Section I – Introduction

This Privacy Policy (“Policy”) is aimed to ensure the Confidentiality, Integrity and Availability of data belonging to JWA Wealth Private Limited is protected and processes and controls that help prevent and detect misuse of data or unauthorized access to critical information and protection of data for record and compliance purposes.

JWA Wealth Private Limited believes in respecting its’ clients’, employees’, and contractors’, right to privacy and safeguarding their personal information in physical or electronic form.

In the course of its regular business activities, JWA Wealth Private Limited needs to collect certain information about individuals including past, present and prospective clients. JWA Wealth Private Limited will only handle their clients’/third party’s personal information in a manner that is reasonable and appropriate in the circumstances and as required under applicable laws.

JWA Wealth Private Limited stores and processes such Information including any sensitive financial information collected (as defined under the Information Technology Act, 2000), if any, on computers that are protected by physical as well as reasonable technological security measures and procedures in accordance with Information Technology Act 2000 and Rules made there under.

JWA Wealth Private Limited shall not retain or store that information for longer than is required for the purposes except when the information may lawfully be used or is otherwise required under any other law for the time being in force. The information collected shall be used for the purpose for which it has been collected. By agreeing to avail the service offered by JWA Wealth Private Limited, the Client (including customers, vendors and third parties) agree to the collection and use of their Personal Data or Information by JWA Wealth Private Limited. The Client shall always have the right to refuse or withdraw their consent to share/dissemination of their Sensitive Personal Data or Information by contacting JWA Wealth Private Limited. However, in such an event, the Client would no longer be able avail the services of JWA Wealth Private Limited, and JWA Wealth Private Limited may not be able to purge the data if it is required to be stored as per AML KYC regulations.

Section II – Applicability

The Policy applies to all the employees, clients, contractors, consultants, outsourcing partners, third parties and including all personnel affiliated with third parties.

Section III – Rationale for Collecting Personal Information

In accordance with the Policy, JWA Wealth Private Limited may ask for the following personal information about the Clients, who engage with JWA Wealth Private Limited, from time to time. This information is needed to identify an individual, and establish the identity of an individual/non-individual to whom the information applies for any legal applications. This information includes and is not limited to:

• Name, address, contact numbers, e-mail address, date of birth, signature, photograph, and information on source of wealth.

• Financial information such as Bank account, PAN, KYC Status, or financial asset statements.

JWA Wealth Private Limited would ensure that it collects requisite information only to the extent it is necessary to establish identity and provide financial services and advice in the best possible manner and required under the applicable laws.

Section IV – Usage of Personal Information:

JWA Wealth Private Limited will use the collected Personal Information necessary to comply with certain applicable laws; or regulatory obligations; or for a legitimate interest in using the Client’s information for the purposes of providing its financial services.

JWA Wealth Private Limited shall not deliberately disclose individual/non individual’s personally identifiable information to any unauthorized third person, save and except where such information shall be disclosed in good faith and for the purpose of compliance with law for the time being in force or to protect the rights and property of JWA Wealth Private Limited.

JWA Wealth Private Limited has a right or duty to disclose such information by law, to judicial bodies and regulatory authorities who have jurisdiction over JWA Wealth Private Limited.

Section VI – Sharing Information

The JWA Wealth Private Limited website sometimes may have links to other website(s) in the World Wide Web. The user’s browsing and interaction on any other website, including those that may have a link on the JWA Wealth Private Limited website, is subject to that third party website’s own set of rules and policies.

JWA Wealth Private Limited may share information about Clients in the limited circumstances spelled out below and with appropriate safeguards with respect to Client’s privacy, such as to:
(i) regulators,
(ii) on account of legal requests such as a subpoena, court order, or other governmental and/or regulatory bodies’ request, and
(iii) any other circumstances to protect the rights and property of JWA Wealth Private Limited.

Section VII – Protection of Information

The privacy and protection of Client data and information provided to JWA Wealth Private Limited is of vital importance. JWA Wealth Private Limited shall ensure safeguarding, security and confidentiality of any Client information.

Any personally identifiable information of the Clients obtained by JWA Wealth Private Limited shall not be used or shared other than for the purposes to which the Individual/non-Individual consent to or provides consent for. However, security and confidentiality of information cannot always be guaranteed. Hence despite JWA Wealth Private Limited’s utmost efforts to protect Client’s personal information, JWA Wealth Private Limited cannot warrant the security of any information that transmits through JWA Wealth Private Limited’s online website. Such transmission of personal information is done at the Client’s own risk.

In order to protect the Client’s personal information and right to privacy, JWA Wealth Private Limited will:
(i) Keep the client’s personal information only for as long as JWA Wealth Private Limited needs it to fulfil the stated purpose or as required by law; or for the purpose of providing financial services,
(ii) Maintain the client’s personal information in as accurate, complete and up-to-date form as possible;
(iii) Safeguard the client’s personal information to the best of JWA Wealth Private Limited’s ability;
(iv) Respond reasonably to any request that the client may make to access or correct the personal information JWA Wealth Private Limited holds about him;
(v) Obtain the appropriate consent from the client for the collection, use or disclosure of his personal information (if required).

Section VIII – Communication

When a client uses the website of JWA Wealth Private Limited or sends emails or other data, information or communication to JWA Wealth Private Limited, the Clients agree and understand that they are communicating with JWA Wealth Private Limited through electronic records and that they consent to receive communications via electronic records periodically and as and when required. JWA Wealth Private Limited may communicate by email or by such other mode of communication, electronic or otherwise.

JWA Wealth Private Limited shall not be responsible for any personal information or sensitive personal data or information found to be inaccurate or deficient or untrue.

JWA Wealth Private Limited may provide notifications, whether such notifications are required by law or are for marketing or other business-related purposes, to Clients via email notice, written or hard copy notice, or through conspicuous posting of such notice on the JWA Wealth Private Limited Website page, as determined by JWA Wealth Private Limited in its sole discretion.

JWA Wealth Private Limited reserves the right to determine the form and means of providing notifications to Clients. The Clients may opt out of certain means of notification by emailing JWA Wealth Private Limited.

Section IX – Policy Governance:

This Policy shall be reviewed by the Chief Operating Officer, on a periodical basis to ensure that the Policy is up to date and reflects all changes to as may be applicable to the Company from time to time.