Compliance Hub
Privacy Policy
Our privacy notice under the Digital Personal Data Protection Act, 2023: what personal data we process, why, who processes it, how long we keep it, and your rights.
Document: Privacy PolicyVersion: 2.1Effective: 22 October 2026
1. Who we are (Data Fiduciary)
- Registered name: Investology Quant Data Services Private Limited
- Trade name: Investology
- Legal form: Private Limited Company
- SEBI Research Analyst registration: INH000029528
- Address: A-001, Ground Floor, Satsang-III Poonam Sagar Complex, Mira Road (East), Thane, Maharashtra 401107
- Phone: +91 90290 26474
- Email: support@investology.in
- Contact person (as registered with SEBI): Anish Achuthan Pillai
Investology Quant Data Services Private Limited (Investology) is the Data Fiduciary for the personal data described here, including data collected on its behalf on ra.investology.in.
We remain responsible for processing carried out by the service providers named in section 4.
2. What investology.in does not collect
investology.in never asks for your PAN, Aadhaar number or VID, date of birth, card details or UPI details. These are entered only on our onboarding portal ra.investology.in (Graphy) or on our partners' secure pages (Digio, the KRA and the payment gateway).
3. Personal data we process
| Data item | Source | Purpose | Lawful basis | Processors / recipients | Retention |
|---|---|---|---|---|---|
| Name, email, mobile (OTP-verified) | You, on Graphy | Account; contact verification; service communications; upload to the KRA as your own contact details | Legitimate use under section 7 of the DPDP Act, 2023 / compliance with SEBI and PMLA obligations | Graphy, KRA | [R1] |
| PAN, date of birth | You, on Graphy | KYC and PAN validation | Legitimate use under section 7 of the DPDP Act, 2023 / compliance with SEBI and PMLA obligations | Graphy, KRA (CVL KRA, to be confirmed), CKYCRR | [R1] |
| KRA-fetched KYC record (address, photo, KYC status) | KRA | KYC | Legitimate use under section 7 of the DPDP Act, 2023 / compliance with SEBI and PMLA obligations | KRA, CKYCRR | [R1] |
| Fresh-KYC documents (OVD, photo, signature, IPV/VIPV recording, where needed) | You | KYC | Legitimate use under section 7 of the DPDP Act, 2023 / compliance with SEBI and PMLA obligations | Graphy / KYC vendor (To be confirmed by Compliance Officer), KRA, CKYCRR | [R1] |
| Aadhaar number / VID | Entered only on Digio's eSign page | Aadhaar OTP eSign of the terms | Your consent to eSign | Digio; not stored by Investology | Digio's retention: To be confirmed by Compliance Officer |
| Signed T&C / MITC record (PDF, timestamp, audit trail) | Digio / Graphy | Proof of your consent before any service or fee (SEBI RA Regulations) | Legitimate use under section 7 of the DPDP Act, 2023 / compliance with SEBI and PMLA obligations | Digio, Graphy | [R1] |
| Payment transaction ID, amount, status (no card or UPI credentials) | Payment gateway via Graphy | Collect the fee; refunds | Legitimate use under section 7 of the DPDP Act, 2023 / compliance with SEBI and PMLA obligations | Payment gateway (To be confirmed by Compliance Officer), Graphy | [R3] |
| Invoice details (name, state, GSTIN if given) | You | GST tax invoice | Legal obligation (GST law) | Graphy | [R3] |
| Telegram username / ID | Telegram, when you join | Deliver research | Voluntarily provided | Telegram | While subscribed, then [R1] |
| Member sign-in: email or mobile, or Google name / email / profile photo | You | Sign in to the members area and check your plan | Voluntarily provided / consent | Supabase, Google (sign-in) | [R4] |
| Support and grievance messages (form, email, WhatsApp, Telegram) | You | Answer requests and handle grievances; SEBI records of interactions with clients and prospects | Legitimate use under section 7 of the DPDP Act, 2023 / compliance with SEBI and PMLA obligations | Email provider (To be confirmed by Compliance Officer), WhatsApp (Meta), Telegram | [R2] |
| Checkout acknowledgement (ACK reference, plan, document versions, time) | Your browser | Your own reference | Not applicable | Stays in your browser; not sent to us | Until you clear it |
| Analytics: pages viewed, device / browser, approximate location, GA client ID | Your browser | Count visits | Consent (opt-in) | Google Analytics | GA setting: To be confirmed by Compliance Officer |
| Technical logs: IP address, user agent | Hosting / CDN | Security; abuse prevention | Legitimate use under section 7 of the DPDP Act, 2023 / compliance with SEBI and PMLA obligations (security safeguards) | Hostinger, Cloudflare; Vercel only if the admin API is deployed | [R5] |
| IP address when fonts load | Your browser | Display fonts | Legitimate use under section 7 of the DPDP Act, 2023 / compliance with SEBI and PMLA obligations | Google Fonts | Google's terms |
Retention codes R1 to R5 are explained in section 7.
4. Processors and recipients
| Name | Role | Data | Where processed |
|---|---|---|---|
| Graphy (ra.investology.in) | Onboarding portal: account, KYC flow, consent, checkout, invoices, course access | Identity, contact, KYC, consent, payment and invoice records | To be confirmed by Compliance Officer |
| KRA (CVL KRA, to be confirmed) and CKYCRR (CERSAI) | KYC registration agencies | KYC record | To be confirmed by Compliance Officer |
| Digio | Aadhaar OTP eSign of the client agreement | Aadhaar / VID (on Digio only), signed document, audit trail | To be confirmed by Compliance Officer |
| Payment gateway (To be confirmed by Compliance Officer) | Payment processing for Graphy checkout | Payment details you enter on the gateway; transaction status | To be confirmed by Compliance Officer |
| Supabase | Member sign-in and members area | Email or mobile, Google profile (if used), plan status | To be confirmed by Compliance Officer |
| Analytics (only with consent), Google sign-in (only if you choose it), web fonts | Analytics data; Google profile; IP address | To be confirmed by Compliance Officer | |
| Hostinger, Cloudflare | Website hosting and CDN | Technical logs | To be confirmed by Compliance Officer |
| Telegram | Research delivery channel | Telegram username / ID | To be confirmed by Compliance Officer |
| WhatsApp (Meta) | Support messages you send us | Mobile number, messages | To be confirmed by Compliance Officer |
We also share data with regulators and authorities when the law requires it: SEBI, BSE (as the Research Analyst Administration and Supervisory Body), FIU-IND and law enforcement agencies.
We do not sell your personal data.
4A. TradeBook, the members’ trading journal
TradeBook at /app is a personal trading journal. How it handles your data:
- Stored on your device: today, the trades, journal entries and settings you enter are kept in your browser's storage on your own device. They are not sent to Investology. Clearing your browser data deletes them.
- Cloud sync (planned): we intend to offer optional sync to our database. This notice will be updated before it is introduced, and it will only apply if you turn it on.
- Google Drive backup (optional): if you connect Google Drive, backups of your TradeBook data are written to a private application folder in your own Google Drive account. You can disconnect at any time.
- Your AI provider (optional): you may add your own API key for an AI provider (Gemini, OpenAI or Groq). The key is kept in your browser. When you use an AI feature, the relevant trade and journal context is sent directly to the provider you chose, under that provider's terms and privacy policy.
- Telegram (optional): if you connect a Telegram bot, its bot token and chat details are stored so TradeBook can send messages to you.
4B. "Notify me" and browser notifications
- “Notify me” on the plans page (optional): if you leave your email to hear when a plan opens, we keep that email and the plan you chose, with your consent, only to send you one email when it opens. It is deleted 30 days after that email. Only our principal officer can read the list.
- Browser notifications for members (optional): if you switch them on, your browser gives us a notification address (an endpoint and keys from your browser's push service) linked to your account, so we can send call alerts to that browser. Switch them off at any time; the address is deleted then, or when the push service reports it is no longer valid.
5. Aadhaar
- Using Aadhaar is optional and voluntary. It is used only for Aadhaar OTP eSign of the client agreement through Digio.
- Investology does not store your Aadhaar number.
- If any document showing your Aadhaar number is needed, mask the first 8 digits.
- Never send your Aadhaar number, Aadhaar card image, PAN image or OTPs on WhatsApp, Telegram or email.
- Investology will never ask for your login credentials or OTPs.
- Alternative to Aadhaar eSign: To be confirmed by Compliance Officer
6. Communications
- Service communications we must send: OTPs, KYC and eSign status, invoices, renewal and expiry notices, research delivery, regulatory notices and changes to terms.
- Marketing: sent only with your separate opt-in, and you can opt out at any time. Current status: To be confirmed by Compliance Officer
Accepting the client agreement does not opt you in to marketing.
7. How long we keep data
| Code | Records | Retention |
|---|---|---|
| R1 | KYC, client register, signed T&C / MITC and eSign records | At least 5 years after the relationship ends or the account closes, whichever is later. Longer while a dispute, investigation or suspicious transaction report is open, or as SEBI directs (SEBI RA Regulations; PMLA rules). |
| R2 | Records of interactions with clients and prospects | 5 years, from first interaction until services end (SEBI RA Master Circular). |
| R3 | Payment and GST records | The period GST law requires: To be confirmed by Compliance Officer |
| R4 | Member sign-in account | Until you ask us to delete it, except records we must keep under R1 to R3. |
| R5 | Security and processing logs | At least 1 year (DPDP Rules, 2025). |
Erasure requests cannot override these legal retention periods; we will tell you what we must keep and why.
8. Cookies and browser storage
investology.in uses a small amount of browser storage that the site needs to work. Google Analytics cookies are used only if you choose Accept in the cookie banner; until then no analytics script is loaded.
| Name | Type | Set by | Purpose | Category | Duration |
|---|---|---|---|---|---|
investology.cookie-consent.v1 | localStorage | investology.in | Remembers your cookie choice | Strictly necessary | Until you clear it |
theme | localStorage | investology.in | Remembers light or dark theme | Strictly necessary (preference) | Until you clear it |
sb-<project>-auth-token | localStorage | Supabase | Keeps you signed in to the members area (only if you sign in) | Strictly necessary | Until you sign out |
investology.onboarding.ack.v1 | localStorage | investology.in | Your checkout acknowledgement reference; stays on your device | Strictly necessary | Until you clear it |
_ga | Cookie | Google Analytics | Distinguishes visitors; set only after you choose Accept | Analytics | Google's default, up to 2 years (to be verified) |
_ga_<id> | Cookie | Google Analytics | Keeps session state; set only after you choose Accept | Analytics | Google's default, up to 2 years (to be verified) |
| Cookies on ra.investology.in | Cookie | Graphy | Set under Graphy's own settings | To be confirmed by Compliance Officer | To be confirmed by Compliance Officer |
Rejecting analytics deletes Google Analytics cookies from this site.
9. Your rights
- Access a summary of your personal data and of who it has been shared with (section 11).
- Correction, completion, updating and erasure of your data (section 12), subject to the retention periods in section 7.
- Grievance redressal (section 13).
- Nominate a person to act for you after death or incapacity (section 14).
- Withdraw consent at any time, as easily as you gave it (section 6(4)):
- Analytics: instantly, through Cookie settings.
- Consent given for the service: by email. Withdrawal does not affect processing done before it, and may end the service, with refunds under the Refund Policy.
To make a request, write to support@investology.in from your registered email or mobile with the subject "Data request". We verify you against your registered contact details and will never ask for Aadhaar or OTPs.
Response time: To be confirmed by Compliance Officer
10. Privacy grievances and the Data Protection Board
- Grievance Officer: To be confirmed by Compliance Officer
- Email: pillai@investology.in
- Phone: +91 90290 26474
- Address: A-001, Ground Floor, Satsang-III Poonam Sagar Complex, Mira Road (East), Thane, Maharashtra 401107
Please raise privacy grievances with us first (section 13(3)). If you are not satisfied, you may complain to the Data Protection Board of India.
Complaints about our research service follow the SEBI escalation matrix: see Complaints & Escalation.
11. Security and breaches
- HTTPS everywhere.
- Card and UPI details never touch investology.in.
- Admin tools need a protected token and keep an access-grant log.
- Access to client data is limited to support staff.
If a personal data breach affects you, we will inform you and the Data Protection Board without delay and as the DPDP Rules 2025 require. We will also inform CERT-In where applicable.
12. Age
Our research services are only for individuals aged 18 or over. We do not knowingly process children's data or track children. If you believe a minor has given us data, contact us and we will delete it, subject to the law.
13. Use of AI tools
Whether AI tools are used in our research, and whether any client personal data is processed by an AI provider: To be confirmed by Compliance Officer
14. Changes to this notice
Version 2.1, effective 22 October 2026. Material changes are notified on this page and by email before they take effect, and we ask for your consent again where it is required.
Registration details
- Registered name
- Investology Quant Data Services Private Limited (Private Limited Company)
- SEBI registration
- Research Analyst, INH000029528
- Validity
- Aug 10, 2026 - Perpetual
- Registered office
- A-001, Ground Floor, Satsang-III Poonam Sagar Complex, Mira Road (East), Thane, Maharashtra 401107
- Correspondence address
- A-001, Ground Floor, Satsang-III Poonam Sagar Complex, Mira Road (East), Thane, Maharashtra 401107
- E-mail (as registered)
- pillai@investology.in
- Contact person (as registered)
- Anish Achuthan Pillai
- Telephone (as registered)
- +91 90290 26474
- Principal Officer
- pillai@investology.in
- Compliance Officer
- pillai@investology.in · +91 90290 26474
- Grievance Officer
- pillai@investology.in · +91 90290 26474
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Registration granted by SEBI, enlistment with BSE and certification from NISM in no way guarantee performance of the intermediary or provide any assurance of returns to investors.
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