Investor Resources

Privacy Commitment

W2D Finverse, AMFI Registered Mutual Fund Distributor (ARN-133132) and APMI Registered PMS Distributor (APRN01605), is committed to maintaining the privacy, confidentiality and security of personal information collected from investors and website visitors. This Privacy Policy explains how we collect, use, store, share and protect personal data in accordance with the Digital Personal Data Protection Act, 2023 (DPDPA), the Information Technology Act, 2000, the SEBI Master Circular for Mutual Funds dated 20-Mar-2026 and the data-sharing principles in the AMFI Master Circular for MFDs dated 14-Jan-2026.

Scope and Applicability

This policy applies to every person who interacts with W2D Finverse through this website, during client onboarding, Know Your Customer (KYC) verification, risk profiling and Mutual Fund or PMS transaction processing. It also binds our partners, staff and service providers who access or process client information on our behalf. By engaging with W2D Finverse or using this website you consent to the collection and use of your personal information as described here.

Information We Collect

• Personal details: name, address, date of birth, PAN, Aadhaar (for KYC), mobile number, email ID, bank account details, nomination details and investment preferences.
• Financial details: income range, family expenses, existing investments, risk profile responses, investment horizon, goals and transaction history.
• KYC documents: PAN copy, Aadhaar or address proof, photograph, cancelled cheque or bank statement, FATCA/CRS self-certification and UBO details for non-individual investors.
• Technical data: IP address, browser, device and cookie information when you visit this website. We do not collect data such as religion, caste or political affiliation, or any data not required for Mutual Fund and PMS distribution and regulatory compliance.

Purpose of Data Collection

Your data is used only to process Mutual Fund and PMS transactions; complete KYC and meet SEBI, AMFI, APMI and PMLA obligations; conduct risk profiling and suitability assessment; send transaction confirmations, account statements and service communications; respond to queries and complaints; meet regulatory reporting requirements; and improve this website. We do not use your data for any other purpose.

Data Sharing Rules

We share your data only with: Asset Management Companies (AMCs) / Mutual Fund Houses and Registrar and Transfer Agents (CAMS, KFintech) to process transactions; SEBI, AMFI and APMI on official request; AMC or AMFI appointed auditors during due diligence; KYC Registration Agencies (CVL KRA, CAMS KRA, NDML KRA) and CKYC for KYC verification; transaction platforms (NSE MF Invest Platform, BSE STAR MF, CAMS Edge 360, KFintech IRIS) for order processing; our back-office software provider for record maintenance under a confidentiality agreement; Portfolio Managers for PMS onboarding; and any other party only with your prior written consent. We do not sell, rent or share your personal or financial data with any marketing agency, advertising platform or unrelated third party.

Data Storage and Security

Digital records are stored on password-protected systems and cloud-hosted software with access restricted to authorised persons. Physical documents are kept in locked storage at our office in Vadodara. We use licensed anti-virus software, operating-system security controls and strong passwords. No client data is stored on personal devices. Transactions on the platforms are authenticated by the investor through OTP; W2D Finverse never asks for your password or OTP.

Data Retention and Disposal

Client records are retained for the period prescribed under the SEBI (Mutual Funds) Regulations, AMFI guidelines, PML Rules, 2005 (five years after the end of the relationship) and the Income Tax Act, 1961. After the retention period, physical records are shredded and digital records permanently deleted, with a disposal log maintained.

Your Rights under DPDPA 2023

You have the right to access your personal data held by us; to request correction of inaccurate or incomplete data; to request erasure, subject to regulatory retention; to withdraw consent at any time, which may affect our ability to continue services; to nominate a person to exercise these rights in the event of your death or incapacity; and to lodge a complaint with the Data Protection Board of India. To exercise any right, write to info@w2dfinverse.com. We respond within 30 days.

Cookies

This website uses cookies to remember preferences and analyse traffic. You can control cookies through your browser settings; disabling them may affect calculators and other features.

Third-Party Links

This website links to external sites such as AMC websites, SEBI, AMFI, SCORES and SMART ODR. W2D Finverse does not control and is not responsible for their content, privacy policies or security practices.

Changes to this Policy

We may update this Privacy Policy to reflect changes in our practices or in law. The latest version will always be available on this page.

Contact for Privacy Concerns

• Data privacy contact: Nikhil Karnik, Partner.
• Email: info@w2dfinverse.com.
• Phone: +91 98923 17777.
• Office: 401, Krisil Tower, Near Iscon Atria, Opp. Yash Complex, Gotri Main Road, Vadodara
• Business hours: Monday to Friday, 9:30 AM to 6:00 PM (IST), Saturdays – 9:30 AM to 1:00 PM, except public holidays.

Policy

This policy sets out how W2D Finverse onboards a new investor. It follows the SEBI KYC norms, the Prevention of Money Laundering Act, 2002 and PML Rules, 2005, the AMFI Master Circular for MFDs dated 14-Jan-2026 and the Digital Personal Data Protection Act, 2023.

Onboarding Steps

Rules We Never Break

• No transaction without valid KYC, PAN and FATCA/CRS certification.
• No cash accepted; no payment into any account other than the AMC / RTA / platform.
• No OTP, password or login credential is ever collected from an investor.
• KYC records are kept for five years after the end of the relationship.
• Suspicious transactions are reported to FIU-IND as per PMLA.
• Personal data is used only for the purposes stated in our Privacy Policy.

Your Rights

• Complete and accurate information about schemes (SID, SAI, KIM, Riskometer) before investing.
• Disclosure of all commission received by the distributor.
• Transaction confirmations and CAS from the RTAs.
• Risk profiling before any recommendation, and recommendations only within your risk category.
• To be told in writing when a request falls outside your risk category and why we decline to recommend it.
• To lodge complaints through our grievance mechanism, SEBI SCORES and SMART ODR.
• Privacy and data protection under DPDPA 2023, including access, correction and erasure subject to retention rules.
• To choose any distributor, change distributor or invest in Direct Plans directly with the AMC at any time.

Your Obligations

• Provide accurate personal, financial and KYC information and keep it updated.
• Read all scheme documents before investing.
• Answer the risk profiling questionnaire honestly and inform us of changes in your circumstances.
• Understand that all investments are subject to market risks.
• Keep your platform credentials and OTP confidential; retain copies of transaction records.
• Report any unauthorized transaction immediately.

Our Obligations

• Act in your best interest and follow the AMFI Code of Conduct for Intermediaries.
• Give complete and transparent information about schemes and risks.
• Disclose all commission and maintain a documented disclosure process.
• Conduct risk profiling and ensure every recommendation is suitable.
• Place transactions only after your confirmation, through authorised platforms.
• Keep your information confidential as per our Privacy Policy and DPDPA 2023.
• Acknowledge complaints within 3 working days and resolve within 15 working days.
• Never guarantee returns or make misleading statements.

Do’s

• Read the Scheme Information Document (SID), Statement of Additional Information (SAI) and Key Information Memorandum (KIM) before investing. The SID / SAI / KIM for all funds can be accessed from the SEBI’s website from the included link: https://www.sebi.gov.in/filings/mutual-funds.html
• Complete your KYC and quote PAN for every investment (for all holders).
• Provide FATCA/CRS self-certification and keep it updated (for all holders).
• Register nomination (or opt out in writing) in every folio.
• Verify that ARN-133132 appears on your application or order.
• Transact only through official platforms (NSE Invest) or AMC/RTA official channels, including CAMS Edge 360 or KFintech IRIS.
• Keep your mobile number, email and bank details updated in every folio.
• In case of more than one investor in a folio, ensure that at least one of contact details of each investor (mobile number and / or e-mail address) are uniquely referenced.

Don’ts

• Do not hand over cash to the Distributor. Payments are made only in favour of the scheme through a cheque, RTGS / NEFT / Bank Transfer or Net banking.
• Do not sign blank or incomplete forms or mandates.
• Do not act on promises of assured, guaranteed or indicative returns.
• Do not share OTP, passwords or login credentials with anyone.

Assessment

W2D Finverse assesses the risk profile of every investor before making any recommendation, as required by the AMFI Master Circular for MFDs dated 14-Jan-2026. The assessment measures the investor's ability and willingness to take investment risk.

Questionnaire

The investor completes a risk profiling questionnaire covering age, occupation, income stability, dependents, investment horizon, investment experience, reaction to market falls, return expectation, liquidity need and financial goals. Each question has five options scored 10 (highest risk-taking ability) to 2 (lowest risk-taking ability). The total risk score is out of 100, where higher the score, higher is the client’s risk taking ability.

Risk Categories

• Conservative
• Moderate / Balanced
• Moderately Aggressive
• Aggressive
• Very Aggressive

Suitability Check

Each risk category is mapped to permitted scheme categories and Riskometer levels in our Suitability Matrix. We recommend only schemes within the investor’s category. If an investor asks for a scheme outside the category, we explain why it is unsuitable in writing and do not recommend it. Existing holdings above the investor’s category are flagged in the High-Risk Holding Intimation with a recommended realignment.

Review

The risk profile is reviewed every year at the annual portfolio review and whenever the investor reports a change in income, goals, dependents or health. The reassessed profile replaces the earlier one and the portfolio is realigned where needed.

Records

The completed questionnaire, score, category, investor acknowledgement and every reassessment are kept in the client file for a period of five years after the end of the relationship.

Purpose

W2D Finverse recommends Mutual Fund schemes to investors based on their risk profile, goals and time horizon. This policy explains how schemes are selected, recommended and reviewed.

Understanding the Client’s Objective

We discuss each financial objective in detail, including its nature, time horizon, current estimated cost, appropriate inflation assumptions, resources already available and the additional corpus required. Reasonable return assumptions may be used for calculations; these are only calculation assumptions and are not represented as assured or guaranteed returns.

Determining the Investment Requirement

Based on the above assessment, we calculate the additional corpus required and determine whether it should be addressed through a lump-sum investment, systematic investments or a combination thereof, considering the client’s cash flows and liquidity.

Asset-Class and Category Selection

Investment horizon is an important consideration in determining broad asset allocation. As a guiding framework, shorter-term objectives are addressed through lower volatility money-market / debt categories, medium-term objectives through appropriate debt and/or hybrid categories, and longer-term objectives through hybrid and equity-oriented categories. These are broad guidelines and are not applied mechanically. The final selection also considers the nature and certainty of the goal, liquidity needs, tolerance for interim losses, existing portfolio and overall financial circumstances.

Risk Profiling

We undertake a documented risk-profiling exercise and classify clients under our internal five-level framework:

The risk profile of the client is evaluated alongside the investment objective and horizon and is not considered in isolation. The investor responds to the Risk Profile Questionnaire before the mutual fund investment recommendations are provided.

The Risk Profile Questionnaire contains questions seeking information on the client’s age, surplus income, goals that the client has planned for, expected growth in investments over a horizon of 5 to 10 years, time horizon for investments, asset mix comfort, reaction to a range of fall in equity markets, stability of source of income, etc. The total marks place the investor in one of five categories: Conservative, Balanced, Moderately Aggressive, Aggressive, and Very Aggressive.

Normally, we do not recommend a mutual fund scheme above the risk category of the client. In case the customer needs to take risk due to various factors including the corpus available for a particular goal and time of the fund requirement, we appraise the customer for taking additional risk (as compared to their risk profile) and we take necessary action to upgrade their risk profile, with proper disclosure of risks of the products that might be recommended to achieve the goal.

• Conservative (Risk profile score of 0 – 20)
• Balanced (Risk profile score of 21 – 40)
• Moderately Aggressive (Risk profile score of 41 – 60)
• Aggressive (Risk profile score of 61 – 80)
• Very Aggressive (Risk profile score of 81 – 100)

Scheme Suitability

For each recommendation, we evaluate the scheme’s Risk-o-Meter, portfolio composition, concentration, market-cap exposure, credit and interest-rate risks where applicable, liquidity characteristics, investment strategy and other relevant scheme information. We seek to ensure that the scheme’s risk characteristics are appropriate to the client’s ability and willingness to bear risk.

Internal Suitability Matrix

As an internal policy, we generally avoid equity-oriented schemes for Conservative clients. For Balanced clients, we generally prefer suitable debt, hybrid and diversified equity exposure and ordinarily avoid dedicated Mid and Small Cap funds. For Moderately Aggressive clients, we generally avoid dedicated Small Cap funds unless justified by the client’s overall circumstances and portfolio. Aggressive and Very Aggressive clients may be considered for a wider range of hybrid and diversified equity strategies, subject to suitability.

The suitability matrix that we follow for mapping the investor risk category and the investment horizon as a guiding principle is outlined below.

Scheme Selection Discipline

Thematic and sectoral funds are recommended selectively, considering their concentration risk. We generally prefer schemes with a meaningful history and do not normally participate in New Fund Offers merely on account of their being new. As an internal preference, we evaluate schemes after they have demonstrated at least two years of operating history, unless there is a specific reason to consider otherwise.

Overall, our approach is to match the appropriate asset allocation and scheme category to the client’s objective, time horizon and risk profile, rather than selecting schemes solely on past performance or returns. We maintain appropriate records supporting our recommendations and periodically review them as the client’s circumstances and objectives change.

Approved List

We maintain an approved list of schemes drawn from the AMCs we are empaneled with.

The approved list of schemes is reviewed every quarter on the following quantitative parameters that include the funds in a particular category and its official benchmark:

Commission rates play no part in product selection.

The list is reviewed every quarter.

• Point to Point performance as on quarter end
• Calendar years performance
• Calendar months performance (last 2 years)
• Rolling returns performance
• SIP performance
• Risk parameters
• Other parameters including age of the fund, AUM, Expense Ratios, Number of holdings, Market cap exposures, etc.

Recommendation

A recommendation is made only after risk profiling and only from scheme categories permitted for the investor’s risk category under the Suitability Matrix. Each recommendation is given in writing in the Portfolio Recommendation Letter, showing scheme, category, Riskometer, allocation, amount and mode, with the commission disclosure. The investor confirms in writing before any transaction is placed.

Information to Investors

For every recommended scheme we point out the investor to SID, SAI, KIM and latest Riskometer on the SEBI / AMC website. Comparisons are made only within the same SEBI category. Illustrations use an assumed return not exceeding 12% per annum.

Process for Reviewing Scheme Selection

Our scheme selection process is subject to ongoing monitoring and periodic review to ensure that recommended schemes continue to remain appropriate for the client’s investment objective, time horizon, risk profile and overall portfolio.

Periodic Review of Schemes

We periodically review schemes in our recommended universe, covering their investment objective and strategy, portfolio composition, asset allocation, market-cap exposure, credit quality and duration for debt schemes, concentration, liquidity, Risk-o-Meter, fund management changes and any material changes to the scheme or its investment strategy.

Performance Assessment

Scheme performance is evaluated over appropriate time periods against the relevant benchmark, category and peers. We do not rely solely on short-term returns; greater emphasis is placed on consistency across market cycles, downside management, portfolio characteristics and adherence to the stated investment mandate.

Fund Manager and AMC Review

Material changes in fund management, investment philosophy, portfolio construction or other relevant AMC processes are considered as part of the review. Significant changes that could alter the scheme’s risk-return characteristics may trigger a more detailed evaluation.

Risk and Portfolio Review

We assess whether the scheme’s current portfolio and risk characteristics remain consistent with the original rationale for its selection. Any significant change in concentration, credit risk, liquidity risk, volatility or other relevant risk factors is evaluated before continuing to recommend the scheme.

Client-Level Suitability Review

Scheme review is complemented by periodic client portfolio reviews. We reassess the client’s objectives, investment horizon, liquidity requirements and risk profile, particularly when there is a significant change in financial circumstances or an objective approaches its target date. A scheme considered suitable earlier is not automatically considered suitable indefinitely.

Trigger-Based Review

In addition to scheduled reviews, specific events may trigger an immediate review. These include significant changes in a scheme’s mandate or portfolio, change in fund manager, material deterioration in credit quality, sustained deviation from the stated investment strategy, significant changes in risk characteristics, regulatory developments or other material events. Similarly, significant changes in the client’s circumstances—such as a major change in income, job loss, serious illness, temporary disability or a significant change in financial commitments—may trigger an immediate review of the client’s portfolio and suitability.

Action Following Review

Where a scheme continues to meet our selection and suitability criteria, it remains in the recommended universe. Where concerns are identified, we may place the scheme under observation, stop fresh recommendations, identify an alternative scheme or, where appropriate, recommend a portfolio change after considering the client’s circumstances, tax implications and transaction costs.

Our review process is therefore not driven by short-term performance or market movements alone. The primary consideration is whether the scheme continues to be suitable for the intended objective and consistent with the client’s risk profile and overall portfolio. Reviews and significant decisions are appropriately documented to provide a clear rationale for continuing, modifying or discontinuing a recommendation.

Our Commitment

W2D Finverse addresses every investor complaint fairly, within fixed timelines and as per SEBI and AMFI guidelines. Every complaint is recorded in our Complaints Register.

How to Lodge a Complaint

Grievance contact person: Nikhil Karnik, Partner.

You may also use the Investor Complaint Form (link to download the complaint form) on this website.

Complaint Resolution Process

Escalation Matrix

Useful Links

• SEBI SCORES: https://scores.sebi.gov.in/
• SMART ODR: https://smartodr.in/
• AMFI: https://www.amfiindia.com
• SEBI: https://www.sebi.gov.in
• APMI: https://www.apmiindia.org