Privacy policy.

The protection of personal data in India is presently governed by the Information Technology Act, 2000 and the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011. In addition, the Digital Personal Data Protection Act, 2023 has been enacted to establish a comprehensive framework for the collection, use, storage, and protection of digital personal data, and will come into effect once notified by the Government of India.

Palette Wealth Management Private Limited (“PWM”) is committed to safeguarding your privacy. This Privacy Notice explains how we collect, use, and protect your personal data in compliance with applicable laws, and outlines the rights and choices available to you. Our objective is to provide you with transparency and confidence regarding the privacy and security of your personal information when you engage with us.

Please read this Privacy Notice carefully. By visiting our website or using any of our services, you indicate your agreement to our use of your personal information as set out in this Privacy Notice.

Who is responsible for your personal data

PWM is responsible for your personal data. The PWM whose Registered Office is at the C Wing, 29th Floor, 2903, PL46, East Tower, N.C. Kelkar Road, Dadar, Shivaji Park, Mumbai – 400028, Maharashtra, India, and Corporate Office is at The Executive Centre, Unit 3006, Level 3, Ascent, Plot 248B, S.K. Ahire Road, Worli, Mumbai – 400025, Maharashtra, India, and their affiliates and representatives (“PWM Entities”). Specifically, your data will be controlled by the PWM Entity that you have instructed or that is providing services or communication to you in your region.

Information we collect about you

We may collect personal data about you in a number of circumstances:

• When you register with us (on website or mobile application), apply to use any of our services, become our client, or contact us in person, by telephone, by email or by post;
• When you provide feedback or complete a contact form on our website or Application;
• When you or your organisation offers to provide or provide services to us.

We may collect the following information depending on the service provided:

• Your contact details, such as your name, job title, postal address (including home address, where provided), business address, telephone number, mobile phone number, fax number and email address;
• Your date of birth, nationality, country of birth, country of residence, employment status and tax identification number;
• Passport details, driving license and utility bills;
• Details of the services you request from us;
• Details of your visit to any of our offices or other third-party locations organised depending on the nature of services provided by us;
• In some circumstances, personal data collected about you from a third-party source — for example your organisation, other organisations with whom you have dealings, government agencies, a credit reporting agency, fraud prevention agencies, financial crime agencies, an information or service provider, or publicly available records;
• Details of your employment status, income and source of wealth;
• IP address and browser-generated data when you visit our website or Application;
• From time to time, personal data relating to health and dietary preferences when relevant to meetings or events to which we invite you.

Our Service may contain links to other sites that are not operated by us. If you click on a third-party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

As a general rule, you will provide us with personal data entirely voluntarily; there are generally no detrimental effects for you if you choose not to consent or to provide personal data. However, there are circumstances in which PWM cannot take action without certain of your personal data — for example, where such data is required to send you newsletters, or to meet our obligations under applicable anti-money-laundering, terrorist-financing and fraud-prevention legislation before we can enter into any contractual obligation for provision of services.

How will we use your information?

We use information provided by you in the following ways:

• To process your application to use our services and to provide you with requested services;
• To undertake checks such as identification verification with fraud prevention agencies, to comply with our anti-money-laundering obligations and for the purposes of crime and fraud prevention, including record keeping;
• To comply with our obligations arising from any contracts entered into between you and us, and to provide the information, products and services you request;
• To help protect your information and prevent unauthorised access to it;
• To deal with any queries, complaints or problems reported by you;
• To generate statistics relating to use of our website and Application, such as the popularity of certain features or services — we do not use personally identifiable information for this purpose;
• If required to do so by law, and to the extent necessary for the proper operation of our systems, to protect us or our customers, or for the enforcement of any agreement between you and us;
• To notify you of changes to our services; and
• To help improve the services we provide to you.

We may also use this information to provide you with information about other services we offer that are similar to those you have already engaged us to provide or enquired about, or to provide information about PWM by way of newsletters or emails.

In such instances PWM will only do so where we have either received consent from you, or we have assessed that there is a legitimate interest for us to send you the communication. When assessing legitimate interest, we will balance our interests with your rights, and will only send communications where you would reasonably expect to hear from us. You may opt out of receiving this information when we collect details, or at any time, by contacting us at compliance@palettewealth.com.

How will we protect your information?

We take appropriate security measures (including physical, electronic and procedural measures) to help protect the confidentiality, integrity and availability of your personal information from unauthorised access and disclosure.

Who would we disclose your information to?

We may disclose your information to:

• Businesses that are legally part of the same group of companies within PWM, or that become part of that group;
• Our brokers, dealers, IT providers, service providers and agents, in order to provide and maintain the services;
• Our appointed auditors, accountants, lawyers and other professional advisers (e.g. compliance consultants), to the extent they require access to advise us;
• Fraud prevention agencies and other organisations to allow us to undertake relevant checks — details supplied on request;
• Auditors appointed by the providers of such products or services, where required;
• Regulators, including any relevant regulatory authority, where they are entitled to require disclosure;
• To meet applicable law, a court order, or market rules and codes of practice applicable at the time;
• To investigate or prevent fraud or activities believed to be illegal or otherwise in breach of applicable law;
• Relevant tax, payments and customs authorities, who may pass this on to tax authorities in other jurisdictions, as tax regulations require us to collect information about each investor’s tax residency;
• A prospective seller or buyer of our business or assets, in the event that we sell or buy any business or assets — in which case personal information held about clients may be one of the transferred assets.

We will not lend or sell your information to third parties.

Personal data about other people which you provide to us

If you provide personal data to us about someone else (such as one of your directors or employees, or someone with whom you have business dealings) you must ensure that you are entitled to disclose that personal data to us, and that, without our taking any further steps, we may collect, use and disclose that personal data as described in this Privacy Notice. In particular, you must ensure the individual concerned is aware of the various matters detailed in this Privacy Notice as they relate to that individual — including our identity, how to contact us, our purposes of collection, our disclosure practices (including disclosure to overseas recipients), the individual’s right to obtain access to the personal data and make complaints about its handling, and the consequences if the personal data is not provided (such as our inability to provide services).

Data retention

We are committed to only keeping your personal data for as long as we need to in order to fulfil the relevant purpose(s) it was collected for, as set out above, and for as long as we are required or permitted to keep it by law. We retain copies of customer contracts to enable us to deal with any legal issues, and information provided for identification verification, financial crime and anti-money-laundering checks (as required by law), for up to 10 years after termination or expiry of our contract with you. We retain details of complaints for up to 10 years from the date of receipt.

We shall keep records of the following for up to 10 years:

• Electronic communications and minutes of face-to-face meetings;
• Suitability and appropriateness assessments;
• Periodic statements (for example, valuations); and
• All orders and transactions in financial instruments on your behalf (including information about your identity).

Transferring information overseas

We may share your personal information with PWM Entities and service providers, and this may involve transferring it to countries outside the European Economic Area (EEA) whose data protection laws may not be as extensive as those which apply to us. Where we do so, we will ensure this is done in accordance with applicable law, and take appropriate measures to ensure the level of protection applied to your personal information in these countries is similar to that which applies within the EEA — for example, only transferring data to jurisdictions with a European Commission adequacy decision, or by using approved model clauses.

We may transfer your personal information between businesses that are legally part of the PWM Entities for the purposes of providing our services to you as follows:

• From our businesses based in the United Kingdom to our businesses based in India or the United States of America, on the basis that we have established Data Processing Agreements containing model clauses as required under GDPR; and
• From our businesses based in India or the US to our businesses based in the United Kingdom, on the basis that the United Kingdom is an authorised jurisdiction for the purposes of the relevant Acts.

Your rights

You have the right to request a copy of the personal data about you which we hold, to have any inaccurate personal data corrected, and to object to or restrict our use of your personal data. You may also make a complaint if you have a concern about our handling of your personal data.

If you wish to do any of the above, please email compliance@palettewealth.com. We may request that you prove your identity by providing a copy of a valid means of identification, in order for us to comply with our security obligations and to prevent unauthorised disclosure of data.

When we receive such a request we will endeavour to provide you with these details without delay, and at the latest within one month of receipt. We may extend the period of compliance by a further two months where requests are complex or numerous; in such instances we will inform you within one month of receipt and explain why the extension is necessary.

When PWM receives a subject access request, we will provide a copy of the information held free of charge. PWM may charge a reasonable fee, based on administrative cost, to comply with requests for further copies of the same information, or where a request is manifestly unfounded or excessive — particularly if repetitive. In certain circumstances we may even refuse to respond to such requests.

You also have the following rights (unless exemptions apply), which can be exercised by contacting us using the details below:

• To ask us not to process your personal data for marketing purposes;
• To prevent any processing of personal data that is causing or is likely to cause unwarranted and substantial damage or distress to you or another individual;
• To request the rectification or completion of personal data which are inaccurate or incomplete;
• To restrict or object to the processing of your personal data;
• To request its erasure under certain circumstances;
• In certain circumstances, to receive your personal data in a structured, commonly-used and machine-readable format, and to have it transmitted to another data controller where technically feasible;
• To be informed about any use of your personal data to make automated decisions about you, and to obtain meaningful information about the logic, significance and envisaged consequences of that processing; and
• To lodge a complaint about the way your personal data is being used with your relevant Data Protection Authority.

When you contact us to exercise any of the rights above, we may ask you to provide some additional information in order to verify your identity, such as your name, your address and proof of identity.

DND subscribers

By submitting the forms on our website, the user consents to being reached out through email, WhatsApp or phone calls. This remains true for DND subscribers as well.

Changes to this Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page, and, where the change is material, by email and/or a prominent notice on our Service prior to the change becoming effective, updating the effective date at the top of this Privacy Policy. You are advised to review this Privacy Policy periodically for any changes; changes are effective when posted on this page.

Contact us

If you would like to lodge a complaint or exercise any of your rights set out above, you can contact us at:

E-mail: compliance@palettewealth.com
Communication Address: The Executive Centre, Unit 3006, Level 3, Ascent, Plot 248B, S.K. Ahire Road, Worli, Mumbai – 400025, Maharashtra, India.