Privacy Policy

This Privacy Policy describes how Fynvestor Investment Advisory (Proprietor: Krishna Goyal) (operating the brand “RealCase”, together with its website realcase.in and mobile application, the “Platform”; “we”, “us” or “our”) collects, uses, discloses and safeguards your information. We are committed to handling your data in accordance with the Information Technology Act, 2000, the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 (“SPDI Rules”) and the Digital Personal Data Protection Act, 2023 (“DPDP Act”), as applicable.

By using the Platform, you consent to the practices described in this policy.

1. Information we collect

• Information you provide: today, when you join our waitlist or community, your name, email address and (optionally) mobile number. Once we go live with the product, this will also include identity/KYC details where a service requires it, and your subscription and communication preferences.
• Payment information (once we go live with the product): subscription payments will be processed by our third-party payment gateway, Razorpay. Card numbers, CVV, UPI PINs, net-banking and other payment credentials are collected and processed directly by the gateway. We do not store your full card or bank credentials on our servers. No payments are collected today.
• Information collected automatically: device and browser type, IP address, approximate location, pages viewed and usage/interaction data, collected through cookies and similar technologies.
• Information from third parties: our SEBI-registered adviser partner and our service providers, where needed to deliver the service.

2. How we use your information

• To create and operate your account and provide the Platform’s features.
• To process subscription payments and send invoices and receipts.
• To deliver model portfolios, research and market content you have access to.
• To provide customer support and respond to your requests and grievances.
• To comply with legal, regulatory (including SEBI), KYC/AML and tax obligations.
• To secure the Platform, prevent fraud and enforce our terms.
• To send service, transactional and (with your consent) marketing communications.
• To analyse usage and improve our products and content.

3. Consent and legal basis

We process personal data on the basis of your consent and for the legitimate uses permitted under the DPDP Act. You may withdraw consent at any time (see “Your rights” below); withdrawal does not affect processing already carried out, and may limit your ability to use parts of the Platform.

4. Cookies and analytics

We use cookies and similar technologies to keep you signed in, remember preferences and measure usage. You can control cookies through your browser settings; disabling some cookies may affect how the Platform works.

5. Payments

We do not collect any payments today. Once we go live with the product, payments will be handled by Razorpay Software Private Limited, and your use of the payment gateway will be subject to Razorpay’s own terms and privacy policy. Razorpay maintains PCI-DSS compliant systems for handling card and payment data.

6. How we share your information

We do not sell your personal data. We share it only as needed:

• Service providers: hosting, analytics, communications and similar vendors who process data on our behalf under confidentiality obligations.
• Payment processor: Razorpay, to complete transactions.
• Our adviser partner: Fynvestor (SEBI Registered Investment Adviser, Reg. no. INA000020563), where required to deliver advisory or research services.
• Legal and regulatory authorities: where required by law, regulation or valid legal process.
• Business transfers: in connection with a merger, acquisition or reorganisation, subject to this policy.

7. Data retention

We retain personal data for as long as your account is active and thereafter for the period required to meet our legal, regulatory and record-keeping obligations (including SEBI record-retention requirements), after which it is deleted or anonymised.

8. Data security

We implement reasonable security practices and procedures designed to protect your data, consistent with Rule 8 of the SPDI Rules. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

9. Your rights

Subject to applicable law, you may:

• access and obtain a summary of the personal data we hold about you;
• request correction, completion or updating of inaccurate data;
• request erasure of your data, subject to our legal retention obligations;
• withdraw consent; and
• nominate another individual to exercise your rights in the event of death or incapacity.

To exercise any of these, email us at contact@realcase.in.

10. Children

The Platform is intended for users aged 18 and above. We do not knowingly collect data from children. If you believe a child has provided us data, contact us and we will delete it.

11. Changes to this policy

We may update this policy from time to time. The “Last updated” date above reflects the latest version, and material changes will be notified through the Platform.

12. Grievance Officer

In accordance with the IT Act and the SPDI Rules, and for the purposes of the DPDP Act, our Grievance Officer is:

• Name: Krishna Goyal
• Email: contact@realcase.in
• Address: 4th Floor, BPTP Centra One, Sector 61, Gurgaon, Haryana 122102

We aim to acknowledge and address grievances within the timelines prescribed under applicable law.