Privacy Policy

Adaaf Advisory Services Private Limited ("Adaaf", "Company", "we", "us", "our") is committed to protecting the privacy of users ("you", "your", "Client") of our website, enquiry form, and SMS-based advisory services (collectively, the "Platform"). This Privacy Policy describes how we collect, use, store, and disclose your personal information, in accordance with the Information Technology Act, 2000, the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, the Digital Personal Data Protection Act, 2023, and applicable SEBI regulations.

1. Information We Collect

1.1 Personal Information

• Full name, date of birth, gender, contact number (including WhatsApp), email address, residential/correspondence address.
• KYC details: PAN, Aadhaar (where permitted), bank account details, demat account number.
• Financial information: income details, investment portfolio, risk profile, financial goals, and plan of interest (e.g., Short-Term, Medium to Long-Term, NRI Advisory).

1.2 Technical Information

• IP address, browser type, device information, operating system.
• Usage data such as pages visited, time spent, and click patterns via cookies and similar technologies.

1.3 Communication Data

• Records of correspondence, including enquiry form submissions, emails, and WhatsApp communication, for service and compliance purposes.

2. How We Use Your Information

We use the collected information to:

1. Provide investment advisory services and deliver SMS-based research recommendations tailored to your risk profile and financial goals.
2. Complete KYC and regulatory due diligence as mandated by SEBI, PMLA, and other applicable laws.
3. Communicate account/subscription updates, advisory recommendations, and service-related notices, including via SMS and WhatsApp.
4. Improve our Platform, research, and overall user experience.
5. Comply with legal, regulatory, and audit requirements, including reporting to SEBI or other statutory bodies as required.
6. Detect and prevent fraud, unauthorized access, or misuse of the Platform.

3. Sharing of Information

We do not sell or rent your personal information. We may share your information with:

• Regulatory Authorities: SEBI, KRAs, and other statutory bodies as required by law.
• Service Providers: Third-party vendors for KYC verification, SMS/bulk-messaging gateways, payment processing, cloud hosting, and customer support, under contractual confidentiality obligations.
• Legal Requirements: Government authorities, courts, or law enforcement agencies pursuant to a valid legal request.
• Business Transfers: In the event of a merger, acquisition, or restructuring, subject to confidentiality commitments.

4. Data Storage and Security

We implement reasonable security practices, including encryption, access controls, and secure servers, to protect your personal data from unauthorized access, alteration, or disclosure, in line with the IT (Reasonable Security Practices) Rules, 2011.

Data is stored on servers located [in India / specify location], and retained only for as long as necessary to fulfil the purposes outlined in this policy or as mandated by SEBI's record-keeping requirements (typically [5-8] years).

5. Cookies and Tracking Technologies

We use cookies to enhance user experience, remember preferences, and analyse Platform traffic. You may disable cookies through your browser settings; however, this may affect certain functionalities of the Platform.

6. Your Rights

Subject to applicable law, you have the right to:

• Access and review the personal information we hold about you.
• Request correction of inaccurate or incomplete information.
• Withdraw consent for processing, where applicable (which may limit our ability to provide certain services, such as SMS delivery of recommendations).
• Request deletion of your data, subject to regulatory record-retention obligations.

To exercise these rights, contact our Grievance Officer at the details below.

7. Grievance Officer

In accordance with the Information Technology Act, 2000 and rules made thereunder, the contact details of the Grievance Officer are:

8. Children's Privacy

Our services are not directed at individuals under 18 years of age, and we do not knowingly collect personal information from minors.

9. Changes to this Policy

We may update this Privacy Policy periodically. Any material changes will be notified via email or a prominent notice on the Platform. The "Last Updated" date reflects the most recent revision.