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Privacy policy

What we collect, why, who can see it, and how to see, fix or delete it. Written for India’s DPDP Act 2023 and friendly to Europe’s GDPR.

Draft v1Last updated 12 min read

DraftA lawyer will review this before accounts go live, so some details may change. Company registration in progress. Full legal details will be published here once registration completes. Words in [brackets] are details we will confirm. If anything here is unclear, ask us and we will explain it in plain words.

The short version

  • We collect only what we need to run your account, journal, payments and Rooms. We never sell your data.
  • Trading connections are read-only, encrypted in a separate key store, and deleted the moment you disconnect.
  • Room owners see only their own members’ handles, and only what you agree to share.
  • You can see, correct, export or delete your data, and withdraw consent, any time.
  • If there is ever a breach, we tell you without delay and report it within 72 hours.

This summary helps you find your way. The full text below is what counts.

01Who we are

CandleHall runs CandleHall and decides how your personal data is used. Company registration in progress. Full legal details will be published here once registration completes. Under India’s Digital Personal Data Protection Act, 2023 (DPDP Act) we are the “Data Fiduciary”. Under the EU and UK GDPR we are the “controller”.

This policy covers candlehall.com, the CandleHall app, the academy, the journal and every community Room. Owners of hosted Rooms are responsible for anything they collect from you outside CandleHall.

02Data we collect

We only collect what we need to run CandleHall. Here is all of it:

Personal data we collect
TypeExamplesWhere it comes from
AccountEmail, password (stored as a scrambled hash we can’t read), login times, two-step login settingsYou
ProfileDisplay name or handle, avatar, bio, markets you trade, time zoneYou
Country of residenceThe country you live in, plus signals used to check it (payment country, network location)You, our payment provider, your device
Trades and journalTrades, prices, sizes, results, notes, tags, screenshots you attach, uploaded statementsYou, or your read-only connection
Read-only connectionsMT4/MT5 server and login number with investor password (outside India only); exchange read-only API keys; sync statusYou
PaymentsPlan, amounts, dates, last 4 digits and card type, USDT network, wallet address and transaction ID, tax details for invoicesYou, our payment providers, the blockchain
CommunityPosts, messages, reactions, reports, Room memberships, strikes and appealsYou and other members
Owners onlyIdentity check (KYC) documents, legal name, address, tax IDs, payout detailsOwners
Device and usageIP address, browser and device type, pages and features used, crash reportsYour device
SupportEmails and chats with us, grievance recordsYou

We don’t collect your master trading password, card numbers in full, seed phrases or government ID numbers from members. We never buy data about you from data brokers.

03Why we use it

Each use has a clear purpose, and a reason the law accepts:

Purposes for using personal data
PurposeData usedReason (legal basis)
Create and secure your accountAccount, deviceYour consent and our contract with you
Run the journal, analytics and AI reviewsTrades and journal, connectionsYour consent and our contract with you
Apply India mode and other country rulesCountry of residenceLegal duty
Take payments, send receipts, keep tax recordsPaymentsContract and legal duty
Run Rooms, moderation, strikes and the Peace DeskCommunity, profileContract and legitimate use
Check owners’ identity and pay themOwner KYC and payout detailsContract and legal duty
Stop fraud, scams, scraping and abuseDevice, usage, communityLegitimate use and legal duty
Answer support requests and grievancesSupport and related dataContract and legal duty
Improve CandleHall (measure what works)Usage, only with your consent where neededConsent
Send product newsEmailConsent (you can switch it off any time)

We don’t sell your data. We don’t use it for advertising, and we don’t let advertisers track you on CandleHall.

0518 and over only

CandleHall is only for people aged 18 or over. We don’t knowingly collect data from children. If we learn that an account belongs to someone under 18, we close it and delete its data. If you think a child is using CandleHall, please tell us.

06How we protect your trading credentials

Read-only, always

We can never place, change or close your trades, and we can never move or withdraw your money. We only accept credentials that can’t do those things.
  • Read-only only. For MT4/MT5 we accept the investor password, never the master password. For exchanges we accept API keys with trading and withdrawal switched off, and we reject keys that have those rights where the exchange lets us check.
  • Passed on, not kept, where possible. Investor passwords are passed to our trade-sync provider to connect your account. Where the provider allows, we don’t store the password ourselves after the connection is made.
  • Encrypted in a separate key store. Anything we must hold is encrypted, and the keys are kept in a separate key store, away from our main database.
  • Few hands. Only automated sync systems use credentials. Staff can’t see them in plain text.
  • One-click disconnect. Disconnect in Settings and we delete the stored credentials. For extra peace of mind, you can also change the investor password or delete the key at your broker or exchange.

07How we protect everything else

  • Data is encrypted in transit (HTTPS) and at rest.
  • Staff access is limited to what their job needs, uses two-step login, and is logged.
  • We keep security logs of access to personal data for at least one year, so we can spot and investigate misuse.
  • Backups are encrypted and tested. Our providers must meet the same standard in writing.
  • Room member lists are hidden, profile views and search are rate-limited, and scraping is blocked, so other users can’t harvest your details.

08Who we share data with

We use trusted service providers (“processors”) that handle data only on our instructions and under written contracts. We name the categories here and share the current list on request:

Categories of service providers
Provider typeWhat they doData involved
Hosting and databaseRun our servers and store dataAll data we hold
Email deliverySend receipts, alerts and repliesEmail, name, message content
VideoStream course and Room videosViewing data, account ID for watermarks
PaymentsProcess cards and USDT payments, prevent payment fraudPayment details, country, email
AI providersPower AI reviews and the AI coachThe trades and text you send to AI features
Trade-sync providerConnect read-only to MT4/MT5 accountsAccount number, server, investor password
Identity checksVerify owners who charge moneyOwner KYC documents
Support and error trackingHelp desk and crash reportsSupport messages, device data

We only choose AI providers whose terms don’t let them train their models on the data we send.

What Room owners can see

  • An owner sees only their own Room’s members: your handle, and what you post in their Room.
  • They see contact details only if you agree to share them, for example when you joined through their invite link and ticked the box.
  • They never see your other Room memberships, your journal, your trades or your payment details, unless you choose to share a verified share card.

Other sharing

  • Authorities: when the law requires it, for example a court order or a lawful request from a regulator or police.
  • Safety: to stop fraud or protect someone from harm.
  • Business change: if CandleHall is sold or merged, your data moves only under this policy, and we tell you first.

09International transfers

CandleHall serves traders in many countries, so your data may be stored or processed outside the country where you live, including outside India and the EU. When we move data across borders:

  • we only transfer to countries the law allows (India can restrict some countries, and we follow that);
  • for data from the EU or UK, we use approved safeguards such as the European Commission’s standard contractual clauses;
  • our providers must protect your data to the same standard as this policy.

10How long we keep data

How long we keep each type of data
DataHow long
Account, profile, journalWhile your account is open. Deleted within 30 days after you delete your account.
Read-only credentialsUntil you disconnect or delete your account. Deleted at once.
Posts in RoomsUntil you or a moderator deletes them, or you delete your account.
Payment and tax recordsAs long as tax law requires (often 6 to 8 years), then deleted.
Security and access logsAt least 1 year, then deleted.
Moderation records (strikes, appeals)Up to 12 months after a strike expires, longer for serious fraud.
Owner KYCWhile the Room runs, then as long as anti-fraud and tax law requires.
BackupsOverwritten within 35 days.

Delete your account in Settings at any time. Download your journal first if you want to keep it. We confirm by email when deletion is complete.

11Your rights

You can ask us to:

  • See a summary of the data we hold about you, what we do with it, and who we shared it with.
  • Correct or complete anything wrong or missing.
  • Erase your data when it’s no longer needed, or when you withdraw consent.
  • Take it with you: export your journal and profile in a common file format.
  • Withdraw consent or object to a use, for example product emails.
  • Nominate someone to use these rights for you if you die or can no longer act for yourself.
  • Complain to our Grievance Officer, and if you are not satisfied, to the Data Protection Board of India, or to your local data protection authority if you live in the EU or UK.

Most of this works directly in Settings. For anything else, write to the Grievance Officer. We may need to confirm it’s really you. We acknowledge within 48 hours and answer within the time the law sets, and in any case within 30 days.

12If something goes wrong

If there is a personal data breach that affects you:

  1. We act at once to contain it and find out what happened.
  2. We tell you without delay: what happened, what data was involved, what we are doing and what you can do (for example, change a password).
  3. We report it within 72 hours to the Data Protection Board of India and, where they apply, to other authorities.
  4. We fix the cause and publish what we changed.

Because we only hold read-only credentials, nobody who gets them can trade or withdraw from your accounts. We still ask you to change them if there is any breach.

13Cookies

Cookies are small files your browser stores. We keep them to a minimum:

  • Essential: keep you logged in, protect forms from attacks, and remember settings such as your country mode. These are always on, because the site doesn’t work without them.
  • Measurement (optional): privacy-friendly statistics about which pages are used. Only with your consent, and you can change your choice any time.
  • No advertising cookies and no cross-site tracking.

14Changes to this policy

When we change this policy in a way that matters, we tell you by email and in the app before it applies, and ask for fresh consent where the law requires. The date at the top always shows the latest version.

15Contact and Grievance Officer

Data Fiduciary
CandleHall
Registered office
Published once registration completes
Grievance Officer
CandleHall support team

The Grievance Officer answers questions about privacy and your rights. Until a grievance email is set up, please message CandleHall Support on Telegram. We acknowledge complaints within 48 hours.

Questions

Message CandleHall Support on Telegram. A person replies, usually within 2 working days.

Grievance Officer

CandleHall support team, on Telegram at CandleHall Support until a grievance email is set up. We acknowledge complaints within 48 hours.