Niel & Ray collects and uses personal information in the ordinary course of business and is therefore responsible for ensuring that the handling and storage of your personal information is in compliance with all applicable data protection laws. This Privacy policy explains how your personal information may be held and used by companies within Niel & Ray. Note that information may be shared between Niel & Ray’s international subsidiaries.
If you have any questions or concerns regarding our Privacy policy, or how we process your information, please contact us via email at privacy@nielnray.com or by postal service at:
Niel & Ray Wealth Advisors
74 Russell House, Khar West, Mumbai 400052
In this policy, “personal information” means all of the non-public personal and financial information about you that we collect, use, share and store. Most of the information collected by us is information which you have provided to us directly, whether this is from you signing up online to receive information from us or by your providing information to us when becoming a client of ours.
Information we collect from you when you visit and/or request to receive information from our website:
- personal contact information (e.g. first name, family name, position in the company, company name, company email address, business phone number, business address, city, postcode and country);
- how you access and use our website or other digital services (e.g. your IP address, your location, the device and software being used, pages visited, content viewed, links and buttons clicked through); and
- information obtained from your mobile device may include coarse location, mobile phone number, mobile device type, and mobile device operating system version.
Information that we collect or generate about you includes:
- the Niel & Ray services or products which you have engaged with and our interactions with you;
- your visits to Niel & Ray websites including information collected through cookies that store technical information about the services that you use and how you use them.
If you are looking to become a client of ours, or are already a client of ours, in addition to the above, we may also collect or generate additional information about you. This includes:
- financial information associated with managing your account with us, including bank account numbers and account transactions;
- investment details including aims and/or objectives, and risk profile;
- regulatory requirements, such as country of tax residency, tax identification number, signature, death and marriage certificates, appointed power of attorney, appointed court of protection order, bankruptcy orders, change of name deed, and trust deed;
- information about other people you are financially linked to (e.g. your spouse) or who have an interest in or association with any of your accounts (e.g. where you have opened an account for the benefit of a child);
- new account information, including date of birth and/or age, city or country of birth, and nationality;
- employment status including whether you are employed, retired or receive benefits;
- proof of identification information, which may include a copy of your driver’s license, passport, or other appropriate identification documentation (depending on what you provide to us); and
- any other relevant information provided by you to us in correspondence, whether by email, written letter, or telephone call.
There may be some instances where we receive information about you from a third party. This includes:
- information received when you use an investment professional to make an application with us;
- information received from any fraud protection agency in relation to you, your account or any of your investments;
- background checks including information from social media; and
- events which you registered for and/or attended that featured a Niel & Ray investment product.
Niel & Ray may use information that cannot be linked to or identify a particular individual such as anonymized or aggregated information. This information is not considered personal information, and therefore, is not subject to this policy. This information is used to produce statistical research, reports, and other information that serves to enhance the products and services provided by us.
We may share your information within Niel & Ray (both in the India and internationally) for the purposes described above. All of our employees and contractors are required to follow our data privacy and security policies when handling personal information.
We may also share your personal information outside of Niel & Ray, only for the purposes described above and under the following circumstances.
Legal obligations: we share information (i) to the extent that we are required to do so by applicable law, by a governmental body or by a law enforcement agency, or for crime prevention purposes (including fraud protection); (ii) in connection with any legal proceedings (including prospective legal proceedings); or (iii) in order to establish or defend our legal rights.
Service providers: we share information with service providers who perform services for us (including cloud services, data storage, sales, marketing, investigations, and customer support). Our contracts with our service providers include commitments that they agree to limit their use of information and to comply with privacy and security standards at least as stringent as the terms of our Privacy policy. We will include instructions for “unsubscribing” in our marketing and/or research related email communications. In addition, if we contact you via telephone, mail, or email in relation to a survey, you can indicate to us that you would prefer not to receive any additional calls of that nature in the future or to participate in that particular survey.
The mobile app service does use third party services that may collect information used to identify you. Links to the privacy policies of the service providers used by the mobile app service are:
Third-party relationships: we share your information with affiliated third parties including financial institutions such as investment advisors and transfer agents. These third parties will be subject to appropriate data protection obligations and they will only use your information as described in our Privacy policy.
Consent: when you request that we share your information with someone else (for example if you engage the services of a professional advisor after you have become a client of ours and request that we provide information about your account to that professional advisor) or when we have otherwise obtained your consent. If we share information other than as permitted or described above, we will provide you with a choice to opt in to such sharing and you may choose to instruct us not to share the information.
Business sale: if we sell some or all of our business or assets we may need to disclose your information to a prospective buyer for due diligence purposes. If we are acquired by a third party, the information held by us about you will be disclosed to the third-party buyer.
We do not disclose, and do not intend to disclose, non-public personal or financial information to non-affiliated third parties with respect to persons who no longer maintain a relationship with Niel & Ray.
We do not sell your non-public personal or financial information without your consent.
Links to other sites
This Service may contain links to other sites. If you click on a third-party link, you will be directed to that site. Note that these external sites are not operated by us. Therefore, we strongly advise you to review the Privacy Policy of these websites. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.
Right to opt out
Niel & Ray is not in the practice of selling or distributing nonpublic information to third parties. If, in the future, our business directs us to do this, you will be notified and given the opportunity to opt out of having this information shared.
Updating and correcting your account information
You may submit a written request to us to correct or amend any information in our records. If you have shares held directly with Janus Henderson, you can correct, update or confirm your personal information anytime on nielnray.com by going to “My Account” and select “Account Profile”. Or, you can call a Niel & Ray Representative at +91 7777 043 999.