Privacy Policy - Vinayaka Funds

1. Who We Are

Vinayaka Funds is an AMFI Registered Mutual Fund Distributor (ARN-340170) operating at www.vinayakafunds.com. We are regulated by the Securities and Exchange Board of India (SEBI) through AMFI. We are a distributor, not a SEBI Registered Investment Adviser (RIA).

Contact: vinayakafunds@gmail.com

2. Information We Collect

We collect the following categories of personal data:

Identity data: name, PAN number
Contact data: phone number, email address
Financial suitability data: risk profile quiz responses, investment horizon, income bracket
Portfolio data: mutual fund holdings and transaction history (for existing clients only)
Technical data: IP address, browser type, pages visited — collected automatically via server logs

We do not collect sensitive personal data such as biometrics, religious beliefs, or health information.

3. How We Use Your Data

To provide mutual fund distribution services to you
To assess suitability of investment products for distribution purposes
To contact you regarding your portfolio, SIP schedules, or regulatory changes
To comply with AMFI, SEBI, and KYC requirements
To send periodic portfolio review reports (existing clients)
To respond to enquiries submitted via the contact form

We do not sell your personal data to third parties. We do not use your data for targeted advertising.

4. Third-Party Data Processors

We share your data only with the following processors, strictly for service delivery:

CAMS / KFintech — mutual fund registrar and transfer agents (regulatory requirement)
AMFI — regulatory submissions and ARN compliance
Supabase — cloud database for storing portfolio and client data (servers in US/EU)
Resend — transactional email delivery (monthly portfolio reports)
Telegram — internal advisory alerts (new enquiry notifications to the distributor only; your data is not shared publicly)
Vercel — website hosting (servers in US/EU)

5. Data Retention

Client records: retained for 7 years from the date of the last transaction, as required by SEBI
Website enquiries (non-clients): retained for 1 year, then deleted
Risk profile quiz responses: retained for 3 years or until you request deletion
Server logs: automatically purged after 90 days

6. Your Rights Under DPDPA 2023

Under the Digital Personal Data Protection Act, 2023 (India), you have the right to:

Access the personal data we hold about you
Correct inaccurate or incomplete personal data
Erase your personal data (subject to legal retention obligations)
Nominate a person to exercise these rights on your behalf in the event of your death or incapacity
Withdraw consent at any time (withdrawal does not affect prior processing)
Lodge a complaint with the Data Protection Board of India if you believe your rights have been violated

To exercise any right, email us at vinayakafunds@gmail.com. We will respond within 30 days.

7. Cookies

We use only essential cookies required for the website to function (session management, login state for the client portal). We do not use advertising cookies, tracking pixels, or third-party analytics cookies. You can disable cookies in your browser settings; this may affect your ability to use the client portal.

8. Data Security

We use industry-standard security measures including HTTPS encryption, hashed password storage (bcrypt), and access controls. No method of transmission over the internet is 100% secure; we cannot guarantee absolute security but take reasonable steps to protect your data.

9. Grievance Officer

As required under the Information Technology Act, 2000 and DPDPA 2023:

Name: Minakshi
Organisation: Vinayaka Funds (ARN-340170)
Email: vinayakafunds@gmail.com
Response time: within 30 days of receipt of complaint

10. Changes to This Policy

We may update this Privacy Policy when our data practices change or when required by law. We will update the "Last updated" date at the top of this page. For significant changes, we will notify existing clients by email. We encourage you to review this page periodically.