Privacy Policy

This Privacy Policy explains how TURBOGAINS FINTECH SOLUTIONS PRIVATE LIMITED (“Turbogains”, “we”, “us”) collects and uses personal data on https://alphafolioz.com, the Alpha product, and related apps (the “Services”).

We are a private limited company incorporated in India on 8 September 2025. CIN U62099UP2025PTC232196. PAN AAMCT2655H. Registered office: 312 C, Tower-3, Golf View Apartments, Sushant Golf City, Lucknow — 226030, Uttar Pradesh, India.

For questions or requests: legal@alphafolioz.com. Our Terms of Use describe the Services.

We follow the Digital Personal Data Protection Act, 2023 and the Information Technology Act, 2000, as applicable.

• We are the Data Fiduciary for data you give us directly as a website visitor, demo or waitlist lead, or RIA user (for example your login, SEBI disclosure, and billing profile).
• We are a Data Processor for personal data of an RIA's clients that the RIA (or the client, at the RIA's request) enters into Alpha. The RIA is the Data Fiduciary for that client relationship. We process that data to provide the Services to the RIA.

If you are a client user and want access, correction, or erasure of data your adviser holds about you, start with your RIA. You may also write to us; we may need to involve the RIA before we can act.

Website and demo. When you book a demo or join a waitlist we collect name, firm name, optional SEBI IA registration number, email, WhatsApp / mobile, approximate family count and AUA, and the page you came from.

RIA desk. Login email, display name, SEBI disclosure fields (registered name, registration number and validity, addresses, telephone, principal officer contacts), fee plans, GSTIN, PAN, billing address, payment gateway credentials you choose to store (secrets are encrypted), idea decisions, research files you upload, and activity needed to operate the desk.

Client users. Name, email, mobile, billing address, GSTIN if provided, plan and fee snapshots, investment budget / SIP figures the RIA or you enter, risk-questionnaire answers and score, goals, portfolio and task records, invoices, and payment status.

Technical data. IP address, browser and device information, approximate timestamps, and security logs. We use essential cookies for sign-in and host routing. We do not use third-party advertising cookies on the marketing site.

We do not ask for Aadhaar. Do not send us Aadhaar numbers or copies of identity documents unless we expressly request them for a legal process.

• To respond to demo and waitlist requests and size a conversation.
• To create and secure accounts, and to operate the RIA desk and customer app.
• To send transactional email and WhatsApp (invites, password reset, onboarding, pending tasks, payment links, invoices).
• To help an RIA collect fees through their payment provider and to generate invoices or fee receipts in the RIA's name.
• To keep an advisory and audit trail the RIA can use for compliance.
• To improve reliability and security, prevent abuse, and meet law or a lawful request.

We do not sell personal data. We do not use client portfolios to advertise third-party products to those clients.

We share data only with people and processors who need it to run the Services:

• Google Cloud and Firebase — hosting, database, file storage, and authentication. Persistent application data is kept in India (asia-south1 / Mumbai) where we control the location.
• MSG91 — email and WhatsApp delivery.
• Meta (WhatsApp) — if we message a number you or your RIA provided, WhatsApp processes that message under its terms.
• Razorpay — payment processing on the RIA's Razorpay account. Card and UPI details are handled by Razorpay, not stored by us as full card numbers.
• The RIA and the client — each sees data needed for that advisory relationship (for example the client sees tasks from their adviser; the RIA sees the client book).
• Professional advisers, successors in a merger or sale, and authorities when law requires.

Some identity or messaging providers may process limited data on servers outside India. Where that happens, we use it only to provide the Service you asked for (sign-in or a message).

Idea generation, monitoring, and internal equity-research briefs use our models and, where configured, third-party AI on market and company information. We do not use your name, contact details, or client identity to train public AI models. Do not paste sensitive personal data into free-text fields that are not required.

Demo and waitlist records are kept so we can contact you and run the practice. Account data is kept for the life of the account. After an RIA or client relationship ends, we retain records for as long as needed for billing, disputes, security, and legal retention (including tax and, where the RIA relies on our logs, typical securities-record periods). We then delete or irreversibly anonymise data where we no longer have a purpose.

We use encryption in transit, access-controlled cloud services, hashed or encrypted secrets where designed (for example payment gateway keys), and staff access on a need-to-know basis. No method of transmission or storage is completely secure. Please use a strong unique password and tell us of suspected misuse.

Subject to the DPDP Act and other law, you may request access to your personal data, correction of inaccurate data, erasure where we no longer need it, and withdrawal of consent for processing that is based only on consent (withdrawal does not affect processing already completed, or that we must continue for the contract or the law).

Write to legal@alphafolioz.com from the email we have on file, and tell us whether you are a visitor, RIA user, or client user. We may need to verify you and, for client data, consult the RIA. We aim to respond within a reasonable period and, for grievances, within thirty (30) days.

The Services are for persons aged 18 or older. We do not knowingly collect personal data from children. If you believe we have, contact legal@alphafolioz.com and we will delete it.

Grievance Officer, TURBOGAINS FINTECH SOLUTIONS PRIVATE LIMITED, 312 C, Tower-3, Golf View Apartments, Sushant Golf City, Lucknow — 226030, Uttar Pradesh, India. Email: legal@alphafolioz.com.

You may also have the right to complain to the Data Protection Board of India or another competent authority once the applicable mechanism is in force.

We may update this Policy. The current version is always at https://alphafolioz.com/privacy. Material changes will be reflected in the “Last updated” date. Continued use after an update is acceptance of the revised Policy.