PRIVACY POLICY


INTRODUCTION

FW Fintech Private Limited ("Novelty Wealth", "we", "us", "our" or "Company") is a SEBI-registered investment advisor (RIA) providing financial solutions and services to users through our Platform, as described in our Terms of Service.

We at Novelty Wealth are committed to protecting your privacy and data security while delivering personalized financial insights. This Privacy Policy explains how we collect, use, process, disclose, and safeguard your information when you use our website and mobile app (collectively referred to as the "Platform") and our Services. It should be read harmoniously with our Terms of Service.

The Platform and related Services are primarily available for use within India and comply with SEBI RIA regulations and the Account Aggregator framework (Sahamati guidelines).

By accessing or using our Platform and Services, you consent to the collection and use of your data in accordance with this Privacy Policy. If you do not agree, please do not use our Platform.

If you have any questions regarding this Privacy Policy, please contact us at support@noveltywealth.com.


1. WHAT INFORMATION DO WE COLLECT?

We collect both Personal Information and Non-Personal Information from you through various means, including direct input, third-party integrations, and automated processes.

1.1 Personal Information

This includes data that identifies you as an individual and is necessary for providing personalized financial services. It may include:

  • User Registration Information: Name, email, mobile number, PAN, date of birth, gender, and Aadhaar details (where applicable).

  • Financial Data:

    • Account Aggregator (AA) Linked Data: Upon user consent, we retrieve financial information via the Account Aggregator framework from banks, NBFCs, and other financial institutions.

    • Mutual Fund Data: We retrieve consolidated mutual fund data from MF Central, CAMS, and KFintech upon user consent.

  • Risk Profile & Investment Preferences: Based on user inputs, we assess risk tolerance and recommend portfolio strategies.

  • Billing & Payment Information: If you subscribe to our advisory services, we collect payment details (credit/debit card, UPI, bank account) through third-party payment processors.

1.2 Non-Personal Information

This includes technical data such as:

  • Device and Browser Information: IP address, browser type, operating system, mobile device details.

  • Usage Data: Platform navigation patterns, time spent, referral sources.

  • Cookies & Tracking Data: Used for analytics, security, and improving user experience.


2. HOW DO WE USE YOUR INFORMATION?

We use your information to:

  • Enable seamless Account Aggregator integration for real-time financial tracking.

  • Optimize investment portfolios using risk-adjusted recommendations.

  • Deliver automated alerts on financial opportunities and inefficiencies.

  • Ensure compliance with SEBI RIA regulations.

  • Detect and prevent fraudulent activity.


3. DATA SHARING & DISCLOSURE

We do not sell your data. However, we may share data under the following circumstances:

  • With SEBI, RBI, or regulatory bodies, when legally required.

  • With third-party financial institutions, only upon user consent, via Account Aggregator (AA) framework.

  • With technology partners assisting in secure data storage and AI analytics.


4. USER RIGHTS & DATA CONTROL

You have the right to:

  • Withdraw consent for data linking (AA, MF Central, etc.).

  • Request deletion of your data, except where regulatory retention applies.

  • Opt-out of marketing communications.

  • Access and correct your personal data.

To exercise these rights, contact support@noveltywealth.com.


5. DATA SECURITY MEASURES

We implement industry-standard encryption and secure servers to protect your data. However, no system is 100% secure. You are responsible for maintaining the security of your login credentials.


6. GOVERNING LAW & DISPUTE RESOLUTION

This Privacy Policy is governed by Indian laws and SEBI RIA regulations. Any disputes shall be resolved through arbitration in Bangalore, India, in accordance with the Indian Arbitration and Conciliation Act, 1996.


7. PRIVACY QUESTIONS & GRIEVANCE OFFICER

For privacy-related concerns, contact:

Name: Naveen Changoiwala
Email: support@noveltywealth.com

We will acknowledge complaints within 36 hours and resolve them within 30 days.


This Privacy Policy may be updated periodically. Continued use of our Platform signifies acceptance of any updates.