Privacy Policy

1. Introduction

Goldmine Wealth Private Limited (“Company,” “we,” “us,” or “our”) operates the Goldmine Wealth Select mobile application (the “App”) available on Android (Google Play) and iOS (Apple App Store) platforms, and the associated back-office web portal (collectively, the “Services”).

This Privacy Policy explains how we collect, use, store, protect, and share your personal information when you use our Services. By downloading, installing, or using the App, you consent to the practices described in this policy.

Important: The Goldmine Wealth Select mobile app is a read-only application. You can view your financial data through the App, but all data entry, modification, and management is performed exclusively by your authorised wealth advisor through our secure back-office portal. The App does not allow users to create, update, or delete any data.

2. Information We Collect

2.1 Personal Information

The following personal information is collected and managed by your wealth advisor through our back-office portal on your behalf:

Full name and family member names
PAN (Permanent Account Number)
NRI (Non-Resident Indian) status
Household and family relationships
Risk profile classification

2.2 Financial Information

To provide you with a consolidated view of your wealth, we process the following financial data:

Category	Data Collected
Mutual Funds	Fund names, folio numbers, units held, invested amount, current value, returns
Direct Stocks	Stock names, quantity, purchase price, current market value
Fixed Deposits	FD details, maturity dates, interest rates, principal amounts
Bonds	Bond names, face value, coupon rates, maturity details
PMS (Portfolio Management Services)	Scheme names, invested amount, current value, returns
AIF (Alternative Investment Funds)	Fund names, commitment amount, current value, returns
Private Equity	Fund names, commitment amount, current value
Real Estate	Property identifiers, purchase value, current estimated value
Gold (including SGBs)	Holdings type, quantity, current value
Bank Accounts	Account identifiers, account type, balances
Insurance	Policy details, premium amounts, coverage information

2.3 Device & Technical Information

When you use the App, we may automatically collect:

Device type, model, and manufacturer
Operating system and version (Android/iOS)
App version number
Unique device identifiers
Biometric authentication capability (Face ID / fingerprint support — we do not store your biometric data; see Section 5)
Network connectivity status
Crash logs and error reports (via Sentry) for app stability improvement
App usage data (screens visited, session duration)

2.4 Authentication Data

Login credentials (email address and encrypted password)
Authentication tokens (stored securely on-device using platform-native secure storage)
Session information

2.5 Information We Do NOT Collect

We do not collect precise location data
We do not access your contacts, photos, camera, or microphone
We do not collect or store biometric data (Face ID / fingerprint data is processed entirely on your device by the operating system)
We do not collect any payment or credit/debit card information through the App
We do not use any advertising identifiers or tracking pixels

3. How We Use Your Information

We use the collected information solely for the following purposes:

Portfolio Display: To present your consolidated net worth, asset allocation, investment returns (including XIRR), and net-worth trend charts in the App
Family View: To display household-level wealth data and individual investor profiles within your family group
Asset Breakdown: To show detailed holdings grouped by asset class (Growth, Real Assets, Bank) with return calculations
Trend Analysis: To display historical net-worth trends over configurable time periods (1 month, 3 months, 6 months, 1 year, all time)
Authentication & Security: To verify your identity and secure access to your account, including biometric verification
App Performance: To monitor and improve app stability, diagnose crashes, fix bugs, and enhance user experience
Communication: To send important account notifications and updates through your wealth advisor
Legal Compliance: To comply with applicable laws, regulations, and legal processes

We do not use your personal or financial information for advertising, marketing to third parties, profiling, automated decision-making, or any purpose unrelated to providing our wealth management services.

We do not sell, rent, or trade your personal information to any third party. We may share your information only in the following limited circumstances:

Your Wealth Advisor: Your authorised wealth advisor accesses your data through our secure back-office portal to manage your portfolio and provide advisory services
Service Providers: With trusted third-party service providers who assist in operating our Services (e.g., cloud hosting infrastructure, error tracking/monitoring), subject to strict confidentiality agreements and data processing agreements
Market Data Providers: We receive market data (prices, NAVs) from third-party providers to display current values; your personal data is not shared with these providers
Legal Requirements: When required by law, regulation, subpoena, court order, or governmental authority under applicable Indian law
Protection of Rights: To protect the rights, property, or safety of our Company, our users, or others
Business Transfers: In connection with a merger, acquisition, reorganisation, or sale of assets, with appropriate notice to you and continued protection of your data
With Your Consent: With your explicit consent for any purpose not described above

5. Data Storage & Security

5.1 Data Storage

Your data is stored on secure cloud servers located in India
Financial data entered by your wealth advisor is maintained in our encrypted database systems
The App may cache limited data locally on your device to enable viewing when network connectivity is limited
Locally cached data on your device is stored using platform-native secure storage mechanisms

5.2 Security Measures

We implement industry-standard security measures to protect your data, including:

Encryption in Transit: All data transmitted between the App and our servers is encrypted using TLS 1.2 or higher (SSL/TLS encryption)
Encryption at Rest: Sensitive data stored on our servers is encrypted at rest
Secure Authentication: JWT (JSON Web Token) based secure token authentication with automatic token refresh and session management
Biometric Security: The App supports device-level biometric authentication (Face ID on iOS, fingerprint on Android) as an additional security layer. All biometric processing occurs entirely on your device through the operating system’s native APIs — we never receive, store, transmit, or have access to your biometric data
Secure On-Device Storage: Authentication credentials and tokens on your device are stored using platform-native secure storage (iOS Keychain / Android Keystore via Expo SecureStore)
Role-Based Access Control (RBAC): The back-office portal implements granular role-based access control ensuring only authorised personnel can access specific categories of your data
Immutable Audit Trail: All data modifications in the back-office portal are logged in an append-only, immutable event store for complete audit traceability
Regular Security Reviews: We conduct regular security assessments of our infrastructure and application

5.3 Data Retention

We retain your personal and financial information for as long as your account is active or as needed to provide our Services
Historical portfolio data is retained to enable trend analysis and reporting features
Upon termination of your advisory relationship, we retain data only as required by applicable laws and regulations (including SEBI guidelines and tax record-keeping requirements), after which it will be securely deleted or anonymised
You may request earlier deletion of your data subject to legal retention obligations (see Section 6)

5.4 Data Breach Notification

In the unlikely event of a data breach that affects your personal information, we will:

Notify affected users within 72 hours of becoming aware of the breach
Inform the relevant regulatory authorities as required by law
Take immediate remedial action to contain and mitigate the breach

6. Your Rights

Under the Digital Personal Data Protection Act, 2023 (DPDPA) and other applicable Indian laws, you have the following rights:

Right to Access: Request a summary of the personal data we hold about you and the processing activities performed on it
Right to Correction: Request correction of inaccurate, incomplete, or misleading personal data. Since the App is read-only, corrections are made through your wealth advisor via the back-office portal
Right to Erasure: Request deletion of your personal data, subject to legal and regulatory retention requirements
Right to Grievance Redressal: File a complaint with our Grievance Officer if you believe your data has been mishandled (see Section 12)
Right to Nominate: Nominate another individual to exercise your data rights in case of your death or incapacity
Right to Withdraw Consent: Withdraw your consent for data processing at any time by contacting us, which may affect your ability to use the Services

To exercise any of these rights, please contact us at wealth@goldmine.co.in or through your wealth advisor.

7. Cookies & Tracking Technologies

The Goldmine Wealth Select mobile app does not use:

Cookies
Web beacons or tracking pixels
Third-party advertising SDKs or trackers
Advertising identifiers (GAID/IDFA)
Cross-app tracking
Social media tracking tools

We use Sentry solely for crash reporting and application performance monitoring. Sentry collects only technical device metadata, stack traces, and session information needed to diagnose and fix application errors. No personally identifiable financial information is included in crash reports.

8. Third-Party Services

Our Services integrate with the following categories of third-party services, each bound by data processing agreements:

Service Category	Purpose	Data Shared
Cloud Infrastructure	Secure data hosting and processing	Encrypted application data
Error Monitoring (Sentry)	Crash reporting and app performance monitoring	Device metadata, error logs (no financial data)
Market Data Providers	Real-time and historical market prices for portfolio valuation	No personal data shared; we receive price data only
Push Notification Services (APNs/FCM)	Delivering app notifications	Device tokens only (no personal or financial data)

We do not embed any third-party analytics, advertising, or social media SDKs in the App.

9. Children’s Privacy

Our Services are not directed to individuals under the age of 18. We do not knowingly collect personal information from children or minors. If you are a parent or guardian and become aware that your child has provided us with personal information, please contact us at wealth@goldmine.co.in. If we become aware that we have collected personal information from a child without parental consent, we will take immediate steps to remove such information from our systems.

10. International Data Transfers

Your data is primarily stored and processed within India. In the event that your data needs to be transferred outside India for any processing purpose, we will ensure that:

Adequate safeguards are in place as required under the DPDPA and other applicable laws
The receiving jurisdiction provides a comparable level of data protection
Appropriate contractual protections (such as standard contractual clauses) are implemented
You are notified of any such transfer

11. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes:

We will update the “Last Updated” date at the top of this page
We will notify you through the App via an in-app notification or through your registered email address
Where required by law, we will seek your consent before applying material changes to data processing
Continued use of the App after notification constitutes acceptance of the updated policy

We encourage you to review this Privacy Policy periodically. The current version will always be available within the App and on our website at www.goldminewealth.co.in.

12. Contact Us

For any questions, concerns, or requests regarding this Privacy Policy or our data practices:

Goldmine Wealth Private Limited
Goldmine House, 4 Niranjan Nirakar Society,
Near Shreyas Crossing, Paldi,
Ahmedabad, Gujarat, 380007, India

Email: wealth@goldmine.co.in
WhatsApp: +91 90999 39172
Website: www.goldminewealth.co.in

13. Grievance Redressal

In accordance with the Information Technology Act, 2000, the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, and the Digital Personal Data Protection Act, 2023, we have designated a Grievance Officer.

If you have any complaints, concerns, or grievances about our data handling practices or this Privacy Policy, you may contact:

Grievance Officer
Goldmine Wealth Private Limited
Goldmine House, 4 Niranjan Nirakar Society,
Near Shreyas Crossing, Paldi,
Ahmedabad, Gujarat, 380007, India

Email: wealth@goldmine.co.in
WhatsApp: +91 90999 39172

We will acknowledge your complaint within 48 hours of receipt
We will investigate and resolve your complaint within 30 days of receipt
If you are not satisfied with our resolution, you may escalate your complaint to the Data Protection Board of India as established under the DPDPA

By downloading, installing, or using the Goldmine Wealth Select mobile application, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy. If you do not agree with this Privacy Policy, please do not use the App.

For users whose data is managed by a wealth advisor, your advisor will obtain your consent before entering your personal and financial information into our system.

App Store Data Safety / App Privacy Disclosures

Google Play Data Safety

Data Type	Collected	Shared	Purpose
Name	Yes	No	App functionality, Account management
Email address	Yes	No	App functionality, Account management
Financial info (investments, assets)	Yes	No	App functionality
App interactions	Yes	No	Analytics, App functionality
Crash logs	Yes	No	Analytics
Device or other IDs	Yes	No	Analytics, App functionality

All data is encrypted in transit: Yes
Users can request data deletion: Yes
Data is not shared with third parties for advertising or marketing

Apple App Privacy

Data Used to Track You: None

Data Linked to You:

Contact Info (email address)
Financial Info (investment accounts, other financial info)
Identifiers (user ID)

Data Not Linked to You:

Diagnostics (crash data, performance data)