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Kwala Intel Privacy Policy (India)

Effective Date: August, 2026

1. Introduction

1.1 IMPLICIT STREAMS PRIVATE LIMITED, a company incorporated under the Companies Act, 2013, having its registered office at H-7, LGF, Lajpat Nagar - 3, New Delhi - 110014 (CIN: U72900DL2022PTC401882) (“Company,” “we,” “us” or “our”), operates the Kwala Intel platform in India (the “Platform”). The Platform is a subscription software service that presents market information about publicly listed companies, sectors and markets — drawn from public sources and exchange-licensed data — in a structured, easy-to-read format. AI Research Chat additionally lets you ask questions about that data and receive a plain-language answer.

1.2 This Privacy Policy (“Policy”) describes how we collect, use, store, share and protect the personal data of persons who access or use the Platform (“you” or “User”). It applies to all Users, including visitors and Registered Users, and is to 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”) for so long as the latter remain in force.

1.4 The Platform is an information and education product: we run your account, deliver the information you have asked for, and collect a Subscription fee where one is payable, and that is the extent of it. The one-time-password verification of your email address and mobile number is an account authentication and security control only; the data we need is limited to what is necessary to run your account, deliver the information you have asked for, collect a Subscription fee where one is payable, and comply with law. The Company is not registered with the Securities and Exchange Board of India or the Reserve Bank of India in any capacity (Clause 4.8 of the General Terms and Conditions).

1.5 Where we rely on your consent, we obtain it by a clear affirmative action by you, and not from your use of the Platform alone. At registration we present you with a notice, independently of this Policy and of our General Terms and Conditions, which itemises the personal data we will process, the specified purpose for each item, the goods or services that purpose enables, how to withdraw your consent, how to exercise your rights under the DPDP Act, and how to complain to the Data Protection Board of India. Your consent is sought separately for each purpose that is not necessary to deliver the Services you have asked for, and declining any such purpose does not affect your access to the Platform. You may withdraw a consent at any time, with the same ease with which you gave it, through your account settings or by writing to [email protected].

1.6 Language of the notice. You are entitled to receive this Policy and the registration notice in English or in any language specified in the Eighth Schedule to the Constitution of India. Translations are made available on the Platform, and you may request a copy in a particular language by writing to [email protected]. Where a translation and the English version differ, the English version governs the legal meaning, and we will correct the translation.

1.7 This Policy explains our data practices in full and supports, but does not replace, the notice described in Clause 1.5. If you do not agree with this Policy, you must not use the Platform.

2. Information We Collect

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 set out below.

2.1 Registration information. When you create an account we collect your name, email address and mobile number. We use this to create and manage your account, to authenticate your access, and to send you the communications described in Clause 3.1(viii).

2.2 Platform usage and interaction data. We collect data about how you use the Platform, including:

  • the companies, sectors and topics you add to a Watchlist or choose to follow;
  • the questions, prompts and inputs you submit to the AI Research Chat interface;
  • the language you select for answers and other Platform output;
  • the content you view, the searches you run and the features you access; and
  • your interaction history with Platform output, including which cards you open, save or dismiss.

2.3 Subscription and payment information. Where you take a paid Subscription, we collect the information necessary to administer it, including your selected plan and billing cycle, payment-confirmation records, invoice records and any billing name and address you provide for tax-invoice purposes. Payment instructions are processed by third-party payment aggregators or gateways. We do not store your full card number, your card verification value, your bank-account credentials, your Unified Payments Interface credentials or any other payment authentication data on our systems. We retain only what is necessary to manage your Subscription status, issue a tax invoice and meet our Goods and Services Tax and accounting obligations.

2.4 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, device identifiers, approximate location derived from IP address, and session timestamps. We use this for security, fraud prevention, technical diagnostics and aggregate analytics.

2.5 Cookies and similar technologies. We use essential cookies and similar technologies, including basic signed session tokens, to keep you signed in, authenticate your requests, keep the Platform secure, and remember your preferences on the Platform. With your consent, given through the cookie banner shown on your first visit and changeable at any time in Settings, we also use analytics cookies to understand how the Platform is used. We do not use cookies or similar technologies to serve you third-party advertising, and we do not share the information they generate with any third party for that party's own advertising or marketing purposes.

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 that communication and our response, together with your name, email address and the nature of your request.

2.7 Data we deliberately do not collect. We do not collect, and you should not send us:

  • any government-issued identity document or identifier, including Aadhaar number, passport or driving licence, and no Permanent Account Number except where you subscribe as an entity and a tax registration number or Permanent Account Number is required for us to issue a valid tax invoice or to deal with tax withheld by you;
  • biometric data;
  • any bank-account, demat-account, investment-account or trading-account number, statement, holding or credential; or
  • any other information that would constitute sensitive personal data or information under the SPDI Rules.

The only exception is where you voluntarily type such information into the AI Research Chat interface. Please do not. Clause 6 explains this further.

3. How We Use Your Information

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

  • to create, authenticate and manage your account and to keep it secure;
  • to provide the Services and to personalise them as to Watchlist scope, display preferences and language only, including to deliver answers in the language you have chosen;
  • to administer a paid Subscription, process payment through our payment provider, issue tax invoices, manage billing cycles and renewals, and meet our Goods and Services Tax, withholding-tax and accounting obligations under Indian law;
  • to operate, maintain, test, debug and improve the Platform, to analyse aggregate usage patterns and to develop new features;
  • to improve, train and evaluate the artificial intelligence models used on the Platform, in accordance with Clause 6;
  • to detect, prevent and investigate fraud, abuse, security incidents and unauthorised access;
  • to respond to your questions, grievances and support requests;
  • to send you the transactional and service communications described in the General Terms and Conditions, including payment receipts, invoices, renewal reminders, security alerts and notices of changes to our policies; and
  • to comply with a legal obligation, a regulatory requirement, or a direction of a competent court or authority.

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 the use is required by applicable law.

3.3 We do not sell your personal data. We do not share it with any third party for that party's own advertising or marketing purposes, and we do not use it to serve you third-party advertising.

4. Sharing and Disclosure

4.1 We do not sell your personal data. We share it only where necessary to operate the Platform, deliver your answer, administer your Subscription, or comply with the law, under confidentiality obligations as protective as this Policy. This includes our service providers and a successor entity if our business is transferred, with notice to you.

4.2 We may disclose your personal data to a law-enforcement agency, court, regulatory authority or other government body where we are required to do so under applicable law, a court order or a lawful regulatory direction, or where disclosure is necessary to establish, exercise or defend a legal claim.

4.3 We may share your personal data with any other third party for any other purpose only with your prior consent.

5. Storage, Security, Transfers and Retention

5.1 We store and process your personal data using secure systems and service providers engaged by us, with appropriate safeguards in place to keep it safe and protected at all times.

5.2 Basis for transfer outside India. Section 16 of the DPDP Act permits the transfer of personal data to any country other than one that the Central Government restricts by notification. We transfer personal data outside India only to a country that is not so restricted, only to a processor bound by a written contract imposing confidentiality, purpose limitation and security obligations at least equivalent to those we owe you, and only to the extent necessary. We will comply with any requirement imposed by the Central Government that a specified category of personal data not be transferred outside India, and with any sectoral law that imposes a stricter localisation obligation.

5.3 Security measures. We employ physical, electronic and procedural safeguards appropriate to the sensitivity of the data we hold, including encryption of data in transit using TLS, encryption of data at rest, role-based access control on a need-to-know basis, logging of administrative access, secure development practices and periodic security review.

5.4 Limits of security. While we take reasonable steps to protect your personal data, no method of transmission over the internet and no method of electronic storage is completely secure. We cannot guarantee absolute security. This Clause does not limit any liability we have for failing to implement the reasonable security safeguards required of us under applicable law.

5.5 Breach notification. In the event of a personal data breach we will, without delay, intimate each affected User in concise, clear and plain language, describing the nature, extent and timing of the breach, its likely consequences, the measures we have taken to mitigate risk, the safeguards you should adopt to protect your interests, and the contact details of a person able to answer your questions. We will also intimate the Data Protection Board of India without delay and furnish the fuller particulars required of us within seventy-two (72) hours, in accordance with the DPDP Act and the rules made under it.

5.6 Retention. We retain your personal data for as long as it is reasonably necessary for the purposes for which it was collected, including to operate your account, provide the Services, administer your Subscription and payment records, and handle support and grievance correspondence, or as required to meet an applicable legal, tax, accounting or regulatory obligation. Where retention is no longer necessary for any of these purposes and no such obligation applies, we take reasonable steps to delete or anonymise the data. A retention obligation imposed by applicable law overrides any request for erasure, to the extent of the conflict.

6. AI Research Chat, Query Data and Model Training

6.1 AI Research Chat. The AI Research Chat feature lets you ask questions in natural language about publicly listed companies, sectors and markets, and receive a plain-language answer with sources attached. When you use it, your question and any input you provide are processed by our system in order to generate the answer, and are retained by us. Where your personal data is deleted or anonymised under Clause 5.6 or Clause 9, we may continue to hold query records in de-identified form, no longer linked to you, including records showing that the Platform declined a request for a recommendation or advice, for security, audit and regulatory-demonstration purposes.

6.2 How query data is used. We use query data for three purposes. Purpose one, to generate and deliver the answer you asked for. Purpose two, for security, fraud prevention and compliance. Purpose three, to improve, train, evaluate and correct the models and systems that produce Platform Content. Purpose three applies only where you have given the consent described in Clause 6.3. Where query data is used for purpose three, the following safeguards apply:

  • we use it in aggregated or de-identified form wherever it is practicable to do so;
  • we apply automated filtering to remove obvious personal identifiers before the data is used for training; and
  • we do not authorise any third-party model provider to use your query data to train that provider's own general-purpose models.

6.3 Managing that consent. You can give, review or withdraw your consent to the use of query data for model improvement at any time in your account settings, or by writing to [email protected]. Withdrawal takes effect for all future use, and it does not affect your access to the Platform or the answers you receive.

6.4 You do not need to share sensitive information. You never need to share personal or financial details to use AI Research Chat, and you should not submit information about another person, account credentials, or any government identifier. Where you choose to type a figure of your own — an amount, a time horizon, a holding — it is used only as an input to the computation you have asked for, is handled as described in this Privacy Policy, and does not cause the Platform to assess your circumstances or form any view about you. The Platform will not accept a risk label as an input and will not construct an allocation for you.

6.5 Nature of the answers. Answers are generated by automated systems. They may contain errors, omissions or outdated information, and are provided for your own reading and independent judgment, not as something we are telling you to do. The AI-Generated Content Disclosure and the General Terms and Conditions set out the full position.

7. Third-Party Links and Data Sources

7.1 The Platform contains citations and links to third-party websites, filings, publications and data sources. Those third parties operate independently of us and have their own privacy policies. We are not responsible for the privacy practices, content or security of any third-party site, and we encourage you to read the relevant policy before providing personal data to them.

7.2 The Platform reads market information, price data, filings and news from public and licensed third-party data sources. That reading happens at the level of public data only. We do not share your personal data with those data sources, and they receive no information about who you are or what you have looked at.

8. Children

8.1 The Platform is not directed at, or intended for use by, any person under the age of eighteen (18) years, and we do not knowingly collect the personal data of a child. If we become aware that we hold the personal data of a person under eighteen years of age, we will delete it promptly, other than any data we are required by law to retain. At registration we require you to declare that you are at least eighteen years of age, and we will suspend and investigate any account we have reason to believe belongs to a child. If you believe we have inadvertently collected data from a child, please write to [email protected] and we will act within seventy-two (72) hours.

8.2 We do not undertake any tracking, behavioural monitoring, targeted advertising or profiling directed at children, and we do not serve targeted advertising to anyone.

8.3 Persons with disability. Where a User is a person with disability who has a lawful guardian, we will process that User's personal data only on the verifiable consent of the guardian. If you are a lawful guardian and wish to give, review or withdraw consent on behalf of such a person, please write to [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, the processing we carry out and the identities of the other data fiduciaries and data processors with whom we have shared it, together with a description of the data shared.
  • Right to correction and completion. You may request correction of inaccurate or misleading data, completion of incomplete data and updating of out-of-date data.
  • Right to erasure. You may request deletion of your personal data, subject to any legal or regulatory obligation requiring us to retain it. Where retention is required by law, we will delete the data as soon as that obligation ceases to apply.
  • Right to withdraw consent. You may withdraw your consent to our processing at any time. Withdrawal does not affect the lawfulness of processing carried out before it. If you withdraw consent to data that is essential to 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 may have any grievance about our processing of your personal data addressed by our Grievance Officer, in the manner set out in Clause 10.

9.2 How to exercise a right. To exercise any of these rights, contact the Grievance Officer whose contact details are given in Clause 10.

9.3 Limits. A right may be limited or unavailable where processing is required by applicable law, where we are required to retain the data, or where giving effect to your request would impair the rights of another person. Where we decline a request in whole or in part, we will tell you why.

9.4 Escalation. If you are not satisfied with our response, you may raise the matter with the Data Protection Board of India in accordance with the DPDP Act. Using our grievance process first is encouraged but does not limit that right.

9.5 Consent Managers. You may give, manage, review and withdraw your consent through a Consent Manager registered with the Data Protection Board of India. We will accept and act on a consent or a withdrawal communicated to us through a registered Consent Manager as though you had communicated it to us directly.

10. Grievance Officer

10.1 In accordance with the IT Act, the IT Rules and the DPDP Act, we have designated a Grievance Officer to address complaints relating to this Policy and to the processing of personal data on the Platform. The contact details are as follows:

  • Grievance Officer: Mukul Singh
  • Email: [email protected]
  • Contact Number: 8826253570
  • Address: H-7, LGF, Lajpat Nagar - 3, New Delhi - 110014
  • Support hours: complaints may be submitted by email at any time and are acknowledged within the timeline in Clause 10.2 regardless of when they are sent.

10.2 The Grievance Officer will acknowledge every complaint within twenty-four (24) hours of receipt, irrespective of the working hours shown above, and will resolve it within fifteen (15) days of receipt, in accordance with the IT Rules. Every complaint is assigned a ticket number at acknowledgement. A complaint may relate to any aspect of this Policy, including the collection, use, storage or sharing of your personal data, or to any alleged infringement of your rights under the DPDP Act or other applicable law.

11. Changes to This Policy

11.1 We may revise or update this Policy to reflect a change in applicable law, a regulatory requirement, our data practices or the features of the Platform. A material change 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 state its revised effective date. A change that is material and adverse to you takes effect no earlier than thirty (30) days after it is notified, except where a shorter period is required by law or regulatory direction.

11.2 Your continued use of the Platform after the effective date of a revised Policy constitutes acceptance of it, except that where a change involves processing your personal data for a new purpose for which the DPDP Act requires consent, we will seek that consent separately, by a clear affirmative action, and your continued use alone will not be treated as that consent. If you do not agree with a change, you must discontinue use of the Platform and may request closure of your account and deletion of your personal data in accordance with Clause 9.

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