Lux Trader Privacy Policy

Your privacy is important to us.

The User (defined below) of this Application (defined below) agrees to be bound by this Privacy Policy ("Policy"). In the event the terms and conditions of this Policy are not agreeable to the User, the User is requested to refrain from using this Application.

PIXELLINK GLOBAL PRIVATE LIMITED ("Developer", "We", "Us", "Our") is concerned about the privacy of the data and information of the Users accessing the Application, Lux Trader, and the other associated/ancillary applications, websites and services managed by the Developer ("Application") and otherwise engaging with the Developer through the Application.

Lux Trader is an online educational platform through which the Developer offers trading and financial-markets learning content, including video courses and lessons, downloadable study resources, daily market tips, and related educational features. Lux Trader does not provide investment, brokerage, trading, tax or financial advice, and does not execute trades on behalf of any User. All content is provided for educational purposes only.

This Policy is a legally binding document between the User and the Developer. The terms of this Policy will be effective upon the User's acceptance of the same (directly or indirectly in electronic form, by use of the Application) and will govern the relationship between the User and the Developer.

This Policy forms an electronic contract within the provisions of the Information Technology Act, 2000 ("IT Act"), the rules made thereunder, and, to the extent applicable and in force, the Digital Personal Data Protection Act, 2023 ("DPDP Act"), and the amended provisions pertaining to electronic documents/records in various statutes as amended by the IT Act, from time to time. This Policy does not require any physical, electronic or digital signature.

This Policy shall, at all times, be read and construed in consonance and along with the Terms and Conditions of use and access available for the Application ("T&Cs").

The Developer will not differentiate between who is using the device to access the Application, so long as the log-in/access credentials match with Yours. In order to make the best use of the Application and enable Your Information (defined below) to be captured accurately on the Application, it is essential that You have logged in using Your own credentials.

This Policy highlights, inter alia, the type of data shared/collected from a User in the course of the User's usage of the Application. The Policy further intends to apprise the User of the purposes for which the data of the User is collected and the Application's policy with regard to sharing such personal information with third-party entities.

As used herein, "You", "User" or "Users" shall mean (as the context may require):

(a) such persons who create User Content and publishers who publish User Content on the Application; or

(b) anyone who uses or accesses/views the Lux Trader platform and/or avails the Services on any computer, mobile phone, tablet, console, or other device.

The terms "We"/"Us"/"Our" individually and collectively refer to and are synonymous with the term 'Developer', and the terms "You"/"Your"/"Yourself" are to be construed as synonymous with the term 'User'.

All defined terms used within this Policy but not specifically defined herein shall draw their meaning from the definition ascribed to such terms under the T&Cs.

1. COLLECTION OF INFORMATION

The Developer may, during the course of the User's usage of the Application, collect the following personal and non-personal information, and such other information from the Users for accessing the Application ("Information"), as part of the voluntary registration process, any on-line survey or interaction on the Application, or a combination thereof, as may be required from time to time. The Information shall be collected in order to conduct operations on the Application. The Application collects or can request the below-mentioned Information from the Users:

1.1 Personal Information (information You provide directly):

(a) Name of the User;

(b) Phone number (mobile and/or residence and/or alternative) of the User;

(c) Date of birth of the User (where requested, to verify that the User meets the Age Requirements set out in Section 12);

(d) Email address (primary/alternative) of the User;

(e) Personal information received from social networking or authentication sites (for example, Google Sign-In) through which the User has registered on the Application, including name, profile picture and email address, and any information made public in connection with that service;

(f) User Content such as course reviews, ratings, feedback, and support communications submitted by the User; and

(g) Sensitive personal data such as passwords and payment-related details.

1.2 Automatically Collected / Non-Personal Information:

(a) Internet Protocol (IP) address of the User;

(b) Device information such as device model, operating system, unique device identifiers, and application version;

(c) Details of the internet or telecom service provider of the User;

(d) Approximate location (only if permission is granted by the User);

(e) Usage data, including courses and lessons viewed, video watch/progress data, daily tips read, duration of use, and interaction logs on the Application;

(f) Push-notification tokens and related identifiers (see Section 1.4 below); and

(g) Such other information that may be required to access and operate the Application.

1.3 Payment Information: When You purchase a course or make any payment on the Application, payment is processed through our third-party payment gateway, Razorpay. The Developer does not store Your complete card, bank, UPI or wallet credentials on its own servers. Such sensitive payment credentials are collected and processed directly by the payment gateway in accordance with applicable law and industry security standards (including, where applicable, the Payment Card Industry Data Security Standard). The Developer retains transaction-related information such as the transaction/order identifier, payment identifier, amount, currency, payment method type, and payment status.

1.4 Push Notifications (planned and/or current feature): The Application may offer, now or in the future, push notifications to inform You about new courses, lessons, daily tips, offers, account activity, and important updates. Where this feature is enabled, We may collect and process a device push-notification token to deliver such notifications. You may enable or disable push notifications at any time through Your device settings or the in-app settings, without affecting Your ability to use the core educational features of the Application.

1.5 The User agrees and affirms that the Information collected by the Developer and shared with the Developer has been so collected by obtaining the requisite consents from the Users (if Users are above the legal age, and from the parents/legal guardians of the Users if the Users are below the legal age) as required under applicable law. The consent taken includes the right to collect, store and disseminate the Information for the purposes described in this Policy.

1.6 Please note that, in addition to the above, the duration of use of the Application by the User may also be logged and stored by the Application.

1.7 The Information may be collected and/or stored in electronic form; however, the Developer is hereby authorised by the User to collect/store such information in physical form as well.

1.8 The Developer may share the Information of a User with third-party entities subject to such entities adopting reasonable safety standards with respect to the use of such Information, and only as described in Section 4 of this Policy.

2. REPRESENTATIONS AND WARRANTIES

Every User hereby represents and warrants to the Developer that:

(a) all Information provided by the User is true, correct, current and updated;

(b) the provision of such Information by the User does not in any manner violate any third-party agreement, law, decree, order or judgement;

(c) all Information provided by the User does not belong to any third party, and if it does belong to a third party, the User is duly authorised by such third party to use, access and disseminate such Information;

(d) the officers, directors, contractors or agents of the Developer shall not be responsible in any manner whatsoever with regard to the authenticity or veracity of the Information that a User may provide to the Application; and

(e) the User shall indemnify and hold harmless the Developer and each of its officers, directors, contractors or agents, and any third party relying on the Information provided by the User, in the event the User is in breach of this Policy.

The Developer represents and warrants to every User that:

(a) it shall not collect the User's sensitive personal data unless such sensitive personal data is collected for a lawful purpose for which such collection of data is necessary;

(b) it shall not retain any sensitive personal data for longer than such sensitive personal data is required or can be lawfully used;

(c) in the event the Developer collects Information directly from the User, the Developer shall make reasonable effort to apprise the User of the purpose of such collection of Information, the intended recipient of the Information, and the details of the agencies collecting and retaining the Information; and

(d) it has in place the security practices and procedures prescribed under the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 ("IT Rules").

3. PURPOSE AND USE OF INFORMATION

All Information collected/stored by the Application shall be used for:

(a) creating and administering the User's account, and authenticating the User at log-in;

(b) providing and personalising the educational services of the Application, including delivering courses, lessons, downloadable resources, and daily tips, and tracking the User's course progress;

(c) processing payments, confirming enrolments, issuing receipts, and maintaining transaction records;

(d) enabling offline downloads of purchased content and securing such content against unauthorised access;

(e) sending the User service-related and transactional communications, and, where the User has not opted out, information about new educational products, features, offers and services (including via push notifications, email or SMS);

(f) continually improving the existing Application and service offerings, and conducting research, analytics and surveys;

(g) implementing the necessary security practices to ensure that all personal data is protected, and detecting, preventing and addressing fraud, illegal activities, or breaches of security or privacy;

(h) contacting the User in cases where fraud, illegal activities or a breach of privacy is recorded;

(i) enabling the employees of, or persons acting on behalf of, the Developer to communicate with the User, as and when necessary, in order to provide the services requested by such User;

(j) complying with applicable law, and responding to legal, regulatory, judicial or governmental requests; and

(k) such other purposes that the Developer, at its sole discretion, but subject to the principles contained in this Policy, may deem fit.

4. SHARING OF INFORMATION

Every User hereby expressly agrees that the Developer may share the Information collected from such User with the following categories of recipients, only to the extent necessary and in accordance with this Policy:

(a) Service providers and sub-processors that support the operation of the Application, including:

    (i) Google / Firebase — for authentication, cloud database, file and media storage, hosting, crash reporting/analytics, remote configuration, and push-notification delivery;

    (ii) Razorpay — for payment processing; and

    (iii) content-delivery and video-streaming providers — for secure delivery of video and downloadable content;

(b) the Developer's affiliates, employees, and such other individuals and institutions located within or outside India from time to time, to ensure efficient management of Application traffic, and to detect and prevent identity theft and other illegal acts;

(c) legal, judicial, quasi-judicial, regulatory or law-enforcement agencies, or in connection with an investigation on matters related to public safety, as required and permitted by law; and

(d) a successor entity in the event of a merger, acquisition, reorganisation, or sale of assets, subject to such successor honouring the commitments made in this Policy.

The Developer does not sell Your personal Information to third parties for their independent marketing purposes.

5. INTERNATIONAL DATA TRANSFER

The Application relies on cloud infrastructure and service providers (such as Google / Firebase) whose servers may be located outside India. Where Information is transferred to, or stored/processed in, a jurisdiction outside the country in which the User is located, the Developer shall make reasonable efforts to ensure that such transfer is carried out in accordance with applicable law and that the recipient maintains a reasonable standard of data protection.

6. DATA RETENTION

The Developer shall retain Information for as long as is reasonably necessary in relation to the purposes for which the data was collected. In many instances, the Developer shall retain Information that is necessary for the operation of the Application by the User, which may include maintaining such Information beyond the point at which the User ceases using the Application.

Information pertaining to account details, course progress, enrolment and transaction records, support communications, and user-activity logs may be retained for operational, security, tax, accounting and legal purposes, and shall be retained by the Developer for a minimum period of 2 (two) years from the date of receipt of such Information, or for such longer period as may be required under applicable law, after which such Information, if deemed fit by the Developer, shall be erased from the Developer's servers and databases.

7. COOKIES AND THIRD-PARTY LINKS

7.1 The Application and its associated website may use cookies and similar technologies (small files or identifiers) to recognise Your browser or device. These are used to keep You logged in, remember Your preferences, understand usage trends, and improve our offerings.

7.2 Most browsers and devices are initially set up to accept cookies, but You can reset Your browser or device settings to refuse cookies or to indicate when a cookie is being sent.

7.3 Disclaimer: Some of the Application's features and services may not function properly if cookies or similar technologies are disabled.

7.4 The Application may contain links that redirect Users to third-party websites or applications that may have access to the personal information of the User, to which this Policy shall not apply. Every User agrees and acknowledges that accessing third-party websites or applications through links provided on the Application is solely at the User's discretion, and the Developer shall not be held liable for the privacy practices or content of such third-party websites or applications, which it does not own, manage or control.

7.5 Promotional Banners: The Application may display promotional banners advertising the Developer's own courses and offers or those of selected third parties. These banners are served directly by the Developer and do not, by themselves, involve third-party advertising networks or behavioural-tracking technologies. If a User taps a promotional banner that links to a third-party website or application, the practices described in Section 7.4 above shall apply. Should the Developer introduce third-party advertising services in the future, this Policy will be updated accordingly before such services collect any personal data.

8. PROTECTION OF INFORMATION

8.1 The Developer understands and acknowledges the importance of security and protection of the Information provided by and/or collected from the Users. The Developer shall make its best efforts to ensure protection of Information by use of such security measures and programs as it may deem fit for the purpose, and shall employ its best efforts to protect the Information against any unauthorised, illegal and fraudulent use by third parties.

8.2 The Developer employs reasonable technical and organisational security measures, which include: encryption of data in transit using HTTPS/TLS secured protocols; delivery of video content through secure streaming (including HLS) protocols; encryption of downloaded offline content using industry-standard encryption (AES-256) to prevent unauthorised access; role-based access controls restricting access to authorised personnel on a need-to-know basis; and use of reputable cloud infrastructure with its own security controls.

8.3 Notwithstanding anything to the contrary, the Developer shall not be held responsible for any loss, damage or misuse of the Information caused to the User if such loss, damage or misuse is attributable to an event beyond the control of, or not attributable to, the Developer, or to a force majeure event.

8.4 The Developer shall use the Information only as authorised and as necessary for the operation of the Application. The transmissions made by means of the Internet cannot be made absolutely secure, and the User agrees and acknowledges that the Developer shall not be liable for disclosure of any Information due to errors in transmission or any unauthorised acts of third parties.

8.5 The Developer shall use the Information collected from the Users in accordance with applicable laws, including but not limited to the IT Act and the rules made thereunder, and use the Information only for the purposes for which it was furnished.

9. YOUR RIGHTS AND CHOICES

Subject to applicable law, the User has the following rights in respect of the Information held by the Developer:

(a) Right to access — to request a copy of, or information about, the personal data the Developer holds about the User;

(b) Right to correction — to request correction or updating of inaccurate or incomplete personal data (Users can update most profile details directly within the Application);

(c) Right to erasure/withdrawal — to request deletion of personal data, or to withdraw consent previously given, subject to the retention obligations in Section 6 and applicable law;

(d) Right to opt out of marketing communications — to unsubscribe from promotional emails, SMS, or push notifications at any time via the relevant settings, links, or device controls, without affecting service-related communications; and

(e) Right to grievance redressal — to raise complaints in the manner set out in Section 11.

To exercise any of these rights, the User may contact the Developer using the details in Section 11. The Developer may require verification of the User's identity before acting on such a request, and may decline requests where permitted or required by law.

10. OPTION TO OPT OUT AND WITHDRAWAL OF INFORMATION

The User has the option of not providing its Information to the Developer; however, certain features or the Application as a whole may not be available without such Information. Information provided and/or collected by the Developer may be withdrawn at any time during, or pursuant to, usage of the Application by a User. Users desirous of withdrawing their Information shall send an email to the Grievance Officer and request such withdrawal. Following such withdrawal, the Developer may, at its sole discretion, continue or discontinue the provision of its services to such User.

11. GRIEVANCE REDRESSAL

Any User may report a violation or breach of privacy, Information, or identity theft, or raise grievances in relation to the Information shared, collected, stored or disseminated by the Developer in relation to the Application, to the Grievance Officer. The details of the Grievance Officer are as below:

Attn: Piyush Kachriya

Grievance Officer, PIXELLINK GLOBAL PRIVATE LIMITED

Address: Second Floor, Office No. 216, Anjani Icon, M.V. Circle, Near Doctor Park Society, Surat, Gujarat, India

Email: luxtrader108@gmail.com 

The Grievance Officer shall endeavour to redress grievances expeditiously and within the timeframes prescribed under applicable law.

12. USE OF THE APPLICATION BY CHILDREN

To register on the Application, You must meet the Age Requirements specified below. If You are a 'Minor' or 'Child', i.e., an individual who does not meet the Age Requirements, then You may not register on the Application; only your parent or legal guardian can register on your behalf, agree to all Application T&Cs, and enable access to you under their guidance and supervision.

While some of our services may require collection of a Minor's or Child's personal information, we do not knowingly collect such personal information. In the event a Minor or Child uses the Application, it is assumed that he/she has obtained the consent of the parent/legal guardian and that such use is made available by the parent or legal guardian. The Developer will not be responsible for any consequences that arise as a result of misuse of our Application by any person, including a Minor or Child, registering on the Application. The Developer reserves the right to terminate a subscription and/or refuse access to the Application if it is discovered that a User does not meet the Age Requirements and that consent has not been given by the parent/legal guardian. We will also take the necessary steps to remove such information from our servers.

If you are a parent/legal guardian and you become aware that your child has provided us with personal information without your consent, please contact us at luxtrader@gmail.com.

Age Requirements to register and use the Application ("Age Requirements"):

If you are a resident of India or Australia, you must have attained at least eighteen (18) years of age to register and use the Application, or else act under parental consent.

If you are a resident of Singapore, you must have attained at least thirteen (13) years of age to register and use the Application, or else act under parental consent.

If you are a resident of South Korea, you must have attained at least fourteen (14) years of age to register and use the Application, or else act under parental consent.

If you are a resident of Vietnam, you must have attained at least sixteen (16) years of age to register and use the Application, or else act under parental consent.

13. UPDATING OF POLICY

The Developer reserves the right to change or update this Policy at any time. Such updates or changes shall take effect from the date indicated in the updated Policy. Where changes are material, the Developer will endeavour to notify Users through the Application, by email, or by other reasonable means. You are advised to review this Policy periodically for any changes. Your continued use of the Application after any such change constitutes Your acceptance of the revised Policy.

14. GOVERNING LAW AND JURISDICTION

This Policy is governed by and construed in accordance with the laws of India. In the event of any dispute arising between the parties with respect to this Policy, the dispute shall be referred to an arbitral tribunal comprising 3 (three) arbitrators, wherein each party shall appoint one arbitrator and the third arbitrator shall be appointed by the aforesaid two arbitrators; and the arbitration shall be conducted in accordance with the Arbitration and Conciliation Act, 1996. The language of the arbitration proceedings shall be English. The seat and venue of arbitration shall be Surat, Gujarat, India, and the decision of the arbitral tribunal shall be final and binding on the parties. Subject to this arbitration clause for dispute resolution, this Policy shall be subject to the exclusive jurisdiction of the courts in Surat, Gujarat, India.

By using the Lux Trader Application, You acknowledge that You have read, understood, and agreed to this Privacy Policy.