Last updated: September 2026. This policy should be reviewed by your legal counsel against the Digital Personal Data Protection Act, 2023 and the rules made under it before publication.
1. Who we are
Redberyl Investment Managers LLP (“Redberyl”, “we”, “us”) is a portfolio manager registered with the Securities and Exchange Board of India under registration number INP000010238, with its principal place of business at K.A Complex, Door No. 25, 2nd Floor, Advaitha Ashram Road, Fairlands, Salem, Tamil Nadu 636004, India. For the purposes of the Digital Personal Data Protection Act, 2023, we are the Data Fiduciary in respect of the personal data described below.
2. What we collect
- Identity and KYC data: name, date of birth, PAN, Aadhaar-based or other officially valid documents, photograph, signature, nationality and tax residency, as required under SEBI and PMLA obligations.
- Contact data: postal address, email address and telephone numbers.
- Financial data: bank and demat account details, income range, net worth declarations, source of funds, and transaction and holdings data relating to your portfolio.
- Suitability data: investment objectives, horizon, risk tolerance and any restrictions you place on your mandate.
- Correspondence: emails, letters, meeting notes and, where recorded and disclosed to you, telephone calls.
- Technical data: IP address, browser type, pages visited and time spent, collected when you use this website.
3. Why we process it
- To on-board you as a client and to comply with KYC, anti-money-laundering and record-keeping obligations under the PMLA, 2002 and SEBI regulations.
- To manage your portfolio, execute transactions, and arrange custody, fund accounting and settlement.
- To report to you, and to report to SEBI, APMI, depositories, custodians and tax authorities as required by law.
- To respond to your enquiries and to redress grievances.
- To detect and prevent fraud, and to protect the security of our systems.
- To send you material you have asked for, such as quarterly letters. You may withdraw this consent at any time.
4. Legal basis
We process personal data on the basis of the consent you provide at on-boarding and, where applicable, for the “legitimate uses” recognised under the Digital Personal Data Protection Act, 2023 — in particular where processing is necessary to comply with a legal obligation, including obligations imposed on us by SEBI, the PMLA and the Income-tax Act.
5. Who we share it with
- SEBI-registered custodians, depository participants, fund accountants, brokers and bankers involved in operating your account.
- KYC Registration Agencies and the Central KYC Records Registry.
- Statutory and regulatory authorities, including SEBI, APMI, the Financial Intelligence Unit and tax authorities, where required by law.
- Auditors, legal advisers and professional advisers under a duty of confidentiality.
- Technology service providers who host or support our systems, under written data-processing terms.
We do not sell personal data, and we do not share it with third parties for their own marketing purposes.
6. Retention
We retain client records for the period prescribed by SEBI and the PMLA — currently a minimum of five years from the closure of the relationship or the completion of the transaction, and longer where litigation, an investigation or a regulatory direction requires it. Enquiry data from this website that does not result in a relationship is retained for XX months and then deleted.
7. Security
We apply reasonable security safeguards including access controls on a need-to-know basis, encryption of data in transit, logging and monitoring, periodic review of user access, employee confidentiality undertakings and a documented incident response process. No system is perfectly secure; where a personal data breach occurs, we will notify the Data Protection Board of India and affected individuals as required by law.
8. Your rights
- To obtain a summary of the personal data we hold about you and how it is processed.
- To have inaccurate or incomplete data corrected, updated or completed.
- To have data erased, where retention is no longer required for the purpose or by law.
- To withdraw consent, where processing is based on consent — noting that we may be unable to continue managing your portfolio if you withdraw consent to processing required by regulation.
- To nominate another individual to exercise these rights in the event of your death or incapacity.
- To grievance redressal in respect of any of the above.
To exercise any of these rights, write to our Data Protection contact at compliance@redberyl.in. If you are not satisfied with our response, you may complain to the Data Protection Board of India.
9. Cookies
This website uses only such cookies and local storage as are necessary for it to function — for example, remembering that you have acknowledged the entry notice for the current browsing session. If analytics, advertising or embedded third-party content are added, list each cookie, its purpose and its duration here, and implement a consent banner.
10. Changes
We may update this policy from time to time. The current version is always published on this page with the date it was last updated. Material changes will be notified to clients directly.
11. Contact
Redberyl Investment Managers LLP
K.A Complex, Door No. 25, 2nd Floor
Advaitha Ashram Road, Fairlands
Salem, Tamil Nadu 636004, India
compliance@redberyl.in · +91 97892 93087