This Privacy Policy describes how {{LEGAL_ENTITY_NAME}} (“Markov”) collects, uses, stores and protects your personal information when you use the Markov mobile application or the markov.inwebsite. We act as a “Data Fiduciary” for the purposes of the Digital Personal Data Protection Act, 2023 (“DPDP Act”).
1. What we collect
We collect only the data we need to deliver and improve the service.
- Account data: name, email, phone number, password hash, device identifiers.
- KYC-lite data (paid plans): PAN (for tax invoicing where applicable), state of residence.
- Configuration data: your configured trading capital, risk preferences, watchlist, and broker (broker linkage is read-only; we do not see your funds).
- Journal data: trades you choose to log, entries, exits, and notes.
- Usage data: pages visited, signals viewed, push-notification opt-ins, crash logs, app version, device OS version.
- Payment data: a transaction reference from Razorpay or the platform store. We do not store full card or UPI credentials — those are handled by the payment processor.
2. What we do not collect
- Your broker login credentials.
- Your bank account or credit-card numbers.
- The contents of your demat or trading account.
- Biometric data of any kind.
3. Why we collect it
- To deliver real-time signals and personalise position sizing to your capital.
- To process payments and issue tax invoices.
- To send transactional and product communications you have opted in to.
- To detect fraud, abuse, and credential sharing.
- To comply with applicable law and SEBI record-keeping requirements.
- To improve the product through aggregated, de-identified analytics.
4. Legal basis
We process your personal data on the following bases under the DPDP Act:
- Consent: for marketing communications and optional features.
- Legitimate use: for delivering the service you have subscribed to, fraud prevention, and compliance with SEBI obligations.
5. Who we share with
We share data only with:
- Payment processors (Razorpay, Google Play, App Store) — to process subscriptions.
- Cloud infrastructure providers (e.g., AWS, in India) — to host the service. They process data on our instruction only.
- Push-notification providers (e.g., Firebase Cloud Messaging) — to deliver alerts.
- Regulators and law enforcement — only when legally required (SEBI inquiries, valid court order, etc.).
We do not sell your personal data. We do not share it for advertising purposes.
6. Where we store it
Personal data is stored primarily on infrastructure located in India. Limited operational data may be processed in other jurisdictions through SEBI-permitted cloud regions; in each case, we apply the same protection standards.
7. How long we keep it
- Active accounts: for as long as you maintain a subscription, plus a regulatory record-retention period (currently 5 years from the date of the last recommendation, per SEBI norms).
- Closed accounts: personal identifiers are deleted or anonymised after the regulatory retention period; aggregated, de-identified data may be retained indefinitely.
8. Your rights
Under the DPDP Act, you may:
- request access to the personal data we hold about you;
- request correction of inaccurate or outdated data;
- request erasure of your data, subject to our regulatory retention obligations;
- withdraw consent for any consent-based processing (e.g., marketing);
- nominate another person to exercise these rights on your behalf in case of death or incapacity.
To exercise any of these rights, write to support@markov.inwith subject “DPDP request”. We will respond within the timelines prescribed under the DPDP Act.
9. Security
We use industry-standard measures, including encryption in transit (TLS 1.2+) and at rest, hashed credentials, role-based access controls, and audit logging. No system is perfectly secure; if you believe your account has been compromised, contact us immediately at support@markov.in.
10. Children
The service is not intended for individuals under the age of 18. We do not knowingly collect data from minors.
11. Cookies
The website uses only essential cookies required for authentication and session management. We do not run third-party advertising cookies. Aggregated, privacy-preserving analytics may be used to improve the product.
12. Changes
We may update this policy from time to time. Material changes will be announced by email and in-app at least 7 days before they take effect.
13. Contact
For any privacy question, contact our designated point of contact for DPDP matters at support@markov.in, or write to {{COMPLIANCE_OFFICER_NAME}} (Compliance Officer), {{REGD_OFFICE_LINE_1}}, {{REGD_OFFICE_CITY}} – {{REGD_OFFICE_PIN}}.