Prepared By Shilpa Dadhich – Senior Manager, Compliance
Approved By Kartik Kini – Chief Operating Officer
Applicable From July 16, 2020
Next Review Date July 15, 2021

Waterfield Advisors is an Independent Multi-Family Office and Wealth Advisory Firm. Waterfield Advisors was founded to be a professionally managed, holistic services provider for family-owned businesses – addressing all their investment and non-investment needs (succession planning, corporate structuring, family governance and philanthropy).We provide users our services in agreement with the following terms of use.

We suggest you to go through our terms and conditions carefully before you make use of our services.

Terms of Use

Waterfield, a company incorporated under the Companies Act, 1956 and having its registered office at 142, 14th Floor, Maker Chambers VI, 220 Jamnalal Bajaj Marg, Nariman Point, Mumbai 400021, India and is registered with the Securities and Exchange Board of India (‘SEBI’) as an Investment Adviser under SEBI (Investment Advisers) Regulations, 2013 (‘IA Regulations’) vide registration INA000001811). Waterfield is in the business of providing investment advisory services to its clients

Terms and conditions apply to the access and use of the, Mobile Application “Waterfield Mobile Application”, including any other sub-domain or platform which is owned, developed, managed or operated by Waterfield, and/ or its affiliates (hereinafter referred to as “Application”) which enables you to trackyour investmentsin one Application.

By registering or clicking the “agree” button or installing the Application or by using the service in any manner, you agree to all of the terms and conditions contained herein. These terms of use (“Terms”) constitute a legally binding agreement between you and Waterfield and govern your use of the application and the information, offers, services, features, content, offered through the Application(“Services”). These Terms may be updated by Waterfield from time to time. Please note that if you are an individual you must be over the age of majority under the laws of your jurisdiction to enter into this Agreement otherwise, you are expressly prohibited from entering into this agreement, and should have your parent or guardian enter into this agreement.

Your using the Services in any way means that you agree to all of these Terms, and these Terms will remain in effect while you use the Services. These Terms include the provisions mentioned below, as well as those in the Investment Advisory Agreement and Privacy Policy.

  1. Except for your own personal and non-commercial use, you agree that you shall not copy, reproduce, sell, redistribute, publish, enter into a database, display, perform, modify, transmit, license, create derivatives from, transfer or in any way exploit any part of any information, content, materials, services available from or through the Application.
  2. You agree that you will not use the Application for any purpose that is unlawful or prohibited by these Terms. You also agree you will not use the Application in any manner that could damage, disable or impair the Application or interfere with any other party’s use, legal rights, or enjoyment of the Application.
  3. You acknowledge that the software and hardware underlying the Application as well as other Internet related software which are required for accessing the Application are the legal property of either Waterfield or its respective third-party vendors. The permission given by Waterfield to access the Application will not convey any proprietary or ownership rights in the above software/hardware. You agree that you shall not attempt to modify, translate, disassemble, decompile or reverse engineer the software/hardware underlying the application or create any derivative product based on such software/hardware.
  4. You understand and accept that not all the products and services offered on this Application are available in all geographic areas and you may not be eligible for all the products or services offered by Waterfield on the Application. Waterfield reserves the right to determine the availability and eligibility for any product or service offered on the Application.
  5. You understand and accept that Waterfield is not responsible for the availability and accuracy of content or other services on third party sites linked from the Application. You are aware that access of hyperlinks to other internet sites are at your own risk and the content, accuracy, opinions expressed, and other links provided by these sites are not verified, monitored or endorsed by Waterfield in any way. Waterfield does not make any warranties and expressly disclaims all warranties express or implied, including without limitation, those of merchantability and fitness for a particular purpose, title or non-infringement with respect to any information or services or products that are available or advertised or sold through these third-party platforms.
  6. Without prejudice to anything contained in the Terms, the Application does not warrant that, Application will be constantly available, or available at all; or the information on Application is complete, true, accurate or non-misleading.
  7. If performance is prevented, hindered or delayed by a Force Majeure event including any pandemic, Waterfield shall not be liable for any failure to perform any of its obligations under these terms and conditions or those applicable specifically to its services/facilities, and in such case its obligations shall be suspended for so long as the Force Majeure event continues. “Force Majeure Event” means any event, due to any cause beyond the reasonable control of Waterfield, including without limitations, unavailability of any communication systems, breach, or virus in the digital processes or payment or delivery mechanism, sabotage, fire, flood, explosion, acts of God, civil commotion, strikes or industrial action of any kind, riots, insurrection, war, acts of government, lockdown, computer hacking, unauthorized access to computer data and storage devices, computer crashes, malfunctioning in the computer terminal or the systems getting affected by any malicious, destructive or corrupting code or program, mechanical or technical errors/failures or power shut down, faults or failures in telecommunication etc.
  8. In no event, Waterfield or its contractors, agents, licensors, directors, employees, associates, partners or suppliers will be liable to You or any third party for any special, direct or indirect, incidental, consequential, punitive, reliance, or exemplary damages, liabilities, losses (including without limitation lost business opportunities, losses in investment products, lost revenues, or loss of anticipated profits or any other pecuniary or non-pecuniary loss or damage of any nature whatsoever) howsoever arising because of use of such Application.
  9. You agree to indemnify, save, and hold Waterfield, their affiliates, employees, officers, directors and partners harmless from any and all claims, losses, damages, and liabilities, costs and expenses, including without limitation legal fees and expenses, arising out of or related to: (i) Use or misuse of the Services / Application; (ii) any violation of this Agreement or applicable laws; or (iii) any breach of the representations, warranties, and covenants made by You herein; or (iv) any act, neglect, misconduct or fraud on your part; or (v) sharing and or disclosing the information disclosed hereunder; or (vi) Your violation of any law, rules or regulations or the rights (including infringement of intellectual property rights) of a third party. Waterfield or its affiliates, reserves the right, at your expense, to assume the exclusive defense and control of any matter for which you are required to indemnify Waterfield, their affiliates, employees, officers, directors and partners, including rights to settle, and you agree to cooperate with Waterfield’s defense and settlement of these claims. Waterfield will use reasonable efforts to notify You of any claim, action, or proceeding brought by a third party that is subject to the foregoing indemnification upon becoming aware of it.
  10. Additionally, by continuing using the Application or services of Waterfield you are confirming that:
    • You are 18 years of age or older and where you are acting as Guardian on behalf of a minor, you have the necessary authority to register/sign up for the services on behalf of the minor. If Waterfield learns that we have collected personal information from a person under age 18, we will delete that information as quickly as possible. If you believe that a person under 18 may have provided us with personal information, please contact us at [email protected]
    • You have read and understood the Privacy Policy published on the Application of Waterfield. The information you provide when you register on the Application is true and correct. In the event, your information is not accessible online, please contact us immediately at [email protected]
    • Waterfield may contact you by phone and/or E-mail and/or SMS or any other form of electronic communication in connection with your registration, advisory and transactions. [email protected]

Privacy Policy

  1. Our Commitment

We are governed by the provisions of applicable law in India including the Information Technology Act 2000 and the Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011 to maintain the privacy of your Personal Data.

Waterfield is a SEBI registered Investment Advisor (INA000001811) and acts as an intermediary for Investment Advisory services.

  1. Personal Data

Personal Data we may collect from you are as under:

  • Personal details (e.g. name, contact details including, residential address, date of birth, documents such as identity card / passport details / Aadhaar details / PAN / Voter ID / driving license, and / or education details) provided by you to us to avail various services from us.
  • Your details including transaction history, balances and payment details, for effecting transfer of monies through various payment channels facilitated by us.
  • Financial details (e.g. income, expenses, and / or credit history) needed as part of request for some of our products / services;
  • Images of documents / photos required to avail any of our products / services.
  • Voice recordings of our conversations with our customer care agent with you to address your queries / grievances;
  • Employment details (e.g. occupation, positions held, employment history, salary and / or benefits) as part of our record retention for credit / various product evaluations or as required under applicable law including Prevention of Money Laundering (Maintenance of Records) Rules, 2005
  • Specimen signature(s) or consent for processing of your instructions received by us through our various payment and delivery channels;
  • Opinions provided by you to us by way of feedback or responses to surveys;
  • Information obtained from your mobile device by way of using our application like device location, communication information including contacts and call logs, device information (including storage, model and mobile network), transactional and promotional SMS / Application notifications.

You hereby agree that, we may fetch or update your personal details from government agencies or regulated authorities like KYC Registration Agency’s, Central Registry of Securitisation Asset Reconstruction and Security Interest, Asset Management Company’s, Registrar and Transfer Agency’s, etc.

We store and process your Personal Data only in India.

  1. Sharing of Personal Data

We may share your personal information with Waterfield’s affiliate companies, as well as with companies, partners that provide services on behalf of Waterfield.

In various processes / submission of applications / availment of product offerings, we may seek your explicit consent to use / share your Personal Data.

We will share your data with competent / legal / statutory / regulatory agencies / authorities or partners / service providers acting on our behalf (as the case may be) in following cases:

  • Only for enabling the delivery of the products / provision of the services availed by you, strictly on a “need to know” basis and subject to applicable laws.
  • It is directed or required by legal / regulatory / statutory / governmental authorities under applicable laws / regulations though a legally obligated request.
  • It is required by financial institutions to verify, mitigate or prevent fraud or to manage risk or recover funds in accordance with applicable laws / regulations.

For the purpose of your investments happening through Waterfield, Waterfield acts as an intermediary. When you invest in any AMCs, you also become a customer of theirs. Your personal and investment information is available to AMCs / RTAs and may be their service providers. Waterfield will not have any control on the way this information is used by them.

  1. Usage of Personal Data

We use your Personal Data in our business operations for providing our or our partners’ products services and to perform, among other actions, the following:

  • To facilitate the transactions or report on these transactions;
  • To undertake research and analytics for offering or improving our services and their security and service quality;
  • To check and process your requests submitted to us for products/ services and/ or instructions or requests received from you in respect of these products / services;
  • To share with you, updates on changes to the products/ services and their terms and conditions;
  • To take up or investigate any complaints / claims / disputes;
  • To respond to your queries or feedback submitted by you;
  • To verify your identity for us to provide products / services to you;
  • To carry credit checks, screenings or due diligence checks as lawfully required by us;
  • To monitor and review services from time to time;
  • To undertake financial / regulatory / management reporting, and create and maintain various risk management models;
  • For conducting audits and for record keeping purposes;
  • For selective offers and promotions.

We also use your Personal Data to fulfill the requirements of applicable laws / regulations and / or court orders / regulatory directives received by us.

  1. Removal of Personal Data

You may disable or delete your account at any point of time by making and completing verification of such request to Waterfield at [email protected], subject to the applicable terms and conditions. With this we will no longer share your data with any new partners. However, we retain your Personal Data as long as the purpose for its usage exists, after which the same is disposed of by us except for any record retention required by applicable law including Securities and Exchange Board of India (Investment Advisers) Regulations, 2013.

The PMLA (Prevention of Money Laundering Act 2002) guidelines, Securities and Exchange Board of India (Investment Advisers) Regulations, 2013 require your transaction logs to be stored for a period of up to 10 years post the deletion of an account. In the event of the pendency of any legal / regulatory proceeding or receipt of any legal and / or regulatory direction to that effect, we may be suggested by the law of the land to retain your Personal Data for longer periods.

  1. Cookie Policy
  • Please note that a “cookie” is a small piece of information stored by a web server on a web browser so it can be later read back from that browser.
  • We may use cookie and tracking technology depending on the features offered.
  • No Personal Data will be collected via cookies and other tracking technology; however, if you previously provided Personal Data, cookies may be tied to such information.
  1. Link to other websites or apps

Our Application may contain links to other websites or apps which are not maintained by us. This privacy policy only applies to us. You are requested to read the other websites or apps’ privacy policies when visiting these websites.

  1. Reasonable Security Practices and Procedures

We take various steps and measures to protect the security of your Personal Data from misuse, loss, unauthorised access, modification or disclosure. Please do not share your login, password and OTP details with anybody.

  1. Contact Us

You may contact us on any aspect of this policy or for any support, discrepancies / grievances with respect to your Personal Data, by writing to us at:

Waterfield Financial and Investment Advisors Private Limited

142, 14th Floor, Maker Chambers VI,

220 Jamnalal Bajaj Marg, Nariman Point,

Mumbai 400021, India

Email:  [email protected]

CIN: U74900MH2012PTC234921

SEBI Reg. No. INA000001811

Non-Individual Investment Advisor

Principal Officer: Mr. Nimish Shah

Email:  [email protected]

Refer to our website www.waterfieldadvisors.co for the SEBI Office Address

Phone no: +91 22 6621 0700

  1. Policy Review and Updates

This policy will be reviewed by us as and when required and the same may change at any time. While we will make reasonable efforts to keep you posted on any updates to this privacy policy, to make sure that you are aware of any changes, we recommend that you review this policy periodically.

In this policy, the words “we”, “ours” and / or “us” refer to Waterfield Financial and Investment Advisors Private Limited. and “you” and / or “your” refer to our customers.