Privacy Policy
This Privacy Policy describes how CINTENT Technology Solutions Pvt. Ltd. ("CINTENT", "we") collects, uses, stores, and shares your personal data when you use the CWOS platform. It is drafted in accordance with India's Digital Personal Data Protection (DPDP) Act, 2023.
1. Data Fiduciary
CINTENT Technology Solutions Pvt. Ltd. is the Data Fiduciary as defined under the DPDP Act, 2023. Contact details:
- Email: contact@cognivantalabs.com
- Phone: +91-9999918814
2. What Personal Data We Collect
2.1 Account Data
When you register for CWOS:
- Name, email address, phone number
- Organization name (for enterprise users)
- Password (stored as a bcrypt hash -- never in plaintext)
- User role and subscription tier
2.2 Usage Data
- Pages visited, features used, session duration
- Search queries within the platform
- Watchlist compositions and portfolio inputs entered by the user
- API request logs (for debugging and abuse detection)
2.3 Technical Data
- IP address, browser type, operating system, device identifiers
- JWT token metadata (not the token content)
- Error logs and crash reports
2.4 Lead & Contact Data
If you submit an evaluation request, demo request, or contact form on the CWOS website, we collect your name, email, organization, and any message you provide.
3. How We Use Your Data
- Service delivery: Authenticating your account and delivering platform features.
- Personalization: Remembering your preferences, watchlists, and layouts.
- Communications: Sending transactional emails (account confirmation, password reset, subscription receipts). Marketing emails only with your consent.
- Security: Detecting and preventing fraud, unauthorized access, and abuse.
- Legal compliance: Meeting obligations under DPDP Act, 2023, IT Act, 2000, and other applicable law.
- Product improvement: Aggregated, anonymized analytics to improve CWOS features.
4. Legal Basis for Processing
Under the DPDP Act, 2023, we process your personal data on the following grounds:
- Consent: For account registration, marketing communications, and optional analytics.
- Legitimate use: For security logging, fraud prevention, and service delivery to existing users.
- Legal obligation: For compliance with court orders, regulatory requirements, and tax obligations.
5. Data Sharing
We do not sell your personal data. We share data only:
- With service providers: Cloud hosting (AWS), email delivery (transactional email providers), payment processors -- all under data processing agreements.
- With data providers: Anonymized API request metadata may be shared with Finnhub, Alpha Vantage, NewsAPI, FRED, and CoinGecko as required for API operation. No personal data beyond IP address (masked) is shared.
- With law enforcement: When required by a valid court order, SEBI directive, or other legal compulsion.
- In business transfers: In the event of a merger, acquisition, or asset sale, subject to the acquirer adopting equivalent privacy protections.
6. Data Retention
- Account data: Retained for the duration of your account + 3 years post-deletion for legal compliance.
- Usage logs: 12 months rolling retention.
- Lead/contact data: 2 years from submission or until you request deletion.
- Financial transaction records: 7 years as required by Indian accounting standards.
7. Your Rights Under DPDP Act, 2023
As a Data Principal under the DPDP Act, 2023, you have the right to:
- Access: Request a summary of personal data we hold about you.
- Correction: Request correction of inaccurate personal data.
- Erasure: Request deletion of your personal data (subject to legal retention obligations).
- Grievance redressal: Lodge a complaint with us; if unresolved, escalate to India's Data Protection Board.
- Nominate: Nominate another person to exercise rights on your behalf in case of death or incapacity.
To exercise any of these rights, email contact@cognivantalabs.com with subject "DPDP Rights Request". We will respond within 72 hours and resolve within 30 days.
8. Cookies & Tracking
CWOS uses strictly necessary cookies for session management (JWT token storage in httpOnly cookies). We use no third-party advertising cookies. Analytics are collected via server-side logs, not client-side trackers like Google Analytics.
9. Data Security
We implement industry-standard security measures including TLS 1.3 in transit, AES-256 encryption at rest for sensitive fields, bcrypt password hashing, and access controls based on role and IP allowlisting for administrative functions. However, no system is 100% secure. In the event of a data breach, we will notify affected users and the Data Protection Board of India within 72 hours as required by the DPDP Act.
10. Children's Privacy
CWOS is not directed at persons under 18. We do not knowingly collect personal data from minors. If you believe a minor has registered, contact us and we will delete the account.
Regulatory Reference
- Digital Personal Data Protection Act, 2023 (DPDP Act)
- Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011
- SEBI Cybersecurity and Cyber Resilience Framework (CSCRF), 2024
11. Changes to This Policy
We may update this policy periodically. Material changes will be notified by email and in-app notice 14 days before taking effect. The "Last Updated" date above reflects the current version.
12. Contact & Grievance Officer
Grievance Officer: CINTENT Data Privacy Team
Email: contact@cognivantalabs.com
Phone: +91-9999918814