Privacy Policy

TruFactor Analytics LLP provides portfolio analytics, client-servicing and practice-management software, along with portfolio review and educational tools. For any privacy question, contact us at support@trufactor.in.

We also operate the TruFactor client app, listed on Google Play as “TruFactor: Portfolio Tracker”, for clients of participating independent mutual fund distributors (MFDs). TruFactor provides the technology platform; your MFD manages its client relationship and the portfolio records it maintains through the platform. Your financial-service relationship is with your MFD; TruFactor supplies the software.

Your app account is linked to one client record and one MFD. Your MFD must enable your access. The app shows that MFD’s identity, available distributor disclosure and published contact details. “Powered by TruFactor” identifies the platform provider. The app displays portfolio information and does not place investment orders.

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.

• Sign-in and account information — your registered email address, account identifier, authentication tokens and the link to your MFD’s client record. Sign-in uses an email verification code, an existing account password, or Google where available. Passwords are sent to our authentication provider for verification and are not saved by the client app. Google provides identity information such as your account identifier, email and basic profile information. This sign-in does not request Gmail, Drive or Calendar access.
• Client and portfolio information — your name, risk profile where recorded, portfolios, holdings, transactions, valuations, returns and allocations supplied through your MFD’s TruFactor account. The client app retrieves these records to display them; it does not ask you to upload statements.
• Device storage — your session, preferences, verified access context and saved portfolio information for offline viewing, subject to the limits below.
• Optional app lock — your device performs fingerprint, face or supported device-passcode authentication. The app receives the result; TruFactor does not receive biometric templates or your device passcode.

• 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.

Production versions of the client app use PostHog for product-usage analytics and Sentry for crash, error and performance diagnostics. Product events include screen visits, sign-in outcomes and feature interactions, with platform and app-version information. PostHog can derive approximate location from the network IP address before discarding that address; this does not use your device’s GPS. Analytics uses a generated identifier before sign-in and an account identifier after sign-in. These identifiers are pseudonymous, not fully anonymous. Sign-out resets the analytics identifier for subsequent activity; it does not erase earlier events.

The app’s product-analytics events do not include your name, email, phone number, portfolio values or holding details. Diagnostics process technical information such as stack traces, app and device information, timings and diagnostic context, with default personal-data collection disabled and additional filtering. We do not use these services to store your portfolio. The staging test build disables delivery to both services.

The client app accesses the record and portfolios associated with your linked MFD. Independent MFDs do not receive access to each other’s client portfolios through the app. Authentication, email-code delivery, hosting, analytics and diagnostics use service providers.

Choosing “Contact your MFD” opens WhatsApp or email using contact details published by your MFD. Any message you choose to send is handled by that application and your MFD. TruFactor platform support and privacy requests are separately labelled.

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), AI providers including Google Cloud Vertex AI and TypeSafe AI, and email, messaging, demo-scheduling, analytics and error-monitoring providers. We use these services for the purposes described here, subject to their applicable data-processing terms. 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.

Saved information on your device

Offline viewing is available only while both the last access check and the saved portfolio information are less than 24 hours old. Saved views show their timestamp. After that, an internet connection and successful access check are required. Signing out, changing accounts, or detecting changed ownership or revoked access clears saved identity and portfolio data. An offline device learns about revocation when it next reaches the server; the 24-hour limit bounds offline viewing.

This viewing limit does not mean every local storage entry is physically erased at exactly 24 hours, and does not set the retention period for server records or records held by your MFD. Managed database backups retain seven daily recovery points. Our separate database backup copies are scheduled to expire 90 days after creation; expiry processing may take additional time. Restricted backup copies are not used for normal app access. If a backup is restored, deletion requests must be reapplied before affected data is returned to service.

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.

Client-app account and data deletion

Open Profile → Data and deletion requests in the app, or use our data request form without signing in. Choose “Erase my personal data”, enter your registered app email, and state that you want your TruFactor client-app account and associated data deleted. Include your MFD’s business name if known. Do not include passwords, sign-in codes or financial statements.

We may verify your identity and clarify which records your request covers. Account deletion differs from signing out or disabling app access. It does not redeem investments or automatically close accounts held with an AMC or another financial institution. If records must be retained for legal or regulatory obligations, we will explain the reason and retention period when responding.

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). AI providers may process and retain submitted data outside India, as described below. 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 using its global endpoint, including Gemini and Claude models, and TypeSafe AI makes the quick checks described below. AI processing and retention may occur outside India. We do not promise India-only processing or zero provider retention.
• Quick checks by TypeSafe AI — TypeSafe AI’s Jev model answers narrow questions inside our advisor assistant. For example, it judges whether saved client context means a rebalancing plan needs an advisor’s review, whether a client’s plan rules out an asset class flagged by the advisor’s market view, which prepared charts, tables and downloads to feature with an answer, whether an answer is out of date or contradicts the information it used, whether a Tool Maker request is ready to build, whether a research question needs our research service, and whether a suggested client nudge is supported by its evidence. Its answers can hide, place or flag the assistant’s work for review; they never approve or carry out an action.
• What TypeSafe AI receives — depending on the check: the advisor’s question and recent conversation; the assistant’s answer and descriptions of its charts and tables, which can include a client’s name and portfolio figures; material an answer drew on, including web and economic research, Knowledge Library documents, earlier assistant conversations and saved client reviews; Tool Maker conversations; and research questions, sent only when they contain no client names, contact details or identifiers. Rebalancing and market-view checks add a summary of the client’s portfolio and plan — allocations, constraints, cash flows, tax estimates, portfolio value, goals, profile details such as income, time horizon and liquidity needs, standing instructions and market views — without account identifiers or raw tax lots. Nudge checks first remove names, contact details, PAN, folio and account numbers. Advisor-written text can still contain personal information.
• No training on your data — our AI providers do not use your prompts, inputs or outputs to train their 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.

Advisors may optionally connect their own Google Calendar to TruFactor. This section describes exactly what that connection does, because Google user data is held to a stricter standard than the rest of this Policy. Connecting is entirely voluntary, is off unless an advisor turns it on, and can be withdrawn at any time.

• What we access — permission to manage events on Google calendars you own (https://www.googleapis.com/auth/calendar.events.owned), plus basic Google account identity and your email address (openid and email) so you can see which account is connected. We write events only to your primary calendar. Earlier connections may retain the broader Calendar events permission until you revoke access in your Google account and reconnect. We request no access to Gmail, Contacts, Drive, Photos, Tasks, or any other Google service, and we cannot read an advisor’s email.
• How we use Calendar access — Google’s event permission includes reading and writing. TruFactor uses it to create, update and delete Google copies of reminders and meetings created in TruFactor, including reminders you approve from TruAI. We process Google’s responses to those writes, including the event identifier. We do not fetch, index or import unrelated calendar entries, and changes made in Google Calendar are not imported into TruFactor.
• Client invitations — when an advisor books a meeting in TruFactor and links it to a client, that client’s email address is added to the calendar invitation and Google sends them an invite, along with a Google Meet link. This happens only for a meeting the advisor creates themselves. Nothing our AI assistant proposes can ever add a client to an invitation or send them an email.
• What we store — a Google refresh token, encrypted at rest with AES-256-GCM; the email address of the connected Google account, shown back to the advisor so they can confirm which account is linked; the permission Google granted; and the identifier of each calendar entry we created, so a later edit updates that same entry instead of duplicating it. Tokens are readable only by the application server and never by a browser.
• What we never do — we do not sell Google user data, do not share it with third parties, do not use it for advertising or profiling, and do not use it to train, retrain or improve any artificial-intelligence model, our own or anyone else’s. It is used solely to provide the calendar feature to the advisor who enabled it.
• How to withdraw — an advisor can disconnect at any time from Account → Calendar in TruFactor, which permanently deletes the stored token. Access can also be revoked directly from the advisor’s own Google account permissions page. Calendar entries already created remain in the advisor’s calendar, under their control, exactly like any entry they made themselves.

TruFactor’s use and transfer of information received from Google APIs to any other app will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

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.