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Kwala Intel Platform Privacy Policy (India)

Effective Date: 5th August 2026

1. Introduction

1.1 [Company Name], a company incorporated under the Companies Act, 2013, with its registered office at [Registered Address] (CIN: [_________]) ("Company," "we," "us," or "our") operates the Kwala Intel Platform ("Platform"), an AI-powered crypto research and market intelligence platform accessible at kwalaintel.in.

1.2 This Privacy Policy ("Policy") describes how we collect, use, store, share, and protect the personal data of users who access or use the Platform ("you" or "User"). This Policy applies to all Users, including visitors and Registered Users, and should be read together with our General Terms and Conditions.

1.3 This Policy is published as an electronic record under the Information Technology Act, 2000 ("IT Act") and the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021 ("IT Rules"). It is to be read in conjunction with the Digital Personal Data Protection Act, 2023 ("DPDP Act") and the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 ("SPDI Rules").

1.4 Kwala Intel is a research and information platform. It does not conduct any financial transactions on your behalf, does not hold or custody any assets, and does not perform KYC (Know Your Customer) verification. OTP-based phone and email verification used on the Platform is for account authentication only and does not constitute KYC or onboarding to any financial or regulated service. Accordingly, the data we collect is limited to what is necessary to operate the Platform, provide the Services, and comply with applicable law.

1.5 By accessing or using the Platform, you acknowledge that you have read and understood this Policy and consent to the collection, use, storage, and sharing of your personal data as described herein. If you do not agree with this Policy, you must not use the Platform.

2. Information We Collect

2.1 We collect only the personal data that is necessary to provide the Services and to comply with applicable law. The categories of data we collect are:

2.2 Registration Information. When you create an account on the Platform, we collect your name, email address, and mobile phone number. This information is used to create and manage your account and to authenticate your identity for Platform access.

2.3 Platform Usage and Interaction Data. We collect data about how you use the Platform, including:

  • assets and tokens you add to personalised watchlists;
  • queries, prompts, and inputs you submit to the AI Research Chat interface;
  • alert and workflow configurations you create, including price-trigger thresholds and notification preferences;
  • content you view, searches you conduct, and features you access; and
  • your interaction history with AI-generated content, including signals and research outputs.

2.4 Subscription and Payment Information. When you subscribe to a paid plan, we collect information necessary to process your subscription, including your selected billing cycle and payment confirmation records. Payment transactions are processed by third-party payment gateway providers. We do not store your full card number, bank account credentials, UPI credentials, or other sensitive payment authentication data on our servers. We retain only the information necessary to manage your subscription status, issue tax invoices, and comply with our GST obligations.

2.5 Device and Technical Information. We automatically collect certain technical information when you access the Platform, including your IP address, device type, operating system, browser type and version, unique device identifiers, and session timestamps. This information is used for security, fraud prevention, technical diagnostics, and analytics.

2.6 Communications. If you contact our support team, submit a grievance, or communicate with us through any channel, we collect and retain the content of your communications and our responses, including your name, email address, and the nature of your inquiry.

2.7 We do not collect any personal data beyond what is reasonably necessary for the purposes described in this Policy. Specifically, we do not collect: government-issued identity documents (such as PAN or Aadhaar); biometric data; financial account or trading account information; or any data that would constitute Sensitive Personal Data or Information under the SPDI Rules, except to the extent that usage data voluntarily submitted by you in the AI Research Chat incidentally contains such information.

3. How We Use Your Information

3.1 We use the personal data we collect for the following purposes:

  • to create, verify, and manage your user account and authenticate your access to the Platform;
  • to provide and personalise the Services, including your watchlists, AI Research Chat, alert workflows, and intelligence feeds;
  • to process subscription payments, issue tax invoices, manage billing cycles, and comply with our GST and TDS obligations under applicable Indian tax law;
  • to improve the Platform, train and refine our AI models, analyse usage patterns, and develop new features, where your interaction data (including AI Research Chat queries) is used to improve model performance, such data is processed in anonymised or aggregated form to the extent practicable;
  • to detect, prevent, and investigate fraudulent activity, security incidents, and unauthorised access;
  • to respond to your queries, grievances, and requests for customer support;
  • to send you transactional and service communications, including subscription confirmations, payment receipts, account alerts, and updates to our policies; and
  • to comply with legal obligations, regulatory requirements, and directions from competent courts or authorities.

3.2 We will not use your personal data for any purpose other than those stated in this Policy without your prior consent, except where such use is required by applicable law.

3.3 We do not use your personal data to provide targeted advertising to third parties, and we do not sell your personal data to any third party for marketing or commercial purposes.

4. Sharing and Disclosure of Information

4.1 We do not sell your personal data to any third party. We may share your personal data only in the following circumstances and to the extent strictly necessary:

4.2 Service Providers. We engage third-party service providers to assist with operating the Platform, including cloud hosting providers, payment gateway operators, analytics providers, and customer support tools. These providers access your data only to the extent required to perform their services on our behalf and are bound by appropriate contractual confidentiality and data protection obligations.

4.3 Payment Processing. When you subscribe to a paid plan, your payment information is transmitted to and processed by our third-party payment gateway provider(s). We do not receive or store sensitive payment authentication data. The payment gateway's own privacy policy governs the processing of your payment data.

4.4 Legal and Regulatory Obligations. We may disclose your personal data to law enforcement agencies, courts, regulatory authorities (including the Income Tax Department, Financial Intelligence Unit – India (FIU-IND), or any other competent authority), or government bodies where we are required to do so under applicable law, court order, or regulatory direction.

4.5 Business Transfers. In the event of a merger, acquisition, restructuring, or sale of all or a substantial part of the Company's business or assets, your personal data may be transferred to the successor entity as part of that transaction, subject to equivalent data protection obligations.

4.6 With Your Consent. We may share your personal data with any third party for any other purpose with your prior written consent.

4.7 In all cases, we ensure that personal data is shared only to the extent necessary for the stated purpose, with appropriate safeguards in place.

5. Data Storage, Security and Retention

5.1 Your personal data is stored on secure servers located within India. We do not transfer your personal data outside India except where required by applicable law or with your prior consent, and subject to the conditions specified under the DPDP Act.

5.2 We employ industry-standard physical, electronic, and procedural safeguards to protect your personal data from unauthorised access, disclosure, alteration, or destruction. These measures include encrypted data transmission (TLS/SSL), access controls, role-based authorisation, and regular security reviews.

5.3 While we take reasonable steps to protect your personal data, no method of transmission over the internet or electronic storage is completely secure. We cannot guarantee absolute security, and we shall not be liable for any unauthorised access or data breach that occurs despite our reasonable safeguards.

5.4 In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify you and the Data Protection Board of India in accordance with the DPDP Act and any applicable rules.

5.5 We retain your personal data for as long as: (a) your account is active; (b) it is necessary to provide the Services; (c) it is required to comply with applicable legal or regulatory obligations, including tax and audit requirements; or (d) it is necessary to resolve disputes or enforce our agreements. Where personal data is no longer required for any lawful purpose, it will be securely deleted or anonymised. Retention obligations under applicable law (including the IT Act and Income Tax Act, 1961) take precedence over any erasure request under the DPDP Act, to the extent of that conflict.

6. AI Research Chat and Query Data

6.1 The Platform's AI Research Chat feature allows you to submit natural-language queries and prompts relating to digital assets, market conditions, and sector analysis. When you use this feature, the queries and inputs you submit are processed by the Company's AI systems to generate a response and are retained by the Company.

6.2 Query data may be used for the following purposes: (a) to generate and deliver your requested research response; (b) to improve, train, and refine the Company's AI models and research capabilities; and (c) for security, fraud prevention, and compliance purposes.

6.3 You should not submit any personally sensitive information, confidential information, or information relating to third parties through the AI Research Chat interface. We are not responsible for the consequences of any sensitive information you choose to submit through this feature.

6.4 AI Research Chat responses are generated by automated systems. They may contain errors, inaccuracies, or outdated information and do not constitute investment advice, financial advice, or any form of professional recommendation. Please refer to the General Terms and Conditions for the full disclaimer applicable to AI-Generated Content.

7. Third-Party Links and Data Providers

7.1 The Platform may contain links to third-party websites, publications, or data sources. These third-party sites operate independently of the Company and have their own privacy policies. We are not responsible for the privacy practices, content, or security of any third-party website, and we encourage you to review their policies before providing any personal data to them.

7.2 The Platform aggregates market data, on-chain analytics, price feeds, and news content from third-party data providers. This aggregation is done at the data level and does not involve the sharing of your personal information with those data providers.

8. Children's Privacy

8.1 The Platform is not directed at or intended for use by persons under the age of 18 years. We do not knowingly collect personal data from minors. If we become aware that personal data of a person under 18 years has been collected without appropriate parental or guardian consent, we will take prompt steps to delete such data. If you believe that we have inadvertently collected data from a minor, please contact us at [email protected].

9. Your Rights

9.1 Subject to the DPDP Act and other applicable law, you have the following rights in relation to your personal data:

  • Right to Access: You may request a summary of the personal data we hold about you and the purposes for which it is being processed.
  • Right to Correction: You may request correction of any inaccurate or incomplete personal data we hold about you.
  • Right to Erasure: You may request deletion of your personal data, subject to any legal or regulatory obligation that requires us to retain it. Where retention is required by law, we will delete your data as soon as the retention obligation ceases to apply.
  • Right to Withdraw Consent: You may withdraw your consent to our processing of your personal data at any time. Withdrawal of consent does not affect the lawfulness of processing carried out prior to the withdrawal. If you withdraw consent to data that is essential for us to provide the Services, we may be unable to maintain your account or continue providing access to the Platform.
  • Right to Nominate: You may nominate another individual to exercise your rights under the DPDP Act on your behalf in the event of your death or incapacity.
  • Right to Grievance Redressal: You have the right to have your grievances regarding the processing of your personal data addressed by the Company's Grievance Officer in accordance with the process set out in Clause 11.

9.2 To exercise any of the above rights, please contact us at [email protected] or through the Grievance Officer contact details in Clause 11. We will respond to your request within a reasonable time and in accordance with the requirements of the DPDP Act.

9.3 Please note that certain rights may be limited or unavailable where the processing of your personal data is required by applicable law, or where fulfilling your request would impair the rights of others.

10. Grievance Officer

10.1 In accordance with the IT Act and the IT Rules, the Company has designated a Grievance Officer to address complaints and grievances relating to the processing of personal data on the Platform. The Grievance Officer's details are as follows:

  • Name: [_________]
  • Designation: Grievance Officer
  • Email: [email protected]
  • Address: [Registered Address of Company]
  • Working Hours: Monday to Friday, 10:00 AM to 6:00 PM IST

10.2 The Grievance Officer shall acknowledge all complaints within 24 hours of receipt and endeavour to resolve them within 15 days from the date of acknowledgment, in accordance with the IT Rules. Complaints may relate to any aspect of this Policy, including the collection, use, storage, or sharing of your personal data, or any alleged violation of your rights under the DPDP Act or other applicable law.

11. Amendments

11.1 We reserve the right to revise or update this Policy at any time to reflect changes in applicable law, regulatory requirements, our data practices, or the features and functionality of the Platform. Material changes will be communicated by posting the updated Policy on the Platform and, where appropriate, by notification to your registered email address. The updated Policy will specify the revised effective date.

11.2 Your continued use of the Platform after the effective date of any revised Policy constitutes your acceptance of the updated terms. If you do not agree with any changes, you must discontinue use of the Platform and may request deletion of your account and personal data in accordance with Clause 10.

- End of Privacy Policy -

Questions about these documents? Write to [email protected].