Privacy Policy

1. Data Fiduciary

Aryzen Capital Advisors LLP, 20174 PLH, Gunjur, Bengaluru 560087, Karnataka (the "Firm"), is the Data Fiduciary under the Digital Personal Data Protection Act, 2023 (DPDP Act). Our Data Protection Officer / Compliance Officer is R D Srivastava — /contact.html?subject=Privacy+Enquiry.

2. Data We Collect

We collect only the data necessary for advisory services and regulatory compliance:

• Identity data: Full name, date of birth, PAN number, Aadhaar (last 4 digits only — as per UIDAI guidelines)
• Contact data: Email address, phone number, residential address
• Financial data: Income, net worth, existing investments, financial goals (for advisory and risk profiling purposes)
• KYC data: As required by SEBI and PMLA regulations
• Website data: Essential cookies only (session identifiers). No tracking or advertising cookies.

Our online tools (Risk Profiler, Calculators, Portfolio Analyser) are session-only — no data from these tools is transmitted to or stored by Aryzen.

3. Purpose of Processing

• Providing investment advisory services as registered with SEBI
• KYC verification and anti-money laundering compliance (PMLA)
• Billing and fee administration
• Regulatory reporting to SEBI and other statutory authorities
• Responding to your enquiries and grievances
• Sending advisory reports and compliance-related communications

4. Consent

We process your personal data only with your explicit, free, specific, informed, and unambiguous consent as required under the DPDP Act 2023. Consent is obtained via the Investment Advisory Agreement and, for website interactions, via the cookie consent banner. You may withdraw consent at any time by writing to R D Srivastava (Compliance Officer) via our contact form — withdrawal may affect our ability to provide advisory services.

5. Data Sharing

We do not sell, rent, or trade your personal data. We share data only as follows:

• Regulatory authorities: SEBI, Income Tax Department, FIU-IND (as required by law)
• KRA / CKYCR: For KYC verification (CVL KRA)
• E-sign providers: Zoho Sign (for agreement execution) — data shared only for signing workflow
• Statutory auditors: As required for annual compliance audit

All data processors engaged by us are bound by data processing agreements consistent with the DPDP Act.

6. Data Retention

Client advisory records, KYC documents, and agreements are retained for a minimum of 5 years as required by SEBI. Regulatory compliance records may be retained for longer as required by law. Website enquiry data is retained for 2 years.

7. Your Rights

Under the DPDP Act 2023, you have the right to:

• Access your personal data held by us
• Correct inaccurate or outdated personal data
• Erasure of data (subject to legal retention obligations)
• Withdraw consent
• Nominate a person to exercise these rights on your behalf
• File a complaint with the Data Protection Board of India

To exercise these rights, write to /contact.html?subject=Privacy+Enquiry. We will respond within 30 days.

8. Security

We implement industry-standard security measures including SSL/TLS encryption for all data in transit, access controls, and periodic security reviews as required by SEBI's CSCRF framework. We do not store Aadhaar numbers (only last 4 digits) and do not store banking passwords or OTPs.

9. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be communicated to clients via email. The updated policy will be published on this page with a revised effective date.

10. Contact

For privacy-related queries, write to:
R D Srivastava, Compliance Officer
Aryzen Capital Advisors LLP
20174, PLH, Gunjur, Bengaluru 560087
/contact.html?subject=Privacy+Enquiry