What we hold, and what we never ask.

Information we collect

Information we do not collect

• 2.1

  Consistent with Section 6 of the Membership Agreement, the Platform never requests or stores Sensitive Credentials — passwords to third-party accounts, PINs, OTPs, CVVs, net-banking/demat logins, or biometric authentication data. Your Apna Trustee account password is stored only in encrypted/hashed form and is never visible to Apna Trustee personnel.

How we use information

• 3.1

  To create and administer your account, verify identity, and provide the Services you select.

• 3.2

  To connect and route RM calls/chats, maintain service records, and resolve disputes or safety concerns.

• 3.3

  To store and, where authorised, disclose Vault content to designated Nominees under Section 8 of the Membership Agreement.

• 3.4

  To maintain Platform security, diagnose faults, and improve features through aggregated, de-identified analytics.

• 3.5

  To comply with legal, regulatory and audit obligations. We do not use your data for unrelated marketing or sell it to third parties.

VOIP & chat data handling

• 4.1

  Call metadata: Call and chat metadata (time, duration, participants) is retained for service records, billing verification and quality assurance.

• 4.2

  Recordings: Call recordings, where made, occur only with prior notice and are used solely for quality assurance, training, dispute resolution and safety review; they are access-restricted and retained per Section 9.

• 4.3

  Chat content: Chat messages are stored securely to preserve continuity of your relationship with your RM and are subject to the access controls in Section 6.

Digital Vault data security

• 5.1

  Vault content is stored in Apna Trustee's Secure Digital Vault, protected by encryption in transit and at rest, access logging and multi-factor authentication, as described in Section 7 of the Membership Agreement.

• 5.2

  Vault content is masked and access-restricted on a need-to-know basis; disclosure to a Nominee occurs only upon the triggers and scope set out in Section 8 of the Membership Agreement.

Sharing of information

• 6.1

  Service providers: We share information with vetted infrastructure providers (VOIP, cloud hosting, analytics) strictly to operate the Platform, under confidentiality and data-processing terms at least as protective as this Policy.

• 6.2

  Network partners: Where a Service requires a Network Partner (medical, legal, financial, security, lifestyle), only the minimum necessary data is shared, per Section 9 of the Membership Agreement.

• 6.3

  Legal disclosure: We may disclose information where required by law, regulation, or a valid order of a competent authority.

• 6.4

  No sale of data: Apna Trustee does not sell or rent Personal Data to third parties.

Cookies & analytics

• 7.1

  The website uses essential cookies (for login sessions) and, where you consent, analytics cookies to understand usage patterns. You may control cookies through your browser settings; disabling essential cookies may limit website functionality.

Data retention

• 8.1

  Platform data is retained only as long as necessary to provide the Services or comply with legal obligations, and is deleted or anonymised within 90 days of account closure or written request, save for statutorily mandated records, consistent with Section 9.2 of the Membership Agreement.

Your rights

In accordance with the Digital Personal Data Protection Act, 2023, you may:

• 9.1

  Access, correct, or request erasure of your Personal Data held on the Platform.

• 9.2

  Withdraw consent for optional features (e.g. call recording, analytics cookies) at any time, prospectively.

• 9.3

  Nominate a person to exercise these rights on your behalf in the event of death or incapacity.

• 9.4

  Lodge a grievance with the Grievance Officer below or, if unresolved, with the Data Protection Board of India.

Children's privacy

• 10.1

  The Platform is not directed at, and shall not knowingly collect data from, individuals under 18 years of age. If we learn a minor's data has been collected without appropriate consent, we will delete it promptly.

International data transfers

• 11.1

  Where Platform infrastructure involves storage or processing outside India, Apna Trustee shall ensure such transfers comply with the DPDP Act, 2023 and applicable government notifications.

Data security

• 12.1

  Apna Trustee applies encryption, access controls, audit logging and periodic security review across the Platform, as described in Section 7 of the Membership Agreement. No system is completely immune to risk; you are responsible for the security of your own device and account credentials.

Changes to this policy

• 13.1

  We may update this Policy periodically; the “Last updated” date will be revised, and material changes will be notified via the Platform.

Grievance Officer & contact