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Privacy Policy
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This policy explains what personal data ApexDelta collects, why, and the choices you have. [legal name of the company] is the Data Fiduciary for this data under the Digital Personal Data Protection Act, 2023 (DPDP Act).
1. What we collect
| Type | Examples | Where it comes from |
|---|---|---|
| Account details | Name, email, mobile number, password (stored only as a hash) | You, at sign-up |
| Trading profile | Segments you trade, option buyer or seller, daily loss limit, goals | You, in Settings |
| Broker credentials | Client ID, API key and secret, access tokens. For some brokers that require it: PIN or TOTP secret | You, when connecting a broker |
| Trading data | Positions, orders, trades, holdings, fund and margin summary, charges | Your brokers' APIs, and tradebooks you upload |
| Journal and support | Trade notes and tags, support tickets, feedback | You |
| Billing | Plan, invoices, payment status. Card, UPI and bank details are handled by our payment partner and never stored by us | You and [payment partner, e.g. Razorpay] |
| Technical data | IP address, device and browser type, log-in times, error logs | Your device |
2. Why we use it
- To run your account and show your dashboard, positions and insights.
- To keep broker connections working and alert you when one needs attention.
- To bill you and send invoices.
- To answer support tickets and improve the product.
- To keep the service secure and to meet legal obligations.
We process your data on the basis of your consent, given when you sign up and when you connect each broker, and for legitimate uses allowed under Section 7 of the DPDP Act, such as complying with law. We do not sell your data and do not use your trading data for advertising.
3. Broker credentials
Credentials are encrypted at rest and in transit, are used only to create read-only sessions with your broker, and are never shown to our staff in readable form. Disconnecting a broker deletes its stored credentials.
4. Who we share it with
- Your brokers, only to fetch your own data.
- Service providers that run the service for us under contract: [hosting provider], [email provider], [payment partner]. They may only use the data to provide their service to us.
- Authorities, when Indian law requires it.
5. Where it is stored and for how long
Data is stored on servers in [India / region]. We keep it while your account is open. After you close your account, we delete your personal and trading data within 30 days, except billing records that tax and accounting laws require us to keep.
6. Security
We use encryption, access controls, role-based staff permissions and activity logs. If a personal data breach occurs, we will inform the Data Protection Board of India and affected users as the DPDP Act and Rules require.
7. Your rights
You can: see a summary of the data we hold about you; correct or update it; ask us to erase it; withdraw consent at any time (this stops the related processing, and may mean we cannot provide the service); nominate a person to exercise your rights if you die or become incapacitated; and raise a grievance with us. Most of this can be done in Settings, or by writing to the Grievance Officer below. If you are not satisfied with our response, you may complain to the Data Protection Board of India.
8. Cookies
We use cookies and local storage that are needed to keep you signed in and remember your settings, such as theme. [List any analytics tools here, or state that none are used.]
9. Children
ApexDelta is not for anyone under 18, and we do not knowingly collect their data.
10. Changes
We will post updates here and email you about material changes.
11. Grievance Officer
[name], [grievance email], [registered address]. We acknowledge requests within 24 hours and respond within the time the law requires.