Privacy Policy
PRATEEK SINGH (Trade Name: AZAD PARIVAAR™) | SEBI Registered Investment Adviser
Effective Date: April 27, 2026 Last Updated: May 21, 2026

1. Introduction
This Privacy Policy explains how Prateek Singh, operating under the trade name AZAD PARIVAAR™ ("we," "us," "our," or "the Adviser"), a SEBI Registered Investment Adviser, collects, uses, stores, and protects the personal information of visitors, applicants, and clients ("you," "your," "Data Principal") when you interact with our website (www.azadparivaar.com), application forms, advisory services, and related communications.

We are committed to protecting your privacy in accordance with the Digital Personal Data Protection Act, 2023 ("DPDP Act"), the Information Technology Act, 2000, and applicable rules made thereunder, as well as the SEBI (Investment Advisers) Regulations, 2013 and circulars issued by the Securities and Exchange Board of India ("SEBI").

By using this website or submitting any personal information to us, you acknowledge that you have read, understood, and agree to the practices described in this Privacy Policy.

2. Identity of the Data Fiduciary
For the purposes of the DPDP Act, the Data Fiduciary is:
Prateek Singh SEBI Registered Investment Adviser Reg. No. INA000020077 | BSE Enlistment No. 2254 Trade Name: AZAD PARIVAAR™
Registered Address: D-64, DGS Apartment, Plot 6, Sector 22, Dwarka, New Delhi, National Capital Territory of Delhi - 110075, India
Contact: prateek@azadparivaar.com Grievance: grievance@azadparivaar.com

3. Information We Collect
We collect the following categories of personal information:

3.1 Information You Provide Directly

• Identification Information: Full name, date of birth, gender, nationality, marital status

• Contact Information: Email address, mobile number, residential address, correspondence address

• Government Identification: PAN, Aadhaar (last four digits or masked), passport details (for NRI clients)

• Financial Information: Income, assets, liabilities, investment holdings, account details, employer information, financial goals, risk tolerance responses

• Family Information: Spouse and dependent details (only when voluntarily shared during advisory engagement)

• Communication Records: Emails, WhatsApp messages, call recordings, video conference recordings (with consent), notes from advisory sessions

• Application Form Responses: Information submitted via Tally forms during the application or onboarding process
   

3.2 Information Collected Automatically

• Website Usage Data: IP address (anonymised where possible), browser type, device type, operating system, pages viewed, time spent, referring URLs

• Cookies and Similar Technologies: Session cookies, analytics cookies (Google Analytics 4), advertising cookies (Google Ads conversion tracking)
   

3.3 Information from Third Parties

• SEBI Verification Records: Public registration data accessible via SEBI portals

• Payment Confirmations: Transaction details from payment gateway providers

• Background Verification (if applicable): Limited verification through publicly available regulatory or commercial databases
   

We collect only the personal data that is reasonably necessary for providing our advisory services and meeting our regulatory obligations.

4. Purpose of Collection and Use
We use your personal information solely for the following purposes:

• To assess your eligibility and suitability for our advisory services

• To deliver the Wealth & Legacy Diagnostic and AZAD PARIVAAR™ ELITE advisory services

• To prepare your Investment Plan & Roadmap (IP&R), financial projections, and ongoing reviews

• To comply with SEBI (Investment Advisers) Regulations, 2013, including KYC, risk profiling, and record-keeping requirements

• To communicate with you regarding scheduled sessions, deliverables, regulatory updates, and ongoing advisory matters

• To process fee payments and issue invoices

• To respond to your queries and grievances

• To meet legal, tax, regulatory, and audit obligations

• To improve our website, services, and client experience
   

We do not use your personal information for direct marketing, sale to third parties, or any purpose unrelated to providing fiduciary advisory services.
 

5. Legal Basis for Processing

Under the DPDP Act, 2023, we process your personal information on the following bases: • Your explicit consent (Sec 6, DPDP Act) — provided through application forms, Letters of Engagement, and advisory consents. Consent forms the basis for our contractual engagement. • Certain legitimate uses (Sec 7, DPDP Act) — including compliance with legal and regulatory obligations under SEBI (Investment Advisers) Regulations 2013, Income Tax Act, and Anti-Money Laundering / KYC norms.

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You have the right to withdraw consent at any time, subject to lawful retention obligations explained in Section 8 below.

6. Third-Party Service Providers
To deliver our services, we use the following third-party tools and platforms. Each is selected for its security posture and compliance maturity:
 

• Tally.so — Application and assessment forms. Data shared: Application data, financial questionnaire responses.

• Zoho Sign — Digital execution of Letters of Engagement (Aadhaar eSign). Data shared: Name, email, signature data, document metadata.

• Calendly — Appointment scheduling. Data shared: Name, email, time-zone, scheduled meeting details.

• Zoom — Video conferencing for advisory sessions. Data shared: Name, email, recordings (only when client consents).

• Google Workspace (Gmail, Drive) — Email communication, document storage. Data shared: Email content, attachments, calendar data.

• Razorpay — Payment processing. Data shared: Name, email, payment method, transaction data.

• Canva — Document and report design. Data shared: Generic templates only — no client PII.

• Claude (Anthropic) — AI-assisted research, drafting, and operational tasks. Data shared: Anonymised or de-identified data only. No client-identifying information is ever entered into these tools. Refer to our AI Use Disclosure at azadparivaar.com/ai-disclosure for full details.

• WhatsApp Business (Meta Platforms) — Client communication. Data shared: Phone number, message content.

• Wix Studio — Website hosting and analytics. Data shared: Website behaviour data, no client PII.

• Google Ads / Google Analytics — Marketing and conversion tracking. Data shared: Aggregated, anonymised website behaviour data.
   

We have entered into appropriate data processing terms with these providers, who are required to maintain confidentiality and apply reasonable security safeguards. Some providers may store data outside India in jurisdictions with comparable or higher data protection standards.
We do not sell, rent, or trade your personal information with any third party for monetary or non-monetary consideration.


7. Data Sharing and Disclosure
We may disclose your personal information only in the following circumstances:

• Regulatory Authorities: SEBI, BSE, Income Tax Department, Financial Intelligence Unit, or any other lawful regulatory or statutory authority on receipt of a valid request

• Auditors and Compliance Reviewers: As required for our annual compliance audit under SEBI (Investment Advisers) Regulations, 2013

• Legal and Tax Advisers: When necessary for our defence in legal, regulatory, or tax proceedings

• Service Providers Listed Above: Strictly limited to the data required for the specific service

• Successor in Interest: In the event of business succession (e.g., conversion to Non-Individual Investment Adviser), with prior notice to you

We do not share client data with product manufacturers, distributors, or any party that may use it for sales, marketing, or commercial purposes.

8. Data Retention
We retain your personal information for the following durations:

• Active Client Records: For the duration of the engagement and 5 years thereafter, in accordance with SEBI record-keeping requirements

• Application Records (where engagement did not commence): For 12 months from the date of application

• Communication Records (emails, call notes, session recordings): 5 years per SEBI requirements

• Financial and Tax Records: 8 years per Income Tax Act requirements

• Website Analytics Data: 14 months (Google Analytics default) or as required for marketing analysis

• Withdrawn Consent or Service Termination: Personal data deleted within 90 days of termination, except records required to be retained under law

After the retention period, data is securely deleted or anonymised.

9. Data Security
We implement reasonable technical and organisational measures to protect your personal information against unauthorised access, disclosure, alteration, or destruction. These measures include:

• Two-factor authentication on all critical platforms

• Encrypted email transmission and document storage

• Access controls limiting data visibility to authorised personnel only

• Quarterly access and security reviews of all SaaS platforms

• Documented Data Security Standard Operating Procedures for each tool we use

• Secure disposal of physical documents containing personal information
   

While we apply industry-standard safeguards, no system is completely impenetrable. You acknowledge that the transmission of information over the internet involves inherent risks, and we cannot guarantee absolute security.
In the event of a personal data breach involving significant risk to you, we will notify you and the Data Protection Board of India in accordance with the DPDP Act.

10. Your Rights as a Data Principal
Under the DPDP Act, you have the following rights:

• Right to Information: Obtain a summary of your personal data being processed and the activities undertaken

• Right to Correction: Request correction of inaccurate or incomplete data

• Right to Erasure: Request deletion of personal data, subject to legal retention obligations

• Right to Withdraw Consent: Withdraw consent for processing where the basis is consent

• Right to Grievance Redressal: Raise grievances regarding the processing of your personal data

• Right to Nominate: Designate another individual to exercise your rights in the event of your death or incapacity
   

To exercise any of these rights, please write to prateek@azadparivaar.com or grievance@azadparivaar.com. We will respond within timelines prescribed under the DPDP Act.

11. Children's Privacy
Our services are intended exclusively for adults aged 18 years and above. We do not knowingly collect personal data of children. Where information about minor dependents is shared during advisory engagements, it is processed only with the verifiable consent of the parent or lawful guardian and used solely for the purpose of family financial planning.
 

12. International Data Transfers

Some of our service providers may store and process data outside India. Such transfers comply with Section 16 of the DPDP Act, 2023 — we do not transfer personal data to any country or territory notified by the Central Government as restricted. Where transfers occur, appropriate contractual safeguards are in place.

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You consent to such transfers when you agree to this Privacy Policy.

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13. COOKIES AND TRACKING TECHNOLOGIES

This section explains how we and selected third-party services use cookies and similar tracking technologies on our website, the choices available to you, and how those choices are recorded.

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13.1 What Cookies Are

Cookies are small text files stored on your device (computer, tablet, or mobile) when you visit a website. They are widely used to make websites work more efficiently and to provide information to the website owner. References to "cookies" in this section include similar technologies such as local storage, session storage, web beacons, and pixel tags.

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13.2 Cookie Categories We Use

Our cookie consent banner organises cookies into the following categories.

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Essential Cookies (always on): Strictly necessary for the website to function and cannot be switched off. Set by our website hosting platform (Wix) for session continuity, security, and content delivery; by our cookie consent management platform (Usercentrics) to record your consent choices; and by Google Fonts to render typography correctly.

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Functional Cookies (optional, off by default): Enable enhanced functionality and personalisation. Set by embedded third-party services such as Tally, our application form provider accessed at azadparivaar.com/apply, to retain your form responses if you navigate away mid-application. If you disable Functional Cookies, some embedded features may not work as expected.

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Analytics Cookies (optional, off by default): Help us understand how visitors interact with our website by collecting and reporting information in aggregated form. Set by Google Analytics 4 to measure page views, traffic sources, and on-site behaviour. If you disable Analytics Cookies, we will not collect aggregated visitor behaviour data through Google Analytics 4.

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Advertising / Marketing Cookies (optional, off by default): Used to deliver advertisements that are relevant to you and to measure the effectiveness of those advertisements. Set by Google Ads for conversion tracking and campaign measurement. If you disable Advertising Cookies, advertisements you see elsewhere on the internet may be less tailored to your interests.

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As our cookie consent platform completes its automatic classification of third-party scripts, category groupings and the specific cookies under each category may be updated. The latest classification is always visible inside the cookie consent banner.

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13.3 Third-Party Cookies

When you interact with embedded third-party services on our website — such as the Tally application form, Google Fonts, or Google Tag Services — those third parties may set their own cookies and use their own internal tools (including analytics and error tracking) directly on your device. Those cookies are governed by the relevant third party's privacy and cookie policies, not by this Privacy Policy. For a list of third-party service providers we use and the categories of data shared with them, please refer to Section 6 above.

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13.4 Your Consent and Choices

Under the Digital Personal Data Protection Act, 2023, processing of your personal data through non-essential cookies requires your explicit consent. Essential cookies necessary for the operation of the website are processed without consent, as permitted under the Act.

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When you first visit our website, our cookie consent banner offers three choices:

- Accept All — consent to all cookie categories

- Deny — refuse all non-essential cookies (Essential Cookies remain enabled)

- Save Settings — customise your preference at category level

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Your preference is recorded by the consent management platform and applied to your future visits. You may change your preference at any time by clicking the consent re-open icon or "More Information" link on our website to reopen the cookie consent banner, or by writing to grievance@azadparivaar.com to request a manual update of your preference.

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Independently of our consent banner, most browsers allow you to manage cookies through browser settings. You may block or delete cookies, prevent third-party cookies, or set your browser to notify you when a cookie is set. Disabling cookies through your browser may impair certain website functionalities. We respect "Do Not Track" signals where technically feasible.

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13.5 Retention

The retention period of cookies stored on your device varies by cookie type and provider. Most non-essential cookies on our website have a maximum lifetime of twelve (12) months from the date of consent, after which your consent expires and you will be asked again. Cookie-related data processed on our servers or by third parties (for example, aggregated analytics data) is retained in accordance with the retention periods set out in Section 8.

14. Use of Artificial Intelligence
In line with our AI/SaaS Disclosure, we use AI-based tools, including but not limited to Claude (Anthropic), for research, drafting, document preparation, and operational tasks. AI tools are used as productivity and research aids only. They do not replace the judgment of the SEBI Registered Investment Adviser, who remains personally accountable for all advisory recommendations and final deliverables.

Where client-specific personal data is processed using AI tools, we apply reasonable de-identification or anonymisation safeguards, and such use is governed by enterprise privacy commitments published by the relevant AI provider.

15. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in regulations, our practices, or services. The updated version will be posted on this page with a revised "Last Updated" date. Material changes will be communicated to active clients via email.

We encourage you to review this Privacy Policy periodically.

16. Grievance Redressal
If you have any questions, concerns, or grievances regarding this Privacy Policy or the processing of your personal information, please contact us through the following channels in sequence:

Step 1: Internal Grievance Redressal
Email: grievance@azadparivaar.com Acknowledgement: Within 1 working day Resolution: Within 21 calendar days

Step 2: Escalation to SEBI
If you are not satisfied with our resolution, you may escalate your grievance to SEBI through:

• SCORES (SEBI Complaints Redress System): https://scores.sebi.gov.in

• SEBI Online Dispute Resolution (ODR) Portal: https://smartodr.in

• SEBI Toll-Free Helpline: 1800-22-7575 / 1800-266-7575
   

Step 3: Data Protection Authority
For grievances specifically related to personal data processing, you may approach the Data Protection Board of India, once constituted under the DPDP Act, 2023.

17. Contact Us
For all communications regarding this Privacy Policy:
Prateek Singh SEBI Registered Investment Adviser SEBI RIA Reg. No. INA000020077 | BSE Enlistment No. 2254
Email: prateek@azadparivaar.com Grievance: grievance@azadparivaar.com Website: www.azadparivaar.com
Registered Address: D-64, DGS Apartment, Plot 6, Sector 22, Dwarka, New Delhi, National Capital Territory of Delhi - 110075, India

Registration granted by SEBI, enlistment as IA with BSE and certification from NISM in no way guarantee performance of the intermediary or provide any assurance of returns to investors. Investments in securities market are subject to market risks. Read all related documents carefully before investing.

SEBI RIA Reg. No. INA000020077 | BSE No. 2254 | Prateek Singh | CFA® CFP® CWM® CTEP™ CREP®