Privacy Policy

This Privacy Policy explains how the wisefolioplatform collects, uses, shares, and protects your personal data, and the rights you have under India's Digital Personal Data Protection Act, 2023 (the “DPDP Act”). It is a working draft pending final legal review.

Effective date: To be confirmed

1. Who we are (Data Fiduciary)

For the purposes of the DPDP Act, the Data Fiduciary who determines the purpose and means of processing your personal data is the operating entity below. Wherever this policy says “we”, “us”, or “wisefolio”, it refers to that entity.

2. Scope & effective date

This policy covers wisefolio.in and the products and services offered through it — memberships, live and recorded events, the community, PMS and AIF discovery, and the unlisted-shares desk. It takes effect on the date shown above and applies to personal data we process from that date. Material changes are handled under “Changes” below.

3. Data we collect

• Account & identity. When you sign up we create an account through our identity provider (Auth): your name, email, phone, and authentication identifiers.
• Contact & marketing preferences. Your email and WhatsApp number, and your marketing-consent choices for email and WhatsApp.
• KYC & financial-identity documents. For the unlisted-shares desk and accreditation flows we collect PAN, a client master list / demat statement (CML/CMR), demat references, a cancelled cheque or bank details for payouts, and — where you seek AIF/accreditation facilitation — income or net-worth evidence. These documents are stored as private objects and are not publicly accessible.
• Transaction & payment data. Orders, memberships, and subscriptions you purchase, and the payment references tied to them. Card, UPI, and bank-account credentials are handled by our payment processor (Cashfree) and are not stored by us. For unlisted settlements we record the bank-transfer reference (UTR) you declare.
• Usage & device data. Pages you view, items you follow or save, IP address, device and browser information, and referrer, recorded as analytics events.
• Marketing attribution. A first-touch attribution cookie (wf_attr) that remembers how you arrived, so we can measure which channels bring investors to the platform.
• Cookie & consent state. Your analytics/ads consent choice (stored under wf_consent).
• Push subscriptions. If you opt in to browser push notifications, the subscription endpoint your browser issues.
• Community content. Posts, comments, and other content you choose to publish on the platform.

4. How we use your data (purposes)

• Deliver, operate, and secure the platform and your account.
• Process orders, memberships, subscriptions, and payments.
• Grant and manage event access and recording entitlements.
• Perform KYC/AML checks for the unlisted desk and AIF/accreditation facilitation.
• Send transactional messages and — with your consent — lifecycle and marketing email/WhatsApp.
• Personalise your feed, follows, and recommendations.
• Measure usage, improve the product, and debug issues.
• Detect and prevent fraud, abuse, and security incidents.
• Comply with legal, tax, and regulatory obligations.

5. Consent & legal basis (DPDP)

We rely on your consent for marketing communications and for non-essential analytics and advertising cookies. You give consent at sign-up, through the cookie banner, and through the marketing toggles in your account, and you can withdraw it at any time — through the same toggles or by emailing our Grievance Officer. Certain processing needed to provide a service you have requested, or to meet a legal obligation, may proceed on the legitimate-uses basis the DPDP Act allows.

6. Cookies & tracking

We distinguish essential cookies (needed to sign you in and keep the site working) from analytics and advertising cookies (used only after you accept). Our cookie banner records your choice under wf_consent, and we respect your browser's Do-Not-Track signal as a decline.

When — and only when — you have accepted and the relevant identifier is configured, we may load third-party measurement and advertising pixels: Meta Pixel, Google Analytics, Google Ads, LinkedIn Insight, and X (Twitter). These pixels are consent-gated and remain dormant until we configure them; none fire before you accept.

7. Who we share it with (processors)

We share the minimum data necessary with the service providers (Data Processors) below. We do not sell your personal data.

8. International transfers

Some of the processors above may process data on servers outside India. Where that happens we rely on the transfer mechanisms permitted under the DPDP Act and applicable rules.

9. Retention

We keep personal data only as long as needed for the purposes above or to meet a legal obligation, then delete or anonymise it. Our current retention periods are:

• KYC / AML documents — To be confirmed
• Transaction & tax records — To be confirmed
• Analytics / usage logs — To be confirmed
• Marketing-consent logs — To be confirmed

10. Security

KYC and financial-identity documents are stored as private objects that are not publicly reachable. Access to personal data inside the platform is role-restricted, and data is encrypted in transit (TLS). No system is perfectly secure, but we take reasonable technical and organisational measures to protect your data.

11. Your rights as a Data Principal (DPDP)

Subject to the DPDP Act, you have the right to access, correct, complete, update, and erase your personal data, to nominate another person to exercise your rights, to withdraw consent, and to a grievance-redressal mechanism.

How to exercise them: use the self-service controls in your account (marketing toggles, KYC/accreditation management), or email our Grievance Officer below.

12. Children

The platform is intended for users aged 18 and over and is not directed at children. We do not knowingly process the personal data of a person under 18 without verifiable parental consent as required by the DPDP Act.

13. Grievance Officer

14. Changes to this policy

We may update this policy from time to time. When we make a material change we will update the effective date above and, where appropriate, notify you. Continued use of the platform after an update constitutes acceptance of the revised policy.

15. Contact

Questions about this policy or your data? Email us at hello@wisefolio.in. See also our Terms of Use, Disclosures, and the Legal & Disclaimers overview.

Last updated: To be confirmed