Privacy Policy

Last modified:

July, 2026

1. Introduction

This Privacy Policy explains how your personal data is collected, used, disclosed, transferred and safeguarded when you visit https://claritaswealth.in (the “Website”) or engage our services. It applies to two related entities operating under the “Claritas” brand:

  • Claritas Wealth & Distribution LLP — AMFI-registered Mutual Fund / SIF Distributor (ARN 331581) and APMI-registered PMS Distributor (APRN 06348; LLPIN ACM-4310), which provides distribution services; and
  • Claritas Insights LLP — SEBI-Registered Investment Adviser (INA000022376; BASL 2483; LLPIN ACT-4963), which provides investment advisory services.

In this Policy, “we,” “us” or “our” refers to the relevant entity depending on the service you use; each entity acts as a Data Fiduciary in respect of the personal data it processes, consistent with the Digital Personal Data Protection Act, 2023 (the “DPDP Act”) and other applicable laws. Data relating to advisory services is handled by Claritas Insights LLP; data relating to distribution services is handled by Claritas Wealth & Distribution LLP. By using the Website or our services, you acknowledge this Policy, and we will obtain your consent where required by law.

2. Definitions

  • “Personal Data” means any data about an individual who is identifiable by or in relation to such data.
  • “Data Principal” means the individual to whom the personal data relates (you).
  • “Data Fiduciary” means the entity that determines the purpose and means of processing.
  • “Processing” means any operation performed on personal data, including collection, storage, use, disclosure and erasure.

3. Information We Collect

  • Identity and KYC information: name, PAN, Aadhaar (collected and stored in accordance with UIDAI / KYC norms, typically in masked form), date of birth, photograph, signature and other KYC documents.
  • Contact information: email, phone number, residential and correspondence address.
  • Financial information: bank account details, income and net-worth details, investment holdings and history, source of funds and nominee details.
  • Advisory information (clients of Claritas Insights LLP): risk-profiling responses, investment objectives, financial goals, risk tolerance, suitability-assessment data and related financial circumstances, collected as required under the SEBI (Investment Advisers) Regulations, 2013.
  • Transaction and relationship information: products held, transactions, communications and service records.
  • Technical and usage information: IP address, device and browser type, operating system, pages visited and browsing behaviour, collected automatically through cookies and similar technologies.

4. How We Collect Information

We collect personal data: (a) directly from you, through forms, onboarding, KYC and the advisory process; (b) automatically, when you use the Website, through cookies and analytics; and (c) from third parties, such as KYC Registration Agencies (KRAs), the Central KYC Registry (CKYC), asset management companies, registrars and other intermediaries, where permitted by law.

5. How We Use Your Information

We use your personal data to:

  • provide and administer distribution services — processing transactions in mutual funds, SIF, PMS and other products, and facilitating account opening with AMCs / providers (Distribution Entity);
  • provide investment advisory services — risk profiling, suitability assessment, preparation of advice / financial plans and ongoing review (Advisory Entity), under the SEBI (Investment Advisers) Regulations, 2013;
  • carry out KYC, customer due diligence and screening, and prevent fraud, money laundering and other unlawful activity;
  • meet regulatory and legal obligations — including the Prevention of Money Laundering Act (PMLA) and the requirements of SEBI, AMFI, APMI, BASL and tax authorities;
  • communicate with you — statements, transaction confirmations, advice, service updates and, with your consent, market updates and newsletters;
  • maintain the security, integrity and proper functioning of the Website and our systems, and perform analytics to improve our services;
  • respond to queries and resolve grievances; and
  • maintain books, records and audit trails required under applicable law, including the annual compliance audit applicable to the Advisory Entity.

6. Legal Bases and Consent

We process personal data on one or more lawful bases under the DPDP Act and other applicable laws, including: your consent; the performance of the services you have requested; and compliance with our legal and regulatory obligations (for which separate consent is not required). Where processing is based on consent, we provide a clear notice describing the personal data and the purposes, and obtain your consent at or before collection. You may withdraw your consent at any time (see “Your Rights”); withdrawal is as easy as giving consent, applies prospectively, and will not affect processing already carried out or processing we are required to continue under law. Withdrawing consent may limit our ability to provide certain services.

7. Cookies and Tracking Technologies

The Website uses cookies and similar technologies to enable core functionality, remember preferences and analyse usage (for example, through web-analytics tools). Cookies may be essential or analytical. You can manage or disable cookies through your browser settings, although some features may not function properly without them.

8. Disclosure and Sharing of Information

We do not sell your personal data. We may share it, on a need-to-know basis and subject to confidentiality obligations, with:

  • Regulators and authorities: SEBI, AMFI, APMI, BASL / BSE, FIU-IND and tax authorities, where required by law;
  • Product providers and intermediaries: AMCs, portfolio managers, Registrars and Transfer Agents (for example, CAMS / KFintech), custodians, depositories and trustees, to execute and service your investments;
  • Service providers / data processors: vendors providing IT, hosting, CRM, communication and similar services, who process data only on our instructions and under confidentiality and data-protection obligations; and
  • Auditors and professional advisers, including in connection with the Advisory Entity’s statutory and compliance audits, and where required to establish, exercise or defend legal claims.

9. Cross-Border Data Transfer

Some service providers (for example, cloud, email or CRM providers) may process or store data on servers located outside India.

10. Data Security

We implement appropriate technical and organisational measures to protect personal data, including access controls, encryption in transit where appropriate, secured infrastructure and staff confidentiality obligations. No method of electronic transmission or storage is fully secure; while we use commercially reasonable safeguards, we cannot guarantee absolute security. In the event of a personal-data breach, we will take steps to mitigate it and will notify the Data Protection Board of India and affected Data Principals as required under the DPDP Act.

11. Data Retention

We retain personal information and investment / advisory records for the periods required under applicable SEBI regulations, the SEBI (Investment Advisers) Regulations, 2013, PMLA and Indian tax laws (generally five years or more, depending on the type of record), and for as long as necessary for the purposes described in this Policy, even after you stop using our services. When data is no longer required, it is securely deleted or anonymised.

12. Profiling and Automated Processing

As part of advisory services, we carry out risk profiling and suitability assessments in order to provide appropriate advice. We do not make decisions producing legal or similarly significant effects based solely on automated processing without human involvement.

13. Your Rights

Subject to applicable law, including the DPDP Act, you have the right to:

  • access a summary of the personal data we hold about you and the processing activities;
  • request correction, completion or updating of inaccurate or incomplete data;
  • request erasure of your data, except where we are required to retain it under SEBI, PMLA, tax or other law;
  • withdraw consent, including for marketing communications;
  • raise a grievance and have it addressed.

To exercise any of these rights, you may contact us. We may need to verify your identity before acting on a request, and will respond within the timelines required by applicable law. Certain data cannot be erased where retention is legally mandated.

14. Marketing Communications

We send service-related communications as part of our relationship with you. We send marketing communications (such as market updates and newsletters) only with your consent, and you may opt out at any time using the unsubscribe facility or by contacting us.

15. Children’s Data and Persons with Disabilities

Our services are intended for adults. Where the data of a minor is processed (for example, for a minor’s investment account), it is done with the verifiable consent of a parent or lawful guardian, and we do not undertake tracking, behavioural monitoring or targeted advertising directed at children. Personal data of a person with a disability who has a lawful guardian is processed with the guardian’s consent, consistent with the DPDP Act.

16. Third-Party Websites

The Website may contain links to third-party websites. This Policy does not apply to those websites, and we are not responsible for their privacy practices. Please review their privacy policies before sharing your data.

17. Grievance Redressal

For any query, complaint or grievance relating to your personal data or this Policy:

  • General / distribution matters: info@claritaswealth.in
  • Investment advisory matters (Claritas Insights LLP): as set out on our Regulatory Disclosures page.

We endeavour to acknowledge and resolve complaints within the timelines required by applicable law. Our Grievance team can be contacted at info@claritaswealth.in. If you are not satisfied with our response, you may escalate to the Data Protection Board of India under the DPDP Act (once operational); advisory clients may also escalate to SEBI through SCORES (scores.sebi.gov.in) and the ODR portal (smartodr.in).

18. Updates to This Policy

We may update this Policy from time to time to reflect changes in law, regulation or our practices. The “Last modified” date at the top reflects the latest version, and material changes will be notified through the Website.

19. Contact

  • Address: 2006, One World by Sanjar, SV Road, Malad West, Mumbai, Maharashtra – 400064
  • Email: info@claritaswealth.in