Privacy Policy

Singhal Consultancy Services ("we", "our", or "us"), operating from 209, 2nd Floor, Pink Tower, Lal Kothi, Tonk Road, Jaipur, Rajasthan 302015, is committed to protecting your personal information and your right to privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website at singhalconsultancy.in or engage with our financial advisory services.

This policy is framed in accordance with the Information Technology Act, 2000, the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, and the Digital Personal Data Protection Act, 2023 (DPDP Act). Please read this policy carefully. If you disagree with its terms, please discontinue use of our website.

1. Information We Collect

We collect personal data only when you voluntarily provide it to us through our contact form, insurance enquiry form, or direct communication. The categories of data we may collect include:

• Identity Information: Full name, date of birth, PAN number (where required for regulatory purposes).
• Contact Information: Email address, mobile phone number, residential city and state.
• Financial Enquiry Details: Investment goals, approximate investable surplus, risk appetite, preferred investment horizon, and existing portfolio details shared voluntarily.
• Insurance Enquiry Details: Type of insurance sought (life, health, motor, etc.), coverage amount required, existing insurance policies, and family composition where relevant to coverage assessment.
• Technical Data: IP address, browser type and version, device type, pages visited, time and date of visit, and time spent on pages — collected automatically via analytics tools.
• Communication Records: Records of your queries, correspondence, and any instructions provided to us via email or telephone.

We do not collect sensitive personal data such as biometric information, passwords, or bank account credentials through our website. Any financial account details required for investment execution are collected through the secure portals of our regulated platform partners (NJ Wealth, Probus Insurance) and are not stored on our servers.

2. How We Use Your Information

We process your personal data on the lawful basis of your consent and for the performance of our advisory services. Specifically, your data is used for:

• Responding to your enquiries and providing personalised financial or insurance advisory services.
• Preparing and presenting financial plans, investment recommendations, or insurance proposals tailored to your stated goals.
• Facilitating mutual fund transactions through the NJ Wealth platform and insurance placements through Probus Insurance or NJ Insurance on your behalf.
• Maintaining records as required under AMFI, SEBI, and IRDAI regulations, including Know Your Customer (KYC) obligations.
• Sending you service-related communications such as portfolio updates, policy renewal reminders, or regulatory notices — not unsolicited marketing.
• Complying with applicable legal and regulatory obligations, including responding to lawful requests from SEBI, AMFI, IRDAI, Income Tax Department, or other competent authorities.
• Improving our website functionality and understanding visitor behaviour through aggregated, anonymised analytics data.

We will not use your personal information for any purpose incompatible with the purposes described above without first obtaining your explicit consent.

3. Data Sharing and Disclosure

We do not sell, rent, or trade your personal information to any third party for commercial purposes. We may share your information only in the following circumstances:

• NJ Wealth (Integrated Enterprises India Ltd.): As our mutual fund distribution platform partner, NJ Wealth receives the personal and KYC data necessary to onboard you as an investor, process your SIP/lump sum transactions, and provide portfolio reporting. NJ Wealth operates under AMFI and SEBI regulations with its own data protection framework.
• Probus Insurance Broker / NJ Insurance: For insurance placements, relevant personal and health/lifestyle data is shared with Probus Insurance or NJ Insurance as required to obtain quotes and bind policies with the respective insurance companies. These entities are IRDAI-registered and bound by applicable data protection norms.
• Asset Management Companies (AMCs): Your KYC and investment instruction data is transmitted to the relevant AMC(s) through the NJ Wealth platform as part of executing your mutual fund investments.
• Regulatory Authorities: We are obligated to share information with SEBI, AMFI, IRDAI, the Registrar and Transfer Agents (RTAs), Central KYC Registry (CKYC), and other competent authorities as required by law, regulation, or court order.
• Email Service Providers: We use Resend (a transactional email service) to deliver our email communications. Your email address and the content of your enquiry are processed through this service solely for the purpose of delivering our reply to you.
• Professional Advisors: In limited circumstances, we may share information with our legal, compliance, or tax advisors who are bound by professional confidentiality obligations.

All third parties with whom we share data are required to maintain the confidentiality and security of your information and to use it only for the specific purpose for which it was shared.

4. Data Security

We implement reasonable security practices and procedures as mandated under the IT (Amendment) Act, 2008 and the SPDI Rules, 2011. Our security measures include:

• Encrypted data transmission using SSL/TLS protocols on our website.
• Restricted access to personal data — only team members who need the information to perform their duties can access it.
• Use of regulated, industry-standard platforms (NJ Wealth, Probus Insurance) for investment and insurance data rather than storing sensitive financial data on our own servers.
• Regular review of our data collection, storage, and processing practices.

However, please note that no method of transmission over the internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security. If you suspect any unauthorised use of your personal data, please contact us immediately.

5. Data Retention

We retain your personal data for as long as is necessary to provide you with our services and to comply with our legal, regulatory, and contractual obligations. Under AMFI regulations, mutual fund distributor records must be maintained for a minimum of 8 years. Insurance-related records are retained in accordance with IRDAI guidelines. Website analytics data is retained in aggregated, anonymised form. Upon ceasing your advisory relationship with us, we will archive your data for the legally mandated retention period and then securely delete it.

6. Your Rights Under Indian Law

Under the Digital Personal Data Protection Act, 2023 (DPDP Act), you have the following rights with respect to your personal data, which you may exercise by writing to us at mutualfund@singhalconsultancy.in:

• Right to Access: You may request a summary of the personal data we hold about you and information about how it has been processed.
• Right to Correction: You may request that we correct any inaccurate or incomplete personal data we hold about you.
• Right to Erasure: You may request deletion of your personal data where it is no longer necessary for the purpose it was collected, subject to our overriding regulatory retention obligations.
• Right to Withdraw Consent: Where we process your data on the basis of your consent, you may withdraw that consent at any time. Withdrawal of consent will not affect the lawfulness of processing carried out before withdrawal.
• Right to Grievance Redressal: You have the right to have your grievances addressed in a timely and effective manner. Our grievance officer is Manan Singhal, reachable at mutualfund@singhalconsultancy.in. Grievances will be acknowledged within 72 hours and resolved within 30 days.
• Right to Nominate: You may nominate any individual to exercise your data rights on your behalf in the event of your death or incapacity.

Please note that certain rights may be limited where we are required to retain or process data to comply with legal obligations, including regulatory compliance under SEBI, AMFI, and IRDAI frameworks.

7. Cookies and Analytics

Our website uses cookies and similar tracking technologies to enhance your browsing experience and to analyse site traffic. Specifically:

• Essential Cookies: Necessary for the website to function correctly. These cannot be disabled.
• Analytics Cookies: We use basic web analytics to understand how visitors interact with our website — pages visited, time on site, and referral sources. This data is aggregated and does not personally identify you.

You may configure your browser to refuse cookies or to alert you when cookies are being sent. However, refusing cookies may limit some functionality of our website. We do not use cookies for targeted advertising or to track your activity across other websites.

8. Children's Privacy

Our services are intended for individuals who are 18 years of age or older. We do not knowingly collect personal data from children. If you believe that we have inadvertently collected information from a child, please contact us immediately and we will take steps to delete such information.

9. Changes to This Policy

We reserve the right to update this Privacy Policy at any time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes, we will update the "Last updated" date at the top of this policy. We encourage you to review this policy periodically. Your continued use of our website after any changes signifies your acceptance of the revised policy.

10. Contact Us for Privacy Concerns

If you have any questions, concerns, or requests regarding this Privacy Policy or the handling of your personal data, please contact our Grievance Officer:

We will acknowledge your request within 72 hours and endeavour to resolve it within 30 days of receipt.