This Privacy Policy is published in compliance with the Information Technology Act, 2000, the IT (Amendment) Act, 2008, the IT (Reasonable Security Practices and SPDI) Rules, 2011 issued by MeitY, Government of India, and the Digital Personal Data Protection Act, 2023 (DPDPA 2023) to the extent rules are notified and applicable.
1. Identity & Contact of Data Fiduciary
In accordance with DPDPA 2023 terminology, the Data Fiduciary for your personal data is:
- Business Name: SMC Order Block (operating as ProIndicator)
- Nature: Provider of educational charting tools (TradingView Pine Script indicators & screeners) — subscription-based digital service
- Legal Status: NOT registered with SEBI as Investment Adviser, Research Analyst, Portfolio Manager, or any regulated financial intermediary under the SEBI Act, 1992
- WhatsApp: +91 70282 83981 | Email: smcorderblock26@gmail.com
- Jurisdiction: Maharashtra, India
2. Scope & Applicability
This Policy applies to all individuals ("User", "you", "Data Principal" under DPDPA 2023) who visit smcorderblock.com, submit enquiry or trial forms, purchase subscriptions, or otherwise interact with our digital services. By using our services, you explicitly consent to the collection, use, and processing of your personal data as described herein. If you do not agree, please discontinue use immediately.
3. Categories of Personal Data Collected
- Identity Data: Full name, date of enquiry/registration.
- Contact Data: WhatsApp/mobile number, email address.
- Platform Data: TradingView username (required solely to grant indicator access).
- Transactional Data: Subscription plan, payment reference, duration, renewal history.
- Technical Data: IP address, browser type, OS, device type, pages visited, session duration — collected via Google Analytics 4 (GA4) and server logs.
- Communication Data: Records of messages via WhatsApp, email, or any support channel.
- Enquiry Data: Address, city, state, country submitted via course or product enquiry forms.
We do NOT collect Sensitive Personal Data (SPDI) as defined under Rule 3 of SPDI Rules 2011, including financial account numbers, passwords, or biometric data, except to the extent required for payment processing — handled entirely by third-party payment processors.
4. Legal Basis & Purpose of Processing
- Contract Performance: To activate, manage, and renew subscriptions; grant TradingView access; provide support.
- Legitimate Interest: To improve services, prevent fraud, maintain system security, and send service-related communications.
- Consent: To send promotional communications where opted in; to use cookies and analytics. Under DPDPA 2023, consent is free, specific, informed, unconditional, and unambiguous, obtained via clear affirmative action (cookie consent banner, form submission, checkbox acceptance).
- Legal Obligation: To comply with applicable Indian laws, including disclosures under court orders or regulatory directives.
5. Cookies & Tracking Technologies
- Google Analytics 4 (GA4): Collects anonymised usage data. IP addresses are anonymised.
- Session Cookies: Essential cookies for basic functionality. Deleted when browser is closed.
- Preference Cookies: Stored upon acceptance of cookie consent banner.
A cookie consent banner is displayed on first visit, providing options to Accept or Reject non-essential cookies. You may manage or withdraw cookie consent at any time through your browser settings or by revisiting the consent banner. Disabling cookies may affect website functionality.
6. Data Sharing & Third-Party Disclosure
We do NOT sell, rent, trade, or commercially exploit your personal data. Data is shared only in these limited circumstances:
- Payment Processors: To facilitate transactions. We do not store full payment card details.
- TradingView Platform: Your TradingView username is shared solely to grant indicator/screener access.
- Analytics Providers: Google LLC (GA4) — governed by Google's Privacy Policy and Data Processing Addendum.
- Legal & Regulatory Authorities: Where required by applicable Indian law, court order, or competent government authority.
7. Data Retention
- Active subscription data: throughout subscription period + 12 months thereafter.
- Enquiry and communication records: up to 24 months from last interaction.
- Financial/transactional records: minimum 8 years as required under Indian taxation laws.
- Technical/log data: up to 90 days.
Upon expiry of retention periods, data is securely deleted or anonymised in accordance with DPDPA 2023 requirements.
8. Data Security
We implement commercially reasonable technical and organisational security measures including SSL/TLS encryption and restricted access controls, consistent with reasonable security practices under SPDI Rules 2011. No electronic transmission method is 100% secure. In the event of a personal data breach posing risk to your rights, we will notify you and relevant authorities (including the Data Protection Board of India, once constituted under DPDPA 2023) as required under applicable law.
9. Your Rights as Data Principal
Under DPDPA 2023 and applicable Indian law, you have the following rights:
- Right of Access: Request a summary of personal data processed and processing activities.
- Right to Correction: Request correction of inaccurate or incomplete personal data.
- Right to Erasure: Request erasure of personal data no longer necessary for the purpose collected, subject to legal retention obligations.
- Right to Withdraw Consent: Withdraw consent at any time for processing based on consent (including marketing communications). Withdrawal does not affect lawfulness of prior processing.
- Right to Grievance Redressal: Raise a complaint with our Grievance Officer. If unresolved, you may approach the Data Protection Board of India (once constituted under DPDPA 2023).
- Right to Nominate: Under DPDPA 2023, you may nominate any individual to exercise your rights in the event of your death or incapacity.
Exercise your rights by contacting: WhatsApp +91 70282 83981 or smcorderblock26@gmail.com. We respond within 30 days.
10. Children & Minors
Our services are strictly for individuals 18 years of age or older. We do not knowingly collect data from minors (as defined under DPDPA 2023, persons below 18 years). If we become aware of such data being collected, we will delete it promptly. We do not undertake tracking, behavioural monitoring, or targeted advertising directed at children.
11. Cross-Border Data Transfers
Your data may be processed outside India by third-party providers (e.g., Google LLC for analytics). Such transfers are governed by appropriate contractual safeguards and comply with applicable Indian law. Under DPDPA 2023, transfers will be subject to any restrictions notified by the Central Government regarding jurisdictions to which personal data may not be transferred.
12. Grievance Officer / Data Protection Contact
In accordance with the IT Act 2000, SPDI Rules 2011, and DPDPA 2023:
- Contact: WhatsApp +91 70282 83981 | smcorderblock26@gmail.com
- Response Time: Within 30 days of receipt of complaint.
- Escalation: If not resolved satisfactorily, you may approach the Data Protection Board of India (once constituted).
13. Changes to This Policy
We may update this Privacy Policy at any time. Changes will be posted with an updated "Last Updated" date. Continued use of services after changes constitutes acceptance of the revised Policy. Material changes affecting your rights under DPDPA 2023 will be notified via email or prominent website notice.
14. Governing Law
This Policy is governed by the laws of the Republic of India, including the Digital Personal Data Protection Act, 2023, the Information Technology Act, 2000, and rules thereunder. Disputes shall be subject to the exclusive jurisdiction of competent courts of Maharashtra, India.
⚠️ Regulatory Notice: SMC Order Block / ProIndicator is NOT registered with SEBI as an Investment Adviser (IA), Research Analyst (RA), Portfolio Manager, or any regulated financial intermediary. Our services are exclusively educational charting tools. We do not provide investment advice, stock tips, buy/sell calls, or portfolio management of any kind.