Proinfinity Wealth Advisors Pvt. Ltd. ("Proinfinity", "we", "us", or "our") is committed to protecting the privacy and confidentiality of all personal information we receive. This Privacy Policy explains how we collect, use, store, and protect your personal data when you visit our website (www.proinfinity.in), communicate with us, or engage with us in connection with our fund products and services.
Overview & Applicability
This Privacy Policy applies to all individuals whose personal data is processed by Proinfinity Wealth Advisors Pvt. Ltd., including visitors to our website, prospective investors, registered investors, and any individuals who contact us through our website, email, or other channels.
As a fund manager regulated by the International Financial Services Centres Authority ("IFSCA") under the IFSCA (Fund Management) Regulations, 2024, and operating out of GIFT City IFSC, Gujarat, India, we are subject to applicable data protection and privacy requirements under Indian law, including the Digital Personal Data Protection Act, 2023 ("DPDP Act"), as and when applicable provisions come into effect.
Information We Collect
We may collect and process the following categories of personal data:
Information you provide directly:
- Name, email address, phone number, and country of residence submitted via our contact form or direct communication.
- Investor classification (NRI, PIO, foreign national, HNI, family office, institutional investor).
- Indicative investment range and any other information voluntarily provided in your enquiry.
- Identity and KYC documentation provided in connection with a subscription to the Fund.
- Financial information required for regulatory compliance, including source of funds declarations and tax identification numbers.
Information collected automatically:
- IP address, browser type, device type, and operating system.
- Pages visited, time spent on the website, and navigation patterns.
- Referring URLs and general geographic location (country/region level).
- Cookies and similar tracking technologies.
How We Use Your Information
We use the personal data we collect for the following purposes:
- To respond to your enquiries and provide information about our funds and services.
- To assess your eligibility as a prospective investor under applicable regulations.
- To process subscriptions, manage investor accounts, and administer the Fund.
- To comply with our legal and regulatory obligations under IFSCA, FATF, anti-money laundering (AML), and Know Your Customer (KYC) requirements.
- To communicate periodic investor letters, fund updates, factsheets, and quarterly reports to registered investors.
- To maintain the security and integrity of our website and digital infrastructure.
- To conduct internal analytics to improve our website and investor communications.
- To exercise or defend legal rights in connection with the Fund or investment management activities.
We will never use your personal data for unsolicited commercial marketing to third parties, nor will we sell your data to any third party.
Legal Basis for Processing
We process your personal data on one or more of the following legal bases:
- Your consent — where you have voluntarily submitted your information through our contact form or otherwise opted in to receive communications from us.
- Contractual necessity — where processing is necessary to perform our obligations under the Fund Documents or any related investor agreements.
- Legal obligation — where processing is required to comply with applicable laws, regulations, and regulatory directions, including IFSCA regulations, AML/KYC requirements, and tax reporting obligations.
- Legitimate interests — where processing is necessary for our legitimate business interests, such as operating our website, responding to enquiries, and managing investor relations, provided those interests are not overridden by your rights.
Sharing & Disclosure
We treat your personal data with the highest degree of confidentiality. We do not sell, rent, or trade your personal data. We may share your information only in the following limited circumstances:
- Fund service providers — our Trustee (Axis Bank Limited), Custodian (Axis Bank Limited), Fund Administrator (Fiducrest Advisors IFSC LLP), Auditor (Forvis Mazars), and Legal Counsel (Khaitan and Company), strictly to the extent required for fund administration and regulatory compliance.
- Regulatory authorities — IFSCA, financial intelligence units, tax authorities, and other governmental or regulatory bodies, where required by applicable law or regulatory direction.
- Professional advisers — our own legal, tax, and compliance advisers, under obligations of confidentiality.
- Business transfers — in the event of a merger, acquisition, or restructuring of the Investment Manager, subject to appropriate confidentiality protections.
- With your consent — in any other circumstances where you have provided explicit prior consent.
All third parties with whom we share personal data are required to maintain confidentiality and process your data only for the stated purpose.
Cookies & Analytics
Our website may use cookies and similar technologies to enhance your browsing experience and collect anonymised analytics data. Cookies are small data files stored on your device that help us understand how visitors interact with our website.
We may use the following types of cookies:
- Essential cookies — necessary for the website to function correctly; cannot be disabled.
- Analytics cookies — used to understand visitor behaviour in aggregate, helping us improve the website's content and structure.
- Preference cookies — used to remember your preferences and settings on subsequent visits.
We do not use advertising or retargeting cookies. You may disable cookies through your browser settings; however, some features of the website may not function optimally as a result. By continuing to use this website, you consent to our use of cookies as described above.
Data Retention
We retain your personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law and regulation.
- Enquiry and contact form data is retained for a reasonable period to manage ongoing communications, typically not exceeding 24 months from the date of last contact, unless an investor relationship is established.
- Investor KYC, subscription, and transaction records are retained for a minimum of 5 years after the termination of the investor relationship, or such longer period as required by IFSCA regulations and applicable law.
- Website analytics data is retained in anonymised or aggregated form only, with no retention limit on aggregated data.
Upon expiry of the applicable retention period, personal data is securely deleted or anonymised.
Security
We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, destruction, alteration, or disclosure. These measures include encrypted data transmission, access controls, and regular review of our information security practices.
While we take all reasonable precautions, no method of transmission over the internet or method of electronic storage is entirely secure. We cannot guarantee the absolute security of your personal data, and any transmission is at your own risk. If you have reason to believe that your interaction with us is no longer secure, please contact us immediately at ir@proinfinity.in.
Your Rights
Subject to applicable law, including the Digital Personal Data Protection Act, 2023 (to the extent in force), you may have the following rights in respect of your personal data:
- Right to access — to request a copy of the personal data we hold about you.
- Right to correction — to request correction of inaccurate or incomplete personal data.
- Right to erasure — to request deletion of your personal data, subject to applicable legal and regulatory retention obligations.
- Right to withdraw consent — to withdraw any consent previously given for processing, without affecting the lawfulness of processing prior to withdrawal.
- Right to grievance redressal — to raise a complaint or grievance with us or, if unresolved, with the relevant data protection authority.
To exercise any of these rights, please contact our Investor Relations team at ir@proinfinity.in. We will respond to all requests within a reasonable timeframe and in accordance with applicable law. Please note that certain rights may be limited where we are required to retain data for regulatory compliance purposes.
Cross-Border Data Transfers
Given the international nature of our investor base — which includes NRIs, PIOs, foreign nationals, and offshore institutions — your personal data may be transferred to and processed in jurisdictions outside India, including the country in which you are resident.
Any such transfer will be conducted in accordance with applicable data protection law and with appropriate safeguards in place to ensure the protection of your personal data, including contractual protections with the receiving party where required. By submitting your information or engaging with us, you acknowledge and consent to such cross-border transfers as described in this Policy.
Third-Party Links
Our website may contain links to third-party websites, including regulatory bodies such as IFSCA (www.ifsca.gov.in) and service providers. These websites operate independently and have their own privacy policies. We are not responsible for the privacy practices or content of third-party websites. We encourage you to review the privacy policies of any third-party websites you visit.
Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or regulatory obligations. When we make material changes, we will update the "Effective" date at the top of this page. We encourage you to review this Policy periodically. Continued use of our website following the posting of any changes constitutes your acceptance of the revised Policy.
Contact Us
If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data, please contact us:
For unresolved grievances, you may also contact the relevant supervisory authority: IFSCA, GIFT SEZ, Block 13A, Road 1C, GIFT City, Gandhinagar, Gujarat 382355 | www.ifsca.gov.in