Privacy Policy

TruFactor Analytics LLP is a Mutual Fund Distributor registered with the Association of Mutual Funds in India (AMFI Registration No. 364110). We provide mutual fund distribution along with portfolio review, analytics and educational tools. For any privacy question, contact us at support@trufactor.in.

This Policy also applies to the TruFactor mobile application (“the App”), through which existing clients sign in with a one-time email code (optionally unlocking with fingerprint/face) to view their own portfolio. The App displays records we already hold for you and does not ask you to enter them; the data practices described in this Policy apply equally to it. In the App we use privacy-preserving product analytics and crash/error monitoring that are tied only to an anonymous identifier — never to your name, email, phone number, or any monetary amount or holding.

Information you provide

• Contact and identity details — name, email address, phone number and any details you share when you book a demo, request a portfolio review, sign up, or contact us.
• Financial and portfolio information — mutual fund holdings, transactions, SIPs, redemptions and related details contained in the statements you upload (for example CAMS, KFintech or other RTA / AMC statements), along with the goals, cash-flow and risk preferences you choose to share. Financial information is treated as sensitive personal data.
• Optional dictated context — when an advisor uses microphone capture, the recording is processed only for that extraction request and discarded. TruFactor does not save the raw audio in browser storage, its database, files, logs or the resulting approval record; only the structured context the advisor reviews and chooses to save is retained.

Information collected automatically

• Technical and usage data — IP address, device and browser type, pages viewed, referring links and similar diagnostics, collected through cookies and analytics to keep the service secure and improve it.

• To provide our services — generate portfolio reviews, analytics, projections and tool outputs, and to facilitate mutual fund distribution.
• To communicate with you — respond to enquiries, schedule and conduct demos, and send service-related updates.
• To operate, secure, maintain and improve our website and products.
• To comply with applicable law and regulatory obligations, and to prevent fraud or misuse.

We process your personal data on the basis of the consent you provide and for the legitimate uses permitted under the Digital Personal Data Protection Act, 2023. By using our services and submitting your information, you consent to the processing described in this Policy. You may withdraw your consent at any time (see “Your rights” below); withdrawal does not affect processing already carried out, and some features may stop working if the underlying data is withdrawn.

We use cookies and similar technologies to keep you signed in, remember preferences, measure usage and improve performance. You can control or delete cookies through your browser settings; disabling some cookies may affect how parts of the site work.

We do not sell your personal data. We share it only as needed to run our services, and with appropriate safeguards:

• Service providers (Data Processors) — our database, storage and backup hosting (in India), our AI assistant provider (data stored in India), and email, messaging, demo-scheduling, analytics and error-monitoring providers. They process data only on our instructions and only for the purposes described here. Some operate outside India (see “Transfers and processing locations” below).
• Mutual fund ecosystem — Asset Management Companies, Registrars and Transfer Agents (RTAs) and platforms, to the extent required to facilitate the distribution transactions you choose to make.
• Legal and regulatory — authorities, regulators or courts where disclosure is required by law or to protect our rights, users or the public.

We keep personal data only for as long as necessary for the purposes set out in this Policy, or as required to meet legal, regulatory, accounting or reporting obligations. When data is no longer required, we delete or anonymise it.

We maintain reasonable security practices and procedures appropriate to the sensitivity of the information, in line with the Information Technology Act, 2000 and applicable rules. These include access controls, encryption in transit and other technical and organisational measures. No method of transmission or storage is completely secure, so we cannot guarantee absolute security.

As a Data Principal, you have the right to:

• access a summary of the personal data we process about you;
• request correction, completion or updating of your data;
• request erasure of your personal data, subject to legal limits;
• withdraw consent previously given;
• nominate another individual to exercise your rights in the event of death or incapacity; and
• raise a grievance with us, and escalate to the Data Protection Board of India if unresolved.

Once a verified erasure request enters TruAI erasure processing, we block new client-linked TruAI proposals and attachments, remove the related structured content, and retain only the minimal deletion-control record needed to complete or retry removal of a stored report file. That control record contains an object path and deletion timestamps, not the report contents, and remains restricted to the erasure service.

To exercise any of these rights, use our data request form or write to us at support@trufactor.in. We may need to verify your identity before acting on a request.

Our services are intended for individuals aged 18 and above. We do not knowingly process the personal data of children without the consent of a parent or lawful guardian. If you believe a child has provided us data without such consent, please contact us so we can remove it.

Your core data — your account, your portfolio and the statements you upload — is stored in India. Some service providers process limited data outside India: product analytics (EU) and error monitoring (US), demo scheduling (EU), and email and messaging delivery (which may route through the US or global infrastructure). Our AI assistant stores data in India, though its processing may occur outside India. Where data is transferred outside India, we do so in accordance with applicable law and with safeguards appropriate to the data.

We may update this Policy from time to time. The “Last updated” date at the top reflects the latest revision. Material changes will be notified through our website or other appropriate means.

We use artificial intelligence to make our services more useful. Our advisor assistant, TruAI, helps registered advisors analyse portfolios, surface insights, draft reports and answer questions about data they are authorised to access. Where AI features are used, the personal and financial data described in this Policy may be processed by them.

• Provider and location — our AI features are powered by Google Cloud Vertex AI (Gemini models), configured to process in the Mumbai, India (asia-south1) region with data stored in India. While storage is in-region, the AI computation (inference) may, depending on the provider’s infrastructure, be processed outside India.
• No training on your data — our AI provider does not use your prompts, inputs or outputs to train its models.
• Human oversight — AI outputs are assistive. A human reviews material outputs, and any outward or bulk action requires explicit confirmation. We do not make decisions that produce legal or similarly significant effects about you solely by automated means without human involvement.
• Accuracy — AI-generated content may be incomplete or incorrect and is provided for information only. It is not investment advice; please see our Disclaimer & Disclosures.

We may expand our use of AI over time and will update this Policy as it evolves.

For any question, request or complaint relating to your personal data, contact our Grievance Officer:

You may also refer to our Grievance Redressal page for the full process and escalation route.