Effective Date: February 2025
Townhall Technologies Private Limited (Operating as "mool.ail")
1. Introduction
Townhall Technologies Private Limited ("Company", "we", "us", or "our"), operating under the brand name "Mool", is committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our capital market intelligence platform and related services.
Townhall Technologies Private Limited partners with Mool Capital Private Limited which is registered with the Securities and Exchange Board of India (SEBI) as:
Research Analyst: Registration No. INH000012449
Investment Adviser: Registration No. INA000018708
This Policy is framed in accordance with the Information Technology Act, 2000, the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, the SEBI (Research Analysts) Regulations, 2014 (as amended), the SEBI (Investment Advisers) Regulations, 2013 (as amended), and is designed to be compatible with the Digital Personal Data Protection Act, 2023 ("DPDP Act") when it comes into full effect.
Definitions
For the purposes of this Privacy Policy:
"Personal Data" means any information relating to an identified or identifiable natural person.
"Sensitive Personal Data or Information" (SPDI) includes passwords, financial information (bank account, credit/debit card details), biometric information, physical/physiological/mental health conditions, sexual orientation, and medical records.
"Data Principal" refers to the individual whose personal data is being processed.
"Data Fiduciary" refers to us, as we determine the purpose and means of processing of personal data.
"Services" refers to our AI-powered capital market intelligence platform, including research reports, analysis, investment advice, and related offerings accessible through www.mool.ai and associated applications.
Purpose of Data Collection
We collect and process your personal data for the following purposes:
Service Delivery: To provide you with our capital market intelligence services, including research reports, equity analysis, forensic analysis, scenario valuations, and investment recommendations
Regulatory Compliance: To comply with KYC norms, anti-money laundering (AML) requirements, and other obligations under SEBI regulations and applicable laws
Client Onboarding: To verify your identity, assess suitability, and establish a client relationship
Communication: To send you research updates, service notifications, regulatory disclosures, and respond to your inquiries
Platform Improvement: To analyze usage patterns, improve our AI-powered research capabilities, and enhance user experience
Risk Management: To assess and manage risks associated with our services
Legal Proceedings: To establish, exercise, or defend legal claims and comply with court orders or regulatory directives
Legal Basis for Data Protection
We process your personal data based on the following legal grounds:
Consent: Where you have provided explicit consent for the collection and processing of your personal data
Contractual Necessity: Where processing is necessary for the performance of our service agreement with you
Legal Obligation: Where processing is required to comply with SEBI regulations, tax laws, AML requirements, and other applicable legal obligations
Legitimate Interests: Where processing is necessary for our legitimate business interests, provided such interests do not override your fundamental rights
Use of Artificial Intelligence
Important Disclosure: In compliance with SEBI guidelines on AI usage by Research Analysts and Investment Advisers, we disclose that Mool utilizes artificial intelligence and machine learning technologies in the following aspects of our services:
Generation of research reports and equity analysis
Processing of financial data, company filings, and market information
Driver-based valuations and scenario analysis
Forensic analysis and earnings quality assessment
Natural language processing for query responses
Data Security with AI: Your personal data, uploaded files, and queries submitted to our platform are:
Not used to train any AI models (our platform uses pre-trained models with your data processed only for generating your specific outputs)
Processed in secure, encrypted environments
Subject to automatic deletion protocols for uploaded files as specified in our platform terms
7. Data Sharing and Disclosure
We may share your personal data with:
7.1 Regulatory Authorities
SEBI, stock exchanges, Research Analyst Administration and Supervisory Body (RAASB), Investment Adviser Administration and Supervisory Body (IAASB), and other regulatory bodies as required by law.
7.2 Service Providers
Third-party service providers who assist us in operating our platform, conducting our business, or servicing you, including cloud infrastructure providers, payment processors, and KYC verification agencies. All such providers are bound by confidentiality obligations.
7.3 Legal Requirements
Government agencies pursuant to valid legal process, court orders, or to protect our rights or the rights of others.
7.4 Business Transfers
In connection with any merger, acquisition, or sale of company assets, your personal data may be transferred as part of such transaction, subject to continued protection under this Policy.
We do not sell your personal data to any third party for commercial purposes.
9. Data Security
We implement reasonable security practices and procedures as required under Section 43A of the Information Technology Act, 2000 and the SPDI Rules, 2011. Our security measures include:
Encryption: Data is encrypted in transit (TLS/SSL) and at rest using industry-standard encryption protocols
Access Controls: Role-based access controls and multi-factor authentication for system access
Security Standards: Our information security program is aligned with ISO/IEC 27001 standards for Information Security Management Systems
Regular Audits: Annual security audits and compliance assessments as required by SEBI regulations
Incident Response: Documented incident response procedures to address any data security breaches
Employee Training: Regular training of personnel on data protection and security practices
10. Cookies and Tracking Technologies
Our platform uses cookies and similar technologies to:
Maintain your session and authentication state
Remember your preferences and settings
Analyze platform usage and improve functionality
Ensure platform security and prevent fraud
You can manage cookie preferences through your browser settings. Disabling certain cookies may affect your ability to use some features of our platform.
11. Your Rights
Subject to applicable law and regulatory requirements, you have the following rights:
Right to Access: Request access to the personal data we hold about you
Right to Correction: Request correction of inaccurate or incomplete personal data
Right to Withdraw Consent: Withdraw your consent at any time for processing based on consent (this does not affect lawfulness of prior processing)
Right to Erasure: Request deletion of your personal data, subject to our retention obligations under SEBI regulations and other applicable laws
Right to Grievance Redressal: Lodge a complaint with our Grievance Officer or the Data Protection Board of India (when operational under the DPDP Act)
To exercise these rights, please contact our Grievance Officer using the details provided in Section 15 below.
12. Cross-Border Data Transfers
Your personal data may be processed on servers located outside India in connection with our cloud infrastructure. Any such transfer is conducted in compliance with applicable law and subject to appropriate safeguards, including:
Ensuring the receiving jurisdiction provides equivalent data protection standards
Implementing contractual data protection obligations with service providers
Complying with any restrictions notified by the Central Government under the DPDP Act
13. Children's Data
Our Services are designed for professional and institutional use and are not intended for individuals under 18 years of age. We do not knowingly collect personal data from children. If you believe we have inadvertently collected such data, please contact us immediately.
14. Updates to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or regulatory guidance. The updated policy will be posted on our website with a revised "Effective Date." For material changes, we will provide notice through email or prominent notice on our platform. Your continued use of our Services after such notification constitutes acceptance of the updated Policy.
16. Acknowledgment
By using our Services, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy. Where applicable, your explicit consent will be obtained through a clear affirmative action at the time of registration or data collection.
End of Privacy Policy
