DPDP Notice

This notice is issued by Prowessca Technology Solutions (OPC) Private Limited (“Prowessca”, the Data Fiduciary) under Section 5 of the Digital Personal Data Protection Act, 2023 (“DPDP Act”) to all users (the Data Principal) of the Fincentive.One website and Platform.

1. Personal data we process

We process personal data you provide to us during signup, Smart Onboarding (ARN, PAN, Aadhaar, bank account, business details), day-to-day use of the Hub (client records, communications, uploaded documents), and payments (invoices, billing address). We also process technical data such as IP address, device information and interaction logs for security and service-improvement purposes.

2. Specified purposes

Your personal data will be processed solely for the following specified purposes:

• Account creation, authentication and access control.
• Verification of identity, ARN, PAN, Aadhaar and bank details through authorised agencies.
• Onboarding with Asset Management Companies and Pension Fund Managers at your direction.
• Operation, security, support and improvement of the Platform.
• Processing of subscription fees, generation of invoices and regulatory record-keeping.
• Sending service-related communications and, where you opt in, marketing material.
• Compliance with SEBI, PFRDA, IRDAI, AMFI, GST, income-tax and anti-money-laundering obligations.

3. Manner of processing

We process personal data by automated means on servers physically located in India. All personal data is encrypted in transit and at rest, access is restricted on a need-to-know basis, and every access is audit-logged. We rely on authorised processors (KYC partners, payment gateways, cloud infrastructure) under contracts that impose the same data protection obligations.

4. Consent

Your consent to process personal data for the purposes above is obtained through an affirmative action — either by accepting our consent banner, by ticking the checkbox during signup, or by clicking the “I agree” button at key points in the onboarding flow. Consent can be withdrawn at any time, without affecting processing already carried out on the basis of prior consent. To withdraw consent, write to dpo@fincentive.one.

5. Your rights under the DPDP Act

• Right to information about the personal data we process about you.
• Right of access to a summary of your personal data and processing activities.
• Right to correction, completion or updating of inaccurate personal data.
• Right to erasure of personal data that is no longer necessary.
• Right to nominate another individual to exercise your rights in the event of your death or incapacity.
• Right to grievance redressal with our Grievance Officer.
• Right to appeal to the Data Protection Board of India.

6. How to exercise your rights

Write to our Data Protection Officer:

We will respond within 30 days of receiving a valid request.

7. Grievance Officer

If you are not satisfied with our response, or if you wish to raise a specific grievance regarding the handling of your personal data, you may contact our Grievance Officer:

The Grievance Officer will acknowledge complaints within 48 hours and resolve them within 30 days. If your grievance remains unresolved, you may lodge a complaint with the Data Protection Board of India through the mechanism notified by the Central Government.

8. Retention

Personal data is retained for seven (7) years from the date of closure of your account, to comply with obligations under SEBI, PFRDA, the Income Tax Act, 1961, and the Prevention of Money Laundering Act, 2002. Thereafter data is securely deleted or irreversibly anonymised.

9. Cross-border transfers

Personal data is stored on servers located in India. We do not transfer personal data outside India except in accordance with Section 16 of the DPDP Act, and only to countries notified as permitted by the Central Government.