Draft for legal review. Text in [brackets] must be completed, and the whole page approved by counsel, before any outside user signs up.

Privacy notice

Version dpdp-2026-10

This notice explains how [COMPANY LEGAL NAME] (the "Data Fiduciary", "we") processes your personal data in the Sharatun trader evaluation, under the Digital Personal Data Protection Act, 2023. We ask for your consent when you create an account; the version of this notice you agreed to is recorded with your account.

1. What we collect

• Mobile number, to sign you in with one-time codes sent by SMS, and your name if you give it.
• Your activity in the evaluation: challenges, simulated orders and trades, positions, results, and the time of each action.
• Technical data: IP address, sign-in times and security events, kept for security and abuse prevention.
• We do not collect financial account details, identity documents, or contacts. We use no advertising or third-party analytics.

2. Why we use it

• To run your challenges and calculate results.
• To assess trading performance in order to identify traders we may offer an engagement to. Our team reviews results and rankings; there is no automated hiring decision.
• To keep the service secure and fair (for example detecting multiple accounts or abuse) and to answer your queries and disputes.

3. Who sees it

• Our evaluation and risk team, on a need-to-know basis. Staff access is logged.
• Service providers that process data for us: SMS delivery ([SMS PROVIDER]) and hosting ([HOSTING PROVIDER]). Data is stored in India. [Confirm and list the processors.]
• If you pass both phases, your name, contact details and evaluation record (challenges, trades and results) are shared with Pratham (Tunir Trade, Bortalav, Bhavnagar), the trading firm that hires traders from this evaluation, so that it can review and engage you.
• We do not sell your data or share it with other traders. Authorities only where the law requires it.

4. How long we keep it

• Account and evaluation records: while your account is active and for [2] years after your last challenge, unless you ask for deletion earlier.
• Security logs: [180 days].
• Records we must keep by law or for an open dispute are kept until that need ends.

5. Your rights

• Access a summary of your data, and correct or update it.
• Withdraw consent and have your data erased. This closes your account and ends any running challenges.
• Nominate a person to exercise these rights if you die or become incapacitated.
• Raise a grievance with our Grievance Officer: [name, email, address]. We respond within [30] days. If you are not satisfied, you may complain to the Data Protection Board of India.

6. Security

Codes, tokens and passwords are stored only as hashes. Connections are encrypted (HTTPS). Staff use two-factor authentication, and every staff action is recorded in an audit log that cannot be edited.

7. Changes

If we change this notice, we will show the new version and ask for your consent again where the law requires it.

8. Contact

[Data protection contact email and postal address.]