Privacy Policy
This Privacy Policy outlines how FW Fintech Private Limited ("Novelty Wealth/we/us") collects, use, disclose, and protect your personal information ("Personal Data") in accordance with the relevant laws, including the Information Technology Act, 2000 and the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, SEBI circulars, operational guidelines, and cybersecurity frameworks applicable to investment advisors, ("Applicable Law") when you ("You/User") use our website and mobile app (collectively referred to as the "Platform") and our Services (as defined under the Terms of Service).
"Personal Data" refers to data relating to you that is directly or indirectly identifiable, having regard to any characteristic, trait, attribute or any other feature of your identity or any combination of such features with any other information, and does not refer to information in the public domain or made available under law. Personal Data includes sensitive Personal Data, which relates to password, financial information such as bank account or credit card or debit card or other payment instrument details, physical, physiological and mental health condition, sexual orientation, medical records and history, biometrics or any other data categorized as sensitive under Applicable Laws in India.
1. GENERAL
Novelty Wealth may change or amend this Privacy Policy from time to time to incorporate necessary future changes. You are required to keep yourself updated with any changes that we make to this Privacy Policy. Your continued use of the Services and Platform amounts to consent to the terms of this Privacy Policy.
Novelty Wealth terms require all account owners to be at least eighteen (18) years of age (or have the permission and supervision of a responsible parent or legal guardian), therefore this policy does not discuss the use of our Services by minors.
Please read through this Privacy Policy to better understand what data we use and how we use your data for each of the above classifications.
2. FAMILY GROUP SETTINGS
By choosing to create or join a "Family" group within the Platform, you provide your explicit consent to share your personal data with other members of that group. Participation is entirely voluntary, and you may opt-in or opt-out at any time through your Account Settings.
We provide you with control over how your Personal Data is accessed by other family members:
- Default group visibility: Upon joining, your Personal Data (including financial data) will be visible to all members of the Family group to facilitate transactions;
- Authorized access: Depending upon your chosen settings, your Personal Data will only be visible to specific members of the Family group after you have granted explicit authorization through an OTP prompt.
Your privacy is dynamic. You maintain the following rights at all times:
- Revoke specific permissions: You may immediately stop sharing specific data points with the group or individual members by adjusting your sharing permissions on the Platform. Please note that revoking access does not retroactively delete information that other members may have already viewed or recorded while access was active.
- Withdrawal from Group: You may leave the Family group at any time. Upon your withdrawal, all active data-sharing with other group members will be severed, and your data will no longer be visible to them.
3. COLLECTION OF DATA
The Company processes Personal Data only for specified purposes. The granularity of data collection depends on your level of interaction with the platform:
3.1System and telemetric information
Data collected: IP address, device identifiers, browser plug-in types and versions, model, storage capacity, mobile network details, and operating system version, and cookies; to maintain network security, optimize website performance, and prevent fraudulent bot activity. This helps us to provide you with a good user experience when you use the Platform and also allows us to improve the Platform.
Usage logs: Data regarding your technical interactions with the Platform to ensure operational stability.
3.2Identity and demographic records
Personal Profile: Legal name, date of birth, gender, and nationality.
Family Details: Information regarding your spouse, parents (father's and mother's names), and designated nominees.
Contact information
Communication data: Primary email address, verified mobile number, and residential/correspondence address.
Details of your nominees as provided by you.
Financial and banking credentials
Account details: Bank account number, your name as it appears on official bank records or passbooks, IFSC code, UPI IDs, virtual payment addresses (VPAs), and e-NACH / mandate registration details for automated processing to facilitate seamless transactions.
Credit score: To assess your creditworthiness, we may request and receive your credit report and credit score from credit information companies (CICs).
We do not store your raw credit or debit card numbers. Instead, with your explicit consent, we utilize secure digital tokens (as per RBI's tokenization framework) which include the card type, name on the card, and a unique digital identifier provided by the card network.
KYC compliance data and transactional details
Identity identifiers: Permanent Account Number (PAN) and Aadhaar details.
Verification records: Digital KYC data, including video-KYC (V-CIP) recordings and other offline/online documentation necessitated by SEBI, RBI, or specific financial product providers.
Onboarding context: Information regarding your interests and the intended purpose of your investments.
To facilitate your investments and monitor your portfolio, we process the following transaction-related information:
Transaction metadata: Date, time, currency, and precise amount of each investment or redemption.
Payment credentials: Mode of payment used (e.g., UPI, Net Banking), transaction success status, and unique transaction IDs.
Portfolio specifics: Details of the specific financial products or services accessed via the Platform.
Counterparty information: Information regarding the beneficiary, fund house (AMC), or other third-party entities involved in the settlement of your transaction.
Balance tracking: Historical and real-time account balances as retrieved through authorized channels (such as RBI Account Aggregators or RTAs).
Professional and income profile
Employment data: Your occupational details and annual income bracket. This is collected to comply with the Prevention of Money Laundering (PML) Rules and for mandatory reporting to the Central KYC Records Registry (CKYCR).
Enhanced security and device binding
System access (consent-based): With your explicit permission, we may access your camera and microphone (for KYC), location (for regional compliance and fraud prevention), and IP address.
Multi-factor authentication: To protect your account and comply with security mandates, we link your registered mobile device and SIM to your account.
Emails, call recordings etc. with and from you. Under Applicable Law, we are required to maintain a complete record of all interactions where investment advice is sought or given. Accessing call logs allows us to automatically timestamp and log advisory calls made through the platform to ensure your protection and regulatory transparency.
If you send us personal correspondence, such as emails, or allow us access to any of your financial information we may collate such information into a file specific to you.
Processing of personal data is carried out based on:
Consent: Explicit, affirmative consent obtained at the time of account creation or purchase.
Certain legitimate uses: Including the voluntary provision of data for specific services or compliance with legal mandates.
In addition to the data provided directly by you, Novelty Wealth may receive and process Personal Data from third-party sources. Such processing is conducted solely to fulfill our contractual obligations to you and in furtherance of provision of Services. These sources include, but are not limited to:
With your explicit and revocable consent, we retrieve your investment records from Financial Information Providers (FIPs) - such as Depositories (NSDL/CDSL), registrar and transfer agents/RTAs (CAMS/KFintech/MF Central), and the Account Aggregator (AA) network. This includes:
- Portfolio intelligence: A comprehensive snapshot of your external holdings, including scheme names, Folio numbers, and unit balances.
- Performance metrics: Historical and current valuation of your investments, including Net Asset Value (NAV), XIRR (Internal Rate of Return), and absolute gains/losses.
- Transaction telemetry: Detailed logs of all historical activity, including systematic investment plans (SIPs), lump-sum purchases, redemptions, switches, and dividend reinvestments.
- Financial flow data: Precise amounts invested or withdrawn, along with time-stamps and success status of each transaction.
Technical & analytics providers: We receive pseudonymized usage trends, crash reports, and engagement metrics from service providers to ensure the technical integrity and optimization of the Platform.
Advertising & search networks: We may receive data regarding your interaction with our advertisements and search queries from advertising partners to measure the effectiveness of our outreach.
Novelty Wealth ensures that any data received from third parties is processed under the grounds of affirmative consent provided by you to the third party.
4. SHARING YOUR DATA
To support delivery of our Services, Novelty Wealth may engage and use data processors with access to certain Personal Data (each, a "Subprocessor"). We do not sell your personal data. We disclose Personal Data only to the following specific categories of recipients for the purposes defined below:
To asset management companies (AMCs), stock-brokers, and custodians as necessary to execute your specific transaction instructions.
To SMS gateways, email service providers, and secure call-recording platforms mandated by SEBI for maintaining interaction audit trails.
Other FW Fintech Private Limited group entities (and any entities acquired hereafter) to provide unified customer support, technical operations, and account management, provided that such entities maintain strict arm's length segregation from any distribution or brokerage activities.
Disclosed to third-party providers for mandatory KYC (Know Your Client) processing, video-CIP, and employee background checks.
Shared with RBI-regulated payment aggregators and banks to verify credentials and facilitate fund transfers, redemptions, and fee payments.
The Company utilizes certain infrastructure and software-as-a-service (SaaS) providers who may, in turn, engage downstream subprocessors to facilitate specialized functions (e.g., cloud storage, content delivery networks, or database management). By agreeing to this Privacy Policy, you provide general written authorization for the Company to involve such Sub-processors.
All our processors and sub-processors are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our processors and sub-processors to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
We may also share Personal Data with statutory and regulatory bodies or third parties with necessary authority to comply with Applicable Law.
5. COMMUNICATION AND MARKETING
When you create an account and/or obtain access to our Services, you will be able to receive promotional emails regarding latest offers and discounts from us.
Novelty Wealth shall utilize your personal data for communication and marketing purposes strictly under the following mandates:
Operational & transactional communications
Novelty Wealth will process your contact data (Email, WhatsApp, SMS) to send essential service-related communications. These are processed under the legal ground of contractual necessity and include:
Operational issues: Communication regarding your portfolio, payments, investments or any other account-related issues.
Service updates: Critical notifications regarding batch timings, curriculum changes, or technical maintenance.
Security alerts: Notifications regarding account login activity or potential data security incidents.
Promotional & marketing communications
Novelty Wealth may process your Personal Data to provide information regarding new offerings or products. We may analyse your usage trends and academic interests to provide relevant recommendations. Novelty Wealth does not sell or rent your personal data to third-party marketers. We may, however, use data processors (e.g., Mailchimp, WhatsApp Business API) to facilitate our own outreach.
Right to withdraw consent (opt-out)
You may withdraw consent for marketing by:
Clicking on the "Unsubscribe" link or "STOP" keyword which forms part of every promotional email or SMS;
Privacy dashboard: Registered Users can manage their communication preferences through their account settings.
Manual request: You may email support@noveltywealth.in with the subject "Marketing Opt-Out" to be removed from all promotional registries within 48 hours.
Effect of withdrawal: Withdrawal of marketing consent will not affect the delivery of operational & transactional communications necessary for your ongoing course or internship.
6. DATA PRINCIPAL RIGHTS
You are entitled to exercise the following statutory rights under Applicable Law:
Right to access: You may request a summary of your personal data being processed and a list of third-party data processors with whom your data has been shared.
Right to correction & erasure: You have the right to rectify inaccurate data or request the erasure of your personal data once the purpose of processing is fulfilled.
Right to withdraw consent: You may withdraw consent as easily as it was given. Upon withdrawal, Novelty Wealth will cease processing, which will result in the immediate forfeiture of access to training portals and certificates.
Right to nominate: You may nominate an individual to exercise your rights in the event of your death or incapacity.
7. RETENTION AND ERASURE
Transaction data is retained for the duration of your relationship with Novelty Wealth. Post-termination, core transaction records are archived for 5 years to comply with Applicable Laws, after which they are securely purged from our active databases.
We process and store your Personal Data on our servers and those of our technology providers. All your sensitive Personal Data is stored within India.
8. SECURITY
Security safeguards: We implement technical and organizational security measures as per to prevent data breaches and to protect your sensitive financial data from unauthorized access or disclosure.
Breach notification: In the event of a personal data breach, we are legally required to notify CERT-In and the affected data principals in the prescribed manner.
The security of Personal Data is important to us. Your Novelty Wealth account information is protected by a password. It is important that you protect against unauthorized access of your account and information by choosing your password carefully and keeping your password and computer secure by signing out after using our services.
We have implemented procedures to help protect the information that you provide to us. However, no method of transmitting or storing electronic data is ever completely secure, and we cannot guarantee that such information will never be accessed, used, or released in a manner that is inconsistent with this policy. You agree and acknowledge that we may engage third-party services providers for the provision of cloud service storage solutions, and Novelty Wealth is not responsible for any lapse in security on the part of such service providers. We expressly disclaim any representation or warranty, whether express or implied, with respect to ensuring, guaranteeing, or otherwise offering any definitive promise of security in connection with your Information. YOU ARE SOLELY RESPONSIBLE FOR MAINTAINING THE SECRECY OF YOUR ACCOUNT INFORMATION AT ALL TIMES.
You shall be solely responsible for all activities performed by you through your Novelty Wealth account. Novelty Wealth assumes no responsibility or liability for the improper use of information relating to usage of your account or banking credentials by you, whether online or off-line.
To protect your privacy and security, we will verify your identity before granting access or making changes to your personally identifying information. Once you have registered with Novelty Wealth, your phone number and OTP are required in order to access your profile information.
9. CONTACT US
Questions, comments, remarks, requests or complaints regarding this Privacy Policy are welcome and should be addressed by you to support@noveltywealth.in.
10. GRIEVANCE REDRESSAL MECHANISM
In accordance with Applicable Law, the following individual is appointed as the Grievance Officer:
Name: Naveen Changoiwala
Email: support@noveltywealth.in
This Privacy Policy may be updated periodically. Continued use of our Platform signifies acceptance of any updates.