Privacy Policy | Wealth Gullak

Wealth Gullak is a brand of FutureGraph India Private Limited ("FutureGraph", "we", "us" or "our"). This Privacy Policy explains how we collect, use, share, store and protect personal data when you use the Wealth Gullak website, mobile applications, investor portal or related services.

This policy should be read together with the specific privacy notice shown to you when information is collected. Where a product or transaction is completed on a third-party platform, that third party may separately determine how it processes the information collected in its own journey and its privacy policy will also apply.

2.1 Information we collect

Category	Examples	Why it is used
Identity and profile	Name, date of birth, gender, PAN, tax status, occupation, user/client code and profile details.	To identify you, create and maintain your account, perform suitability/service checks and support regulated investment processes.
Contact and address	Postal address, email address, mobile number and contact declarations.	To communicate with you, authenticate transactions, deliver statements/alerts and respond to enquiries.
KYC, FATCA and compliance	KYC status and supporting documents, tax residency, country of birth, income slab, source of wealth, PEP declaration and other compliance information.	To meet KYC/FATCA/CRS, exchange, AMC/RTA and other legal or regulatory requirements.
Bank and payment information	Bank account number, account type, IFSC, bank name, mandate details and payment/transaction status.	To register investment accounts, facilitate permitted transactions and reconcile payments.
Nominee, guardian and family information	Nominee details, relationship, date of birth and share; guardian details for minors; family/household mapping where enabled.	To maintain investment/nomination records, service minor accounts through guardians and provide consolidated portfolio views where requested.
Investment and portfolio information	Folios, schemes, orders, SIP/STP/SWP, holdings, units, NAV, transactions, mandates, valuations, returns and capital-gains information.	To process and reconcile investments and provide portfolio reporting and servicing.
Fixed-deposit journey information	Name, mobile, email, PAN, date of birth and selected FD/issuer/tenure/amount before the partner journey; booking status and FD summary received after booking.	To initiate an FD booking with the partner/issuer and show the resulting FD in your consolidated portfolio.
Pre-IPO / unlisted interest information	Name, mobile, email, PAN, selected security and quantity when you ask us to initiate a partner transaction.	To pass your request to the identified partner for an offline unlisted-security transaction.
Insurance information	Insurer, policy number, plan/policy type, policyholder/insured, sum assured, premium, dates, nominee, policy status, remarks and policy documents if provided.	To maintain a consolidated portfolio and provide servicing/reminders. Insurance data entered in this module is not automatically shared with an insurer by Wylth.
Documents	KYC/supporting documents, statements and other documents uploaded by you or by authorised FutureGraph staff for servicing.	To complete regulated processes, verify information and maintain service records.
Device, security and audit information	IP address, login time, user ID, role, MFA status, device/session information, consent records and audit logs.	To authenticate users, secure the platform, detect misuse, maintain evidence and troubleshoot service issues.
Communications and enquiries	Messages, support requests, callback/enquiry details and your communication preferences.	To respond to you, provide support and record your communication choices.

Aadhaar: the Wylth platform is not intended to store full Aadhaar numbers. Where an Aadhaar copy is accepted as a supporting document, we require it to be masked so that only the last four digits are visible, unless an authorised process under applicable law specifically requires otherwise.

2.2 How we obtain information

directly from you, including through the website, app, investor portal, documents and communications;
from your parent or legal guardian where the investment/account is in the name of a minor;
from BSE StAR MF and other permitted transaction infrastructure used for mutual fund onboarding and orders;
from RTAs such as CAMS and KFintech through FutureGraph-authorised reports/mailback files;
from KYC/KRA/exchange lookup services to the extent used for status verification;
from product partners where a transaction you initiated generates a status or portfolio update for Wealth Gullak; and
automatically from security/session technologies when you use the website, portal or app.

2.3 How we use personal data

to register, authenticate and service your Wealth Gullak account;
to complete KYC, FATCA/CRS, bank, nominee, mandate and other onboarding requirements;
to route and administer mutual fund transactions and reconcile holdings/transactions;
to calculate and display portfolio values, returns, reports, capital gains and consolidated family views where enabled;
to initiate FD or Pre-IPO/unlisted-security partner journeys when you ask us to do so;
to record insurance information and documents for portfolio consolidation and reminders;
to send transaction, service, security, SIP, maturity, renewal and other operational communications;
to respond to requests, complaints, privacy requests and support queries;
to maintain consent records, audit trails, security logs and evidence required for legal, regulatory or dispute purposes;
to prevent fraud, unauthorised access, misuse and cyber incidents; and
to send promotional or educational communications only where a separate opt-in or other lawful basis applies.

We process personal data only for lawful purposes. Where consent is required, we obtain it through a clear action linked to the relevant notice. We may also process or retain information where this is required or permitted by applicable law, regulatory directions, legal proceedings, fraud prevention or the protection of our systems and users.

2.4 Who we share information with

Recipient / category	Typical information	Purpose / role
Wylth (technology/platform provider)	Information processed through the Wealth Gullak platform.	Wylth hosts and operates the white-label technology environment and processes Wealth Gullak customer data on FutureGraph's instructions.
BSE StAR MF and related mutual fund infrastructure	UCC/onboarding details, bank/nominee/FATCA information, order and mandate details.	Mutual fund account registration, transaction routing, authentication and status processing.
AMCs, RTAs and KYC/KRA ecosystem, as applicable	Investment/KYC information required through the permitted transaction and servicing chain.	To process and service mutual fund holdings and meet regulatory requirements.
Fixerra and participating bank/NBFC issuer	FutureGraph/Wylth initially shares the minimum data needed to start the booking. Fixerra/issuer may then collect additional KYC, bank, nominee, Aadhaar/DigiLocker and transaction information directly under its own journey.	FD booking and issuer processing. Fixerra/issuer privacy terms apply to information they collect in that journey.
InvestValue Fintech Private Limited	Name, mobile, email, PAN and selected security/quantity when you ask to proceed.	To initiate an offline Pre-IPO/unlisted-security transaction. The partner collects additional transaction/KYC/bank/demat data under its own process and privacy terms.
Communication and support providers, where used	Contact details and message/notification content strictly as needed.	Email, SMS, WhatsApp, push notifications, customer support or similar service delivery.
Professional advisers, auditors and service providers	Only information reasonably necessary for the relevant service.	Audit, legal, compliance, accounting, security or other professional support, subject to appropriate confidentiality obligations.
Government, regulators, courts and law-enforcement authorities	Information required by a valid legal or regulatory request.	Compliance with law, regulatory requirements, court orders and lawful investigations.

We do not sell Wealth Gullak customer personal data. Wylth processes Wealth Gullak customer data to provide the contracted platform services and is not authorised by FutureGraph to use that data for its own marketing, cross-selling or customer profiling. Platform improvement is limited to aggregated, non-identifiable operational metrics.

2.5 Third-party product journeys

Some services require you to continue on, or interact with, a partner or issuer environment. Once the partner begins collecting information directly, the partner is responsible for its own processing under its privacy terms. Before we send your data to an identified partner, the Wealth Gullak journey will tell you what will be shared and why.

2.6 Children and minor investments

Wealth Gullak may service investments held in the name of a minor through a parent or legally appointed guardian in accordance with applicable mutual fund, exchange, AMC and RTA requirements. A minor must not independently create the account or give the required consents. The guardian is required to provide the minor's details and evidence of the guardian relationship/authority.

For the processing of a child's personal data, we will obtain the consent/authorisation of the verified adult parent or lawful guardian to the extent required by applicable law. We will not use a minor's personal data for targeted advertising or behavioural profiling, and will not undertake child-directed tracking or behavioural monitoring except to the extent permitted by applicable law for security, safety or delivery of the requested service.

2.7 Marketing communications

Marketing consent is separate from the consent needed to provide investment or portfolio services. If you opt in, we may send product information, educational content, offers or other promotional communications by the channel you select. You may withdraw that preference at any time without affecting core services. Service, transaction, security and legally required communications may still be sent where necessary.

2.8 Cookies, sessions and app permissions

The website, portal and app use security and session technologies needed to sign you in, prevent misuse, maintain your session, remember limited preferences and apply the correct Wealth Gullak interface. More detail is set out in the Cookie Policy.

The mobile app may request camera access, photos/files access, notifications and biometric/Face ID access only when the related feature is used. These permissions are optional unless needed for the feature you choose. The current Wealth Gullak configuration is not intended to request location, contacts, SMS, call logs or microphone access.

2.9 Storage and security

Wylth has confirmed that the Wealth Gullak platform environment is hosted in Microsoft Azure in India (Central India), with its database and storage protected within private infrastructure. The platform uses layered technical and organisational controls, including encrypted transmission and storage, access controls, multi-factor authentication, network security controls, audit logging, monitoring, backup and disaster-recovery arrangements.

No online system can be made completely risk-free. We therefore maintain safeguards appropriate to the nature of the information and require our service providers to support incident detection, investigation and response.

2.10 Retention and deletion

We retain personal data only for as long as it is reasonably required for the purpose for which it was collected and for any longer period required by applicable financial-services, tax, anti-money-laundering, securities, information-technology, cybersecurity, record-keeping or other law. Different categories of records may therefore have different retention periods.

If you close your account or make a valid deletion request, information that is not required to be retained may be deleted or irreversibly anonymised. Information that must be retained by law will be restricted from ordinary use and deleted when the applicable retention period ends. Residual copies in controlled backups are removed through the normal backup-retention cycle.

2.11 Your choices and privacy rights

Subject to applicable law and verification of your identity, you may ask us to:

provide information about the personal data we process about you and the persons/entities with whom it has been shared, where applicable;
correct, complete or update inaccurate or incomplete personal data;
erase personal data that is no longer required to be retained by us;
withdraw a consent that you previously gave, where processing is based on that consent;
change your optional communication preferences;
raise a grievance about the handling of your personal data; and
record or update a nominee for exercise of applicable data-protection rights in the event of death or incapacity, where the law provides for such nomination.

You can make a privacy request by writing to privacy@wealthgullak.com from your registered email address or by using any privacy/account control made available in the app. We may ask for reasonable information to verify that the request relates to the correct customer. Please do not send passwords, OTPs or full Aadhaar details by email.

2.12 Personal data breaches

If a personal data or cybersecurity incident affects Wealth Gullak data, we will assess the incident, take containment and remedial measures, work with Wylth and other relevant service providers, and make notifications to affected individuals and authorities where required by applicable law.

2.13 Links and independent third parties

The platform may contain links or redirects to third-party websites or product journeys. We do not control the privacy practices of an independent third party. You should review the privacy notice shown by that third party before providing information directly to it.

2.14 Changes to this policy

We may update this Privacy Policy when our services, technology, partners or legal requirements change. The revised policy will be posted on the website/app with an updated date. Where a change materially affects a consent previously given, we will take the additional steps required by applicable law.

2.15 Contact us

Privacy and data protection enquiries: privacy@wealthgullak.com

Grievance Officer: Chinky Jindal, Director
Email: grievance@wealthgullak.com
FutureGraph India Private Limited
1204, 12th Floor, R.G. Trade Tower, B-7, Netaji Subhash Place, Pitampura, New Delhi - 110034