Privacy Policy
Applicability of Privacy Policy
Neo Group comprises of Neo Investment Value Advisors Private Limited (Holding Company) and it’s subsidiaries
including Neo Advisory and Consulting Services Pvt Ltd, Neofinity Services Pvt Ltd, Neo Trusteeship
Services Pvt Ltd, Neo Technology and Innovation Pvt Ltd, Neo Investment and Finserv Services Pvt
Ltd, Neo Wealth Management Pvt Ltd, Neo Asset Management Pvt Ltd, Neo Wealth Partners Pvt Ltd, Neo
Markets Services Pvt Ltd and Neo Risk Management and Insurance Brokers Pvt Ltd.
The Neo Group Privacy Policy applies to all Companies forming part of the Neo Group, and it’s Mobile
applications, Websites, Web applications AI-powered application platforms and related services.
At Neo Group we are strongly committed to protecting the personal and financial information that
you submit to us. This information is provided when you register to receive certain services or products..
The personal information we get from you will help us provide you with improved services and products.
Once you provide your information to us, you provide such information to Neo Group and its affiliates
and we and/or our affiliate may use such information to provide you various services with respect
to your transaction conducted with Neo Group.
If you object to your Information being transferred or used in this way, please do not provide the
details of your information on the Neo Group mobile, AI-powered and Web applications ("Neo Group
Apps”) and Neo Group Websites.
All information disclosed by you shall be deemed to be disclosed willingly and without any coercion.
No liability pertaining to the authenticity/ genuineness/misrepresentation/fraud/negligence, etc.
of the information disclosed shall apply on Neo Group nor will Neo Group be in any way responsible
to verify any information obtained from you. We share information as part of normal business operations,
such as providing you with any services to which you subscribe, and any related activity such as
but not limited to collecting fees for those services, any activity as part of legal/regulatory requirements
of Securities and Exchange Board of India / NSE/ BSE/ CDSL/ NSDL/ Depository / Depository Participants
/ MCA / RBI / Registrar and Transfer Agents /Mutual Funds/ KYC agents / Asset Management Companies
of Mutual Funds /Collecting Banks/KYC Registration Agencies (KRAs) etc. or any regulatory and/or
government authorities, or other third parties invited to participate in any offers for the benefit
of users of services of Neo Group.
Neo Group may share your information to subcontractors, however, Neo Group would take reasonable
care to ensure but not warrant that such parties would use the information obtained from Neo Group
for required use exclusively.
To ensure security of access to the personal information and transaction details, the access to the
secured zone of Neo Group App and Neo Group Website are restricted by the unique login ID and Password/One
Time Password ("OTP”) you. Unique login id/ username and password/OTP that you need to use each time
you want to access your account/ your information on the site; is to protect your privacy and you
need to maintain secrecy of the username and password you use for any of our services. You should
be very careful in handling the ID and password/OTP and ensure that you do not reveal it to anybody,
nor do you keep it in writing and keep changing your password periodically.
Please note that this privacy policy does not create any contractual or other legal rights in or
on behalf of any party, nor is it intended to do so.
Neo Group respects your privacy and strives to safeguard your right to privacy. Neo Group will continuously
endeavour to ensure that Personal Data shall be used in line with all applicable data protection
laws and your information will be kept secured with restricted access; to the possible extent and
as per limits provided under law.
We shall use the personal information to improve our service to you and to keep you updated about
our new product or information. The information collected from you would be used for the purpose
for which it is intended to be used; including to process your trading request and to carry out the
settlements of your obligations subject to applicable laws.
We store and process your Information including any sensitive financial information collected on
computers (as defined under the Information Technology Act, 2000 or any modification / amendment(s)
thereof or any rule(s) thereunder if any,) that may be protected by physical as well as reasonable
technological security measures and procedures in accordance with Information Technology Act 2000
and Rules thereunder.
If you object to your Information being transferred or used in this way, please do not provide the
details of your information on the Neo Group App and/orNeo Group Website.
Neo Group and its affiliates may share/sell/transfer/license/convey some or all of your personal
information with another business entity to carry out any business activity or re-organization, amalgamation,
restructuring of business or for any other reason whatsoever.
1. Collection of Sensitive Personal Data or Information:
Neo Group may for the purpose of rendering its services, may collect personal information such
as:
- Name, gender, residential / correspondence address, telephone number, date of birth, marital status,
email address or other contact information; PAN, KYC Status, Signature and Photograph; Bank account
or other payment instrument details; or any other detail for providing services.
- Registration of multiple Bank Accounts etc. through application forms
- Payment instrument details at the time of submitting application at the time of
investment or as proof for carrying out change of Bank Account or any other details of debit
card obtained (if any)
- Generation and storing password (PIN) in encrypted form based on the request from the
investor under the online mode of investments
- Annual Income and savings profile; andPassword(s)/ MPIN usage
- Financial information such as Bank Account, Credit Card, Debit Card or other payment
instrument details
- Physical, Physiological and Mental health condition (iv) Sexual orientation (v) Medical
records and historyBiometric information /Biometric authentication
- Any detail relating to the above clauses as provided to body corporate for providing
service; and
- Any of the information received under above clauses by body corporate for processing,
stored or processed under lawful contract or otherwise: provided that, any information that is
freely available or accessible in public domain or furnished under the Right to Information Act,
2005 or any other law for the time being in force shall not be regarded as sensitive personal
data or information for the purposes of Rules.
- Information we may collect from your use of our services.
- Usage of information for responding to your queries.
- Storage Information: We may facilitate user to download and display information such as
scheme commission details which a user may refer to, or to upload relevant documents as per
various processes during user account management or transaction order placement.
- Media Information: We facilitate users to capture / upload relevant documents as may be
required to be uploaded during user account management or transaction order placement.
- Device Information: We may collect specific information about your device when you
access our Services, including your storage, hardware model, operating system and version,
unique device identifier, mobile network information, location, contacts, Microphone accessand
information about the device’s interaction with our services.
- Information needed for Entities/Service Providers to respond to your requests, to
process various applications and to also ensure safe transactions through points of acceptance
in physical form, website, online portals, mobile application, Automated Teller Machines and
such other mode.
- Additionally, we may obtain Personal Information about you from third parties. Also, we
obtain Personal Information about you through call recordings at our call centre(s), Internet
technology, including our Site.
- Neo Group may also call the investors with respect to the other products or services
offered by the AMC. Information shall also be collected to be compliant with the Know Your
Client (KYC) norms under the Prevention of Money Laundering Act, 2002, (PMLA), the rules issued
thereunder, and guidelines and circular on Anti- Money Laundering issued by SEBI and SEBI
(Mutual Funds) Regulations, 1996 as amended till date. The customers/ clients (whether
existing/prospective) must ensure to recheck the information or data being provided to the Neo
Group/ AMC or any person acting on its behalf. In case if any of the data/information is found
to be inaccurate or incorrect, the same shall be informed to the Neo Group / AMC for immediate
amendment. The Neo Group / AMC and any person acting on its behalf shall not be responsible for
the authenticity of the personal information or sensitive personal data or information supplied
by the customers/ clients (whether existing/prospective).
Neo Group offers online platform ‘Neo Group App’ and website for carrying out transactions that collects
such personal data or information to process your financial and non-financial transaction requests.
The information so collected may end up being shared with SEBI/ NSE/ BSE/ MCX /Asset Management Companies
of Mutual Funds/Registrar and Transfer Agents/Collecting Banks/KYC Registration Agencies (KRAs) etc.
solely for the purpose of processing your transaction requests or serving you better.
Under certain circumstances we may be required to share the information given by you
with the third parties, where we feel, they can contribute to add value and improve the quality
of services imparted by us to you. We shall take all reasonable steps to ensure that the
confidentiality of your information is maintained by imposing strict confidentiality standards
on all the third parties with whom we part this information. We shall take such measures as are
reasonably possible not to allow any third parties to retain your personal information longer
than what is warranted by the nature of services rendered. We would also impart your personal
information wherever it is required to be disclosed under law to any of the governmental agency
or regulatory bodies. By agreeing to avail the service offered by us, you have agreed to the
collection and use of your Sensitive Personal Data or Information by Neo Group. You always have
the right to refuse or withdraw your consent to share/dissemination of your Sensitive Personal
Data or Information by contacting the customer care. However, in such an event, you may no
longer avail the services offered by Neo Group.
Neo Group App .Neo Group App Neo Group Website Neo Group App .
2. Use of Personal Information :
We use the Personal Information and other Non-Personal Information, for the following:
- to provide and improve the Services that you request on the Neo GroupApp and/or Neo
Group Website;
- to resolve disputes and troubleshoot problems;
- to help promote a safe service on the Neo Group App and/or Neo Group Website and
protect the security and integrity of the Neo Group App and/or Neo Group Website, the Services
and the users;
- collect money from you in relation to the Services,
- inform you about online and offline offers, products, services, and updates;
- customize your experience on the Neo Group App and/or Neo Group Website or share
marketing material with you;
- to detect, prevent and protect us from any errors, fraud and other criminal or
prohibited activity on the Neo Group App and/or Neo Group Website ;
- enforce and inform about our terms and conditions;
- to process and fulfil your request for Services or respond to your comments, and
queries on the Neo Group App and/or Neo Group Website ;
- to contact you;
- to allow Our business partners and/or associates to present customised messages to you;
- to communicate important notices or changes in the Services, use of the Neo Group App
and/or Neo Group Website and the terms/policies which govern the relationship between you and
the Neo Group and with Our affiliates for providing Services to you; and
- for any other purpose after obtaining your consent at the time of collection. You also
specifically agree and consent to us and/our group, affiliate companies collecting, storing,
processing, transferring and sharing information (including Personal Information) related to you
with third parties such as Banks, Financial Institutions, Credit Information Companies, Entities
registered under applicable laws with Securities Exchange Board of India, National Stock
Exchange of India Limited/BSE Limited/Central Registry of Securitisation Asset Reconstruction
and Security Interest of India (CERSAl)/Payment Gateways/ Collecting Banks/KRAs etc. solely for
the purpose of reviewing your profile and processing your transaction requests for the Services
or for such other products/services offered by us or our group, affiliate or associates.
- In addition to the above, We identify and use your IP address to help diagnose problems
with Our server, resolve such problems and administer the Neo Group App and/or Neo Group
Website. Your IP address is also used to help identify you and to gather broad demographic
information.
- We may occasionally ask you to complete optional online surveys. These surveys may ask you
for your contact information and demographic information (like zip code, age, or income level). We
use this information to tailor your experience at the Neo Group App and/or Neo Group Website , providing
you with content that We think you might be interested in and to display content according to your
preferences. We use your Personal Information to send you promotional emails, however, we will provide
you the ability to opt out of receiving such emails from us. If you opt out, the Neo Group may still
send you non promotional emails, such as emails about the Services and your account on the Neo Group
App and/or Neo Group Website .
3. Sharing of information :
We may make your Personal Information and/or other Non-Personal Information available to Our
group entities/ affiliates to enable providing you Services. Please note that all information
shared with our group entities or affiliates or made available to our group entities or
affiliates will be governed by the terms of this Privacy Policy. In addition to the Personal
Information and in order to provide Services to you, we may also collect your Aadhaar, finger -
print details and signature solely for completing the account opening procedures and
authenticating your transactions on the Neo Group App and/or Neo Group Website . The act of
providing your Aadhaar is voluntary in nature and the Neo Group, hereby agrees and acknowledges
that Neo Group will collect, use and store such details in compliance with applicable laws and
this Privacy Policy.
We may also disclose your Personal Information to third party vendors, consultants, and other
service providers who work for the Neo Group, who are bound by contractual obligations to keep
such personal information confidential and use it only for the purposes for which we disclose it
to them. This disclosure may be required for us, for instance, to provide you access to Our
Services and process payments including validation of your bank accounts, to facilitate and
assist Our marketing and advertising activities/initiatives, for undertaking auditing or data
analysis, or to prevent, detect, mitigate, and investigate fraudulent or illegal activities
related to Our Services.The Neo Group may disclose your information, to the extent necessary:
- to comply with laws and to respond to lawful requests and legal process,
- to protect the rights and property of Neo Group, it’s users, and others, including to
enforce the Terms,
- in an emergency to protect the personal safety and assets of Neo Group, the users, or any
person. In such an event Neo Group is in no manner responsible for informing you or seeking your
approval or consent. We and Our group entities or affiliates (to the extent Personal Information
is collected by them) may, in compliance with applicable laws, share/transfer/assign all or any part
of your Personal Information and other information with any other business entity (ies), in the event
of a merger, sale, re-organization, amalgamation, joint ventures, assignment, restructuring of business
or transfer or disposition of all or any portion of Our business.
4. Disclaimer on specific event :
Neo Group shall be under no liability whatsoever in respect of
- any loss or damage arising directly or indirectly out of the decline of authorization
for any Transaction, on Account of you (Payer / Cardholder) having exceeded the pre-set limit
mutually agreed by us with our partner bank from time to time;
- any loss, notional or otherwise, incurred by you due to delays either at the bank, BSE
Star mutual fund, registrar and transfer agency and/or the AMC and/or due to any technical
issues faced by you on the Neo Group App and/or Neo Group Website ;
- rejection of your instructions by the bank, BSE Star MF, registrar and transfer agency
and/or AMC; and
- any NAV related issue, loss etc where orders are placed by you after the cut off time
prescribed which is specified on the Neo Group App and/or Neo Group Website . Queries/complaints
with respect to deduction of amount by the Neo Group prior to the SIP date.
- Neo Group App Neo Group Website restrictions imposed on "SMS stocks" as per its
internal policy
- Processing of instructions authenticated by your login credentials, non-availability or
non-accessibility of the Neo Group App and/or Neo Group Website , telephone(s), or office(s) of Neo
Group and its group entities/affiliates incase of circumstances beyond their control.
5. Intellectual Property Rights, Trademarks and Copyright:
Neo Group App and Neo Group Website and all information, content, materials, products including,
but not limited to text, content, photographs, graphics, texts, video and audio content and
computer code ("Content") on the Neo Group App and/or Neo Group Website are the property of Neo
Group and is either owned and controlled by the Neo Group or any other third party or partner
(where applicable). The trademark, trade names and logos that are used and displayed on Neo
Group App and Neo Group Website , and the design, structure, selection and feel and arrangement
of the Content are the properties of Neo Group and / or other third parties and/ or our / Third
Party’s partners and are protected by copyright, patent and trademark laws and other various
intellectual property rights either in the favour of the Neo Group, or third party’s from whom
the appropriate permissions have been taken under applicable laws. Nothing contained on this Neo
Group App and/or Neo Group Website should be construed as granting of any license to you or any
right to you to use any Trade Marks, Trade Names, Logos and any other IPs (Intellectual
Property) displayed on Neo Group App and Neo Group Website . We retain all proprietary rights on
Neo Group App and Neo Group Website . Users are prohibited from using the same without written
permission of owner as deemed essential. Without the prior written consent of Neo Group no part
of any materials on Neo Group App and Neo Group Website may be modified, reproduced, copied,
stored, transmitted, distributed, used for creating works or used in any other way for
commercial or public purposes.
Further, you understand and accept that all information, except your personal information and other
data submitted by you for the purposes of transacting on the Neo Group App and Neo Group Website
, through the Neo Group App and Neo Group Website shall be deemed the property of the Neo Group,
and the Neo Group shall be free to use any ideas, concepts, know-how or techniques provided by you
on the Neo Group App and/or Neo Group Website , in any manner whatsoever. On initiating a contact
or query through the Neo Group App and Neo Group Website , you agree to be contacted by the Neo Group
or any other entities with whom the Neo Group has entered into an arrangement for the provisions
of Services to you.
6. Refund Policy:
Refunds of payments made, if any, for using Neo Group App or any other services of Neo Group shall be done as per the extant policies of the Group entities from time to time.
7. Disclosure of Customer Information:
Neo Group shall not deliberately disclose customer's personally identifiable information to any unauthorized third person. Save and except where such information shall be disclosed in good faith and for the purpose of law for the time being in force or to protect the rights and property of Neo Group. However, Neo Group has a right or duty to disclose or is permitted or compelled to so disclose such information by law, for the time being in force. For example, Neo Group may share/provide information with/to judicial bodies and regulatory authorities who have jurisdiction over Neo Group.
8. Children, Minors:
This Neo Group App and Neo Group Website are not intended for use by children and minors without supervision of their Parents/Guardians. Parents/Guardians are requested to ensure that Personal Information is not provided by minors.
9. Security of Data:
Neo Group will continuously endeavour to ensure that Personal Data shall be used in line with
all applicable data protection laws. Your information will be kept secured with restricted
access according to the ‘need to know’ principles.
Neo Group or its authorized agents shall not retain or store any information for longer than is required
for the purposes except when the information may lawfully be used or is otherwise required under
any other law for the time being in force.
The information collected shall be used for the purpose for which it has been collected.
We cannot however ensure or warrant the security of any information you transmit to the Neo Group
or guarantee that your Personal Information and/or other Non-Personal Information provided for availing
the Services or accessing the Neo Group App and/or Neo Group Website will not be accessed, disclosed,
altered or destroyed by a breach of any of our security measures and safeguards. It is further clarified
that you have, so long as you access and/or use the Neo Group App (directly or indirectly) and/or
Neo Group Website , the obligation to ensure that you shall at all times, take adequate physical,
managerial, and technical safeguards, at your end, to preserve the integrity and security of your
data which shall include and not be limited to your Personal Information.
By agreeing to avail the service offered by Neo Group you have agreed to the collection and use of
your Sensitive Personal Data or Personal Information by Neo Group.
10. Right to Opt Out:
You always have the right to refuse or withdraw your consent to share/disseminate your Sensitive Personal Data or Personal Information by contacting the customer care. However, in such an event, you would no longer avail the services of Neo Group. The withdrawal of consent shall not affect the lawfulness of processing of your data based on consent before its withdrawal. Thus, opt out request would not be applicable to the correspondence and communications already initiated by Neo Group.
11. Communications:
When you use the Neo Group App and/or Neo Group Website or send emails or other data,
information or communication to us, you agree and understand that you are communicating with us
through electronic records and you consent to receive communications via electronic records from
us periodically and as and when required. We may communicate with you by SMS and/or E-mail or
through WhatsApp or by such other mode of communication, electronic or otherwise. You hereby
expressly agree to receive communication (including transactional messages) through said modes
of communications from the Neo Group.
Neo Group reserves a right to create any Whatsapp groups ("Groups") through its representatives (hereinafter
referred to as "Group Admin") who are expressly authorized to control, monitor and administer the
Groups on its behalf.
The Group Admin reserves the right at all times to determine, in its sole discretion, whether the
content posted on the Group is appropriate and in compliance with these Terms of Use. The Group Admin
further reserves the right to remove any participant/member from the Group if it finds you or any
participant/member to have circulated/posted any content which is objectionable or improper for the
Groups or its participants and/or deemed to have violated the Terms of Use or for any reason whatsoever.
12. Log File Information Collected and Stored Automatically (Cookies):
Neo Group Website and Neo Group App may place and access certain Cookies on your device. Cookies are unique identifiers that we transfer to your device to enable our systems to recognise your device. We may also use relevant technologies to analyse traffic on Neo Group Website and Neo Group App to improve your user experience.
13. Updating or Reviewing Your Sensitive Personal Data or Personal Information:
You may upon written request to us review the sensitive personal data or information provided. Neo Group shall ensure that any personal information or sensitive personal data or information found to be inaccurate or deficient shall be corrected or amended as feasible.
14. Reasonable Security Practices for Protecting Information:
Neo Group uses commercially reasonable physical, managerial, and technical safeguards to
preserve the integrity and security of your personal information. Neo Group cannot, however,
ensure or warrant the security of any information you transmit to Neo Group and you do so at
your own risk. Once we receive your transmission of information, Neo Group makes commercially
reasonable efforts to ensure the security of our systems. However, please note that this is not
a guarantee that such information may not be accessed, disclosed, altered, or destroyed by
breach of any of our physical, technical, or managerial safeguards.
To protect your privacy and security, Neo Group shall take reasonable steps (such as requesting a
unique password) to verify your identity before granting you access to your account. You are responsible
for maintaining the secrecy of your unique password and account information, and for controlling
access to your email communications from Neo Group, at all times.
15. Links to Other Web Sites:
Neo Group App and Neo Group Website sometimes may have links to other website(s) or mobile applications. The privacy policies of these website(s) and mobile applications are not under our control. Once you leave our servers, use of any information you provide is governed by the privacy policy of the operator of the site/mobile application you are visiting. It is advisable to read their privacy policies for further information. Your browsing and interaction on any other Web site, mobile application including those that have a link on Neo Wealth Web site, Neo Group App is subject to that Web site's/mobile application’s own rules and policies. It is advisable to read their privacy policies for further information.
16. Notification Procedures:
Neo Group provides notifications, whether such notifications are required by law or are for marketing or other business-related purposes, to you via email notice, written or hard copy notice, or through conspicuous posting of such notice on our Neo Wealth App, as determined by Neo Group in its sole discretion. Neo Group reserves the right to determine the form and means of providing notifications to you, provided that you may opt out of certain means of notification as described in this Privacy Policy.
17. Changes to Our Privacy Policy:
Please note that this policy may change from time to time. If Neo Group changes its privacy
policies and procedures, Neo Group will post the revised Policy on Neo Group App to keep
you/users aware of what information Neo Group may collect, how Neo Group uses it and under what
circumstances Neo Group may disclose it. Changes to this Privacy Policy are effective when they
are posted on this page. Please visit our Neo Group App to keep yourself abreast of any changes
to this policy.
Certain sections or pages on this site may contain separate privacy policy, which is
in addition to this privacy policy. In the event of any conflict between the two, the additional
privacy policy will govern those sections or pages.
18. Queries and Complaints:
If you have any queries or complaints with respect to the Neo Wealth App, please feel free to
reach out to our Customer Care Department, the name and contact details of the Head-Customer
Care have been provided below:
Name: Nitesh Shah
Email id: neocare@neo-wealth.com
Designation: Vice President
In case of escalations, please reach out to :
compliance@neo-wealth.com
Neo Interactive Services Private Limited Is a Company incorporated under the Companies
Act, 2013.
CIN: U74999MH2022PTC390124
Officer Contact Number +91 22 66423600, Email Id- info@neo-group.com
Registered Office Address: Neo Interactive Services Private Limited, 903, 9th Floor, B
Wing, Marathon Futurex, N M Joshi Marg, Lower Parel (E), Mumbai, Maharahstra - 400013.
For any queries or complaints email at neocare@neo-wealth.com
Disclaimer - Please ensure you carefully read the Risk Disclosure Document as prescribed
by SEBI and our Terms of UseInvestment in securities market are subject to market risks, read
all the scheme related documents carefully before investing. The securities quoted are exemplary
and are not recommendatory. Registration granted by SEBI, membership of BASL and certification
from NISM in no way guarantee performance of the intermediary or provide any assurance of
returns to investors.
There is no assurance or guarantee that the objectives of the investments /investment
products / clients will be achieved. The users of this document are advised to consult their
legal, tax and financial advisers to determine possible legal, tax and financial or any other
consequences before making an investment decision. Past performance of the stocks/securities are
not indicative of future returns. The securities quoted, if any, are exemplary and are not
recommendatory. Nothing contained in this document is verified or approved by Securities and
Exchange Board of India (SEBI) or any other Regulators or any other Authorities. Anything
mentioned in this email or any material forming part of this email do not constitute any advice
or recommendation of the same and Neo Group or it’s Associates, Affiliates, Employees,
Directors, Promoters, Shareholders may or may not have any present / future positions or
interests in these stock(s)/sector(s)/products/services.
