1. Introduction
Kuberhunt Treasure Private Limited ('we', 'us', 'our', or 'Company') respects your privacy and is committed to protecting your personal information. This Privacy Policy explains how we collect, use, disclose, store, and safeguard your information when you use the Kuberhunt platform (the 'Platform' or 'Service').
By using the Platform, you consent to the data practices described in this Privacy Policy. If you do not agree with our policies and practices, please do not use the Platform. This Privacy Policy is incorporated into and forms part of our Terms and Conditions.
We process your personal data in accordance with the Digital Personal Data Protection Act, 2023 (the 'DPDP Act') and the rules made under it. Where we rely on your consent as the lawful basis for processing, that consent is free, specific, informed, and unambiguous, and you may withdraw it at any time as described in Section 7. For Kuberhunt Edge, this includes your explicit consent to share specified personal data with the relevant SEBI-registered Research Analyst partner (see Section 4.6). Kuberhunt acts as the Data Fiduciary for the personal data it collects through the Platform.
2. Information We Collect
2.1 Information You Provide Directly
We collect information that you voluntarily provide to us when you:
- Register for an account
- Create or update your profile
- Use the Platform's features and services
- Contact customer support
- Participate in surveys or promotions
- Subscribe to newsletters or marketing communications
This information may include:
Personal Identification:
- Full name, email address, phone number
- Date of birth, gender, photograph (optional)
- Government-issued ID (PAN, Aadhaar, Passport, etc.)
Payment Information:
- Billing address, payment card details (processed by third-party payment processors)
- Transaction history and invoices
Communications:
- Messages, applications, and correspondence sent through the Platform
- Customer support interactions
- Survey responses and feedback
2.2 Information Collected Automatically
When you access or use the Platform, we automatically collect certain information:
Technical Information:
- IP address, browser type and version
- Device type, operating system
- Unique device identifiers
- Mobile network information
Usage Data:
- Pages viewed, features used, time spent on pages
- Click patterns, navigation paths
- Search queries and filters applied
- Date and time of visits
- Referring/exit pages and URLs
2.3 Cookies and Tracking Technologies
We use cookies, web beacons, pixels, and similar tracking technologies to collect information about your interaction with the Platform. These technologies help us:
- Remember your preferences and settings
- Understand how you use the Platform
- Improve Platform functionality and performance
- Deliver relevant advertisements
- Analyze trends and user behavior
You can control cookies through your browser settings. However, disabling cookies may limit your ability to use certain features of the Platform.
3. How We Use Your Information
We use the information we collect for the following purposes:
3.1 Service Provision
- To create and manage your account
- To process transactions and send confirmations
- To provide customer support and respond to inquiries
3.2 Platform Improvement
- To analyze usage patterns and improve user experience
- To develop new features and services
- To conduct research and analytics
- To troubleshoot technical issues and bugs
3.3 Communication
- To send service-related notifications and updates
- To send administrative information (policy changes, terms updates)
- To send marketing and promotional communications (with your consent)
- To respond to your comments and questions
3.4 Security and Fraud Prevention
- To detect, prevent, and address fraud, abuse, and security issues
- To verify user identity and account information
- To protect the rights, property, and safety of the Company, users, and the public
- To enforce our Terms and Conditions and other policies
3.5 Legal Compliance
- To comply with applicable laws, regulations, and legal processes
- To respond to lawful requests from public authorities
- To establish, exercise, or defend legal claims
3.6 Other Purposes
- To personalize your experience on the Platform
- To conduct surveys and gather feedback
- For any other purpose with your consent
4. How We Share Your Information
We may share your information in the following circumstances:
4.1 With Your Consent
We share your information with third parties when you provide explicit consent, such as your contact number and email ID.
4.2 Service Providers
We engage third-party service providers to perform functions on our behalf, including:
- Cloud hosting and data storage providers
- Payment processors (e.g., Razorpay, PayU, Stripe)
- Email and SMS communication services
- Analytics and performance monitoring tools
- Customer support platforms
- Marketing and advertising partners
- The respective Research Analyst / Expert you subscribe to
These service providers have access to your information only to perform specific tasks on our behalf and are obligated to protect your information and use it only for the purposes for which it was disclosed.
4.3 Business Transfers
In the event of a merger, acquisition, reorganization, bankruptcy, or sale of all or a portion of our assets, your information may be transferred to the acquiring entity. We will notify you via email and/or prominent notice on the Platform before your information becomes subject to a different privacy policy.
4.4 Legal Requirements
We may disclose your information if required to do so by law or in response to:
- Valid legal processes (court orders, subpoenas, warrants)
- Requests from government or regulatory authorities
- Legal claims or litigation
- Emergencies involving potential threats to safety or security
4.5 Aggregate and De-identified Data
We may share aggregated, anonymized, or de-identified information that cannot reasonably be used to identify you for research, marketing, analytics, or other purposes.
4.6 Sharing With Edge Partners (Kuberhunt Edge)
If you subscribe to Kuberhunt Edge, you expressly consent, under the DPDP Act, 2023, to our sharing the following personal data with the relevant SEBI-registered Research Analyst partner ('Edge Partner') — currently Investology (SEBI RA Reg. No. INH000015297):
- Your name, registered email address, and mobile number.
- KYC details, including PAN and Aadhaar verification status.
- Your acceptance of the Most Important Terms and Conditions (MITC) and consent records.
- Your Edge subscription and transaction record.
This data is shared only so the Edge Partner can deliver its research to you and meet its own SEBI Research Analyst recordkeeping, KYC, and audit obligations. The Edge Partner processes this data as an independent Data Fiduciary under its own privacy policy and applicable SEBI regulations. You may withdraw this consent at any time by cancelling your Edge subscription and contacting us as set out in Section 12; withdrawal does not affect processing already carried out or records the Edge Partner is required by law to retain.
5. Data Security
We implement appropriate technical and organizational security measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include:
- Encryption of data in transit using SSL/TLS protocols
- Encryption of sensitive data at rest
- Regular security assessments and vulnerability testing
- Access controls and authentication mechanisms
- Employee training on data security and privacy
- Incident response and data breach notification procedures
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.
6. Data Retention
We retain your personal information for as long as your account is active or as necessary to:
- Fulfill the purposes outlined in this Privacy Policy
- Comply with legal, regulatory, or contractual obligations
- Resolve disputes and enforce agreements
- Prevent fraud and abuse
When personal information is no longer needed, we will securely delete or anonymize it. You may request deletion of your account and data at any time, subject to legal retention requirements.
To request account deletion, contact us at support@kuberhunt.com.
7. Your Rights and Choices
Depending on your jurisdiction, you may have the following rights regarding your personal information:
7.1 Access and Portability
- Right to access your personal information and obtain a copy
- Right to receive your data in a structured, machine-readable format
- Right to transfer your data to another service provider (where technically feasible)
7.2 Correction and Update
- Right to correct inaccurate or incomplete personal information
- Right to update your profile and account information at any time through Account Settings
7.3 Deletion
- Right to request deletion of your personal information (subject to legal obligations)
- Right to close your account
Note: Some information may be retained as required by law or for legitimate business purposes.
7.4 Restriction and Objection
- Right to restrict or object to certain processing of your personal information
- Right to opt out of marketing communications at any time
- Right to object to automated decision-making and profiling (where applicable)
7.5 Withdraw Consent
- Right to withdraw consent for processing based on consent (without affecting the lawfulness of processing before withdrawal)
7.6 Lodge a Complaint
Right to file a complaint with a data protection authority if you believe your rights have been violated.
7.7 Exercising Your Rights
To exercise any of these rights, please contact us at support@kuberhunt.com. We will respond to your request within 30 days. We may require verification of your identity before processing your request.
8. Children's Privacy
The Platform is not intended for children under the age of 18 years. We do not knowingly collect personal information from children. If we become aware that we have collected information from a child without parental consent, we will take steps to delete such information promptly.
If you are a parent or guardian and believe your child has provided us with personal information, please contact us immediately.
9. International Data Transfers
Your information may be transferred to, stored in, and processed in countries other than India, where our servers and service providers are located.
These countries may have data protection laws that differ from those of your country. We ensure that appropriate safeguards are in place to protect your information in accordance with this Privacy Policy, including:
- Standard Contractual Clauses approved by relevant authorities
- Adequacy decisions by regulatory bodies
- Binding Corporate Rules
- Other legally recognized transfer mechanisms
10. Third-Party Links and Services
The Platform may contain links to third-party websites, services, or applications that are not owned or controlled by us. This Privacy Policy does not apply to third-party websites or services.
We are not responsible for the privacy practices of third parties. We encourage you to review the privacy policies of any third-party websites or services you visit or use. Your interactions with third-party websites and services are governed solely by their respective privacy policies and terms.
11. 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 the updated Privacy Policy on the Platform with a new 'Last Updated' date
- Sending an email notification to your registered email address
- Displaying a prominent notice on the Platform
Your continued use of the Platform after the effective date of the updated Privacy Policy constitutes your acceptance of the changes. If you do not agree to the updated Privacy Policy, you must stop using the Platform and may request deletion of your account.
We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information.
12. Contact Us
If you have questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us:
- Privacy Team: support@kuberhunt.com
We will respond to your inquiry within 30 days.
For privacy or data-handling concerns relating to data shared with our Kuberhunt Edge partner, you may also contact the Edge Partner's grievance officer:
- Investology — Grievance Officer: Neelima Pillai, compliance@investology.in. Registered office: VO 872, WeWork NESCO IT Park, 10th Floor, Building 4, Nesco IT Park, Western Express Highway, Goregaon (East), Mumbai, Maharashtra 400063.