Effective Date: 01-01-2024
Entity: Finlock Assets CTC (“Company,” “we,” “our,” “us”)
Offerings: Hedge Fund Trading Secrets (HFTS) Workshop and Hedge Fund Trading Mastermind (HFTM) Program (collectively, the “Courses”).

We respect your privacy and are committed to protecting your personal information. This Privacy Policy explains how we collect, use, store, and safeguard your data when you access our website, enroll in our Courses, or otherwise interact with us.

 
1. Information We Collect
We may collect the following categories of information:

Personal Identifiable Information (PII): Name, email address, phone number, billing address, government ID (if voluntarily provided for invoicing/KYC).
Financial Information: Payment method, transaction details (processed securely via third-party payment gateways; we do not store card details).
Technical Data: IP address, browser type, device information, cookies, log files, usage statistics.
Course Usage Data: Attendance, progress, feedback, assignments, participation in live sessions, chat messages.
Marketing Data: Preferences, survey responses, testimonials, communications.
 
2. How We Use Your Information
We process your information for the following purposes:

To register you for HFTS/HFTM Courses and manage your account.
To deliver course materials, live sessions, recordings, and support.
To process payments, issue GST invoices, and maintain accounts/records.
To improve Courses, customize content, and enhance learning experience.
To communicate with you (updates, reminders, administrative notices, promotions).
To comply with legal/regulatory obligations under Indian law.
 
3. Legal Basis for Processing
We process personal data under the following legal bases (as per Indian law):

Consent – when you voluntarily provide data or subscribe to communications.
Contractual necessity – for delivering Courses you purchase.
Legal obligation – for tax, compliance, and record-keeping.
Legitimate interests – to improve services, prevent fraud, and protect rights.
 
4. Data Sharing & Disclosure
We do not sell your data. We may share data only with:

Payment processors (for transactions).
Learning platforms/technology providers (to deliver content and live sessions).
Professional advisers (lawyers, auditors, accountants).
Regulatory authorities if legally required (e.g., SEBI, IT department).
All third parties are bound by confidentiality and data protection obligations.

 
5. Data Security
We implement reasonable technical and organizational safeguards, including encryption, secure servers, restricted access, and periodic audits. However, no system is 100% secure; you use our services at your own risk.

 
6. Data Retention
Personal data is retained as long as necessary for providing Courses and complying with legal/tax obligations.
Course activity logs and testimonials may be retained for business purposes unless you request deletion.
You may request deletion, subject to legal obligations.
 
7. Cookies & Tracking
Our website uses cookies and tracking technologies to improve functionality, remember preferences, analyze traffic, and deliver relevant promotions. You may disable cookies in your browser settings, but certain features may not work properly.

 
8. Your Rights (under Indian Law)
Depending on applicable laws, you may have the following rights:

Right to access – request a copy of your personal data.
Right to rectification – correct inaccurate/incomplete data.
Right to withdraw consent – stop marketing communications.
Right to erasure – request deletion (subject to legal limits).
Right to grievance redressal – contact our Data Protection Officer.
Requests can be made by emailing [support@finlockassets.com].

 
9. Children’s Privacy
Our Courses are intended for adults (18+). We do not knowingly collect data from minors. If you believe a minor has provided information, contact us for deletion.

 
10. International Transfers
Although based in India, we may use service providers with servers outside India. By using our services, you consent to such transfers subject to contractual safeguards.

 
11. Updates to this Policy
We may update this Privacy Policy periodically. Updates will be posted on our website with a revised effective date. Continued use of our Courses after updates signifies acceptance.

 
12. Governing Law & Jurisdiction
This Privacy Policy is governed by the laws of India. Any disputes shall be resolved under the Arbitration and Conciliation Act, 1996, with a sole arbitrator appointed by the Company. The seat and venue of arbitration shall be Udupi, Karnataka. Subject to arbitration, courts in Udupi, Karnataka shall have exclusive jurisdiction.

 
13. Contact Information
For privacy-related queries, complaints, or to exercise your rights, contact:

Data Protection Officer (DPO)
Finlock Assets CTC
Email: [support@finlockassets.com]
Address: [Hariom Villa, Eshwar Nagar, Manipal Karnataka, India]

 
This Privacy Policy makes you compliant with Indian IT laws and aligns with global best practices.