Compliance Document

Privacy Policy

2. Scope & Applicability

This policy applies to all individuals interacting with Finovia Wealth Private Limited through our website https://finovia.net, during client onboarding, KYC verification, risk profiling, and mutual fund transaction processing.

By engaging with Finovia Wealth Private Limited or accessing our website, you consent to the collection and use of your personal information as described in this policy.

3. Information We Collect

Personal Details

Name, address, date of birth, PAN, Aadhaar (for KYC), contact details (mobile number, email ID), bank account information, nomination details, and investment preferences.

Financial Details

Annual income range, net worth, existing investments, risk profile assessment responses, investment horizon, goals, and transaction history.

KYC Documents

PAN card copy, Aadhaar copy, address proof, photograph, bank statement or cancelled cheque, FATCA/CRS self-declaration, and UBO details (for non-individual investors).

Technical Data

IP address, browser type, device information, operating system, and cookies when you visit our website.

We do NOT collect unnecessary personal data such as religion, caste, political affiliation, or any data not required for mutual fund distribution services and regulatory compliance.

4. Purpose of Data Collection

Your data is used strictly for processing mutual fund transactions, completing KYC and meeting SEBI/AMFI/PMLA regulatory obligations, conducting risk profiling and suitability assessment, sending transaction confirmations, account statements, and service communications, and responding to queries and complaints.

We do NOT use your data for any purpose other than what is stated above.

5. Data Sharing Rules

We share your data only with AMCs and RTAs (for processing transactions), SEBI and AMFI (upon regulatory request), auditors (during compliance audits), and KRAs (CAMS KRA, CVL KRA, NDML KRA, CKYC for KYC verification). We do NOT sell, rent, lease, or share your personal or financial data with any marketing agency or unrelated third party under any circumstances.

6. Data Storage & Security Measures

• Data is stored on secure, encrypted systems with two-factor authentication (2FA)
• Role-based access controls are implemented
• Physical documents are stored securely at the registered office
• Employees sign confidentiality agreements
• Strong password policies and regular security audits are enforced

7. Data Retention & Disposal

Client records are retained as per SEBI, AMFI, PMLA, and Income Tax regulations. After the required retention period, physical records are securely shredded and digital data is permanently deleted. All disposals are documented and require approval.

8. Your Rights Under DPDPA 2023

You have the right to: access your personal data, request correction of inaccurate data, request deletion (subject to regulatory requirements), withdraw consent, and file a complaint with the Data Protection Board of India.

To exercise these rights, contact: help@finovia.net

9. Cookies

Our website uses cookies to enhance user experience and analyze traffic. You can disable cookies through browser settings, but some features may not function properly.

10. Third-Party Links

Our website may contain links to external websites (AMC, SEBI, AMFI, etc.). Finovia Wealth Private Limited is not responsible for their privacy practices or content.

11. Changes to This Policy

We may update this Privacy Policy periodically. The latest version will always be available on our website. Users are encouraged to review it regularly.

Compliance Document

Commission Disclosures

Compliance Document

Fund Selection Policy

Fund Selection Process Flow

Exclusion Criteria

The following are automatically excluded from our recommended list:

1. Schemes from AMCs under SEBI regulatory action or warning
2. Schemes with high portfolio concentration in a single stock or sector beyond category norms
3. Debt schemes with significant exposure to below-investment-grade (below AA-) securities
4. Schemes with more than 2 fund manager changes in the last 3 years
5. Close-ended or interval schemes unless specifically required for a client's goal
6. SIF products with opaque strategy or inadequate risk disclosure

Data Sources

AMC factsheets and monthly portfolio disclosures; Value Research and Morningstar India for performance data and fund ratings; AMFI website for NAV and AUM data; SEBI Riskometer classification for risk categorization; SEBI Mutual Fund filings portal for SID/SAI/KIM documents.

Suitability Mapping

No scheme whose SEBI Riskometer category exceeds the client's assessed risk level is recommended. If a client insists on an unsuitable scheme, the Execution-Only process is followed with written unsuitability communication and client consent.

Conflict of Interest Declaration

Compliance Document

Investor Grievance Redressal Policy

How to Lodge a Complaint

Timelines

If coordination with AMC or RTA is required, we will keep you updated on the progress. All complaints are recorded in our Complaint Register and tracked until closure. The register is reviewed periodically by the Director.

Escalation & External Platforms

If you are not satisfied with the resolution, you may escalate your complaint through:

• SEBI SCORES: https://scores.gov.in
• SMART ODR: https://smartodr.in

Compliance Document

Important Links

Regulatory

AMFI

Exchanges & Depositories

MF Portals

KYC

PMS & Research

Compliance Document

Rights & Obligations of Investors

1. Receive complete, accurate, and updated information about mutual fund schemes, including SID, SAI, KIM, factsheets, and performance reports.
2. Know all commissions (trail or any other form) received by us for schemes recommended to you. This disclosure is available on our Commission Disclosure page and at the point of sale.
3. Receive a proper risk assessment and suitability check before any scheme recommendation.
4. Receive a written unsuitability communication if you choose to invest in a scheme that does not match your risk profile, along with your right to proceed on an execution-only basis.
5. Have your complaints acknowledged within 2 working days and resolved within 7 working days.
6. Escalate unresolved complaints to AMC, SEBI SCORES (scores.sebi.gov.in), or SMART ODR (smartodr.in).
7. Choose Direct Plans through AMC websites without distributor involvement. Direct Plans have lower expense ratios.
8. Have your personal and financial data treated with confidentiality as per our Privacy Policy and the Digital Personal Data Protection Act, 2023 (DPDPA).
9. Receive periodic portfolio review communications and account statements.
10. Switch distributors or go direct at any time without any penalty or restriction from our side.

Your Obligations as an Investor

1. Provide accurate and complete information for KYC, risk profiling, and transaction processing.
2. Read all scheme-related documents (SID, SAI, KIM) carefully before investing.
3. Inform us promptly about any change in personal details, financial situation, or investment objectives.
4. Review your Consolidated Account Statement (CAS) regularly and report discrepancies immediately.
5. Understand and acknowledge that mutual fund investments are subject to market risks and past performance is not indicative of future returns.
6. Not hold Finovia Wealth Private Limited responsible for investment losses arising from market movements.

Do's and Don'ts for Investors

Our Obligations to You

Finovia Wealth Private Limited (ARN-339710) is committed to:

1. Acting in your best interest at all times
2. Not indulging in mis-selling, churning, or pushing products purely for commission
3. Providing transparent commission disclosures on our website and at the point of sale
4. Maintaining strict confidentiality of your personal and financial data
5. Ensuring all our staff hold the appropriate certifications
6. Following the AMFI Code of Conduct in letter and spirit
7. Cooperating fully with any regulatory inquiry by SEBI, AMFI, or AMCs
8. Resolving your complaints within the committed timelines
9. Providing accurate and updated information about mutual fund schemes
10. Never making false promises about returns or guaranteeing any investment outcome

Compliance Document

Disclaimer

Investment Risk Disclaimer

No Guarantee of Returns

Finovia Wealth Private Limited, its directors, employees, or affiliates do not guarantee or assure any returns on investments made through mutual fund schemes or other financial products.

We do not guarantee: any specific returns, minimum returns, or capital protection. The company shall not be responsible for any direct or indirect losses arising from the use of information provided on this website or associated platforms.

Commission Disclosure

We receive trail commission from AMCs for distributing Regular Plan mutual fund schemes. This commission is included in the scheme's Total Expense Ratio (TER) and does NOT increase investor cost.

Investors may choose Direct Plans directly through AMC platforms, which have lower expense ratios. Detailed commission disclosure is available on our website at https://finovia.net/commission-disclosures

Scheme Documents

Investors are requested to read: Scheme Information Document (SID), Statement of Additional Information (SAI), and Key Information Memorandum (KIM).

These documents are available on AMC websites and SEBI portal: https://www.sebi.gov.in/filings/mutual-funds.html

Data & Privacy

We strive to ensure that all information on the website is accurate and updated. However, we do not guarantee completeness or accuracy. NAV data, performance, and market information are sourced from AMCs and public sources and may be subject to time lag. By using this website, you agree to our Privacy Policy.

Third-Party Links

This website may contain links to external websites for user convenience. Finovia Wealth Private Limited does not control or endorse these websites and is not responsible for their content or privacy practices.

Jurisdiction

Finovia Wealth Private Limited operates in accordance with Indian laws and SEBI/AMFI regulations. All disputes shall be subject to the jurisdiction of courts in Pune, Maharashtra.

Copyright

All content on this website, including text, graphics, logos, and documents, is the intellectual property of Finovia Wealth Private Limited. Unauthorized reproduction or distribution is strictly prohibited.

Compliance Document

Email Signature

Standard email signature for official communications from Finovia Wealth Private Limited. Copy and use in your email client.