Privacy Policy
Version 1.0 · Effective [date — pending SKEPTIX]
1. Who We Are and How to Contact Us
1.1 SKEPTIX is the business name under which [full name of proprietor / owner — pending SKEPTIX] carries on the business of software development and trading technology, from Gujarat, India. SKEPTIX is presently operated as an unregistered business (sole proprietorship). It is not an incorporated company, and "SKEPTIX" is a trade name and not a registered corporate entity.
1.2 We own and operate the website skeptix.in ("Website").
1.3 You can contact us at:
Email: skeptix.in@gmail.com
WhatsApp / Phone: +91 96628 34620
Grievance Officer: see Clause 18
GSTIN: [GSTIN or turnover-threshold statement — pending SKEPTIX]
1.4 Our principal place of business is in [city — pending SKEPTIX], Gujarat, India. Our full postal address is available on written request to the email address above, and is provided on every invoice we issue.
1.5 This document is our Privacy Policy. It also serves as the notice we are required to give you under Section 5 of the Digital Personal Data Protection Act, 2023 ("DPDP Act") and the Digital Personal Data Protection Rules, 2025 ("DPDP Rules"), and as the published privacy policy required under the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 and the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021.
1.6 Under the DPDP Act, we are the Data Fiduciary and you are the Data Principal. Where the EU or UK General Data Protection Regulation applies, we are the controller.
1.7 Languages. This Policy is published in English. On request, and at the point where we seek your consent, we will make its contents available in Gujarati, Hindi, or any other language specified in the Eighth Schedule to the Constitution of India. Write to us at the email address above to request another language.
2. Scope
2.1 This Policy applies to the Website and to all three of our business tracks:
- India Track (skeptix.in/india/) — custom analytical charting indicators for Indian markets, supplied for educational, analytical, study and demonstration use;
- Global Track (skeptix.in/global/) — licensed trading software for international clients, including clients in the European Union and United Kingdom;
- Web Development Track (skeptix.in/web-development/) — website design, development and related digital services for business clients.
2.2 Where a track collects or handles personal data differently, this is set out in Clause 15.
2.3 This Policy does not apply to third-party websites, platforms or services that we link to or that our products operate on. See Clause 17.
3. Summary
3.1 This table is a plain-language guide only. The detailed clauses below prevail if there is any difference. We do not sell your personal data to anyone.
| What we collect | Why | How long we keep it |
|---|---|---|
| Name, WhatsApp number, email, city, enquiry details | To answer your enquiry and prepare a quotation | Up to 24 months after last contact, unless a project proceeds |
| Files you upload (your rules, chart screenshots, references) | To scope and build what you asked for | For the project term, then 24 months |
| Name and WhatsApp number of customers | To send product updates, important notices and renewal reminders | For as long as you hold the product, plus 12 months |
| Website analytics data | To understand how the site is used (only if you accept analytics cookies) | Up to 14 months |
| Invoicing and tax details | To raise invoices and meet Indian tax law | 8 years |
4. What We Do Not Collect
4.1 No accounts. The Website has no user accounts, no login, no password, no client portal and no online payment checkout. You do not create an account or a password with us. Any message asking you to log in to a SKEPTIX account, or requesting a password, does not come from us.
4.2 We never collect, and will never ask you for:
- trading account passwords or investor passwords;
- broker login credentials of any kind;
- bank account passwords, net banking credentials, or debit or credit card numbers;
- UPI PINs;
- one-time passwords (OTPs);
- Aadhaar number, except where legally unavoidable;
- PAN, except where legally required to issue a tax invoice.
4.3 If any person asks you for any of the above while claiming to represent SKEPTIX, do not provide it, and report it to us immediately at the email address in Clause 1.3.
5. Personal Data We Collect
5.1 Enquiry and request forms. The Website has four forms: the India Track "Request an Indicator" form, the Global Track "Custom Build" form, the Web Development Track enquiry form, and a general Contact form. Depending on which you use, we collect: your name; your WhatsApp number, with country code; your email address; your city; your business name (Web Development Track); the instrument or market you are interested in; your platform preference; timeframes; a free-text description of your requirement, rules or project; your indicative budget range; your expected timeline.
5.2 WhatsApp. Every enquiry button on the Website opens WhatsApp with a pre-filled message. If you send it, the conversation continues on WhatsApp Business. See Clause 14.
5.3 File uploads. The request forms allow you to optionally upload files (PDF, PNG, JPG or TXT, maximum 10 MB) such as your own trading rules, chart screenshots, or reference material. We recognise this material may be commercially sensitive and confidential to you, and we treat it accordingly under Clause 13 and Clause 15.
5.4 Customer contact details for product updates and renewals. If you purchase, license or commission anything from us, we retain your name and WhatsApp number (and email, where provided) in order to: notify you of updates, corrections, fixes and new versions of the product you hold; notify you of any issue affecting your product, including a platform change that affects its operation; remind you when a subscription, licence period, activation or maintenance arrangement is due to expire or requires renewal; confirm renewals and issue related invoices; and provide support you request. See Clause 12.5 for your control over these communications.
5.5 Newsletter. We do not currently operate an email newsletter. If we introduce one, this Policy will be updated first and any signup will be opt-in and separate from your project communications.
5.6 Analytics. Usage data as described in Clause 8 — collected only if you accept analytics cookies.
5.7 Invoicing. If you buy from us, we collect the billing details required for a valid invoice, which may include name, billing address, and GSTIN or PAN where legally required.
5.8 Technical data. Our hosting and security providers automatically process technical data such as IP address, browser type, device type, and timestamps, for security, load balancing and abuse prevention.
6. Consent and Lawful Basis
6.1 India — DPDP Act. Our lawful basis for processing your personal data is your consent, which must be free, specific, informed, unconditional and unambiguous, given by a clear affirmative action, and limited to the purpose stated in this notice.
6.2 Consent checkboxes. Every form on the Website carries a consent checkbox that links to this Policy. It is never pre-ticked. You must tick it yourself.
6.3 India Track additional acknowledgement. On the India Track only, there is a second, mandatory checkbox by which you acknowledge that the indicator is supplied for educational, analytical and demonstration use, that it does not place orders or connect to any broker or trading account, and that all decisions are your own. The exact wording you agreed to is stored with your submission record as a durable record of what was disclosed to you.
6.4 Withdrawing consent. You may withdraw your consent at any time, and doing so is as easy as giving it (Clause 12.5). Withdrawal does not affect processing already lawfully carried out. Withdrawing consent may mean we can no longer provide the service you asked for.
6.5 Product updates and renewal reminders. Communications under Clause 5.4 are service communications relating to a product you hold — not promotional marketing. We send them because they are necessary to deliver and maintain what you have purchased. You may ask us to stop sending them at any time (Clause 12.5), but if you do, we will not be able to notify you of fixes, critical issues, or expiry of your licence, and you accept responsibility for tracking these yourself.
6.6 EU and UK — GDPR. Where the GDPR or UK GDPR applies to you, we rely on the following lawful bases:
| Activity | Lawful basis |
|---|---|
| Responding to your enquiry, preparing quotations, delivering and supporting products | Contract — Article 6(1)(b) |
| Product updates, critical notices, licence renewal reminders | Contract — Article 6(1)(b), or legitimate interests — Article 6(1)(f) |
| Analytics and marketing cookies | Consent — Article 6(1)(a) |
| Website security, spam and fraud prevention | Legitimate interests — Article 6(1)(f) |
| Invoicing, accounting and tax records | Legal obligation — Article 6(1)(c) |
7. Why We Process Each Category
| Data | Purpose |
|---|---|
| Enquiry and form data | Understand and respond to your request; prepare a quotation |
| Uploaded files | Scope, design and build what you asked for |
| WhatsApp number and message content | Communicate with you about your enquiry, project or product |
| Customer name and WhatsApp number | Send product updates, corrections, critical notices, and renewal reminders |
| Analytics data | Understand how visitors use the Website and improve it (consent-gated) |
| Invoicing and tax data | Raise invoices and comply with Indian tax and accounting law |
| Technical data | Security, abuse prevention and reliable delivery of the Website |
7.1 We do not use your personal data for any new purpose that is incompatible with the purpose for which it was collected, without giving you a fresh notice and, where required, obtaining fresh consent.
10. International Transfers
10.1 We are based in India and use some service providers located outside India. Your personal data may therefore be transferred to and processed in other countries.
10.2 Under the DPDP framework, transfer of personal data outside India is permitted except to any country restricted by the Central Government. We monitor for any such restriction and will comply with it.
10.3 EU and UK personal data. India does not currently benefit from an adequacy decision of the European Commission. Where we process personal data protected by the GDPR or UK GDPR, transfers rely on the European Commission’s Standard Contractual Clauses, with the UK International Data Transfer Addendum where applicable, and, where relevant, on our providers’ certification under the EU–US Data Privacy Framework and its UK extension.
10.4 You may request further information about these safeguards using the contact details in Clause 18.
11. How Long We Keep Personal Data
11.1 We keep personal data only for as long as necessary for the purpose for which it was collected, or as required by law, and then delete or anonymise it.
| Category | Retention period |
|---|---|
| Enquiry and form data, no project proceeds | Up to 24 months from last contact |
| Enquiry data, where a project proceeds | For the project term, then 24 months |
| Customer name and WhatsApp number, for updates and renewals | For as long as you hold the product, plus 12 months |
| WhatsApp conversation history | Duration of the business relationship, plus 24 months |
| Trading account numbers and licensing records (Global Track) | Licence term plus 24 months |
| India Track acknowledgement record (Clause 6.3) | 8 years, as a durable record of disclosure |
| Invoicing, accounting and tax records | 8 years, in line with Indian record-keeping requirements |
| Server and security logs | 12 months |
11.2 We erase personal data once its purpose is served, or on withdrawal of consent, unless we are required by law to retain it. Where a legal dispute, audit, investigation or regulatory proceeding is open or reasonably anticipated, we retain relevant records until it concludes.
12. Your Rights
12.1 Under the DPDP Act, you have the right to: obtain a summary of the personal data we process about you and the processing activities we undertake; obtain the identities of other Data Fiduciaries and Data Processors your data has been shared with; request correction, completion, updating and erasure of your personal data; grievance redressal through the mechanism in Clause 18; nominate another individual to exercise your rights in the event of your death or incapacity; and withdraw consent at any time.
12.2 Under the GDPR and UK GDPR, if they apply to you, you additionally have the rights of access, rectification, erasure, restriction of processing, data portability, and objection, and the right not to be subject to a decision based solely on automated processing producing legal or similarly significant effects. We do not carry out such automated decision-making (Clause 17.1).
12.3 How to exercise your rights. Contact us using the details in Clause 18. We may need to verify your identity before acting, to ensure we do not disclose your data to the wrong person.
12.4 Our response times. DPDP requests: without undue delay, and in any event within a reasonable period. DPDP grievances: within 90 days. GDPR and UK GDPR requests: within one month of receipt, extendable by up to two further months for complex requests.
12.5 Stopping communications. Product updates and renewal reminders: write to us or reply STOP on WhatsApp. Please note that if you opt out, we will not be able to inform you of fixes, critical issues, platform changes affecting your product, or the expiry of your licence, and you will be responsible for tracking these yourself. Support conversations relating to an open request are not marketing and continue until the request is resolved.
12.6 Complaints to a regulator. If you are not satisfied with our response, you may complain to the Data Protection Board of India. If you are in the EU or UK, you may complain to your local supervisory authority.
13. Security
13.1 We implement reasonable security safeguards to protect personal data, including as appropriate: access controls limiting who can reach systems holding personal data; logging and monitoring to detect unauthorised access; backups; storage of files you upload in private storage accessed only through time-limited signed URLs, never at a publicly guessable address; spam and bot protection using hCaptcha; transmission of all data over HTTPS; and contractual security obligations imposed on our service providers.
13.2 We retain security logs for 12 months to support detection, investigation and remediation.
13.3 No system is completely secure. We cannot guarantee absolute security, but we take the measures described above and review them periodically.
13.4 Personal data breach. On becoming aware of a personal data breach, we will notify each affected Data Principal without delay, in plain language; notify the Data Protection Board of India without delay; and, where EU or UK personal data is affected, notify the relevant supervisory authority within 72 hours where the breach is likely to result in a risk to individuals’ rights, and notify affected individuals where the risk is high.
14. WhatsApp
14.1 WhatsApp is our primary communication channel. Enquiry buttons on the Website open WhatsApp with a pre-filled message. If you choose to send it, the conversation continues on WhatsApp Business, operated by Meta.
14.2 When you message us, Meta processes your phone number, your message content, and related metadata under Meta’s own terms and privacy policy, over which we have no control. Messages between you and us are end-to-end encrypted in transit. We use the conversation only for our stated business purposes.
14.3 We retain your WhatsApp number after a purchase in order to send you product updates, critical notices and renewal reminders, as described in Clause 5.4. You can stop these at any time under Clause 12.5.
14.4 Please do not send passwords, OTPs, card numbers, UPI PINs, broker credentials or other financial credentials over WhatsApp. We will never ask for them. If you prefer not to use WhatsApp, you can email us instead at the address in Clause 1.3.
15. Track-Specific Provisions
15.1 India Track
(a) We supply custom analytical charting indicators for Indian markets, for educational, analytical, study and demonstration use.
(b) SKEPTIX is not a SEBI-registered Investment Adviser or Research Analyst. We do not provide investment advice, trading recommendations, calls or tips.
(c) Indicators supplied on this track do not connect to any broker, exchange or trading account, do not place, route or execute any order, and do not act on your behalf in any way. We do not collect any trading account number, broker identifier or account credential on this track.
(d) The acknowledgement record described in Clause 6.3 — the exact wording of the educational-use confirmation you ticked, together with the date and time — is stored with your submission and retained for 8 years.
(e) Files you upload on this track frequently contain your own trading rules and method. This material is treated as your confidential information, is not reused for any other client, and is covered by Clause 13 and by the confidentiality terms of our Terms and Conditions.
15.2 Global Track
(a) We license trading software to international clients, which you install and operate on your own account with your own broker.
(b) Trading account numbers. Where a licensed Product is bound to a specific trading account using an activation key, we collect and store the account number you provide for that purpose at the point the licence is issued — this is separate from, and not part of, the general enquiry forms described in Clause 5.
(c) What an account number is and is not. A trading account number simply identifies an account. It is not a credential. It gives no access to your funds, no ability to place orders, and no ability to view your positions. We cannot trade on your account, and we never ask for your trading account password or investor password.
(d) We use account numbers only to issue, bind, verify, reissue and maintain your licence, and to provide support. We do not use them for marketing and do not disclose them to third parties.
(e) If you are a consumer in the EU or UK, the additional rights described in Clauses 6.6, 10.3 and 12.2 apply to you.
15.3 Web Development Track
(a) We provide non-financial website design, development and related services to business clients.
(b) We collect business contact and project details, including business name, and any credentials you choose to share for the purpose of the project, such as hosting, domain or content management access.
(c) Project credentials. Where you give us access credentials to perform work, we use them only for that purpose, store them securely, and ask you to revoke or change them after handover. We recommend you create a separate limited-access account for us rather than sharing your primary credentials.
(d) We do not collect trading data or trading account numbers on this track, and no trading-related provision of this Policy applies to it.
16. Children
16.1 Our services are intended for persons aged 18 years or over. We do not knowingly collect personal data of anyone under 18.
16.2 We do not undertake tracking, behavioural monitoring or targeted advertising directed at children.
16.3 If we become aware that we have collected the personal data of a person under 18 without verifiable parental or guardian consent, we will delete it promptly. If you believe a child has provided us personal data, contact us at the address in Clause 18.
17. Automated Decisions and Third Parties
17.1 Automated decision-making. We do not carry out any solely automated decision-making or profiling that produces legal effects concerning you or similarly significantly affects you.
17.2 Third-party platforms. Our products operate on, and our Website references, third-party platforms including TradingView, MetaTrader 5, the MQL5 Market and WhatsApp. These are controlled by others and governed by their own privacy policies and terms. This Policy does not cover them, and we have no control over their data practices.
17.3 External links. The Website may link to external sites. We are not responsible for their content or their privacy practices.
18. Grievance Officer and Contact
18.1 In accordance with the DPDP Act, the Information Technology (Reasonable Security Practices) Rules 2011, and the Information Technology (Intermediary Guidelines) Rules 2021, our Grievance Officer is:
Name: [full name — pending SKEPTIX]
Designation: [designation — pending SKEPTIX]
Email: supportskeptix@gmail.com
WhatsApp / Phone: +91 92135 63582
Working Hours: Mon–Fri, 10:00 AM – 5:00 PM IST
18.2 How to raise a grievance. Write to the Grievance Officer stating your name, contact details, the nature of your grievance, and the outcome you seek.
18.3 Our timelines. We acknowledge every grievance within 48 hours of receipt, and issue you a unique reference number. We resolve grievances within one month of receipt. Grievances raised specifically under the DPDP Act are addressed within 90 days.
18.4 EU and UK representatives. EU representative under Article 27 GDPR: not appointed — see Clause 18.5. UK representative: not appointed.
18.5 Where a representative has not been appointed, EU and UK data subjects may contact us directly using the details in Clause 18.1, and we will respond within the timelines in Clause 12.4.
19. Changes to This Policy
19.1 We may update this Policy from time to time, for example to reflect changes in law, in our services, or in the service providers we use.
19.2 The updated Policy is published on the Website with a revised "Last Updated" date. Where a change is significant, or where the law requires, we will take reasonable steps to bring it to your attention.
19.3 Where a change materially expands the purposes for which we process your personal data, we will seek fresh consent before doing so.
19.4 Continued use of the Website after the effective date of an update means the updated Policy applies to you.