wish to withdraw consent previously provided by you, you may contact us using the contact details provided in this Privacy Policy.
You may also request access, correction, updating or deletion of your personal information, where applicable under the law.
Please note that withdrawal of consent or a request for deletion may not affect processing that is necessary to comply with applicable legal or regulatory obligations, complete or maintain records of transactions, fulfil contractual or service-related requirements, or otherwise process information where permitted or required by applicable law.
A. Introduction:
At True Wealth Co., we recognise the importance of protecting personal, financial and other confidential information entrusted to us. We seek to implement appropriate technical, organisational and administrative safeguards to protect such information against unauthorised access, disclosure, alteration, loss or misuse.
The security measures applicable to your information may vary depending on the nature of the information, the system through which it is processed, and the services provided.
B. Information Processed Through Third-Party Applications:
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We use authorised third-party applications, including Investwell, to support portfolio tracking, client servicing and other financial services.
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According to the security information provided by Investwell, its infrastructure incorporates measures such as encryption, secure communication protocols, access controls, firewalls, data backups and other security mechanisms designed to protect information processed through its platform.
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Information processed through such applications is subject to the applicable security practices, terms and privacy policies of the respective service providers, in addition to our own responsibilities for handling and accessing such information.
C. Information Collected Through Our Website:
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Our website is hosted on the Wix platform. Information submitted through our website forms, including contact forms and request-a-call forms, may be processed and stored through Wix's infrastructure.
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Wix describes security measures that include HTTPS and TLS encryption for data transmission, encryption of stored data, access controls, security monitoring and other technical and organisational safeguards.
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Access to information submitted through our website is managed through the applicable account permissions and administrative controls. We seek to restrict access to such information to authorised persons who require it for legitimate business purposes.
D. Storage of Client Documents:
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Documents provided by clients during onboarding, identity verification, KYC procedures and other financial or regulatory processes may include PAN cards, Aadhaar-related documents, bank statements and other personal or financial records.
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Such documents may be stored electronically in password-protected folders on our computer systems. Access to these documents is intended to be limited to authorised persons for legitimate business, service-related and compliance purposes.
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We take reasonable steps to handle these documents responsibly and to protect them against unauthorised access, disclosure, loss or misuse.
E. Use of Third-Party Service Providers:
We may rely on authorised technology providers and other service providers to host, process, store, manage or transmit information necessary for our operations.
These providers may maintain their own security infrastructure and data protection practices. The processing of information through such providers is subject to the applicable arrangements, terms and legal requirements governing their services.
F. Limitations and Security Incidents:
While we take reasonable measures to protect personal and financial information, no electronic storage system, digital platform or method of data transmission can be guaranteed to be completely secure.
If a security incident affecting personal information occurs, we will take appropriate steps in accordance with applicable legal and regulatory requirements.
H. Client Responsibility:
Clients should exercise reasonable care when sharing personal or financial information and should provide such information only through the communication channels or processes designated by us.
We encourage clients to contact us if they have concerns regarding the security or handling of their information.
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True Wealth Co. may facilitate financial services and investment opportunities relating to international markets. Certain such transactions may be facilitated through GIFT City (Gujarat International Finance Tec-City) / International Financial Services Centre (IFSC) in India and are subject to the applicable rules, regulations, protocols and compliance requirements governing such transactions.
Any personal, financial or other information that is collected, processed, transferred or otherwise handled by the relevant authorised entities, financial institutions, intermediaries or service providers in connection with such international transactions will be subject to their respective privacy policies, terms and applicable regulatory requirements.
To the extent that such processing or data handling is undertaken independently by such entities and is outside the systems, control or processing activities of True Wealth Co., such processing and the associated privacy practices do not fall within the scope of this Privacy Policy, and True Wealth Co. shall not be responsible for the independent data-handling practices of such third parties.
Clients are advised to review the applicable terms, privacy policies and disclosures of the relevant entities involved in such transactions.
We retain personal, financial and other information only for as long as reasonably necessary to fulfil the purposes for which it was collected, provide our services, maintain appropriate records, and meet applicable legal and regulatory requirements.
The period for which information is retained may vary depending on the nature of the information and the purpose for which it is processed. We may retain information:
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For as long as necessary to provide our services, maintain our relationship with clients, complete transactions and fulfil the purposes for which the information was collected.
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To meet regulatory requirements, including applicable record-keeping, reporting, KYC and other obligations imposed by regulatory authorities.
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To comply with legal obligations, including requirements relating to taxation, financial records, audits, investigations and other applicable laws.
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For dispute resolution, including where information is necessary to establish, exercise or defend legal claims, resolve complaints, or address disputes.
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For fraud prevention, security and compliance purposes, where continued retention is necessary to investigate or prevent unauthorised activity, fraud or misuse.
When information is no longer required for these purposes and there is no legal, regulatory or other lawful requirement to retain it, we will take reasonable steps to delete, destroy or anonymise the information, as appropriate.
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Subject to applicable law and the conditions prescribed under the Digital Personal Data Protection Act, 2023 (DPDP Act) and other applicable regulations, you may have the following rights in relation to your personal data:
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Right to Access: You may request information about the personal data we process about you and, where applicable, information regarding how such data is being processed.
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Right to Correction: You may request correction of personal data that is inaccurate or incomplete.
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Right to Updating: You may request that your personal information be updated where there has been a change or where the information held by us is no longer current.
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Right to Erasure: You may request erasure of your personal data where permitted under applicable law. However, we may retain certain information where its retention is required or permitted for legal, regulatory, contractual, record-keeping, dispute resolution or other lawful purposes.
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Right to Withdraw Consent: Where processing is based on your consent, you may withdraw your consent at any time, subject to applicable law. Withdrawal of consent may not affect the lawfulness of processing carried out before the withdrawal and may not apply where we have another lawful basis or obligation to continue processing the information.
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Right to Grievance Redressal: You may raise a grievance regarding the collection, use, processing or handling of your personal data by contacting us through the grievance contact details provided in this Privacy Policy.
To exercise any of these rights or raise a grievance, you may contact us using the contact details provided in the Grievance Redressal and Contact Information section of this Privacy Policy. We may take reasonable steps to verify your identity before processing certain requests.
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Our services are not intended for children below the age prescribed under applicable law.
We do not knowingly collect or process personal data of children except where such collection or processing is permitted under applicable law and any required consent or authorisation from a parent or lawful guardian has been obtained.
Where processing of a child's personal data requires parental or guardian consent under applicable law, we will take reasonable steps to obtain and verify such consent as required.
If you believe that a child has provided personal data to us without the required parental or guardian consent, you may contact us using the contact details provided in this Privacy Policy. We will take appropriate steps in accordance with applicable law.
Our website may contain links, references or integrations to websites, applications, platforms or services operated by third parties, including financial institutions, service providers and other external organisations.
These third-party websites and services may have their own privacy policies, terms and data collection practices. True Wealth Co. is not responsible for the privacy practices, security, content or data handling practices of third-party websites or services that are not operated or controlled by us.
We encourage you to review the applicable privacy policies and terms of use of any third-party website or service before providing your personal or financial information.
Your use of any third-party website or service is subject to the terms and privacy practices of that respective third party.
True Wealth Co. may update, modify or revise this Privacy Policy from time to time to reflect changes in our services, business practices, technology, applicable laws, regulations or regulatory requirements.
Any changes to this Privacy Policy will be published on our website and will become effective upon publication, unless otherwise stated in the revised Privacy Policy.
We encourage you to review this Privacy Policy periodically to remain informed about how we collect, use, store and protect your information.
The “Last Updated” date displayed at the beginning or end of this Privacy Policy will indicate when the policy was most recently revised.
If you have any questions, concerns, complaints or grievances regarding the collection, use, processing, storage or handling of your personal information, you may contact our designated Grievance Officer using the contact details provided below. The Grievance Officer will review and address your grievance in accordance with applicable laws, regulations and our internal grievance redressal procedures. You may also contact the Grievance Officer if you wish to exercise any applicable rights in relation to your personal data or seek clarification regarding our Privacy Policy.
Grievance Officer: Sameer Lalwaani
Email: sameer@truewealthco.inBy accessing or using the Company's website or services, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, use, processing, storage and disclosure of your personal data in accordance with this Privacy Policy and applicable laws.
Where applicable, you may withdraw your consent or exercise your rights in accordance with the provisions set out in this Privacy Policy and applicable law. Withdrawal of consent will not affect processing that is required or permitted under applicable legal, regulatory or other lawful requirements.