Introduction
DelWA ("we", "our", or "us") values your privacy. This Privacy Policy explains how DelWA collects, uses, stores, and shares personal information when you use the DelWA application and related services, including our Smart Wealth Assistant, risk profiling, and mutual fund distribution services in India.
By using DelWA, you agree to the practices described in this policy.
Scope
This Privacy Policy applies to:
- The DelWA mobile application and related digital interfaces.
- Mutual fund distribution services provided as an ARN-certified entity.
- Services integrated through ONDC and affiliated service providers.
- Communications and support interactions related to DelWA.
This policy does not apply to third-party services that have their own privacy policies.
Information We Collect
Depending on your use of DelWA, we may collect:
- Account and identity information: Name, mobile number, email address, PAN, and KYC details as required.
- Financial profile information: Risk profiling responses, investment goals, horizon, income band, and wealth assignment preferences.
- Transaction information: Order details, SIP instructions, redemption requests, payment references, timestamps, and status updates.
- Device and technical information: Device type, operating system, app version, IP address, crash logs, and diagnostic data.
- Usage information: In-app interactions, AI assistant queries, preferences, and support history.
- Regulatory and compliance data: Information required for fraud prevention, dispute handling, and legal compliance.
Information We Do Not Collect
DelWA does not intentionally collect:
- Your plaintext payment card details for direct storage by DelWA.
- Biometric data, unless explicitly required and clearly disclosed for a specific feature.
- Personal data beyond what is necessary for service delivery, legal compliance, and security.
How We Use Your Information
We use collected information to:
- Provide, operate, and improve DelWA services.
- Generate risk profiles and wealth assignments suited to your stated goals.
- Power the Smart Wealth Assistant and related AI-driven guidance features.
- Process transactions, requests, and mutual fund service workflows.
- Facilitate ONDC-based discovery, order, and fulfillment flows.
- Communicate updates, alerts, and support responses.
- Detect, prevent, and investigate fraud, abuse, and security incidents.
- Comply with legal, regulatory, and contractual obligations in India.
Information Sharing
We may share information only as needed with:
- Asset Management Companies (AMCs) and registrars for mutual fund transactions.
- ONDC ecosystem participants for transaction execution.
- Regulated financial entities involved in your requested services.
- Payment processors and banking partners for payment handling.
- Service providers supporting hosting, analytics, notifications, and customer support.
- Government authorities, regulators, or law enforcement when legally required.
We do not sell personal information.
ONDC Data Exchange
As DelWA operates within ONDC workflows, relevant transaction and operational data may be exchanged with ONDC-connected entities to complete user-initiated actions. Such sharing is limited to what is necessary for order lifecycle management, reconciliation, and compliance.
Payment Processing (AMC Responsibility)
Where applicable, payment processing and settlement responsibilities are handled by the relevant Asset Management Company (AMC), its authorized intermediaries, or regulated payment partners. DelWA does not independently underwrite or assume AMC regulatory obligations related to payment execution, settlement, or fund management.
Data Storage & Security
We use commercially reasonable safeguards to protect information, including:
- Encryption in transit where applicable.
- Access controls and role-based permissions.
- Monitoring, logging, and incident response procedures.
No method of transmission or storage is completely secure. While we work to protect your data, absolute security cannot be guaranteed.
Data Retention
We retain personal information only for as long as needed to:
- Deliver services and maintain records.
- Meet legal, tax, accounting, and regulatory requirements.
- Resolve disputes and enforce agreements.
When no longer required, data is deleted, anonymized, or securely archived per applicable standards.
Your Rights in India
Subject to applicable law, including the Digital Personal Data Protection Act, 2023, you may have the right to:
- Access your personal information.
- Request correction of inaccurate or incomplete data.
- Request deletion of data, where legally permissible.
- Withdraw consent for certain processing activities.
- Raise grievances regarding data processing.
You can exercise these rights through the contact channels provided in the app or via support.
Children's Privacy
DelWA is not intended for children under the age required by applicable local law to independently use financial or regulated digital services. We do not knowingly collect personal information from children without lawful authorization.
Third-Party Services
DelWA may integrate with third-party services such as analytics, payments, communications, KYC verification, and ONDC network participants. Their handling of data is governed by their own terms and privacy policies. We encourage users to review those policies.
Legal Compliance
We process and disclose data as necessary to comply with:
- Applicable Indian data protection and privacy laws.
- SEBI, AMFI, and other financial services regulatory obligations.
- Lawful requests from competent authorities.
Changes to This Policy
We may update this Privacy Policy from time to time. Material updates will be reflected by revising the "Last updated" date and, where appropriate, providing additional notice in-app or through other communication channels.
Mutual fund investments are subject to market risks. Read all scheme-related documents carefully. Past performance is not indicative of future returns.