Privacy Policy

Native Investment Managers LLP is a SEBI Registered Investment Advisor (RIA No. INA000022163) operating the Native Invest platform at https://www.nativeinvest.in. We are the data controller responsible for the personal information we collect from you.

For privacy-related queries, contact us at: info@nativeinvest.in.

2.1 Information You Provide to Us

• Identity Information: Full name, date of birth, gender, PAN card number.
• Contact Information: Mobile number, email address, State of your residence.
• Financial Information: Annual income range, existing investments, risk profile responses, net worth category (as part of KYC and risk profiling).
• KYC Documents: Aadhaar number (masked as per UIDAI guidelines), PAN card details, proof of address.
• Bank Details: Bank account number and IFSC code (for payment processing and verification).
• Advisory Agreement: Your Aadhaar-based digital signature and agreement execution details.
• Communication Records: Emails, messages, and call records with our support team.

2.2 Information Collected Automatically

• Device & Browser Data: IP address, browser type, operating system, device identifiers.
• Usage Data: Pages visited, features used, time spent on pages, clicks and navigation paths.
• Cookies & Tracking Technologies: Session cookies, persistent cookies, and analytics tags (see Section 8).
• Transaction Logs: Subscription initiation, fee payment records, and platform activity timestamps.

2.3 Information from Third Parties

• KYC Verification Providers: Identity verification data from NSDL / CDSL, UIDAI (Aadhaar), or authorised KRA (KYC Registration Agencies).
• Payment Gateways: Transaction status and payment confirmation data from our payment processor.
• Brokers / Gateway: Details of trades executed including instrument, quantity & price.

• Onboarding & KYC: To verify your identity, complete SEBI-mandated KYC, and establish the advisory relationship.
• Risk Profiling: To assess your risk appetite and recommend the appropriate SMART Portfolio product.
• Advisory Services: To generate, deliver, and update investment recommendations tailored to your risk profile.
• Fee Processing: To collect advisory fees and issue invoices / receipts.
• Platform Access: To manage your account, authenticate logins, and enable platform features.
• Communication: To send advisory recommendations, rebalancing alerts, market insights, fee reminders, and support responses.
• Legal & Regulatory Compliance: To comply with SEBI regulations, tax obligations, anti-money laundering (AML) laws, and other applicable legal requirements.
• Improving Our Services: To analyse platform usage, fix bugs, improve features, and enhance user experience.
• Marketing (with consent): To send newsletters, market insights, and promotional communications about new features or services — only if you have opted in.

• Contractual Necessity: Processing required to provide advisory services under the Investment Advisory Agreement.
• Legal Obligation: Processing required to comply with SEBI regulations, income tax laws, and AML regulations.
• Legitimate Interests: Analytics and platform improvement activities that do not override your privacy rights.
• Consent: Marketing communications and optional data sharing, where you have given explicit consent.

Native Invest does not sell your personal data to any third party. We share data only in the following limited circumstances:

• KYC & Regulatory Authorities: With SEBI, KRAs, NSDL, CDSL, income tax authorities, or other regulators as mandated by law.
• Technology & Service Providers: With our cloud infrastructure providers, payment gateways, KYC verification services, and analytics tools — all bound by strict confidentiality obligations.
• E-Sign Provider: With Aadhaar-based e-sign service providers for execution of the Advisory Agreement.
• Legal Requirements: Where disclosure is required by court order, government mandate, or applicable law.
• Business Transfers: In the event of a merger, acquisition, or restructuring of Native Investment Managers LLP, your data may be transferred to the successor entity, subject to the same privacy protections.

• 6.1 We retain your personal data for as long as your advisory relationship with us is active and for a minimum of 5 years thereafter, as required by SEBI regulations and applicable law.
• 6.2 KYC records and investment advisory records are retained for a minimum period as mandated by SEBI (Investment Advisers) Regulations, 2013 and the Prevention of Money Laundering Act (PMLA).
• 6.3 If you withdraw consent for marketing communications, we will promptly remove you from our marketing lists, while retaining records necessary for legal and regulatory compliance.

7.1 Native Invest implements industry-standard technical and organisational security measures to protect your personal data against unauthorised access, disclosure, loss, or alteration. These include:

• Encryption of data in transit (SSL / TLS) and at rest.
• Access controls limiting data access to authorised personnel only.
• Regular security audits and vulnerability assessments.
• Secure cloud infrastructure with reputable service providers.

7.2 While we take all reasonable precautions, no method of electronic transmission or storage is 100% secure. In the event of a data breach affecting your rights, we will notify you as required by applicable law.

7.3 You are responsible for maintaining the security of your platform login credentials. Do not share your password with anyone.

8.1 Our Website uses cookies and similar tracking technologies to enhance user experience and gather analytics data.

Types of cookies we use:

• Essential Cookies: Required for the Website to function (login sessions, security tokens). Cannot be disabled.
• Analytics Cookies: Help us understand how users navigate the Website (e.g. Google Analytics). These are anonymised and do not identify individuals.
• Preference Cookies: Remember your settings and preferences for future visits.
• Marketing Cookies: Used only if you opt into marketing communications. Track engagement with our content.

8.2 You can manage cookie preferences through your browser settings. Disabling non-essential cookies will not affect your ability to use core advisory features.

As a data subject under applicable Indian law, you have the following rights:

• Right to Access: Request a copy of the personal data we hold about you.
• Right to Correction: Request correction of inaccurate or incomplete personal data.
• Right to Deletion: Request deletion of your data, subject to legal and regulatory retention obligations.
• Right to Withdraw Consent: Withdraw consent for marketing communications at any time by emailing info@nativeinvest.in or clicking ‘Unsubscribe’ in any marketing email.
• Right to Grievance Redressal: Lodge a privacy complaint with us at info@nativeinvest.in. We shall respond within 30 days. Unresolved complaints may be escalated to the relevant regulatory authority.

To exercise any of the above rights, please contact us at info@nativeinvest.in with the subject line ‘Privacy Request’.

Our Website may contain links to third-party websites (brokers, SEBI portals, payment gateways). This Privacy Policy does not apply to those websites. We encourage you to review the privacy policies of any third-party site you visit.

Our advisory services are not intended for persons under 18 years of age. We do not knowingly collect personal data from minors. If you believe we have inadvertently collected data from a minor, please contact us immediately at info@nativeinvest.in.

• 12.1 We may update this Privacy Policy from time to time to reflect changes in our practices, technology, or regulatory requirements.
• 12.2 We will notify you of material changes via email or a prominent notice on the Platform. The updated Policy will display the revised effective date at the top.
• 12.3 Your continued use of the Platform after the effective date of any update constitutes acceptance of the revised Privacy Policy.

For any privacy-related queries, requests, or complaints, please contact:

We will respond to all privacy requests within 30 business days.