Privacy Policy

1. Scope

This policy applies to information collected through truenovawealth.com, any digital medium through which we deliver research services, and offline interactions such as email, telephone and onboarding forms. It is to be read together with our Terms of Service.

2. Information we collect

Depending on how you interact with us, we may collect the following categories of information:

• Identity and contact details: name, email address, mobile number, postal address, date of birth and PAN, as required for client onboarding and KYC under SEBI regulations.
• Financial and suitability information: income range, investment experience, risk profile and other details needed to assess suitability of research services.
• Account and subscription details: plan selected, fee payment records, invoices and communication history.
• Technical data: IP address, browser type, device identifiers, pages visited, referring URLs and approximate location, collected through server logs and cookies.
• Correspondence: messages you send us through forms, email or other channels, including grievance communications.

3. How we use your information

• To register you as a client, verify identity, complete KYC and comply with SEBI (Research Analyst) Regulations, 2014 and related circulars.
• To deliver research reports, model portfolios and service communications you have subscribed to.
• To process fees, issue invoices and maintain accounting and tax records.
• To respond to enquiries, resolve grievances and maintain records of complaints as required by law.
• To operate, secure and improve this website and our digital medium.
• To send service announcements, regulatory disclosures and, where you have not opted out, information about our offerings.
• To comply with legal obligations, court orders, and requests from SEBI, BSE Ltd. (Research Analyst Administration and Supervisory Body) or other authorities.

4. Legal basis and consent

We process personal data on the basis of your consent, the performance of our contract with you, our legal and regulatory obligations, and our legitimate interest in operating and securing our services. Where processing is based on consent, you may withdraw it at any time by contacting us; withdrawal does not affect processing carried out before withdrawal and may limit our ability to provide the services.

We handle personal data in accordance with the Information Technology Act, 2000, the rules made under it, and the Digital Personal Data Protection Act, 2023, to the extent applicable.

5. How we share information

We do not sell personal information. We may share it with:

• Regulators and authorities including SEBI, BSE Ltd., KYC Registration Agencies, tax authorities and law enforcement, where required.
• Authorised technology vendors and partners who help us deliver services, such as CASE Platforms Private Limited (smallcase), payment processors, email and hosting providers. These parties are bound by contractual obligations to protect your data and use it only for the purposes we specify.
• Professional advisers such as auditors, lawyers and compliance consultants, under duties of confidentiality.
• A successor entity in the event of a merger, acquisition or reorganisation, subject to this policy.

6. Cookies and similar technologies

This website uses cookies and similar technologies to keep the site secure, remember preferences and understand how the site is used. Details of the cookies we use and how to control them are set out in our Cookie Settings page.

7. Data retention

We retain client records, research reports, rationale, communications and fee records for at least five years, or such longer period as required by SEBI regulations, applicable law or ongoing disputes. Website technical data is retained for a shorter period consistent with security and analytics needs. When information is no longer required we delete or anonymise it.

8. Security

We use reasonable administrative, technical and physical safeguards, including encrypted connections, access controls and secure hosting, to protect personal information against unauthorised access, alteration or loss. No method of transmission or storage is completely secure and we cannot guarantee absolute security.

We will never ask for your trading account, demat account or bank login credentials or OTPs. Do not share such details with anyone claiming to represent TrueNova Wealth.

9. Your rights

Subject to applicable law and our regulatory record-keeping obligations, you may:

• Access the personal information we hold about you and request a copy.
• Ask us to correct inaccurate or incomplete information.
• Request deletion of information that we are not required to retain.
• Withdraw consent for processing that is based on consent.
• Opt out of marketing communications using the unsubscribe link in our emails or by writing to us.
• Nominate a person to exercise these rights on your behalf in the event of death or incapacity.

To exercise these rights, contact us using the details below. We may need to verify your identity before acting on a request.

10. Children

Our services are intended for persons who are at least 18 years old and competent to contract under the Indian Contract Act, 1872. We do not knowingly collect personal information from children. If you believe a child has provided us information, please contact us and we will delete it.

11. Third-party websites

This website may link to third-party websites and platforms, including smallcase. Those sites have their own privacy policies and we are not responsible for their content or practices. Review their policies before providing any information.

12. Changes to this policy

We may update this Privacy Policy from time to time. The revised policy will be posted on this page with an updated date, and material changes may also be notified by email. Continued use of the website or services after changes take effect constitutes acceptance of the revised policy.

13. Contact and grievance officer

For questions about this policy or to exercise your rights, contact our Compliance Officer: