Version 2026-10, effective 1 October 2026. This policy is written to meet the Digital Personal Data Protection Act, 2023 (DPDP Act) and the IT Act, 2000 with the SPDI Rules, 2011.
1. Who we are
Finvolve Ventures LLP (LLPIN ACM-5260), UG 06, MGF Metropolis Mall, Mehrauli Gurugram Road, Gurugram, Haryana 122002 (“Finvolve”, “we”), operates the Finvolve website and mobile app. For the personal data you give through Finvolve, we are the Data Fiduciary. We provide technology services to the managers of the funds listed on our Regulatory Disclosures page. We share common promoters with those managers.
2. Who this policy covers
Investors who have been onboarded to one of those funds, their nominees and authorised signatories, and wealth managers who use the app. Finvolve is not for anyone under 18 years of age.
3. Personal data we collect
- Identity and KYC data: name, PAN, date of birth, address, photograph, signature, and the KYC details and status held for you under SEBI and PMLA requirements.
- Contact data: mobile number and email address.
- Financial data: bank account and demat account details, commitments, drawdowns, payments, distributions and unit holdings.
- Accreditation data: accredited investor status and certificate, where applicable.
- Documents: agreements, consents, notices and statements, and your electronic signatures and consent records (time, device and IP address).
- Wealth managers: firm and individual details, registration details you provide, and which investors you serve.
- Device and usage data: device identifiers, app version, crash logs and security logs.
4. Why we use it
- To log you in and verify your identity (one-time passwords, biometric unlock on your device).
- To show you your commitments, notices, documents and statements, and to record your consents.
- To meet KYC, anti-money laundering and other legal and regulatory obligations of the funds and managers.
- To send service messages such as OTPs, drawdown notices and statement alerts.
- To secure the app and to detect and prevent fraud and misuse.
We do not use your personal data for advertising and we do not sell it.
5. Consent and withdrawing it
We ask for your consent in the app before we collect your personal data, and we record it. You can withdraw consent at any time by writing to compliance@finvolve.co. Withdrawal does not affect processing we are required by law to continue, or processing already done. If you withdraw consent we may no longer be able to provide the app to you.
6. Who receives your data
We share personal data only as needed to run the funds and the app:
- The fund’s trustee, investment manager, custodian, registrar and transfer agent (RTA) and fund administrator.
- Depositories (NSDL and CDSL) for demat and unit credit.
- Auditors.
- Our service providers: Amazon Web Services (cloud hosting and email delivery), Zoho Sign (electronic signature), and Google Firebase Cloud Messaging and Apple Push Notification service (delivery of push notifications).
- Regulators, courts and law-enforcement authorities where the law requires.
Wealth managers can see the data of the investors they serve, as needed to assist them.
7. Where your data is stored
Your data is stored on Amazon Web Services in Mumbai, India (ap-south-1). We do not transfer your stored personal data outside India. Push notifications pass through Google and Apple servers and are written not to contain your PAN, bank details or amounts.
8. How long we keep it
We keep your personal data while you are an investor and for eight (8) years after your relationship with the fund ends, because KYC, anti-money laundering and AIF record-keeping rules require it. After that we delete it or make it anonymous, unless a law or legal proceeding requires us to keep it longer.
9. Security
We use encryption in transit and at rest, access controls, logging and device-level protections. If a personal data breach affects you, we will tell you and the Data Protection Board of India as the law requires.
10. Your rights
You may ask us to give you a summary of the personal data we hold and how it is used, to correct or complete it, and to erase it (subject to the retention in section 8). You may also nominate another person to exercise these rights if you die or become incapacitated. To ask, write to compliance@finvolve.co or use the steps on Account & Data Deletion.
11. Grievances
Our Data Protection contact is the Grievance Officer for the fund you are invested in, listed on our Grievance Redressal page, at compliance@finvolve.co, +91 99588 83990. If we do not resolve your concern, you may complain to the Data Protection Board of India once it is operational for this purpose.
12. Changes
We will post changes here with a new version and date. Where the change needs your consent, we will ask for it in the app.