Effective Date: 25-05-2025
Last Updated: 25-05-2025

1. Introduction

Portfolio Auditor ("we," "us," or "our") is committed to protecting your privacy and personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mutual fund portfolio analysis services through our website at www.portfolioauditor.com (the "Service").

By using our Service, you agree to the collection and use of information in accordance with this Privacy Policy. If you do not agree with the terms of this Privacy Policy, please do not access or use the Service.

Contact Information:

• Business Address: 58, Ground Floor, 2nd Main Road, Nagapareddy Layout, Kaggadaspura, Bangalore, Pin Code - 560093
• Email: support@portfolioauditor.com
• Website: www.portfolioauditor.com

2. Information We Collect

2.1 Personal Information

We collect the following types of personal information:

Account Registration:
• Name
• Email address

Contact Communications:
• Name
• Email address
• Mobile number (when you contact us through our "Contact Us" page)

Financial Data:
• CAMS PDF statements containing your mutual fund investment transaction data (collected only when you choose to use our analysis services)

2.2 Automatically Collected Information

Cookies and Session Data: We use cookies and similar tracking technologies to maintain your login session and ensure secure navigation of our application. These technologies help us:

• Maintain your authenticated session
• Ensure application security
• Improve user experience

3. How We Use Your Information

We use the collected information for the following purposes:

3.1 Service Provision

• Portfolio Analysis: Process your CAMS statements to perform comprehensive mutual fund portfolio analysis and generate performance comparison reports against benchmark funds
• Account Management: Maintain your user account and provide access to our services
• Communication: Send notifications when analysis reports are ready or if there are issues with uploaded documents

3.2 Automated Processing

Our Service includes automated analysis and profiling features:

• We use a Portfolio analysis tool built on Power BI technology to analyze your investment data
• Automated generation of comprehensive analysis reports comparing your portfolio performance against benchmarks
• Performance mimicking against standard or custom benchmark funds using publicly available NAV data

3.3 Data Sources

To provide accurate benchmark comparisons, we use the open-source "mftool" package to fetch publicly available NAV history for benchmark funds.
Important: We do not share your uploaded CAMS data with this or any other third-party tool.

4. Data Sharing and Disclosure

4.1 Third-Party Sharing

We do not share your personal information with third parties except as described in this Privacy Policy.

4.2 Legal Disclosures

We may disclose your personal information in the following circumstances:

Legal Requirements: If required to do so by law or in good faith belief that such action is necessary to:
• Comply with a legal obligation
• Protect and defend our rights or property
• Act in urgent circumstances to protect the personal safety of users or the public
• Protect against legal liability

Business Transfers: In the event that Portfolio Auditor is involved in a merger, acquisition, sale of assets, or other business transfer, your personal information may be transferred as part of that transaction. We will provide notice before your personal information is transferred and becomes subject to a different privacy policy.

5. Your Rights and Choices

You have the following rights regarding your personal information:

5.1 Data Subject Rights

• Access: Request access to the personal information we hold about you
• Correction: Request correction of any inaccurate or incomplete personal information
• Deletion: Request deletion of your account and all associated data, including transactional data and personal information shared during signup
• Restriction of Processing: Request restriction of processing under certain circumstances
• Data Portability: Receive your personal information in a structured, commonly used, machine-readable format and transmit it to another controller

5.2 Exercising Your Rights

To exercise any of these rights, please contact our support team at support@portfolioauditor.com. We will respond to your request in accordance with applicable data protection laws and after verifying your identity.

5.3 Marketing Communications

If we send you marketing communications, you can opt-out by clicking the "unsubscribe" link provided in those emails.

6. Data Security

We are committed to protecting the security of your personal information through multiple layers of protection:

6.1 Security Measures

• Encryption: Data is encrypted at rest in our backend database to protect against unauthorized access
• Access Controls: Strict access controls limit access to personal information to authorized personnel only
• Secure Transmission: We use secure protocols (HTTPS) for all data transmission between your browser and our servers
• Regular Security Reviews: We regularly review and update our security practices to align with industry standards and evolving threats

6.2 Financial Data Protection

Given the sensitive nature of financial information, we implement enhanced security measures for processing CAMS statements and analysis reports, including secure storage and controlled access protocols.

7. Data Retention

7.1 Retention Periods

• Customer Account Data: Maintained until you explicitly request account deletion
• CAMS Statements and Analysis Reports: Automatically deleted after a maximum period of 30 days from our backend systems
• Legal Retention: Certain information may be retained longer if required by law, to resolve disputes, prevent fraud and abuse, or for legitimate business interests

8. Data Breach Notification

In the event of a data breach that poses a high risk to your rights and freedoms, we will:

• Notify affected users without undue delay as required by applicable data protection laws
• Provide notification via email when possible
• Include information about the nature of the breach, likely consequences, and measures taken to address and mitigate the breach
• Assess breach risk based on the sensitivity and volume of impacted data

9. International Data Transfers and Jurisdictional Compliance

9.1 Global Accessibility

Our web application is accessible globally via the internet.

9.2 Applicable Laws

We strive to comply with applicable privacy laws depending on user location, including:

• Digital Personal Data Protection Act, 2023 for users in India
• Other applicable international privacy regulations as relevant

9.3 International Transfers

Your personal information may be transferred to and processed in countries other than your country of residence. By using our Service, you consent to such transfers. We take reasonable steps to ensure your personal information is treated securely and in accordance with this Privacy Policy.

10. Special Considerations

10.1 Children's Privacy

Our Service is intended for adults and does not knowingly collect personal information from children under 18 years of age. If we become aware that we have collected personal information from a child without verifiable parental consent, we will take steps to delete that information.

10.2 Financial Data Processing

We process financial-related data contained within CAMS statements with appropriate security measures as outlined in Section 6 of this Privacy Policy. This information is retained only for the periods specified in Section 7.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. We will notify you of any material changes by:

• Posting the new Privacy Policy on this page
• Updating the "Last Updated" date at the top of this Privacy Policy
• Sending notification via email for significant changes

Your continued use of the Service after any modifications indicates your acceptance of the updated Privacy Policy.

12. Contact Us

If you have any questions about this Privacy Policy or our privacy practices, please contact us at:

Portfolio Auditor

• Email: support@portfolioauditor.com
• Address: 58, Ground Floor, 2nd Main Road, Nagapareddy Layout, Kaggadaspura, Bangalore, Pin Code - 560093

This Privacy Policy is designed to comply with applicable data protection laws and regulations. We recommend consulting with legal counsel to ensure full compliance with all applicable laws in your jurisdiction.