CalQuity
CalQuity · Legal

Privacy Policy

Effective Date · 1 August 2025

For Institutional Clients, Users, and Website Visitors
Effective Date: 1 August 2025
CalQuity Technologies Private Limited
Suite 501, 6 Garstin Place, Kolkata – 700001, West Bengal, India
CIN: U62099WB2024PTC272030 | GSTIN: 19AALCC9904F1ZD
legal@calquity.com | +91 91638 84849

1. Introduction and Scope

CalQuity Technologies Private Limited ("CalQuity", "we", "us", or "our") operates an institutional-grade AI platform for equity research, financial analysis, and related services (the "Platform"). This Privacy Policy explains how we collect, use, store, share, and protect personal data and institutional data in connection with our Platform and website (www.calquity.com).

This Policy applies to:

Registered users of the CalQuity Platform (analysts, fund managers, compliance officers, and other authorized personnel at client institutions)

Employees, officers, or representatives of institutional clients who interact with CalQuity in a business capacity

Visitors to our website at www.calquity.com

Prospective clients, partners, and third parties who engage with CalQuity

By accessing or using the Platform or our website, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with this Policy, please do not use the Platform.

2. Data Controller and Contact Information

CalQuity Technologies Private Limited is the data controller (or "Data Fiduciary" under the Digital Personal Data Protection Act, 2023) for personal data collected through the Platform and website.

Registered Office: Suite 501, 6 Garstin Place, Kolkata – 700001, West Bengal, India

CIN: U62099WB2024PTC272030

GSTIN: 19AALCC9904F1ZD

Privacy & Legal Enquiries: legal@calquity.com

Support: support@calquity.com

Phone: +91 91638 84849

3. Categories of Data We Collect

3.1 Account and Identity Data

When an institution subscribes to CalQuity and when individual users are provisioned on the Platform, we collect:

Full name, job title, and department

Professional email address and phone number

Employer / institutional affiliation

Login credentials (passwords are hashed and never stored in plain text)

User roles and permission levels assigned by your institution's administrator

3.2 Usage and Analytics Data

We collect information about how users interact with the Platform for the sole purposes of product improvement, security monitoring, and technical support. This includes:

Log data: IP addresses, browser/device type, operating system, access timestamps

Feature usage patterns: which modules, tools, or queries are used, and session duration

Error logs and crash reports to diagnose technical issues

API call metadata (not the content of queries) for rate-limit and billing purposes

Usage and analytics data is used exclusively for operational purposes. It is not used for advertising, profiling, or resale.

3.3 Client-Submitted Research Data

As part of using the Platform, clients and users may upload or input documents, financial data, proprietary research, company notes, earnings transcripts, models, or other files (collectively, "Client Data"). CalQuity treats all Client Data as strictly confidential. Specifically:

Client Data is NOT used to train, fine-tune, or improve any AI model — including third-party models used in our infrastructure

Client Data is NOT shared with other clients, third parties, or affiliates for any commercial purpose

Client Data is processed only to deliver the services requested by the client

For enterprise and on-premises deployments, CalQuity may access Client Data solely for maintenance or support, and only with prior written consent from the client's authorised representative

3.4 Communications Data

If you contact us via email, our website contact form, or support channels, we retain the content of those communications and your contact details for the purpose of responding and maintaining service records.

3.5 Cookies and Tracking Technologies

Our website uses cookies and similar technologies. These include:

Strictly necessary cookies: Required for the website and Platform to function

Analytics cookies: Help us understand visitor behaviour (e.g., pages visited, time spent). We use anonymised, aggregate-only analytics

Preference cookies: Remember your display preferences

You can manage or disable non-essential cookies through your browser settings or via our cookie consent banner. Disabling cookies may affect some Platform features.

4. How We Use Your Data

We process personal and institutional data only for lawful, specific, and transparent purposes:

To provision and manage your user account and institutional subscription

To deliver the Platform's features — AI-powered research, document analysis, report generation, and collaboration tools

To authenticate users and maintain platform security

To send transactional communications: onboarding, service updates, billing, security alerts

To provide technical support and resolve disputes

To monitor and improve platform performance, reliability, and features

To comply with applicable laws, regulations, and legal obligations

To enforce our Terms of Service and other contractual obligations

We do not use your data for targeted advertising, sale to data brokers, or behavioural profiling.

5. Legal Bases for Processing

Depending on your jurisdiction, our processing of personal data is grounded in the following legal bases:

Contract performance: Processing necessary to fulfil our contractual obligations to your institution and to you as an authorised user

Legitimate interests: Operating, securing, and improving our Platform in a manner that does not override your rights

Legal obligation: Compliance with applicable Indian law (including the Companies Act, IT Act, DPDP Act) and any applicable foreign law

Consent: Where we rely on consent (e.g., non-essential cookies), you have the right to withdraw it at any time without affecting prior processing

6. Third-Party AI Infrastructure and Sub-processors

CalQuity uses third-party cloud infrastructure and, in certain product configurations, third-party large language model (LLM) API providers to power AI features. We take the following safeguards:

Zero data-retention agreements: CalQuity has contractually negotiated zero data retention terms with all LLM API providers we work with. This means provider systems do not store your queries or outputs beyond the time needed to generate a response

No model training: Your data is never used by third-party providers to train, evaluate, or improve their AI models

Data processing agreements: We maintain formal Data Processing Agreements (DPAs) with all sub-processors handling personal data

Data minimisation: We transmit only the minimum data required for the service request

Our key sub-processor categories include: cloud hosting providers (data centres in India and/or approved jurisdictions), LLM API providers (under zero-retention and no-training contracts), and authentication and security service providers.

A current list of material sub-processors is available upon request by emailing legal@calquity.com.

7. On-Premises and Private Deployments

For clients who opt for an on-premises or private cloud deployment:

All Client Data remains within the client's infrastructure. CalQuity does not have persistent access to that data

CalQuity personnel may access client systems solely for the purposes of installation, configuration, upgrades, or troubleshooting, and only upon receipt of explicit, written consent from an authorised representative of the client institution

No Client Data from on-premises deployments is transmitted to CalQuity servers without the client's explicit prior approval

In such deployments, the client institution acts as the primary data controller / data fiduciary for data hosted on their infrastructure

8. Data Retention

We retain personal data and Client Data only for as long as necessary to fulfil the purposes described in this Policy, or as required by law:

Active account data: Retained for the duration of your subscription

Post-termination: Account data is deleted or anonymised within 90 days of subscription termination, unless a longer period is required by applicable law or ongoing dispute resolution

Client Data uploaded to the Platform: Deleted promptly upon contract termination or upon the client's written request, whichever is earlier

Usage logs: Retained for up to 12 months for security and audit purposes, then deleted

Legal hold: Where required, data may be retained longer to comply with legal obligations or court orders

9. Data Security

CalQuity implements a layered, institutional-grade security framework appropriate to the sensitivity of the financial data we process:

Encryption in transit: All data transferred between users and the Platform is encrypted using TLS 1.2 or higher

Encryption at rest: Client Data stored on CalQuity infrastructure is encrypted at rest

Access controls: Role-based access control (RBAC) ensures that employees access only the data necessary for their role; production data access is restricted and logged

Audit logging: All administrative actions are logged and regularly reviewed

Vendor security: We assess the security posture of sub-processors before engagement and periodically thereafter

Incident response: We maintain a documented incident response plan. In the event of a data breach, we will notify affected clients and, where required, relevant authorities within the timeframes mandated by applicable law

10. Cross-Border Data Transfers

CalQuity is incorporated in India and primarily processes data within India. In cases where data is transferred to infrastructure or sub-processors located outside India (for example, where an LLM API provider operates data centres abroad), we ensure:

Such transfers occur only to countries or processors providing adequate data protection

Appropriate contractual safeguards (including standard contractual clauses or equivalent instruments) are in place

We comply with the cross-border transfer provisions of the DPDP Act 2023 and any rules notified thereunder

11. Your Rights as a Data Principal

Under the Digital Personal Data Protection Act 2023 and, where applicable, the General Data Protection Regulation (GDPR) and other laws, you have the following rights:

Right to access: Request a summary of the personal data we hold about you and how it is used

Right to correction: Request correction of inaccurate or incomplete personal data

Right to erasure: Request deletion of your personal data, subject to legal retention obligations

Right to grievance redressal: Lodge a complaint with CalQuity's grievance officer regarding our data practices

Right to withdraw consent: Where processing is consent-based, withdraw consent at any time

Right to nominate: Under the DPDP Act, nominate an individual to exercise rights on your behalf in the event of death or incapacity

Right to data portability (GDPR): Where applicable, receive your personal data in a portable format

Right to object and restrict processing (GDPR): Object to certain processing activities or request restriction

To exercise any of these rights, please contact us at legal@calquity.com. We will respond within the timeframe required by applicable law (generally 30 days). We may need to verify your identity before processing the request.

If you are not satisfied with our response, you have the right to lodge a complaint with the Data Protection Board of India (once operational) or the supervisory authority in your jurisdiction.

12. Children's Data

The CalQuity Platform is designed exclusively for institutional clients and professional users. We do not knowingly collect personal data from individuals under the age of 18. If we become aware that a minor's data has been collected, we will delete it promptly.

13. 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 business operations. When we make material changes:

We will update the "Effective Date" at the top of this Policy

We will notify institutional clients via email or in-Platform notification at least 15 days prior to the change taking effect

For non-material changes (e.g., clarifications, formatting), we will update the Policy without a formal notification period

Your continued use of the Platform following the effective date of the revised Policy constitutes acceptance of the changes.

14. Governing Law and Jurisdiction

This Privacy Policy is governed by the laws of the Republic of India. Any disputes arising under this Policy shall be subject to the exclusive jurisdiction of the courts of Kolkata, West Bengal.

15. Contact Us

For any questions, concerns, or requests relating to this Privacy Policy, please contact our Privacy / Legal Team:

CalQuity Technologies Private Limited

Address: Suite 501, 6 Garstin Place, Kolkata – 700001, West Bengal, India

Email: legal@calquity.com

Support: support@calquity.com

Phone: +91 91638 84849

CIN: U62099WB2024PTC272030

We aim to acknowledge all privacy-related enquiries within 48 business hours and resolve them within 30 days.