Privacy Policy

Under the DPDP Act, 2023, Rahul Rajgopal Wealth Advisor is the Data Fiduciary — the entity that determines the purpose and means of processing your personal data.

• Name: Rahul Rajgopal
• Entity: Rahul Rajgopal Wealth Advisor
• SEBI Registration No.: INA000021933
• Registered Address: F1/38, Sector-2A, Vaishali, Ghaziabad – 201019, UP
• Operations Address: 7th Floor, Plot A/8A Knowledge Boulevard, Block A, Industrial Area, Sector 62, Noida – 201309, UP
• Data Privacy Contact / Nodal Officer: Rahul Rajgopal — [email protected]

We collect only the data necessary to provide advisory services and comply with regulatory obligations. This includes:

2.1 Identity & Contact Data

• Full name, date of birth, gender
• Email address, phone number
• Residential address (city, state, country — for NRI clients, country of residence)
• PAN number (where required for KYC and SEBI record-keeping purposes)

2.2 Financial Data

• Annual income, monthly savings, and expense patterns
• Net worth details — assets (investments, real estate, EPF, etc.) and liabilities
• Existing investment portfolio details
• Insurance coverage, loans, and EMI obligations
• Financial goals and investment horizon
• Risk tolerance and investment experience

2.3 Payment Data

• Payment transaction reference numbers and timestamps
• Payment method type (UPI, card, NEFT — not full card numbers)
• Note: Full payment card numbers, CVVs, and bank account numbers are never stored by us. Online payments are processed by Cashfree Payments, a PCI-DSS compliant payment gateway, whose own privacy policy applies to payment data.

2.4 Technical & Usage Data

• IP address and approximate geographic location (city/country level)
• Browser type, device type, and operating system
• Pages visited, time spent, and interaction patterns
• Referral source (how you found our website)

2.5 Communication Data

• Emails, messages, and correspondence with the adviser
• Grievance submissions and complaint records
• Consent records and audit trail documentation

We process your personal data for the following specific, lawful purposes:

• Providing our services: Generating your personalised 360° Wealth Report™, and providing investment advice where you have signed an advisory agreement
• Risk profiling and suitability assessment: As mandated by SEBI Regulations to ensure advice is appropriate for your circumstances
• Payment processing: Facilitating secure payment for services via Cashfree Payments
• Regulatory compliance: Maintaining records as required by SEBI (Investment Advisers) Regulations, 2013 — minimum 5 years retention
• KYC compliance: Verifying identity as required by SEBI and anti-money laundering regulations
• Communication: Sending service-related communications, report delivery, and advisory correspondence
• Grievance redressal: Processing and resolving complaints and escalations
• Platform improvement: Analysing usage patterns to improve service quality (using anonymised or aggregated data only)
• Legal obligations: Complying with court orders, regulatory directions, or law enforcement requests

We do not use your personal data for targeted advertising, profiling for commercial purposes unrelated to advisory services, or sale to third parties.

Under the DPDP Act, 2023, we process your personal data on the following bases:

• Consent: You voluntarily provide financial data through the intake form, having been informed of the purpose of collection
• Contractual necessity: Processing necessary to deliver the advisory service you have engaged and paid for
• Legal obligation: SEBI Regulations mandate record-keeping of client data and advisory interactions for a minimum of 5 years
• Legitimate use: As defined under Section 7 of the DPDP Act — specifically for fulfilment of obligations under applicable law

We do not sell, rent, or commercially share your personal data. Limited data sharing occurs only in the following circumstances:

• Cashfree Payments (Payment Processor): Transaction data necessary to process payments. Cashfree is PCI-DSS compliant and governed by its own privacy policy.
• Vercel (Hosting Provider): Platform hosting and content delivery. Server logs may contain IP addresses and technical data.
• Formspree (Form Processing): Details you enter in the website contact and enquiry forms, for delivering your enquiry to us.
• Resend (Email Delivery): Name, email address and phone number you submit, for delivering enquiries and service emails.
• Upstash (Data Storage): Order and report-access records needed to deliver paid services.
• Google and Microsoft (only with your consent): usage data collected by Google Analytics and Microsoft Clarity, as described in Section 9.
• SEBI / BSE IAASB: As required by regulatory obligations — SEBI may request client records during audits or investigations.
• Law enforcement / Courts: Where required by a court order, legal process, or regulatory direction under applicable Indian law.
• Professional advisers: Chartered Accountants or Company Secretaries engaged for compliance audit, who are bound by confidentiality obligations.

All third-party service providers who process your data are contractually obligated to maintain data security and confidentiality.

We retain your personal data for as long as necessary to fulfil the purposes described in this policy, and as required by law:

• Advisory records and client data: Minimum 5 years from the date of last advisory interaction, as mandated by SEBI Regulations
• Payment records: 5 years from date of transaction, as required for financial record-keeping under applicable law
• Complaint records: 5 years from resolution date, per SEBI grievance redressal requirements
• Website usage data: Maximum 12 months in anonymised form

After the applicable retention period, data is securely deleted or anonymised in a manner that prevents re-identification.

Under the Digital Personal Data Protection Act, 2023, you have the following rights as a Data Principal:

• Right to access: Request a summary of the personal data we hold about you and how it is being processed
• Right to correction: Request correction of inaccurate or incomplete personal data
• Right to erasure: Request deletion of your personal data, subject to our legal and regulatory retention obligations
• Right to grievance redressal: File a complaint with us regarding processing of your personal data. If unresolved, escalate to the Data Protection Board of India (once operational)
• Right to withdraw consent: Withdraw your consent for processing at any time, subject to the consequence that we may be unable to continue providing advisory services
• Right to nominate: Nominate another person to exercise your rights in the event of your death or incapacity

To exercise any of these rights, email us at [email protected] with the subject line “Data Privacy Request”. We will respond within 30 days.

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These include:

• SSL/TLS encryption for all data in transit
• Secure cloud hosting on Vercel with access controls
• Payment data handled exclusively by PCI-DSS compliant processors
• Restricted internal access to client data on a need-to-know basis
• Regular security reviews of platform and third-party integrations

In the event of a personal data breach that is likely to cause harm to you, we will notify you and the Data Protection Board of India as required under the DPDP Act, 2023.

We ask for your permission before any optional cookies or tracking tools run. When you first visit, a banner lets you accept or reject analytics. Rejecting does not affect your use of the site. We do not use advertising or marketing tracking tools.

Strictly necessary (always on)

• Your light/dark theme preference, stored in your browser.
• Your cookie choice, stored in your browser so we do not ask again.

Analytics (only with your consent)

• Google Analytics 4 (Google LLC): pages visited, time on site, device and approximate location.
• Microsoft Clarity (Microsoft Corporation): clicks, scrolling and page interactions, used to find usability problems.

Embedded content

Pages with a map embed Google Maps, which is provided by Google and may set its own cookies when the map loads.

These providers may process data outside India. We do not sell this data or use it to make decisions about you.

Changing your mind: you can review or withdraw consent at any time using “Cookie settings” in the site footer. Withdrawing consent stops these tools from loading and removes their cookies from this site.

For NRI clients whose data may be processed across jurisdictions, we confirm that data is stored on servers within permissible locations as per applicable Indian law. The DPDP Act, 2023 permits transfer of personal data outside India except to countries restricted by the Central Government by notification.

NRI clients retain all rights under the DPDP Act, 2023 as Data Principals whose data is processed in connection with services offered to them in India.

Our services are intended for adults aged 18 years and above. We do not knowingly collect personal data from individuals below the age of 18. If we become aware that a minor has provided personal data without verifiable parental consent, we will delete such data promptly. If you believe a minor has submitted data to our platform, contact us immediately at [email protected].

We may update this Privacy Policy periodically to reflect changes in our practices, regulatory requirements, or legal obligations. Material changes will be communicated by updating the “Last updated” date at the top of this page and, where appropriate, by email notification to existing clients. Continued use of the platform after updates constitutes acceptance of the revised policy.

For any grievance related to the processing of your personal data:

• Nodal Officer: Rahul Rajgopal
• Email: [email protected] (Subject: “Data Privacy Grievance”)
• Response time: Within 30 days of receipt
• Escalation: Data Protection Board of India — once fully operational (expected 2027). Current escalation via IT Act, 2000 mechanisms.
• SEBI SCORES (for grievances related to advisory services): scores.sebi.gov.in

For any questions, concerns, or requests related to this Privacy Policy or our data practices:

• Rahul Rajgopal Wealth Advisor
• F1/38, Sector-2A, Vaishali, Ghaziabad – 201019, UP, India
• Email: [email protected]
• Phone: +91 93110 33796
• Website: www.rahulrajgopalwealth.com