2. User Consent and Acknowledgement

By accessing Our website, submitting any form, booking a review, or otherwise providing Us with Your Personal Information, You explicitly and voluntarily consent to the collection, use, storage, and disclosure of Your information as described in this Policy.

If You do not agree to this Policy, please do not access Our website or submit Your Personal Information to Us.

This Policy should be read in conjunction with any agreement You enter into with BARS Wealth Management for the provision of services.

3. Information We Collect

3.1 Information You Voluntarily Provide

When You interact with Us — by booking a review, filling out a contact form, or onboarding as a client — We collect:

• Identity information: Full name, date of birth, gender
• Contact information: Email address, phone number, residential and correspondence address
• Financial information: Income and net worth details, risk appetite, investment objectives, and bank account information
• Regulatory and compliance information: PAN, Aadhaar (as required for KYC), Demat account details, FATCA/CRS declarations, Politically Exposed Person (PEP) status
• Nominee details, as required under applicable regulations
• Any other information You choose to share with Us

3.2 Information Collected Automatically

When You visit barswealth.com, We may automatically collect:

• IP address and approximate geographic location
• Browser type, version, and language settings
• Device information (operating system, hardware settings, unique device identifiers)
• Pages visited, links clicked, and time spent on the website
• Referral URL and search terms that led You to Our website
• Cookies and similar tracking technologies

3.3 Information from Third-Party Sources

We may receive information about You from third-party sources, including:

• KYC Registration Agencies (KRAs) and the Central KYC Registry (CKYC)
• Account Aggregators (AAs) licensed by the Reserve Bank of India, through whom You may share financial data with Your explicit consent
• MF Central Platform, for Mutual Fund investment data
• BSE STAR MF platform, for transaction processing
• Marketing and referral partners, where applicable

4. How We Use Your Information

We use Your Personal Information for the following purposes:

4.1 Service Delivery

• Processing Your investment instructions across Mutual Funds, Portfolio Management Services (PMS), Alternative Investment Funds (AIFs), and Fixed Income instruments
• Onboarding You as a client and maintaining Our relationship with You
• Executing transactions on Your behalf with Asset Management Companies, Registrar and Transfer Agencies, and other relevant entities
• Generating portfolio reports and performance statements

4.2 Regulatory and Legal Compliance

• Meeting Know Your Customer (KYC) and Anti-Money Laundering (AML) obligations under SEBI, AMFI, and APMI regulations
• FATCA/CRS reporting obligations
• Complying with orders or directions from SEBI, AMFI, stock exchanges, courts, or other regulatory authorities
• Maintaining records as required under applicable laws

4.3 Communication

• Sending You portfolio updates, transaction confirmations, and account statements
• Notifying You about important changes to Our services, regulatory updates, or this Policy
• Responding to Your queries and grievances
• Sending promotional communications about Our services (You may opt out of these at any time)

4.4 Security and Fraud Prevention

• Verifying Your identity and detecting fraudulent or unauthorized activity
• Monitoring and protecting the security of Our systems and platforms

4.5 Analytics and Improvement

• Analysing website usage to improve Our online experience
• Understanding client needs and enhancing Our service offerings
• Generating anonymised, aggregated statistical reports (which do not identify You personally)

5. How We Share Your Information

We do not sell or rent Your Personal Information to any third party.

We may share Your information in the following circumstances:

5.1 With Regulated Financial Entities

To process Your investments and comply with regulatory obligations, We share information with:

• Asset Management Companies (AMCs) for Mutual Fund transactions
• Portfolio Management Services providers and Alternative Investment Fund managers
• Registrar and Transfer Agencies (RTAs)
• BSE STAR MF and other stock exchange platforms
• Payment gateways and banking partners
• KYC Registration Agencies and CKYC
• SEBI, AMFI, APMI, and other regulatory or government bodies as required by law

5.2 With Service Providers

We engage third-party service providers who assist Us in running Our business, including technology providers, analytics platforms, and customer communication tools.

These providers are contractually obligated to maintain the confidentiality of Your information and may only use it for the specific purpose for which it was disclosed.

5.3 For Legal and Regulatory Reasons

We may disclose Your information to judicial, administrative, regulatory, or law enforcement bodies where required by applicable law, court order, or regulatory direction.

5.4 Business Restructuring

In the event of a merger, acquisition, reorganisation, or sale of all or part of Our business, Your Personal Information may be transferred to the successor entity, in compliance with applicable laws.

6. Cookies and Tracking Technologies

Our website uses cookies and similar technologies to improve Your browsing experience.

Cookies are small data files stored on Your browser. We use:

• Session cookies — deleted when You close Your browser
• Persistent cookies — remain until You delete them or they expire
• Analytics cookies — to understand how visitors use Our website (e.g., via Google Analytics)

You may disable cookies through Your browser settings; however, this may affect Your ability to use certain features of Our website.

By continuing to use Our website, You consent to Our use of cookies as described in this Policy.

7. Data Retention

We retain Your Personal Information for as long as necessary to fulfil the purposes for which it was collected, including to provide Our services, meet regulatory and legal obligations, resolve disputes, and enforce Our agreements.

In accordance with SEBI and AMFI regulations, client records and transaction data are typically retained for a minimum of five years from the date of the last transaction, or as otherwise required by applicable law.

On expiry of the applicable retention period, Your data will be securely deleted or anonymised.

8. Data Security

We implement industry-standard technical and organisational measures to protect Your Personal Information from unauthorised access, disclosure, alteration, or destruction.

These include:

• Secure (HTTPS) transmission of data between Your browser and Our servers
• Encryption of sensitive data at rest
• Role-based access controls limiting access to Your data on a need-to-know basis
• Regular review of Our data security practices

While We take all reasonable steps to protect Your information, no method of electronic transmission or storage is completely secure. We cannot guarantee absolute security. If You suspect that Your information has been compromised, please contact Us immediately at hello@barswealth.com.

9. Your Rights

Subject to applicable law and Our regulatory obligations, You have the following rights with respect to Your Personal Information:

• Access: You may request a copy of the Personal Information We hold about You
• Correction: You may request that We correct any inaccurate or incomplete information
• Withdrawal of Consent: You may withdraw Your consent to processing at any time; however, this may affect Our ability to continue providing certain services to You
• Deletion: You may request deletion of Your Personal Information, subject to Our legal and regulatory retention obligations

To exercise any of these rights, please write to Us at hello@barswealth.com.

10. Information of Minors

Our website and services are not directed at individuals under the age of 18. We do not knowingly collect Personal Information from minors.

If We become aware that We have inadvertently collected information from a minor without the consent of a parent or legal guardian, We will take steps to delete such information promptly.

11. Third-Party Websites

Our website may contain links to third-party websites. These websites operate under their own privacy policies, which We encourage You to review.

BARS Wealth Management is not responsible for the privacy practices or content of any third-party websites.

12. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in Our practices, regulatory requirements, or for other operational reasons.

The updated Policy will be posted on Our website with a revised “Last Updated” date.

Your continued use of Our website or services following the posting of changes constitutes Your acceptance of the updated Policy. We encourage You to review this Policy periodically.

13. Grievance Officer and Contact

If You have any questions, concerns, or grievances relating to this Privacy Policy or the handling of Your Personal Information, please contact Our Grievance Officer:

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

14. Governing Law and Jurisdiction

This Privacy Policy is governed by and construed in accordance with the laws of India.

Any disputes arising from or relating to this Policy shall be subject to the exclusive jurisdiction of the competent courts in India.