Privacy Policy

Who We Are

Fintwiz Pvt Ltd ("Fintwiz", "we", "us", or "our") is a company incorporated under the Companies Act 2013, operating as a SEBI Registered Research Analyst under SEBI (Research Analysts) Regulations, 2014.

We operate the website fintwiz.com and provide equity research, trading intelligence, portfolio advisory, and investor education services to retail and institutional investors across India.

For the purposes of the Digital Personal Data Protection Act, 2023 ("DPDP Act") and the Information Technology Act, 2000 ("IT Act"), Fintwiz Pvt Ltd is the Data Fiduciary responsible for your personal data.

Data We Collect

We collect personal data only to the extent necessary to provide our services and comply with applicable regulations. The categories of data we collect are described below.

How We Use Your Data

We use your personal data for the following specific purposes only. We will never use your data for purposes incompatible with those stated below without obtaining your fresh consent.

You may opt out of marketing communications at any time by clicking "Unsubscribe" in any email or by writing to us at info@fintwiz.com. Opting out of marketing does not affect your ability to receive service-related communications.

Legal Basis for Processing

Under the Digital Personal Data Protection Act 2023 (DPDP Act), we process your personal data under the following lawful bases:

• Consent: You have given clear, specific, informed, and unambiguous consent for a specific processing purpose (e.g., marketing emails, newsletter subscriptions). You may withdraw consent at any time without affecting the lawfulness of prior processing.
• Contract Performance: Processing is necessary to fulfil a contract with you (e.g., delivering a research subscription, processing your payment, delivering reports).
• Legal Obligation: Processing is required to comply with Indian law — including SEBI (Research Analysts) Regulations 2014, SEBI SCORES grievance requirements, GST obligations, and the IT Act 2000.
• Legitimate Interests: Processing is necessary for our legitimate business interests (e.g., improving our services, website analytics, fraud prevention, security) where these interests are not overridden by your fundamental rights.

Data Sharing & Third Parties

We do not sell, rent, trade, or otherwise transfer your personal data to third parties for their own commercial purposes. We share your data only in the following limited circumstances:

Cookies & Tracking Technologies

Our website uses cookies and similar technologies to operate correctly, understand how you use our site, and improve your experience.

When you first visit fintwiz.com, a cookie consent banner will ask for your permission before non-essential cookies are set. You can update your cookie preferences at any time by clicking "Cookie Settings" in the website footer.

Most browsers also allow you to block or delete cookies through browser settings. Note that disabling essential cookies may prevent some parts of our website from working correctly.

Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law. Our retention schedule is as follows:

Upon expiry of the retention period, personal data is securely deleted or anonymised so that it can no longer be associated with you. Where deletion is not technically feasible immediately (e.g., backups), we will isolate the data from further processing until deletion is possible.

Data Security

Fintwiz Pvt Ltd implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, loss, destruction, alteration, or disclosure.

• Encrypted transmission: Our website uses HTTPS (SSL/TLS) encryption for all data transmitted between your browser and our servers.
• Payment security: All payment card data is processed exclusively by Razorpay, a PCI-DSS certified payment gateway. We do not store, transmit, or have access to your full card number, CVV, or PIN at any time.
• Access controls: Personal data is accessible only to authorised Fintwiz personnel who require it for their specific role. Access is controlled via role-based permissions.
• Regular security reviews: We conduct periodic reviews of our data handling practices, third-party integrations, and security configurations.
• Incident response: In the event of a personal data breach, we will notify affected individuals and relevant authorities (including CERT-In, as required under the IT Act) within the timeframes specified by applicable law.

Your Rights Under the DPDP Act 2023

As a Data Principal (individual whose data we process), you have the following rights under India's Digital Personal Data Protection Act, 2023. We will respond to all verified rights requests within 30 days.

To exercise any of these rights, please write to our Grievance Officer at grievance@fintwiz.com with the subject line "DPDP Rights Request", clearly identifying yourself and the right you wish to exercise. We may need to verify your identity before processing the request.

Please note that certain rights may be limited where processing is required to comply with SEBI regulations, legal obligations, or ongoing grievance proceedings — in which case we will inform you accordingly.

Children's Privacy

Our services are intended for individuals who are 18 years of age or older, or the age of majority in their jurisdiction. We do not knowingly collect or process personal data of children under 18.

If you are a parent or guardian and believe that a minor has provided us with personal data without your consent, please contact us immediately at info@fintwiz.com. We will promptly delete such data upon verification.

Cross-Border Data Transfers

Some of our third-party service providers (including Google LLC and Meta Platforms Inc.) are based outside India and may process your data on servers located in other countries. Where such transfers occur, we ensure that appropriate safeguards are in place, including:

• Standard Contractual Clauses or equivalent data transfer mechanisms as recognised under the DPDP Act 2023 and its implementing rules.
• Processing limited to what is necessary for the stated service purpose.
• Contractual obligations on the recipient to provide equivalent data protection standards.

By using our services, you acknowledge and consent to the transfer of your data to countries outside India where our service providers operate, subject to the safeguards described above.

Research Disclaimer & SEBI Disclosures

Personal data collected as part of your subscription to Fintwiz research services (including investment preferences, risk profile, and communication history) is retained and processed in accordance with SEBI (Research Analysts) Regulations, 2014, and SEBI Master Circular for Research Analysts (as amended). Such data is subject to SEBI inspection and regulatory requirements and may be disclosed to SEBI or other regulatory bodies as required by law.

Fintwiz Pvt Ltd is registered as a Research Analyst with SEBI. We are not a Portfolio Manager, Investment Advisor, Broker, or Stock Exchange. Our services are research-based and do not constitute personalised investment advice regulated under SEBI (Investment Advisers) Regulations, 2013, unless separately registered and disclosed.

Grievances related to SEBI-regulated services may be filed at the SCORES portal: scores.sebi.gov.in or via the Smart ODR platform: smartodr.in.

Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, services, or applicable law (including any rules or regulations notified under the DPDP Act 2023). When we make material changes, we will:

• Update the "Last Updated" date at the top of this page.
• Send a notification to your registered email address for significant changes that affect your rights or our data processing activities.
• Display a prominent notice on fintwiz.com for at least 30 days following any material change.

Your continued use of our services after any changes to this Privacy Policy constitutes your acceptance of the updated terms. We encourage you to review this page periodically.

Grievances & Contact Us

If you have any questions, concerns, or complaints about this Privacy Policy or our data handling practices, or if you wish to exercise any of your rights under the DPDP Act 2023, please contact us through any of the following channels. We will acknowledge your request within 48 hours and resolve it within 30 days.

If you are not satisfied with our response, you have the right to escalate your complaint to the Data Protection Board of India once operationalised under the DPDP Act 2023, or to seek other legal remedies available under Indian law.