Draft for early access. Replace the bracketed details and have it reviewed by a lawyer before any public launch.

Privacy notice

Last updated: [date]. Data fiduciary: [operator name], [address]. Grievance contact: [name, email].

What we collect

• Account: name, email, mobile number, user ID, role, and for advisers optionally a firm name and SEBI registration number.
• Password: stored only as a salted one-way hash; we cannot read it.
• Portfolio data: portfolios, transactions, recommendations and notes entered by you or your adviser.
• Security records: sign-in times, the device description your browser reports, and account changes.

We do not collect PAN, Aadhaar, bank account or demat details.

Why we use it

To run your account, verify your email, secure sign-in with one-time codes, show you your portfolio, and keep an audit trail of changes. We do not sell your data or use it for advertising.

Who can see it

Clients see only the portfolios linked to them. Advisers see only their own clients. The operator can see platform data to run and support the service. Every request is checked on the server against the signed-in account.

Where it is stored

In the operator's Google account (Google Sheets and Apps Script), with sign-in codes sent by Gmail. Google may process data outside India under its own safeguards.

How long

Until your account is closed. After closure your personal details are removed; transaction records in a model portfolio may be kept by your adviser where they need them for their own records, and security logs are kept for up to [period].

Your rights

Under the Digital Personal Data Protection Act, 2023 you can ask to access, correct or erase your personal data, withdraw consent, and raise a grievance with us and then with the Data Protection Board of India. Write to [email].