Privacy Policy

This website is operated by Ritvik Vipin, an individual educator based in India, offering a paid, cohort-based trading education program. For the purposes of the DPDP Act, we act as the Data Fiduciary who determines the purpose and means of processing your personal data. Grievance contact details are set out at the end of this policy.

• Identity and contact data: full name, email address, mobile number (including WhatsApp/Telegram handle where you choose to share it), city and country.
• Application data: trading experience, markets and instruments traded, capital range indicated by you, goals, and any free-text you submit in an application or enquiry form.
• Transaction data: payment status, invoice details, GSTIN (if you request a GST invoice) and partial payment references. Full card, UPI or bank credentials are never collected or stored by us — they are handled directly by RBI-regulated payment gateways.
• Program data: attendance, session recordings you appear in, questions asked, trade reviews you voluntarily submit, and community messages within our private groups.
• Technical data: IP address, browser and device type, referring URL, pages viewed and time on page, collected through server logs and analytics.

We do not knowingly collect sensitive personal data such as passwords, financial account credentials, biometric data or health information. Please do not share brokerage login credentials or account passwords with us at any time.

We process your personal data on the basis of your consent, or for certain legitimate uses permitted under Section 7 of the DPDP Act (such as data you voluntarily provide for a purpose and do not object to). Data is used only for the purposes below:

• Reviewing and responding to your Proximity application or enquiry.
• Onboarding you into a batch, granting access to sessions, recordings, resources and the private community.
• Processing payments, issuing invoices and meeting statutory tax and accounting obligations.
• Sending operational communications — schedules, reminders, material updates and support responses.
• Sending marketing or program updates, only where you have consented; you may withdraw this at any time.
• Improving the website, curriculum and content quality through aggregated, non-identifying analysis.
• Preventing fraud, unauthorised content sharing, abuse of the community, and enforcing our Terms and Conditions.

Where processing is based on consent, you give it freely, specifically and unambiguously by submitting a form or opting in. You may withdraw consent at any time by writing to the contact address below. Withdrawal is prospective — it does not affect processing already carried out, and it may prevent us from continuing to deliver the program to you where the data is essential to service delivery.

We do not sell, rent or trade personal data. We share limited data with service providers who process it on our instructions under contractual confidentiality obligations, including:

• Payment gateways and banking partners, for collecting fees and issuing refunds.
• Email, messaging and CRM providers, for scheduling and communication.
• Video conferencing and recording platforms used to deliver live sessions.
• Cloud hosting, storage and analytics providers used to run this website and the learning material.
• Accountants, auditors and legal advisers, and government or judicial authorities where disclosure is required by law.

Some of our service providers store data on servers located outside India. Such transfers are made in accordance with Section 16 of the DPDP Act and only to countries not restricted by the Central Government, with contractual safeguards requiring comparable standards of protection.

Personal data is retained only for as long as necessary for the purpose for which it was collected, or as required under applicable law — for example, financial records are retained for the statutory period under Indian tax legislation. Application data for candidates who are not enrolled is erased or anonymised within 24 months. Once the purpose is served and no legal retention obligation applies, data is deleted or irreversibly anonymised.

We implement reasonable security practices proportionate to the nature of the data, including access control on a need-to-know basis, encrypted transmission (HTTPS), reputable hosting and payment infrastructure, and restricted administrative access. No method of electronic transmission or storage is fully secure; while we take reasonable care, we cannot guarantee absolute security. In the event of a personal data breach, we will notify the Data Protection Board of India and affected Data Principals as required under the DPDP Act.

• Right to access a summary of the personal data we process about you and the processing activities undertaken.
• Right to correction, completion, updating and erasure of your personal data.
• Right to nominate another individual to exercise your rights in the event of death or incapacity.
• Right of grievance redressal — you may raise a complaint with us first, and escalate to the Data Protection Board of India if unresolved.

Requests can be made to the grievance contact below and will ordinarily be actioned within 30 days. We may ask for reasonable verification of identity before acting on a request.

The Proximity and this website are intended for individuals aged 18 years and above. We do not knowingly process the personal data of children as defined under the DPDP Act, and we do not undertake tracking, behavioural monitoring or targeted advertising directed at children. If you believe a child's data has been submitted to us, please contact us for immediate deletion.

This website uses strictly necessary cookies for functionality and may use privacy-respecting analytics to understand aggregate traffic patterns. You can block or delete cookies through your browser settings; some parts of the site may not function as intended if you do.

Our website and communications may link to third-party platforms such as Instagram, payment pages or conferencing tools. Those platforms are governed by their own privacy policies, and we are not responsible for their practices.

We may update this Privacy Policy from time to time to reflect changes in law or our practices. The revised version will be posted on this page with an updated revision date, and material changes will be communicated to enrolled students by email.

In accordance with the Information Technology Act, 2000 and the rules made thereunder, and Section 13 of the DPDP Act, any grievance regarding the processing of your personal data may be addressed to: Ritvik Vipin, Grievance Officer, India — email: privacy@ritvikvipin.com. We will acknowledge your complaint and endeavour to resolve it within 30 days of receipt.