Privacy Policy

Last Updated: January 1, 2025

Your Privacy is Our Priority

At Protocall, we are committed to protecting your personal information and your right to privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our platform.

1. Introduction

Welcome to Protocall's Privacy Policy. This policy describes how Protocall ("we," "us," or "our") collects, uses, and shares your personal information when you use our website, mobile applications, and services (collectively, the "Platform").

By accessing or using the Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, use, and disclosure of your personal information as described herein.

If you do not agree with our policies and practices, please do not use our Platform.

2. Information We Collect

We collect several types of information from and about users of our Platform:

2.1 Information You Provide to Us

Account Registration Information:

  • Full name and display name
  • Email address
  • Mobile phone number
  • Password (encrypted)
  • Profile picture (optional)
  • Trading experience level
  • Preferred investment sectors

Financial Information:

  • Payment card details (processed securely via payment gateways)
  • Bank account information (for payouts and withdrawals)
  • Demat account details (for Pledge Pool feature)
  • Investment portfolio data you choose to track
  • Transaction history

KYC and Verification Documents:

  • PAN card number and document
  • Aadhaar card details (as required by law)
  • Bank statements or proof of address
  • SEBI registration documents (for advisors)

User-Generated Content:

  • Messages in chat rooms and forums
  • Comments, posts, and recommendations
  • Poll votes and community feedback
  • Reviews and ratings
  • Support inquiries and correspondence

2.2 Information Collected Automatically

Usage Data:

  • Pages visited, features used, and time spent on the Platform
  • Links clicked and actions taken
  • Search queries and filters applied
  • Device information (type, operating system, browser)

Technical Data:

  • IP address and location data
  • Browser type and version
  • Device identifiers and characteristics
  • Cookies and similar tracking technologies
  • Log files and analytics data

2.3 Information from Third Parties

  • Social media profile information (if you connect social accounts)
  • Payment gateway transaction data
  • Market data providers and stock exchanges
  • Credit bureaus or financial verification services
  • Government databases for KYC verification

3. How We Use Your Information

We use the information we collect for the following purposes:

3.1 To Provide and Maintain Our Services

  • Create and manage your account
  • Process transactions and payments
  • Execute pledge pool orders and trading activities
  • Provide access to chat rooms, polls, and community features
  • Deliver personalized content and recommendations
  • Track your portfolio and send alerts

3.2 To Communicate With You

  • Send transactional emails (confirmations, receipts, notifications)
  • Respond to your inquiries and support requests
  • Send important updates about the Platform
  • Notify you about new features, events, and promotions
  • Send educational content and market insights

3.3 To Ensure Security and Compliance

  • Verify your identity and prevent fraud
  • Comply with KYC and AML regulations
  • Detect and prevent prohibited or illegal activities
  • Monitor for security threats and vulnerabilities
  • Enforce our Terms of Service and policies
  • Comply with legal obligations and regulatory requirements

3.4 To Improve Our Platform

  • Analyze usage patterns and user behavior
  • Conduct research and develop new features
  • Test and optimize Platform performance
  • Personalize your experience
  • Generate analytics and reports

3.5 For Marketing and Advertising

  • Send promotional communications (with your consent)
  • Display relevant advertisements
  • Conduct surveys and gather feedback
  • Run referral programs and campaigns

You can opt out of marketing communications at any time.

4. Sharing and Disclosure of Information

We may share your information in the following circumstances:

4.1 Service Providers

We share information with third-party service providers who perform services on our behalf:

  • Payment processors: Razorpay, Stripe (for payment processing)
  • Cloud hosting: AWS, Google Cloud (for data storage and hosting)
  • Email services: SendGrid, AWS SES (for transactional emails)
  • Analytics providers: Google Analytics (for usage analytics)
  • Customer support: Help desk software providers
  • SMS providers: For OTP and notifications

4.2 Business Partners

  • SEBI Registered Advisors: When you subscribe to advisor services
  • Brokers: For executing trades through Pledge Pool
  • Market data providers: For real-time stock information
  • Event organizers: When you register for events

4.3 Legal and Regulatory Requirements

We may disclose your information if required by law or to:

  • Comply with legal processes (subpoenas, court orders)
  • Respond to government or regulatory requests
  • Enforce our Terms of Service
  • Protect our rights, property, or safety
  • Prevent fraud or illegal activities
  • Comply with SEBI, RBI, and other regulatory bodies

4.4 Business Transfers

If Protocall is involved in a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction. We will provide notice before your information becomes subject to a different privacy policy.

4.5 With Your Consent

We may share your information with third parties when you give us explicit consent to do so.

4.6 Aggregated or De-identified Data

We may share aggregated or de-identified information that cannot reasonably be used to identify you for research, analytics, marketing, or other purposes.

5. Data Security

We implement industry-standard security measures to protect your personal information from unauthorized access, disclosure, alteration, and destruction.

5.1 Security Measures

  • Encryption: We use SSL/TLS encryption for data transmission
  • Data encryption at rest: Sensitive data is encrypted in our databases
  • Secure authentication: Passwords are hashed and salted
  • Two-factor authentication: Available for enhanced account security
  • Regular security audits: We conduct periodic security assessments
  • Access controls: Strict internal policies limit data access
  • Firewall protection: Network-level security measures
  • Intrusion detection: Monitoring for suspicious activities

5.2 Payment Security

Payment information is processed through PCI-DSS compliant payment gateways (Razorpay, Stripe). We do not store complete credit card numbers on our servers.

5.3 Your Responsibility

You are responsible for:

  • Maintaining the confidentiality of your password
  • Restricting access to your devices
  • Logging out after using the Platform on shared devices
  • Notifying us immediately of any unauthorized access

Important: No method of transmission over the internet or electronic storage is 100% secure. While we strive to protect your information, we cannot guarantee absolute security.

6. Data Retention

We retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.

6.1 Retention Periods

  • Account information: Until you request deletion or close your account
  • Transaction records: 7 years (as required by Indian tax laws)
  • KYC documents: 5 years after account closure (regulatory requirement)
  • Communication records: 3 years for support and dispute resolution
  • Usage logs: 90 days for security and analytics purposes
  • Marketing data: Until you opt out or request deletion

6.2 Account Deletion

When you delete your account, we will delete or anonymize your personal information, except where we are required to retain it for legal, regulatory, or legitimate business purposes.

7. Your Privacy Rights

You have the following rights regarding your personal information:

7.1 Right to Access

You can request a copy of the personal information we hold about you. You can access most of your information directly through your account settings.

7.2 Right to Correction

You can update or correct inaccurate personal information through your account settings or by contacting us.

7.3 Right to Deletion

You can request deletion of your personal information, subject to certain legal and regulatory exceptions. To delete your account, go to Profile → Settings → Delete Account.

7.4 Right to Object

You can object to certain processing of your personal information, such as direct marketing.

7.5 Right to Data Portability

You can request a copy of your data in a structured, machine-readable format.

7.6 Right to Withdraw Consent

Where we rely on your consent to process your information, you can withdraw consent at any time.

7.7 How to Exercise Your Rights

To exercise any of these rights, you can:

  • Update your information in Profile settings
  • Email us at privacy@protocall.in
  • Contact our Data Protection Officer (details in Section 15)

We will respond to your request within 30 days. If we need additional time, we will notify you.

8. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to collect information about your browsing activities and to personalize your experience.

8.1 Types of Cookies We Use

  • Essential cookies: Required for the Platform to function properly
  • Performance cookies: Help us understand how you use the Platform
  • Functionality cookies: Remember your preferences and settings
  • Targeting cookies: Deliver relevant advertisements and content

8.2 Third-Party Cookies

We may allow third parties to place cookies for:

  • Analytics and measurement (Google Analytics)
  • Advertising and marketing (Google Ads, Facebook Pixel)
  • Social media integration

8.3 Managing Cookies

You can control cookies through your browser settings. However, disabling cookies may affect the functionality of the Platform.

For more information, see our Cookies Policy.

9. Third-Party Services

Our Platform may contain links to third-party websites, services, or applications that are not operated by us.

9.1 Third-Party Advisors and Services

When you interact with SEBI-registered advisors or other service providers on our Platform, their own privacy policies and terms will apply to the services they provide.

9.2 External Links

We are not responsible for the privacy practices of third-party websites. We encourage you to review their privacy policies before providing any information.

9.3 Social Media Integration

If you connect your social media accounts to Protocall, we may collect information from those platforms in accordance with your settings and their privacy policies.

10. International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence, including India and other countries where our service providers operate.

We ensure that appropriate safeguards are in place to protect your information when it is transferred internationally, including:

  • Standard contractual clauses approved by regulatory authorities
  • Privacy Shield certifications (where applicable)
  • Ensuring service providers meet adequate data protection standards

By using our Platform, you consent to the transfer of your information to countries that may have different data protection laws than your country of residence.

11. Children's Privacy

Our Platform is not intended for individuals under the age of 18. We do not knowingly collect personal information from children under 18.

If you are a parent or guardian and believe your child has provided us with personal information, please contact us at privacy@protocall.in, and we will delete such information from our systems.

To use our trading and investment features, you must be at least 18 years old and have the legal capacity to enter into binding contracts under Indian law.

12. Compliance with Indian Laws

12.1 Information Technology Act, 2000

We comply with the Information Technology Act, 2000, and the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011.

12.2 SEBI Regulations

As a platform facilitating investment-related services, we comply with SEBI regulations regarding the collection and use of investor information.

12.3 Prevention of Money Laundering Act (PMLA)

We maintain records and conduct KYC verification as required under the Prevention of Money Laundering Act, 2002, and related rules.

12.4 Data Localization

Critical personal data and payment information is stored on servers located in India, in compliance with RBI and data localization requirements.

12.5 Grievance Officer

In accordance with the Information Technology Act and Rules, we have appointed a Grievance Officer to address your concerns regarding data privacy. Contact details are provided in Section 15.

13. Financial and Trading Data

13.1 Portfolio Data

Investment portfolio data you enter into our Platform is stored securely and used solely for providing portfolio tracking, analysis, and alert services to you.

13.2 Trading Activity

Information about your trading activity through Pledge Pool is recorded for transaction processing, regulatory compliance, and dispute resolution.

13.3 Market Data

Real-time market data, stock prices, and financial information displayed on the Platform are sourced from third-party providers and are subject to their terms of use.

13.4 Payment Information

Payment card details are processed through PCI-DSS compliant payment gateways. We do not store complete card numbers on our servers. Only tokenized payment information is retained for recurring payments with your consent.

13.5 Demat Account Information

Demat account details provided for Pledge Pool are encrypted and stored securely. We use this information solely for facilitating trade execution through authorized brokers.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors.

14.1 Notice of Changes

We will notify you of material changes by:

  • Posting the updated Privacy Policy on this page
  • Updating the "Last Updated" date at the top
  • Sending an email notification to your registered email address
  • Displaying a prominent notice on the Platform

14.2 Your Continued Use

Your continued use of the Platform after changes become effective constitutes your acceptance of the revised Privacy Policy. If you do not agree to the changes, you should discontinue using the Platform and close your account.

14.3 Review Regularly

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information.

15. Contact Us

If you have questions, concerns, or complaints about this Privacy Policy or our data practices, please contact us:

Privacy & Data Protection

General Privacy Inquiries:

Email: privacy@protocall.in

Phone: +91-80-4567-8900

Data Protection Officer:

Name: [DPO Name]

Email: dpo@protocall.in

Grievance Officer (As per IT Act, 2000):

Name: [Grievance Officer Name]

Email: grievance@protocall.in

Phone: +91-80-4567-8901

Mailing Address:

Protocall Technologies Private Limited

Bangalore, Karnataka - 560001

India

Response Time:

We aim to respond to all privacy-related inquiries within 30 days.

For urgent security concerns or to report a data breach, please contact security@protocall.in immediately.

Your Privacy Matters

At Protocall, we are committed to protecting your privacy and handling your personal information with care and transparency. We continuously review and enhance our security measures to keep your data safe.

BY USING PROTOCALL, YOU ACKNOWLEDGE THAT YOU HAVE READ AND UNDERSTOOD THIS PRIVACY POLICY AND CONSENT TO THE COLLECTION, USE, AND DISCLOSURE OF YOUR INFORMATION AS DESCRIBED HEREIN.