Account & Data Deletion Policy

Version 1.1 · Effective 14 September 2026 · adwizr app, operated by Zenara Technologies Private Limited · SEBI Registered Non-Individual Investment Adviser INA000022774

This policy explains how to delete your adwizr account, precisely what we erase, precisely what Indian law requires us to keep, for how long, and how to complain if you are unhappy with any of it.

1. Scope

This policy covers the adwizr account you create with your mobile number, and the personal and financial data held against it by Zenara. It does not govern data held independently by regulated third parties — see section 8.

Read it with our Privacy Policy and Terms of Service. Where this policy is more specific about deletion, this policy prevails.

2. Your right to erasure, and its limits

Section 12 of the Digital Personal Data Protection Act, 2023 (DPDP Act) gives you the right to have your personal data erased.

That right is not absolute. The Act preserves it only so far as no other law requires the data to be kept. Because adwizr is a regulated financial platform, certain records must be retained even after you leave — under the Prevention of Money Laundering Act, 2002 (PMLA) and the SEBI (Investment Advisers) Regulations, 2013. Where that applies, the DPDP Act requires us to retain the record, to tell you we have, and to state why. Section 6.2 is that disclosure.

Everything not legally required to be retained is erased. We do not keep anything "just in case".

3. How to delete your account

Deletion is performed from inside the app, while signed in. This is deliberate: signing in proves the account is yours, and stops anyone else — including someone who merely knows your mobile number — from destroying your financial history.

3.1 Steps

1. Open the adwizr app and sign in.
2. Tap your profile avatar at the top-right of the Home screen. (You can also open the ☰ menu at the top-left and tap your name at the top.)
3. You are now on the Account screen.
4. Scroll to the bottom and tap Delete Account.
5. Read what will be erased and what must be retained, and note any warnings about active SIPs or unsettled orders.
6. Tap Delete my account. The screen states the exact date your data is erased before you tap; nothing is erased before that date, and Go back sits beside the button if you change your mind.

The same screen is also reachable from Account → Account & Data Deletion, and from Account → Privacy Policy → Delete My Account.

3.2 If you no longer have the app installed

You do not have to reinstall it. Write to privacy@zenaratechnologies.com from the email address registered on your account, or from any address quoting your registered mobile number, with the subject "Account deletion request".

We will verify that the account is yours before acting. We will never delete an account on an unverified request — doing so would let a stranger destroy someone's financial plan by sending an email. Once verified, we begin the same 30-day process described below and confirm to you in writing.

5. The 30-day grace period

The grace period protects you. It is why a stolen or borrowed phone cannot destroy your financial history in a single tap, and why a mistaken tap is recoverable.

5.1 Cancelling

Sign in, go to Account → Delete Account, and tap Cancel deletion — keep my account. Your account and all your data continue untouched; because nothing was erased, nothing is lost.

Once the erasure job has actually begun, it can no longer be cancelled. The app will tell you so plainly rather than pretending otherwise.

6. Exactly what we erase, and exactly what we keep

6.1 Erased permanently

These are deleted — not hidden, not flagged inactive, not merely unlinked:

Removed from the app, but not erased. Your AI chat and support conversations, the plans and advice we gave you, the orders we placed for you and the Account Aggregator consents we relied on are statutory records. They disappear from the app and their text is cleared from our live systems, but a sealed copy is kept for the period in section 6.2.

6.2 Retained, because the law requires it

We keep each record for exactly as long as the statute requires, and no longer. Over-retention is not caution — under the DPDP Act it is itself a breach, because the Act permits retention past the purpose only where a law compels it. So we do not round the numbers up.

You may see other Indian platforms quote 8 years for KYC and transactions. That figure comes from the broker/depository regime and from the books-of-account rule, and from a SEBI consultation paper that is not in force. It is not the statutory minimum for a Registered Investment Adviser, and holding your identity documents for three years longer than the law requires would be over-retention. We do not do it.

6.3 How the retained records are treated

• They are removed from the app entirely. Nobody can sign in and see them.
• The text of conversations, complaints and plans is cleared from our live systems; the full record survives only in a sealed, tamper-proof archive.
• They are accessible only to our compliance function, or to a regulator, court or law-enforcement authority that lawfully compels their production.
• They are never used for marketing, analytics, profiling, AI/model training, product development, or any other commercial purpose.
• The record of your deletion request stores your mobile number only in masked form (for example 98xxxxx210) — never in full. A record that outlives the erasure must not itself defeat it.
• When the retention period expires, these records are destroyed too.

7. Anything not on that list is erased

Our deletion system works from an allowlist: only the categories named in section 6.2 survive. Any other data — including any new kind of data we may collect in future — is erased by default, automatically, without anyone having to remember to add it.

We built it this way deliberately, so that the failure mode is "we erased something we were allowed to keep" rather than "we quietly kept something we should have erased".

8. Data held by third parties

Some of your data necessarily sits with independent, regulated entities. We cannot delete it on their systems, and deleting your adwizr account does not do so:

• KYC Registration Agencies (KRAs) hold your KYC record. This is a shared, industry-wide record relied on by every SEBI-registered intermediary — it is not ours to delete, and it is what lets you invest elsewhere without redoing KYC from scratch.
• BSE STAR MF and the Registrar & Transfer Agents (CAMS, KFintech) hold your investor account (UCC), your folios, and your mutual fund transaction history.
• Your bank and the Account Aggregator remain the source of the financial data you shared with us. We revoke the consent; the data at source belongs to your bank.
• KYC, eSign and payment providers retain their own transaction and audit records, under their own obligations.

Each has its own statutory retention duties. To exercise rights against them, approach them directly.

9. Timing, failure, and honesty

Erasure runs automatically once the grace period ends, normally within 24 hours. Every run is logged and audited.

If a technical failure prevents any part of the erasure from completing, the request is not marked as done. It is marked failed and retried automatically until it succeeds. We would rather retry a deletion than tell you it happened when it did not.

10. Registering again

Your mobile number is released when your account is erased, so you may register again with the same number. It will be a genuinely new account: none of your previous plan, goals, portfolio or chat history can be restored to it — what was not erased is sealed away as a statutory record, never reattached to an account. Depending on your KYC status with the KRAs, you may or may not need to repeat onboarding.

11. Complaints

We take complaints seriously and we publish the whole escalation path, not just an inbox.

The Grievance Officer is the officer named in our Privacy Policy. The Principal Officer and the Compliance Officer are the officers designated under the SEBI (Investment Advisers) Regulations, 2013 for registration INA000022774. For voice contact on any of these, use our company line +91 82967 32984.

Our service levels. We acknowledge any complaint or rights request within 1 business day and resolve it within 30 days. We keep records of complaints and their resolution for 5 years, as SEBI requires.

12. Changes to this policy

We may update this policy. The version number and effective date at the top always reflect the current text, and material changes are notified in the app. We will not shorten what we erase, or widen what we retain, without updating this page first.