Privacy Policy

Effective Date: 16 Jul 2026 · Last Updated: 05 Aug 2026

1. Introduction

adwizr is a digital financial wellness and wealth-advisory application operated by Zenara Technologies Private Limited (“Zenara”, “adwizr”, “we”, “us” or “our”).

Zenara Technologies Private Limited is a SEBI Registered Non-Individual Investment Adviser bearing Registration No. INA000022774, providing investment advisory services in accordance with the SEBI (Investment Advisers) Regulations, 2013, as amended from time to time.

This Privacy Policy explains how we collect, use, process, store, share and protect personal data when you:

• download, access or use the adwizr mobile application
• use any website, dashboard, communication channel or service linked to adwizr
• communicate with our team
• otherwise interact with the adwizr platform and related services

By using adwizr, you acknowledge that your personal data will be handled as described in this Privacy Policy. Where required by applicable law, we will seek your consent before processing your personal data.

This Privacy Policy should be read together with our Terms of Use and any additional notices or consents presented to you within the application.

2. About adwizr

adwizr is designed to help users understand, organise and evaluate aspects of their personal finances. Depending on the features available to you, adwizr may provide:

• financial planning tools
• portfolio and investment analysis
• SEBI-regulated investment advisory services, where applicable, after completion of the prescribed onboarding, suitability assessment and client agreement
• financial-health assessments
• goal planning
• educational content
• alerts, insights and recommendations
• AI-assisted conversations and responses
• access to financial advisers or other professionals
• other related financial-wellness services

Unless expressly stated otherwise, information generated through adwizr is intended for informational and educational purposes and should not automatically be treated as personalised investment, tax, legal or accounting advice.

3. Personal Data We May Collect

The data we collect depends on the features you use and the information you choose to provide.

3.1 Account and identity information

We may collect:

• your name
• email address
• mobile number
• date of birth or age range
• gender, where voluntarily provided
• residential city, state, PIN code or country
• login credentials or authentication identifiers
• profile photograph
• occupation, employer, industry or employment status
• other information used to create or maintain your account

Where identity verification is required, we may also collect or process:

• Permanent Account Number or PAN details
• Know Your Customer or KYC information
• government-issued identity-document details
• address-verification information
• identity-verification results received from authorised service providers

3.2 Financial information

Because adwizr is a financial wellness and wealth-advisory platform, we may collect financial information that you choose to provide or authorise us to access, including your income, expenses, assets, liabilities, investments, insurance, tax information, portfolio holdings, transaction history, financial goals, risk profile and supporting financial documents.

Where you choose to link an external account or financial-data source, we may receive information from that source in accordance with your authorisation and the provider’s terms.

3.3 Information you provide during conversations

When you use chat, AI-assisted tools, customer support or adviser-interaction features, we may collect:

• questions and prompts submitted by you
• messages and conversation history
• documents or images attached to conversations
• voice recordings, where you choose to speak to the AI assistant instead of typing
• feedback and ratings
• call notes or meeting notes
• support requests
• telephone call recordings, virtual meeting recordings and communication logs maintained for regulatory, audit, dispute resolution and quality assurance purposes, where permitted by applicable law
• other information you voluntarily share

Please avoid including information that is unnecessary for the service you are requesting.

3.4 Device and technical information

When you use the application, we may automatically collect technical information such as your device type, operating system, application version, IP address, device identifiers, network information, diagnostic logs, security signals and application performance data.

We will access identifiers, permissions or device features only where required for an app function, security, analytics or another purpose disclosed to you.

3.5 Usage information

We may collect information about how you interact with adwizr, including features accessed, screens viewed, searches performed, navigation patterns, notification interactions and application performance.

3.6 Information from third parties

We may receive personal data from:

• identity-verification or KYC providers
• account aggregators or financial-data providers
• Consent Managers operating under the RBI Account Aggregator framework
• investment platforms, registrars or intermediaries
• payment-service providers
• analytics and crash-reporting providers
• authentication providers, including Google Sign-In
• advisers or service partners authorised by you
• publicly available sources
• other third parties where you have authorised the disclosure or applicable law permits it

We do not collect information from an external account merely because you have that account. Data is accessed only when the integration is enabled and the required authorisation has been provided.

3.7 Permissions used by the application

Depending on the features you use, adwizr may request access to:

• camera, for scanning or uploading documents
• photos, media or files, for uploading financial records or profile images
• notifications, for reminders, alerts and service messages
• microphone, for voice-based interactions
• contacts, only where a specific contact-related feature requires it
• other device functionality disclosed when permission is requested

You can manage app permissions through your device settings. Disabling a permission may prevent the corresponding feature from working.

4. How We Use Personal Data

We may use personal data to:

4.1 Provide and operate adwizr

This includes using data to:

• create and manage your account and authenticate your identity
• provide financial planning, portfolio analysis and investment advisory services
• process documents, maintain your preferences and generate reports, dashboards, alerts and insights
• communicate with you regarding your account and requested services
• conduct client onboarding, suitability assessment, risk profiling and other regulatory activities in accordance with applicable SEBI regulations

4.2 Personalise the service

We may use your financial profile, preferences, goals and activity to:

• customise the information shown to you
• identify relevant financial-planning topics
• provide personalised calculations or scenarios
• improve the relevance of educational information
• tailor reminders, alerts and application experiences

4.3 Provide AI-assisted functionality

adwizr may use artificial intelligence, machine-learning models and automated systems to:

• interpret questions and documents
• organise or categorise financial information
• identify possible gaps, risks or inconsistencies
• generate summaries, explanations and insights
• answer questions
• create financial scenarios
• assist our support, operations or advisory teams

AI-generated results may be incomplete, outdated or incorrect. You should independently verify important information before acting on it.

We do not rely on a single artificial-intelligence model. Different models are better suited to different tasks — a short factual question, a long piece of financial analysis and a spoken reply are not necessarily handled well by the same one — so we route each request to whichever of the providers below is best suited to it, and we may change that routing at any time without notice to you. Any request may reach any of the providers named below.

Where you have given that permission, your information may therefore be sent to any of the following providers, all of which are located outside India:

• DeepSeek — an artificial-intelligence provider that generates the assistant's answers. Processing takes place in China.
• OpenAI — an artificial-intelligence provider that generates the assistant's answers. Processing takes place in the United States.
• Anthropic (Claude) — an artificial-intelligence provider that generates the assistant's answers. Processing takes place in the United States.
• ElevenLabs — the speech provider used only if you use the assistant's voice features. Processing takes place in the United States.

The artificial-intelligence providers receive the questions you ask the assistant and the financial context needed to answer them: your goals, holdings, cashflow figures, amounts, dates and percentages. ElevenLabs receives the audio of what you say, in order to convert it into text, and the text of the assistant's reply, in order to read it aloud.

The same rules apply whichever provider handles your request. The protections described in this section are not specific to one provider: the same identifiers are removed before the request leaves us, the same contractual restrictions bind the recipient, and no provider is engaged at all until those restrictions are in place.

Before anything is sent to an AI provider we remove your direct identifiers. Your name, PAN, mobile number, email address, Aadhaar number, bank account numbers and mutual-fund folio numbers are replaced with neutral placeholders, and the real values are restored only in the answer displayed to you. Amounts, goals, dates and percentages are not removed, because the assistant cannot answer a financial question without them.

We never send your banking password, card PIN, UPI PIN or any one-time password to an AI provider.

We engage each of these providers under terms that permit them to use your information only to produce the response returned to you. Your conversations are not used to train their models. They may not retain your information beyond what is needed to return that response, may not sell it, and may not disclose it to anyone else or use it for their own purposes. Each is required to apply protections equivalent to those described in this Privacy Policy. We do not sell your personal data, and we do not share it with an AI provider for advertising, profiling for third parties, or any purpose other than answering you.

We may add, replace or stop using a provider on this list as models change. Any provider we use will be named in this section, and will be bound by the restrictions above before it receives anything from us. If we change the way your information is prepared before it is sent, we will update this section and, where the change is material, ask for your permission again.

4.4 Communicate with you

We may send:

• account and security messages
• service announcements
• beta-testing communications
• reminders and alerts requested by you
• responses to support requests
• product updates
• surveys and feedback requests
• promotional communications where permitted by law

You may opt out of promotional communications using the unsubscribe mechanism provided. You may still receive essential transactional, security and service-related communications.

4.5 Maintain safety and security

We may process personal data to:

• protect user accounts
• detect suspicious, fraudulent or unauthorised activity
• prevent misuse of the application
• investigate security incidents
• enforce our agreements
• maintain audit and security records
• protect the rights and safety of users, Zenara and third parties

4.6 Improve and develop our services

We may use data to:

• analyse application performance and usage
• diagnose and resolve technical issues
• develop and improve products and features
• conduct product research and user-experience improvements
• generate aggregated or anonymised insights

Where reasonably possible, we use aggregated or de-identified information for analytics and product-development purposes.

4.7 Comply with legal and regulatory obligations

We may process or retain information to:

• comply with applicable laws, regulations, court orders and lawful government requests
• fulfil KYC, anti-money-laundering, taxation, accounting or record-keeping obligations, where applicable
• respond to regulatory authorities
• comply with the Securities and Exchange Board of India (SEBI), BASL, stock exchanges and other applicable regulatory or supervisory authorities
• establish, exercise or defend legal claims
• cooperate with fraud-prevention or law-enforcement investigations

5. Basis for Processing

Depending on the circumstances and applicable law, we process personal data on one or more of the following grounds:

• your consent
• processing necessary to provide services requested by you
• compliance with applicable legal obligations
• processing for legitimate uses permitted by law
• protection of your vital interests or those of another person
• prevention and investigation of fraud or security incidents
• another lawful basis available under applicable law

Where processing is based on your consent, you may withdraw that consent through the application or by contacting us. Withdrawal will not affect processing that occurred before the withdrawal. Certain features may no longer be available where the relevant data is necessary to provide them.

6. How We Share Personal Data

We may disclose personal data to the following categories of recipients where reasonably necessary.

6.1 Technology and service providers

We may engage providers for:

• cloud hosting and infrastructure
• authentication, KYC and identity verification
• analytics, cybersecurity and AI services
• customer support and communications
• payment processing
• other operational or professional support services

These providers may process information only to perform services for us, subject to applicable contractual, confidentiality and security obligations.

The artificial-intelligence providers in that list are named: DeepSeek, OpenAI and Anthropic (Claude), any of which may generate the assistant's answers, and ElevenLabs, which converts speech to text and text to speech for the assistant's voice features. They receive information only where you have permitted AI features, and only as described in section 4.3.

The principal providers we currently rely on, and what each receives, are:

• Decentro — to pre-fill your profile during onboarding. With your consent given at login, we send your mobile number and name so Decentro can retrieve your identity and address details from a credit bureau (Equifax), and we use Decentro to verify your bank account by penny-drop and to process payments. This saves you re-typing details we can verify.
• Finvu (Cookiejar Technologies) — our RBI-licensed Account Aggregator. It carries your consent to your banks, depositories and insurers, and returns the account data you approve.
• Digio and Fintech Primitives — KYC verification, e-signature and mandate execution.
• BSE StAR MF — placing and settling the mutual-fund orders you authorise.
• Amazon Web Services — cloud hosting, in the Asia Pacific (Mumbai) region.
• Sentry — crash and performance diagnostics. Identifiers are stripped before events leave your device.
• Google Firebase Cloud Messaging — delivery of push notifications.

Each is engaged as a processor under contract, may use your data only to perform the service we have asked for, and may not use it for its own advertising or sell it onward. This list is kept current; where a provider changes we will update this policy.

6.2 Financial-service partners and advisers

Where required to provide a service requested by you, we may share relevant information with:

• investment advisers and financial planners
• brokers, investment platforms and registrars
• banks, payment providers and insurance intermediaries
• tax or accounting professionals
• other financial institutions or service providers required to provide services requested by you

We will seek your authorisation where required before sharing information for such purposes.

6.3 Affiliates and corporate group entities

We may share information with our holding company, subsidiaries or affiliates for internal administration, security, service delivery and business operations, subject to this Privacy Policy and applicable law.

6.4 Legal and regulatory disclosures

We may disclose information where we reasonably believe disclosure is necessary to:

• comply with applicable law
• respond to a court, tribunal, regulator, government authority or law-enforcement agency
• protect against fraud, cybersecurity threats or illegal activity
• enforce our agreements
• provide information to SEBI, BASL, statutory auditors, compliance officers or other regulatory authorities for inspections, audits, investigations or regulatory reporting, where required
• protect the rights, property or safety of Zenara, our users or another person

6.5 Business transactions

If Zenara is involved in a merger, acquisition, financing, restructuring, sale of assets, insolvency or similar transaction, personal data may be disclosed to advisers, potential counterparties and successors, subject to appropriate safeguards.

6.6 At your direction

We may disclose information to another person or organisation when you instruct or authorise us to do so.

7. Third-Party Services and Links

adwizr may include integrations, links or embedded services operated by third parties. Their handling of your personal data is governed by their own privacy policies and terms.

We encourage you to review the privacy practices of any third-party service before authorising an integration or providing information to it.

Zenara is not responsible for the privacy or security practices of independent third parties that do not process data on our behalf.

8. Data Storage and International Transfers

Your personal data may be stored or processed in India and in other countries where Zenara or its service providers operate.

Where personal data is transferred across borders, we will take reasonable steps to ensure that the transfer complies with applicable legal requirements and that appropriate contractual, organisational or technical safeguards are used.

Where you have permitted AI features, information is transferred outside India for that purpose: to DeepSeek, whose processing takes place in China, or to OpenAI or Anthropic (Claude), whose processing takes place in the United States — any of the three may handle a given request — and, if you use the voice features, to ElevenLabs, whose processing takes place in the United States. Section 4.3 sets out exactly what is sent, what is removed before it is sent, and how to decline or withdraw your permission.

9. Data Retention

We retain personal data only for as long as reasonably necessary to provide our services, maintain your account, comply with legal and regulatory obligations, resolve disputes, prevent fraud and enforce our agreements.

Retention periods may vary depending on the type of information and the reason it was collected.

Without limiting the above, client records including KYC documents, client agreements, suitability assessments, risk profiling records, investment advice, communication records, portfolio reports and related records shall be retained for a minimum period of five (5) years or such longer period as may be prescribed under the SEBI (Investment Advisers) Regulations, 2013 or any other applicable law.

When personal data is no longer required, we will take reasonable steps to delete, anonymise or securely isolate it, unless continued retention is required or permitted by law.

Backup copies may remain for a limited period after deletion and will be removed or overwritten in accordance with our backup and retention procedures.

10. Account and Data Deletion

You may request deletion of your adwizr account and associated personal data through:

• the Delete Account option available under Account → Delete Account; or
• the account-deletion webpage at https://app.adwizr.com/legal/delete-account.html; or
• an email sent to privacy@zenaratechnologies.com.

After receiving a valid deletion request, we will delete or anonymise personal data associated with your account, except for information we are required or permitted to retain for legal, security, fraud-prevention, dispute-resolution, accounting or regulatory purposes.

Before processing a deletion request, we may verify your identity to protect your account against unauthorised requests.

Deletion may be irreversible and may result in the loss of your reports, history, uploaded documents, preferences and other account information.

How to delete your account   Read the full deletion policy

11. Your Rights and Choices

Subject to applicable law, you may have the right to:

• access, review or obtain a copy of your personal data
• request correction, updating or deletion of your personal data
• withdraw consent or request restriction of certain processing where applicable
• request portability of your personal data where legally available
• nominate another individual to exercise your rights where recognised by law
• submit a grievance or complaint regarding our handling of your personal data

You may update certain account information directly within adwizr.

To exercise your rights, contact us using the details provided in Section 18. We may request information necessary to verify your identity. We will respond within the period required by applicable law.

12. Security

We use reasonable technical, organisational and administrative measures designed to protect personal data against:

• unauthorised access
• alteration
• disclosure
• loss
• destruction
• misuse

These measures may include encryption, access controls, authentication mechanisms, monitoring and logging, secure software development practices, vulnerability management, employee confidentiality obligations and periodic security reviews.

No method of transmission or electronic storage is completely secure. We therefore cannot guarantee absolute security.

You are responsible for keeping your login credentials confidential, using a secure device and promptly informing us if you suspect unauthorised access to your account.

13. Personal Data Breaches

If a personal-data breach occurs, we will take reasonable steps to:

• investigate and contain the incident
• mitigate potential harm
• restore the security of affected systems
• provide notifications to affected users or authorities where required by applicable law

14. Children’s Privacy

adwizr is intended for individuals who are at least 18 years old and legally capable of using financial services.

We do not knowingly collect personal data directly from children under 18 through independent user accounts.

If you believe that a child has provided personal data to us without appropriate authorisation, please contact us. We will take reasonable steps to review and, where appropriate, delete the information.

Information about children or dependants may be entered by an adult user for household financial-planning purposes. The adult user must have the authority to provide that information and should provide only information reasonably necessary for the relevant planning feature.

15. Analytics, Advertising and Tracking

We may use analytics technologies to understand app usage, diagnose problems and improve adwizr.

We may use cookies, software development kits (SDKs), pixels, local storage and similar technologies to improve application functionality, security, fraud prevention, analytics and user experience.

We may use device identifiers or similar technologies for analytics, security, attribution or app-functionality purposes. Any such use will be disclosed in the Google Play Data Safety section and managed in accordance with applicable platform requirements.

We may use analytics, attribution, crash-reporting and similar technologies provided by trusted third-party service providers to improve the functionality, performance and security of adwizr.

15.1 What we do not do

To be specific about current practice: adwizr does not track you. We do not serve advertising in the app, we do not embed advertising or attribution SDKs, and we do not sell or share your personal data with data brokers.

We do not combine information collected in adwizr with data from third parties for advertising purposes, and we do not follow you across other companies’ apps or websites. On iOS the app therefore does not request App Tracking Transparency permission, because it performs no activity that requires it.

The diagnostic and crash data we do collect is used only to keep adwizr working, and identifiers are removed from it before it reaches our provider.

16. Automated Analysis and Decision-Making

adwizr may use automated tools to analyse financial information and generate insights, classifications, reminders or recommendations.

Unless expressly disclosed, adwizr does not make legally binding decisions about your eligibility for credit, insurance, employment or another service solely through automated processing.

Where a regulated financial recommendation or material decision is involved, additional disclosures, suitability assessments, human review or consent may apply.

Where automated analysis is carried out by a third-party artificial-intelligence provider rather than by our own systems, section 4.3 names every provider that may be used and states what is sent to it. We use more than one, and which one handles a given request depends on the task.

17. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes in:

• our products and services;
• legal or regulatory requirements;
• technology;
• service providers; or
• our data-handling practices.

When we make material changes, we may notify you through the application, email or another appropriate channel. The updated policy will display a revised “Last Updated” date.

Where required by law, we will obtain fresh consent before applying a materially different use of personal data.

18. Contact and Grievance Officer

The entity responsible for the adwizr application is:

Please include your registered email address or mobile number and a description of your request or grievance. Do not send passwords, PINs or one-time passwords.

If you are not satisfied with the resolution of your grievance, you may also lodge your complaint through the SEBI SCORES (SEBI Complaints Redress System) platform at scores.sebi.gov.in in accordance with applicable SEBI regulations.

19. Governing Law

This Privacy Policy shall be governed by the applicable laws of India, including the Digital Personal Data Protection Act, 2023, the Information Technology Act, 2000, the Securities and Exchange Board of India (Investment Advisers) Regulations, 2013, and other applicable financial-sector laws and regulations.

Nothing in this Privacy Policy limits any rights available to you under applicable law.

20. Investment Advisory Disclaimer

Zenara Technologies Private Limited is registered with the Securities and Exchange Board of India (SEBI) as a Non-Individual Investment Adviser (Registration No. INA000022774).

SEBI registration, BASL membership, certifications or regulatory approvals do not guarantee investment performance or assure returns.

Investments in securities markets are subject to market risks. Investors are advised to read all relevant scheme documents and investment-related documents carefully before investing.

Advisory services are provided strictly in accordance with applicable SEBI regulations and subject to completion of the prescribed client onboarding, suitability assessment and execution of the required agreements.