Privacy Policy

Last Updated: January 14, 2025

1. Introduction

TeddyBull ("we", "us", "our", or "the Company") is committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our educational stock trading platform, website, and mobile application (collectively, the "Platform").

By accessing or using the Platform, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy. If you do not agree with our practices, please do not use the Platform. Remember: TeddyBull is an educational platform providing delayed BSE stock data only - not real-time data or financial advice.

2. Information We Collect

2.1 Personal Information You Provide

We collect information that you voluntarily provide when using our Platform:

Account Information: Email address, phone number, password, and display name
Profile Information: Age, location, investment preferences, and risk tolerance (if provided voluntarily)
Survey Responses: Feedback and opinions when you participate in surveys or promotions

Note: As an educational platform, we do NOT collect government IDs, PAN cards, Aadhaar numbers, or any identity verification documents. We do NOT require KYC (Know Your Customer) compliance as we do not facilitate real trading.

2.2 Virtual Trading and Learning Activity Data

We collect data related to your educational platform activities (all simulated/virtual):

Virtual Paper Trading History: Simulated buy/sell orders, quantities, prices (no real money)
Virtual Portfolio Holdings: Simulated stock holdings and composition
Virtual Wallet Transactions: Virtual currency transactions and balance history (zero real-world value)
Watchlists: BSE stocks you choose to track for learning purposes
Learning Preferences: Investment preferences and simulated trading patterns
Performance Metrics: Virtual profit/loss data for educational tracking

Educational Purpose: All trading data is 100% simulated. No real securities are bought or sold. All data is for learning purposes only using delayed BSE stock prices.

2.3 Automatically Collected Information

We automatically collect certain technical information when you use the Platform:

Device Information: Device type, operating system, browser type and version, unique device identifiers
Usage Data: Pages viewed, features accessed, time spent on pages, click patterns, navigation paths
Log Data: IP address, access times, error logs, and diagnostic data
Location Data: Approximate geographic location based on IP address (with your consent for precise location)
Cookies and Tracking: Session data, preferences, and analytics information (see Section 8)

2.4 Third-Party Authentication

When you register or log in using third-party services (e.g., Google, Firebase Authentication), we receive basic profile information such as your name, email address, and profile picture as permitted by the third-party service and your privacy settings.

3. How We Use Your Information

We use the collected information for the following purposes:

3.1 Platform Operation and Services

Create and manage your account on our educational platform
Provide access to platform features and learning services
Process virtual trading transactions and maintain simulated portfolio records
Display delayed BSE market data (NOT real-time, NOT NSE) and personalized educational content
Generate AI-powered insights and recommendations for educational purposes only (not financial advice)

3.2 Communication and Support

Respond to your inquiries and provide user support
Send service-related notifications and platform updates
Deliver educational content and market learning insights (delayed BSE data only)
Send educational resources and platform announcements (with your consent)

3.3 Platform Improvement and Analytics

Analyze platform usage patterns and user behavior
Improve platform features, functionality, and user experience
Conduct research and develop new products and services
Train and improve our AI and machine learning algorithms

3.4 Security and Compliance

Protect against fraud, unauthorized access, and security threats
Verify your identity and prevent duplicate accounts
Comply with legal obligations and regulatory requirements
Enforce our Terms and Conditions and protect our rights
Detect and prevent prohibited activities

3.5 Personalization

Customize content and recommendations based on your preferences
Tailor educational resources to your experience level
Provide personalized market insights and stock suggestions

4. Legal Basis for Processing (India)

Under Indian law, including the Information Technology Act, 2000, and the Personal Data Protection Bill (when enacted), we process your personal information based on:

Consent: You have given us explicit consent to process your data for specific purposes
Contract Performance: Processing is necessary to provide the services you requested
Legal Obligations: We must process your data to comply with Indian laws and regulations
Legitimate Interests: Processing is necessary for our legitimate business interests (e.g., fraud prevention, platform improvement)

5. How We Share Your Information

We do not sell your personal information. We may share your information in the following circumstances:

5.1 Service Providers and Business Partners

We share information with trusted third-party service providers who assist us in operating the Platform, including:

Cloud hosting and infrastructure providers (e.g., AWS, Google Cloud)
Authentication services (e.g., Firebase)
Market data providers (e.g., Alpha Vantage)
Analytics and performance monitoring services
Customer support and communication platforms
Payment processors (for any future paid services)

These service providers are contractually obligated to protect your data and use it only for the purposes we specify.

5.2 Legal Requirements and Protection

We may disclose your information if required by law or when we believe disclosure is necessary to:

Comply with legal obligations, court orders, or government requests
Enforce our Terms and Conditions
Protect our rights, property, or safety, or that of our users or the public
Detect, prevent, or address fraud, security, or technical issues
Respond to claims that content violates third-party rights

5.3 Business Transfers

In the event of a merger, acquisition, reorganization, or sale of assets, your information may be transferred as part of the transaction. We will notify you of any such change and provide you with choices regarding your information.

5.4 Aggregated and Anonymized Data

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

5.5 With Your Consent

We may share your information for any other purpose with your explicit consent.

6. Data Security

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

Encryption: Data is encrypted in transit using SSL/TLS protocols and at rest using AES-256 encryption
Authentication: Secure authentication mechanisms including JWT tokens and Firebase Authentication
Access Controls: Role-based access controls and principle of least privilege
Monitoring: Continuous security monitoring and intrusion detection systems
Regular Audits: Periodic security assessments and vulnerability testing
Employee Training: Regular security awareness training for our team

However, 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. You are responsible for maintaining the confidentiality of your account credentials.

7. 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:

Active Accounts: Data is retained while your account is active
Inactive Accounts: If your account is inactive for 3 years, we may delete or anonymize your data after providing notice
Legal Requirements: Some data may be retained longer to comply with legal, tax, or regulatory obligations (typically 7 years for financial records)
Dispute Resolution: Data related to disputes or investigations may be retained until the matter is resolved

When we delete your information, it will be removed from our active systems but may persist in backups for up to 90 days before permanent deletion.

8. Cookies and Tracking Technologies

8.1 What Are Cookies?

Cookies are small text files stored on your device that help us provide and improve our services. We use both session cookies (which expire when you close your browser) and persistent cookies (which remain until you delete them or they expire).

8.2 Types of Cookies We Use

Essential Cookies: Required for platform functionality, authentication, and security
Performance Cookies: Help us understand how users interact with the Platform
Functionality Cookies: Remember your preferences and settings
Analytics Cookies: Collect anonymous usage statistics (e.g., Google Analytics)

8.3 Managing Cookies

You can control cookies through your browser settings. However, disabling essential cookies may affect platform functionality. Most browsers allow you to:

View and delete cookies
Block third-party cookies
Block all cookies (not recommended)
Delete cookies when you close your browser

9. Your Privacy Rights

Under Indian law and our commitment to transparency, you have the following rights regarding your personal information:

9.1 Right to Access

You can request a copy of the personal information we hold about you at any time.

9.2 Right to Correction

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

9.3 Right to Deletion

You can request deletion of your personal information, subject to legal retention requirements. Note that deleting your account will permanently erase all associated data, including virtual portfolio history.

9.4 Right to Withdraw Consent

You can withdraw your consent for processing activities that require consent (e.g., marketing communications) at any time without affecting the lawfulness of processing before withdrawal.

9.5 Right to Data Portability

You can request your data in a structured, commonly used, machine-readable format (e.g., CSV, JSON).

9.6 Right to Object

You can object to certain types of processing, such as direct marketing or processing based on legitimate interests.

9.7 How to Exercise Your Rights

To exercise any of these rights, please contact us at privacy@teddybull.com. We will respond to your request within 30 days. You may be required to verify your identity before we process your request.

10. Children's Privacy

Our Platform is not intended for users under the age of 18. We do not knowingly collect personal information from children under 18. If we become aware that we have collected information from a child under 18, we will take immediate steps to delete such information. If you believe we have inadvertently collected information from a minor, please contact us immediately at privacy@teddybull.com.

11. International Data Transfers

Your information may be transferred to and processed in countries other than India, including countries that may have different data protection laws. When we transfer data internationally, we ensure appropriate safeguards are in place:

Standard Contractual Clauses approved by relevant authorities
Certification under recognized frameworks (e.g., Privacy Shield equivalents)
Ensuring service providers maintain adequate data protection standards

12. Third-Party Links and Services

Our Platform may contain links to third-party websites, services, or content. We are not responsible for the privacy practices of these third parties. This Privacy Policy applies only to information collected by ShareFunds. We encourage you to review the privacy policies of any third-party services you access through our Platform.

13. 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. We will notify you of material changes by:

Posting a notice on the Platform
Sending an email to your registered email address
Displaying a prominent notification when you log in

The updated Privacy Policy will be effective as of the "Last Updated" date. Your continued use of the Platform after changes are posted constitutes your acceptance of the revised Privacy Policy.

14. Data Protection Officer / Grievance Officer

In compliance with the Information Technology Act, 2000, and rules made thereunder, we have appointed a Grievance Officer to address your privacy concerns:

Name: [Grievance Officer Name]

Designation: Data Protection Officer

Email: dpo@teddybull.com

Phone: [Contact Number]

Address: [Company Address]

The Grievance Officer will respond to your complaints or concerns within 15 days of receipt.

15. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

Privacy Inquiries: privacy@teddybull.com

General Support: support@teddybull.com

Data Protection Officer: dpo@teddybull.com

Mailing Address:

TeddyBull
[Street Address]
[City, State, Postal Code]
India

16. Regulatory Compliance

This Privacy Policy is designed to comply with:

Information Technology Act, 2000
Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011
Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021
The Personal Data Protection Bill (when enacted)
Other applicable Indian laws and regulations

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

This Privacy Policy was last updated on January 14, 2025

Version 1.0

TeddyBull - Educational Stock Trading Platform | Your Privacy Matters