1. Data Fiduciary Identity
8848 Invest (Lokhandwala Raj Zahir, SEBI Registered Research Analyst, Reg. No. INH000025452), 2nd Floor, AR Plaza, Ravapar Road, Morbi, Gujarat. 363641, admin@8848invest.com, is the Data Fiduciary for personal data collected through 8848invest.com.
2. Data Collected & Purpose of Processing
| Data Category | Purpose | Legal Basis / Requirement |
|---|---|---|
| Name, email, mobile | Account creation, delivery of research, service notices, renewal reminders | Contract; SEBI requirement to keep contact details current |
| PAN, date of birth, address, KYC documents | Mandatory KYC of fee-paying clients and upload to a KYC Registration Agency (KRA); family-level fee cap tracking | SEBI RA Regulations, Reg. 25(1); PMLA/KYC norms |
| Consent records (terms version, timestamp, IP) | Proof that terms were accepted before service | SEBI RA Regulations, Reg. 24(6) |
| Payment details | Processed by Razorpay; 8848 Research sees only transaction status, amount and last 4 digits — never full card numbers | Contract; RBI/PCI-DSS handled by the gateway |
| Records of interactions (emails, support messages, calls) | Regulatory record-keeping and grievance handling | SEBI RA Regulations, Reg. 25; retained 5 years |
| Website usage (cookies, analytics) | Keeping the members' area working; essential cookies only by default | Consent via cookie banner; essential cookies only by default |
3. Data Retention Period
KYC, consent and interaction records: Retained for 5 years after the subscription ends, or longer if a dispute is pending or SEBI directs.
Account data: Retained until you request deletion, subject to the statutory retention obligations above.
4. Data Sharing & Disclosures
Data is shared strictly with Razorpay (payment processing), cloud hosting and transactional email providers (service delivery), the SEBI-designated KRA (KYC validation), and RAASB/SEBI/statutory compliance auditors when mandated by law or supervisory inspection.
We never sell, rent, or trade personal data, and never share information for marketing by third parties.
5. Your Rights as a Data Principal
You may access, correct, or request deletion of your personal data, withdraw consent for non-essential processing, and nominate a person to exercise these rights by writing to admin@8848invest.com.
Deletion requests are honoured except where SEBI retention rules require us to keep the record; we will explain which specific rule applies. Grievances regarding personal data are addressed by the Grievance Officer within 7 business days, with the right of escalation to the Data Protection Board of India.
6. Security, Minors & Policy Amendments
- Security: Data access is limited to the RA, transmission is encrypted (HTTPS/TLS), and KYC documents are stored encrypted at rest. If a breach affecting your data occurs, you and the Data Protection Board of India will be notified as required by law.
- Children: The service is designed solely for persons aged 18 and over.
- Policy Amendments: Material changes are notified by email 15 days before taking effect.