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Privacy Policy

Effective date: 10 October 2026

This policy explains, in plain language, what personal information NavayaTrace collects, why we need it, who we share it with and the choices you have. It applies to this website and to the share recovery services we provide.

NavayaTrace Solutions Private Limited (“NavayaTrace”, “we”, “us”) is an independent service provider that helps investors and families with the recovery, transmission and regularisation of shares.

  • CIN: U70200KA2026PTC216335
  • Registered office: G08, A Block, SVS Signature, Seegehalli, KR Puram, Bangalore North, Karnataka 560049
  • Mumbai office: 91SpringBoard, Gate No 2, Plant No. 6, LBS Marg, opp. Vikhroli Bus Depot, Vikhroli West, Mumbai 400079
  • Email: biswajeet@navayatrace.com
  • Phone: +91 77602 11005

For the purposes of Indian data protection law, NavayaTrace is the “data fiduciary” for the personal information described in this policy.

We collect only what we need to respond to you and, if you engage us, to work on your case. What we need depends on your situation.

When you send an enquiry through this website: your name, phone number, email address, the service you are interested in, any company names you mention and any message you write.

When you engage us for a case, we may ask for:

  • Identity and address documents, such as your PAN and address proof, and the KYC details companies and registrars require.
  • Shareholding records, such as folio numbers, share certificate and distinctive numbers, dividend details and correspondence from companies or registrars.
  • Demat account and depository participant details, and the bank account details needed for shares and dividends to be credited to you.
  • Where shares belonged to someone who has passed away: documents such as a death certificate, nomination, will, succession certificate or probate, and details of legal heirs or nominees.
  • Signed forms, affidavits and indemnities required by companies, registrars or the IEPF Authority.

If you give us information about other people, such as other legal heirs, please make sure they know you are sharing it with us for this purpose.

When you visit this website: our website host automatically processes technical information, such as your IP address and browser type, to deliver the site and keep it secure. If you choose to accept optional analytics cookies, we also collect information about how the website is used through Google Analytics, as explained in section 3.

How you give us documents: you send documents to our official company email accounts or give them to us in physical (paper) form. We collect them to prepare your share recovery applications and related documentation.

This website uses Google Analytics, a website analytics service provided by Google, which we load through Google Tag Manager. Analytics is optional. It runs only if you select “Accept Analytics”. If you select “Reject Optional Cookies”, or do not make a choice, Google Tag Manager and Google Analytics are not loaded and no analytics information is sent to Google.

What we use analytics for: to understand how many people visit the website, which pages and sections they view, which of our buttons and contact links are used, and whether an enquiry was sent, so that we can improve the website. We do not use analytics for advertising, and advertising features are switched off.

What analytics may collect:

  • The pages you visit, the time of your visit and the website that referred you.
  • Information about your device and browser, such as device type, operating system, browser, screen size and language.
  • Your approximate location, such as your city or country, which Google works out from your IP address.
  • How you use the website, such as scrolling, clicks on our buttons and contact links, starting the enquiry form and successfully sending an enquiry.
  • A randomly generated identifier stored in a cookie, which lets Google Analytics recognise repeat visits from the same browser.

This information can be personal data, because it relates to a browser and device that may be linked to you. Our website does not send your name, phone number, email address, enquiry message, or any shareholding, identity or financial details to Google Analytics: the analytics events it sends are limited to fixed labels, such as which button was clicked, and we have switched off Google Analytics’ automatic detection of details such as email addresses and phone numbers.

Cookies used: if you accept analytics, Google Analytics sets two cookies on this website, _ga and _ga_JEHBSGSZ5G. They contain random identifiers. Google Analytics sets them to last up to two years, although some browsers shorten this (Chrome, for example, to 400 days). They are deleted earlier if you withdraw consent or clear them in your browser. We remember your cookie choice in your browser's local storage on this device (not in a cookie) for 12 months, after which we ask you again.

Changing your choice: you can accept, reject or change your choice at any time by selecting “Cookie Settings” at the bottom of any page. If you withdraw consent, Google Analytics stops collecting information from that point, and we delete the Google Analytics cookies for this website from your browser. Withdrawal does not affect information collected before it. You can also delete cookies in your browser settings.

Google and transfers outside India: Google provides the analytics service to us and may process analytics information on servers outside India. Google explains this in How Google uses information from sites or apps that use its services.

How long analytics information is kept: our Google Analytics account is set to keep event-level and user-level analytics data for 14 months, after which Google deletes it. Aggregated reports, which do not identify individual visitors, may be kept for longer.

  • To reply to your enquiry and understand your situation.
  • To check the status of your shareholding and tell you which documents your case needs.
  • To prepare your share recovery applications and related documentation, and to submit the required documents to the registrars and transfer agents (RTAs), companies and authorities involved, according to your instructions.
  • To follow up with the companies, registrars and authorities involved and keep you informed.
  • To manage our client agreement with you, including our professional fee.
  • To meet our legal obligations and to protect against fraud and misuse.

We process your information on the basis of your consent, which you give when you send an enquiry or engage us, and for other purposes permitted by law. You may withdraw your consent at any time by contacting us. If you do, we may no longer be able to work on your case, and withdrawal does not affect processing already carried out.

Share recovery cannot be done without sharing some information. We share only what each party needs for your case:

  • The company whose shares are involved, and its registrar and transfer agent (RTA).
  • Depositories and depository participants, for demat credits.
  • The IEPF Authority and other competent authorities, where a claim requires it.
  • Banks and other financial institutions, where needed for credits or verification.
  • Notaries, courts or other bodies, where a document must be attested or issued.
  • Google Workspace, which provides our official company email accounts. Documents and messages you send us by email are held there.
  • Service providers who help us operate, such as our website host and the provider that delivers emails from our website enquiry form, who process information only on our instructions.
  • Google, which provides our website analytics, but only if you accept analytics cookies (see section 3).

We may also disclose information where the law requires it. We do not sell your personal information.

Some of our service providers, including Google (for Google Workspace and, if you accept analytics cookies, Google Analytics), our website host and our enquiry-form email provider, may process information outside India.

We store the documents you provide for your case as follows:

  • Paper documents are kept as paper files at our office.
  • Digital documents are stored on company computers.
  • Documents you send by email are also held in our Google Workspace company email accounts.

Access to stored client documents is restricted to the founders of NavayaTrace.

This website is served over an encrypted (HTTPS) connection. Enquiries sent through the website are delivered to our team by email and are not stored in a website database.

We will notify affected individuals and the authorities of a personal data breach as required by law.

We keep personal information only for as long as we need it for the purposes in this policy, or for longer where the law requires it.

When your share recovery is successfully completed:

  • We return to you any original paper documents we hold.
  • We delete, immediately, the digital copies of your documents stored on our company computers and the copies held in our company email accounts.
  • We keep any records that we are legally required to preserve, for the period the law requires, and use them only for that purpose.

Enquiries that do not go ahead, and cases that are unsuccessful or unresolved: we do not currently have a fixed retention period for this information. We keep it only for legitimate operational and legal purposes, such as dealing with your enquiry, continuing or closing your case, answering questions about it and meeting our legal obligations, and we delete it when it is no longer needed for those purposes.

Information held by others: documents and information we have submitted to RTAs, companies, depositories, authorities or other recipients for your case are held by them under their own rules and legal obligations. We cannot delete information held by them.

Subject to applicable law, you may ask us to:

  • Give you a summary of the personal information we hold about you and how we use it.
  • Correct, complete or update your information.
  • Erase your information, where we no longer need it and the law does not require us to keep it.
  • Nominate another person to exercise your rights if you die or become unable to do so.
  • Withdraw consent you have given. For analytics cookies, you can do this at any time through “Cookie Settings”.

To make a request, email our Privacy and Grievance Officer at charchika@navayatrace.com (see section 9), or call +91 77602 11005. We may need to verify your identity before acting on a request. We will respond within the time required by law.

Our Privacy and Grievance Officer handles questions, requests and complaints about personal information:

  • Name: Charchika Prasad Mishra, Co-Founder — Data & Compliance
  • Email: charchika@navayatrace.com

If you are not satisfied with our response, you may approach the Data Protection Board of India once it is able to receive complaints under the Digital Personal Data Protection Act, 2023.

Our website and services are intended for adults. Where a case involves shares inherited by a minor, we deal with the minor's parent or lawful guardian.

We may update this policy from time to time. The latest version will always be available on this page, with its effective date.

See also our Terms of Use.