Privacy Policy

Last updated: April 25, 2026

1. COLLECTION OF INFORMATION

We collect your personal data when you use our Platform, register for our services, or otherwise interact with us. The information we may collect includes but is not limited to:

• Personal identification: full name, email address, phone number, city of residence
• Account information: username, password (stored in hashed form), and trading preferences
• Broker credentials: API keys, client IDs, and TOTP secrets — stored in encrypted form and used solely to execute trades on your behalf
• Trading activity: orders placed, positions held, and P&L records generated through the Platform
• Technical data: IP address, device type, browser type, session logs, and access timestamps
• Payment information: subscription and billing details processed by our payment partner (we do not store full card or bank account details)

Some information may be collected with your consent, such as broker account credentials, in order to enable the algorithmic trading features of the Platform. You always have the option to not provide information by choosing not to use a particular feature on the Platform.

2. USE OF INFORMATION

We use the personal data we collect to provide the services you request. Specifically, we use your information to:

• Authenticate your account and provide access to subscribed Platform features
• Execute algorithmic trading strategies through your connected broker API
• Process your subscription payments and maintain billing records
• Respond to your queries, resolve disputes, and provide customer support
• Detect, prevent, and investigate fraudulent or illegal activities
• Analyse usage patterns and improve Platform performance and features
• Comply with applicable laws, regulations, and lawful government requests
• Send you service-related notifications, subscription updates, and important policy changes

To the extent we use your personal data for any marketing purpose, we will provide you the ability to opt out of such uses.

3. SHARING OF INFORMATION

We do not sell, rent, or trade your personal information to any third party. We may share your data only in the following limited circumstances:

• Broker APIs (Alice Blue and others): Your credentials are used exclusively to execute trades on your behalf. They are never shared with any other third party.
• Payment Partners: Payment information is processed by our payment gateway in accordance with PCI-DSS standards. We share only the minimum data required to complete your transaction.
• Legal and Regulatory Requirements: We may disclose your information if required by law, court order, or a request from SEBI, law enforcement, or other governmental authority.
• Group Entities and Affiliates: We may share your personal data internally within our group entities and affiliates to provide you access to services and products offered by them.
• Business Transfers: In the event of a merger, acquisition, or sale of assets, your information may be transferred to the successor entity under the same privacy protections.

4. DATA SECURITY

To protect your personal data from unauthorised access, loss, or misuse, we adopt reasonable security practices and procedures. Once your information is in our possession, we adhere to our security guidelines to protect it against unauthorised access. Specific measures include:

• Broker API credentials stored using strong encryption
• All data transmitted between your browser and our servers encrypted via SSL/TLS (HTTPS)
• Access to user data restricted to authorised personnel on a need-to-know basis
• Regular security reviews and vulnerability assessments

However, the transmission of information over the internet cannot always be guaranteed as completely secure. By using the Platform, you accept the security implications of data transmission over the internet and acknowledge that there will always remain certain inherent risks.

5. DATA DELETION AND RETENTION

You have the option to request deletion of your account by contacting us at support@hbterminal.com. This action will result in you losing all information related to your account. We may refuse or delay deletion in the event of any pending claims, disputes, or ongoing services.

We retain your personal data for no longer than is required for the purpose for which it was collected, or as required under applicable law, and for a minimum of two (2) years following account closure. Certain financial and transaction records may be retained for longer periods as required by Indian law. Upon expiry of the retention period, your data will be securely deleted or anonymised.

6. YOUR RIGHTS

You may access, rectify, and update your personal data directly through the functionalities provided on the Platform. You may also write to us at the contact information provided below to assist you with these requests.

7. CONSENT AND WITHDRAWAL

By visiting our Platform or by providing your information, you consent to the collection, use, storage, disclosure, and otherwise processing of your information in accordance with this Privacy Policy. You have the option to withdraw your consent at any time by writing to our Grievance Officer at the contact information provided below, mentioning "Withdrawal of consent for processing personal data" in the subject line. However, withdrawal of consent will not be retrospective, and we reserve the right to restrict or deny the provision of services for which such information is necessary.

8. COOKIES AND TRACKING

HB Terminal uses session cookies exclusively for authentication and security purposes (to maintain your logged-in session). We do not use tracking cookies, advertising cookies, or third-party analytics cookies that profile your behaviour across other websites. You may configure your browser to refuse cookies; however, this will prevent you from logging in to the Platform.

9. CHILDREN'S PRIVACY

The Platform is not intended for use by individuals under the age of 18. We do not knowingly collect personal information from minors. If you believe we have inadvertently collected data from a minor, please contact us immediately and we will take prompt steps to delete such information.

10. CHANGES TO THIS POLICY

Please check our Privacy Policy periodically for changes. We may update this Privacy Policy to reflect changes to our information practices. We will alert or notify you about significant changes in the manner required under applicable laws. Your continued use of the Platform after the effective date of any update constitutes your acceptance of the revised Privacy Policy.

11. GRIEVANCE OFFICER

For any questions, concerns, or requests related to this Privacy Policy or your personal data, please contact the Grievance Officer at the details above. We will respond to your request within 30 days.