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Privacy At Gentle

Last updated on: 15 Sept ’26

This Privacy Policy (“Policy”) applies to the website located at www.napl.one (“Website”) and the financial advisory, wealth management, and digital services provided by NEOGENTLE ADVISORY PRIVATE LIMITED (“NAPL”, a company incorporated under the laws of India and registered as an investment adviser/regulated intermediary where applicable). The Terms and Conditions of Use accessible on the Website are deemed incorporated into this Policy by reference.

NAPL is firmly committed to protecting and respecting the privacy and confidentiality of information collected, received, possessed, stored, dealt with, or handled from any individual or entity that visits, browses, uses, or accesses the Website, or avails of the services offered thereon (“User”).

This Policy makes all necessary disclosures mandated under the Information Technology Act, 2000, the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 (“SPDI Rules”), and applicable circulars, guidelines, and regulations issued by the Securities and Exchange Board of India (“SEBI”) governing registered intermediaries and investment advisers.

This Policy applies to all Personal Information and Sensitive Personal Data or Information (“SPDI”) disclosed by, or collected from, the User.

By accessing the Website, registering an account, or availing of NAPL’s services, the User explicitly consents to the collection, storage, usage, processing, disclosure, and transfer of their Information in accordance with this Policy.

If a User does not agree with the terms of this Policy, they must immediately cease using the Website and its services. Declining to provide necessary information may restrict access to specific features or services.

NAPL reserves the right to modify, amend, or update this Policy at its sole discretion. Registered Users will be notified of material changes via the email address registered with their account. Continued use of the Website following such notification constitutes binding acceptance of the revised Policy.

NAPL collects information to operate efficiently, deliver personalized wealth management and advisory experiences, and fulfill strict statutory obligations.

Identity & Contact Data: Name, date of birth, residential/billing address, electronic mail address, telephone numbers, and PAN required for regulatory verification.

Financial & Transaction Data: Bank account details, income brackets, risk appetite, investment objectives, and Know-Your-Client (KYC) records necessary for rendering compliant financial advisory services.

Technical & Log Data: Browser type, IP address, device identifiers, operating system, network information, access dates, time stamps, and pages viewed (“Log Data”). Log Data does not constitute SPDI under applicable rules; NAPL reserves the right to utilize Log Data for statistical analysis, security hardening, traffic tracking, and marketing analytics.

Authentication Data: Credentials required for secure sign-in, including encrypted passwords and session tokens.

User Authentication Disclaimer: NAPL disclaims all liability regarding the authenticity, accuracy, or completeness of Information provided by the User. Users shall be solely liable for any legal consequences, losses, or damages arising from the submission of inaccurate, fraudulent, or incomplete data.

Regulatory Retention Mandate: As an entity subject to SEBI oversight, NAPL is statutorily obligated to maintain comprehensive audit trails, client agreements, KYC documents, risk profiling assessments, suitability records, and specific advisory recommendations.

Retention Period: In strict compliance with SEBI record-keeping regulations, all client records, investment advice rationales, and transactional communications shall be archived and securely preserved for a minimum period of five (5) years from the date of creation, or longer if mandated by specific regulatory directives, statutory audits, or active legal proceedings/disputes.

Audit Readiness: NAPL maintains secure digital infrastructure and robust audit logs tracking access to client databases, ensuring data integrity and regulatory transparency during SEBI inspections.

NAPL collects and processes User Information strictly for lawful business purposes connected to its core operations, including:

Verifying User identity and executing mandatory KYC and anti-money laundering (AML) checks;

Providing, personalizing, and continually improving investment advisory and financial planning services;

Establishing and maintaining mandatory statutory databases of all client interactions and risk evaluations;

Communicating administrative notices, subscription renewals, service updates, security alerts, and promotional offers;

Evaluating website performance, diagnosing technical glitches, and securing the digital environment against cyber threats; and

Complying with applicable laws, court orders, subpoenas, and directives issued by SEBI or other regulatory authorities.

Zero Storage Policy: Payment Data (such as credit/debit card numbers, UPI handles, net banking credentials, and CVV codes) provided during online purchases is never stored on NAPL’s servers.

Third-Party Payment Gateways: NAPL collaborates with PCI-DSS compliant, industry-reputed independent payment gateway providers. Users are redirected to the secure portal of the independent contractor to complete financial transactions.

NAPL assumes no liability whatsoever for any security breaches, technical failures, defaults, or financial losses attributable to the actions or omissions of such independent payment gateways.

The Website utilizes cookies and similar tracking technologies to optimize User experience, remember session preferences, analyze traffic trends, and customize service delivery.

Users may configure their browser settings to refuse or disable cookies. However, disabling cookies may impair core functionalities and prevent optimal performance of certain sections of the Website.

Access to User Information is strictly restricted to authorized personnel, partners, employees, officers, legal counsels, statutory auditors, and affiliates bound by strict confidentiality obligations.

NAPL may disclose Information to third-party service providers (such as cloud hosting providers, KYC registration agencies, and analytics partners) strictly on a “need-to-know” basis. NAPL undertakes reasonable contractual and technical diligence to ensure third parties maintain data protection standards equivalent to its own.

NAPL shall not be held liable for any loss of confidentiality or security breaches arising entirely from the independent, unauthorized actions of third-party vendors.

NAPL reserves the right to disclose Information without prior notice if required by law, subpoena, judicial mandate, or regulatory request from SEBI, law enforcement agencies, or courts of competent jurisdiction.

NAPL implements commercially reasonable administrative, physical, and technical security practices (including encryption, secure firewalls, and strict access controls) to safeguard User Information against unauthorized access, destruction, or alteration.

Limitation of Liability: While NAPL deploys robust industry-standard security measures, no electronic transmission over the internet or data storage system is entirely infallible. NAPL disclaims absolute security guarantees. NAPL shall not be liable for any direct, indirect, incidental, special, or consequential damages resulting from unauthorized access, cyber intrusions, malware attacks, or data theft beyond its reasonable control.

The Website may contain hyperlinks to external websites operated by third parties. NAPL assumes no responsibility or liability for the privacy practices, terms of use, or content of such external websites. Users are advised to review the privacy policies of every third-party website they visit.

In accordance with the Information Technology Act, 2000 and applicable rules thereunder, the name and contact details of the Grievance Officer are provided below to address any complaints, discrepancies, or privacy concerns:

Name: Mr. Vihar Patel

Designation: Grievance & Compliance Officer

Electronic Mail: grievance@napl.one

Postal Address: D523, Swati Clover, SP Ring Road, Shilaj, Ahmedabad – 380 059

For general queries, operational assistance, or support regarding the services rendered by NAPL, please reach out via:

Customer Service Desk

Electronic Mail: support@napl.one