Privacy Policy

Last updated: 10 November 2026

This policy explains what personal data FinSharpe Private Limited ("FinSharpe", "we", "us") collects when you use the FinSharpe mobile app or the FinSharpe web app, why, who it goes to, how long it is kept, and the rights you have under India's Digital Personal Data Protection Act, 2023 (the "DPDP Act"). For the purposes of the DPDP Act, we are the Data Fiduciary and you are the Data Principal.

FinSharpe Private Limited (CIN U66190PN2021PTC201064) is registered with the Securities and Exchange Board of India (SEBI) as an Investment Adviser, registration number INA000018489, and is enlisted with BSE Administration and Supervision Limited under BASL2075. Registered office: Office No. 506, S. No. 128, Seasons Business Square, Aundh, Haveli, Pune 411007, Maharashtra.

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1. The short version

• You can browse Home, Discover and IPO Watch without an account. While you browse as a guest, the app sends us no account or device identifier for you.
• To chat, connect your investments or run reports, you create an account with your name, email and a password.
• What you type into chat is answered by AI models from Z.ai (GLM), OpenAI, Anthropic and Google. Every request to those models goes through our AI routing provider, OpenRouter, which sends it only to services that keep no copy of it once they have answered and do not train on it — today Together AI, Fireworks AI and DigitalOcean for Z.ai's models, and Microsoft Azure, Google Cloud and Amazon Web Services for the others. One exception: when our data tools search company filings, prospectuses or their own catalogue, a short search text written from your question goes directly to OpenAI, which does not train on it and may keep it for up to 30 days (section 2.2). Our AI hosting and monitoring provider (LangChain / LangSmith) keeps your conversations so you can return to them. Some of these providers process data outside India.
• If you connect your investments, your financial data comes to us through MoneyOne (OneMoney), an RBI-licensed Account Aggregator, only with your consent. We do not keep a separate copy of your holdings on our servers other than the copies chat and answer reports keep, described next; to price your investments the mobile app sends us their identifiers, without quantities, and we store none of them, apart from a server log line when one cannot be priced (section 2.8); the mobile app keeps a copy on your phone so your portfolio opens quickly, and a browser you used with an earlier version of the web app may still hold one (section 3). If you ask about your portfolio in chat, or use a button that asks chat about it for you, the holdings or figures used are saved with that conversation, and copies can stay in our AI monitoring records for up to 180 days (section 2.3). If you report a chat answer that described your investments, the copy of that answer we keep with your report includes what it said about them, for a year; the email that tells our support team about the report carries none of the answer (section 2.10).
• You can withdraw consent for any connection at any time, and you can delete your account.
• We do not sell your data and the app shows no advertising.

2. What we collect, and why

2.1 Account

Verification codes are delivered by Amazon Web Services Simple Email Service (Mumbai region), which receives your email address and the code.

2.2 Chat

When you use chat we process:

• the messages you send, including any images or spreadsheet files you attach;
• the answers, tool results and reports generated for you;
• which AI model you picked for each conversation;
• if you ask about your own portfolio, the holdings you have connected (section 2.3).

Why: to answer your questions, keep your conversation history so you can return to it, check that answers are grounded in the data they cite, suggest follow-up questions, and screen messages for content we cannot help with (for example, requests that include someone's PAN, Aadhaar or bank account numbers).

Who receives it:

Where the AI models run. OpenRouter sends each request only to a service it classifies as zero data retention: one that keeps no copy of the request or the answer once it has responded, and does not train on it. Today that means Together AI, Fireworks AI or DigitalOcean for Z.ai's GLM models, Microsoft Azure for OpenAI's models (including the embedding model that chooses data tools), Google Cloud (Vertex AI) for Gemini, and Amazon Web Services (Bedrock) or Google Cloud (Vertex AI) for Anthropic's Claude; requests sent through OpenRouter do not go to Z.ai, OpenAI or Anthropic themselves. These services may hold part of a request in memory for a short time so that a follow-up is processed faster; they do not store it. If OpenRouter's list of zero-data-retention services changes, a request may go to another service on that list, never to one outside it. OpenRouter may also sort a small sample of requests by topic for its public usage statistics; it does this without linking them to us or to you, and does not keep the text.

Searches by our data tools. One kind of request does not go through OpenRouter. When one of our data tools searches company filings, IPO prospectuses or its own list of data sources, it sends the search text — a short query the AI writes from your question — directly to OpenAI in the United States, to turn it into an embedding. OpenAI is not told who you are. Under OpenAI's terms for its API, it does not use the text to train its models, and it may keep it for up to 30 days to check for misuse, or longer where the law requires.

These providers process data on their own infrastructure, some of it outside India (see section 5). None of the AI model providers uses your data to train its models.

Push notification text. If you allow notifications, the notification that tells you an answer is ready shows the first 48 characters of your question. That text passes through Google Firebase Cloud Messaging to reach your phone, and on an iPhone also through Apple Push Notification service. On Android the notification is marked private: if your phone's lock screen is set to hide sensitive notification content, it shows only that FinSharpe has a notification until you unlock the phone. If your lock screen is set to show all content, the question is visible there. On an iPhone, whether the question shows on the lock screen follows your notification Show Previews setting. You can change this in your phone's notification settings, or turn off FinSharpe's notifications altogether.

2.3 Connected investments (RBI Account Aggregator)

FinSharpe is a Financial Information User on India's Account Aggregator network, regulated by the Reserve Bank of India. We use MoneyOne (OneMoney) as the Account Aggregator.

What happens when you connect:

1. You enter your mobile number and PAN in the app. We pass them to MoneyOne so it can find your accounts. We keep your mobile number on the consent record (below); we do not store your PAN on our servers.
2. MoneyOne shows you, on its own page, exactly what is being requested: the type of data, the purpose, how often it can be fetched, and how long the consent lasts. You approve or reject it there. The app never sees your OneMoney login.
3. With your approval, the institutions that hold your data — depositories and registrars such as CDSL, NSDL, KFintech and CAMS, and your bank if you connect a bank account — send it through MoneyOne.

The data can include, depending on what you connect: holdings (ISIN, security or scheme name, units, price and value), mutual-fund folio numbers and transactions, SIPs, bank account type, masked account number, branch, IFSC, balance and transactions, and account holder details such as holder name, KYC status and nominee.

Why we use it: to show your portfolio and net worth, analyse allocation, returns, risk and concentration, detect SIPs, answer your questions about your portfolio in chat, and generate the alerts and reports you ask for. We do not use it for anything you have not consented to, and we do not use it to lend to you or to sell you products.

What we keep, and where:

Your portfolio in chat. If you ask about your own portfolio in chat, we fetch your connected holdings through MoneyOne at that moment, give the AI model a summary of them (section 2.2), and save the full list with that conversation so the app can show it. It is deleted with the conversation. Copies can also appear in our AI monitoring records (LangSmith), which we keep for up to 180 days and which are not removed when the conversation or your account is deleted. Some buttons in the app ask chat for you, and the question the app writes then carries figures from your connected investments: analysing your bank accounts in chat sends each account's type, balances, average monthly spending and income, and the number and dates of its transactions (never the bank's name, the account number or the IFSC), and Ask AI on an alert sends what that alert shows, such as the holding it is about, a SIP's amount and dates, how much of your equity rides on one company, or which of your shares a fund also holds. The app sends them only when you tap; they go to the AI model like any message you send (section 2.2), and are saved with that conversation and can appear in our monitoring records in the same way as fetched holdings. If you report an answer that described your investments, the copy of the answer kept with your report keeps what it said about them for a year, even after the conversation is deleted or you revoke the consent, and without your account ID if you delete your account; the email that tells our support team about the report carries none of the answer (section 2.10). Holdings you type or upload into chat yourself are handled as chat content (section 2.2), not under the Account Aggregator consent; the figures the app writes into a question for you come from the consent, and this section covers them.

Lines written about your holdings. Some lines on the Portfolio screen and in Smart alerts are written by an AI model. For one holding or alert at a time, we send the model the holding's name, the verdict shown beside the line, and the figures the line is about, such as its scores, a SIP's amount and dates, how much of your equity rides on one company, or which of your shares a fund also holds. We do not send who you are. The request goes through OpenRouter (section 2.2) to Z.ai's GLM model, or for fund and look-through lines to Google's Gemini. The line is saved by the figures it was written from, not by account, so anyone whose holding shows the same figures sees the same line.

Consent terms. Our consent requests follow the Account Aggregator fair-use template for wealth management and advisory services (Sahamati template CT004). Under that template, a consent is for providing wealth management and advisory services, lasts at most 1 year, lets data be fetched at most 31 times a month, and covers at most 20 years of history for securities and mutual funds and 13 months for other accounts such as bank deposits. The mobile app fetches by itself at most once for each connection after each market day's close, and otherwise when you connect an account, when it has no copy of that account's data yet, or when you tap to retry a new connection's first fetch. Earlier versions of the mobile app also fetch when you tap their sync button. MoneyOne shows you the exact values, including how long we may keep the data, before you approve. A consent ends on its own when its term is over, and no more data can be fetched after that.

Revoking consent. In the app, open Portfolio, then the connection, and choose to disconnect it. We ask MoneyOne to revoke the consent, delete our consent record, and remove the copy on your phone. You can also revoke consents directly in the OneMoney app or website. When you do, the app shows that connection as no longer active once we learn of it, and we keep the consent record, marked that way, until you disconnect or renew the connection. Revoking stops future data fetches; it does not affect analysis we have already shown you.

2.4 Credits and reports

Research reports are paid for with credits, and chat is measured in credits; our Terms of Use say when chat answers use them. We add credits to your account — when you sign up, and when you ask us for more. Nothing is sold in the app.

We keep a credit history for your account: an entry for every chat turn, with the credits it cost (or, before chat answers use credits, would have cost) and the conversation it belongs to; every report you ran; and every time credits were added to or returned to your account — each with the date. Where the app shows you this history, it shows it in credits only. Behind each chat entry we also keep our own cost figures for it (which AI models ran and how much text they processed), to check what our providers bill us. The app never shows those figures. We use the credit history to charge credits, to show you your usage where the app offers it, and to check our providers' bills; not to profile you, and not for advertising.

Asking for credits. You can ask us for more credits by email. Where the app offers Request credits, tapping it opens a message in your own email app, addressed to info@finsharpe.com and prefilled with your account email, your balance, and your phone platform and app version. You decide whether to send it; the app itself sends nothing.

Reports. When you run a research report, we record the report and the run's results, so you can open it again; the credits it cost appear in your credit history. If you create a share link for a report, anyone with the link can open that report, and we count how many times it is viewed. You can revoke a share link at any time.

2.5 Notifications

• Answer-ready notifications (optional). If you allow them, we store your phone's Firebase Cloud Messaging token, its platform (Android or iOS) and your user ID, so we can tell you when a long answer is ready. We delete this registration when you sign out, when the token stops working, or when another account signs in on the same phone. See section 2.2 for the text a notification carries.
• IPO reminders. These are scheduled on your phone only. The issue name, symbol and closing time stay on the device; nothing is sent to us.

We ask for notification permission only when you first use a feature that needs it.

2.6 Guests

While you browse without an account, the app sends no account identifier with its requests. Google Firebase, which delivers notifications, may create an installation identifier and a notification token on your phone when the app starts. They stay between your phone and Google: the app sends the token to us only once you are signed in (section 2.5). Crash reports and usage events (section 2.7) are sent while you browse as a guest too. They are tied to that installation identifier and not to a person.

2.7 Crash reports and usage analytics

The mobile app sends crash reports and six usage events to Google Firebase (Crashlytics and Analytics), so that we can find and fix errors and see how many people get from opening the app to using it. The web app sends neither.

Crash reports. When the app hits an error it did not handle, it sends Google the error message, the place in the app's code where it happened, the app's version, and your phone's model, its Android or iOS version, and its state at the time (for example free memory), with a Firebase installation identifier. If you are signed in, the report also carries a one-way hash of your user ID, so that we can tell that several crashes happened to one account. It never carries your email address, and we do not add your conversations or your financial data to it. An error message is written by the code that failed, and can include a fragment of what the app was handling at that moment.

Usage events. The app sends six events: that it was opened, that it was opened without an account, that the sign-up form was opened, that sign-up was completed, that a first chat message was sent from this phone, and that a first investment account was connected from this phone. Each event is a name with nothing attached: no message text, no holdings, no email address and no user ID. Firebase Analytics adds what it collects from every app that uses it: the installation identifier, the app's version, your phone's model and its Android or iOS version, your approximate region taken from your IP address, and when and for how long the app was open. The app turns off the collection of your phone's advertising ID, and on an iPhone also of its vendor identifier; it never asks for permission to read the advertising ID or to track you.

There is no setting in the app that turns these off. Google keeps crash reports for 90 days and usage events for 2 months.

Separately from these, the one record we keep of how much you use chat and reports is your credit history (section 2.4), which exists so that credits can be charged and shown to you.

2.8 Server logs

Our servers keep operational logs to run and secure the service. They can contain your user ID, consent IDs, the IP address a request came from (for example, when we limit repeated sign-in attempts), the app version and phone platform the app reports, and, if an email fails to send, your email address. We do not log your password or verification codes. We do not log your holdings, balances or transactions, with one exception: when the app asks us to price your investments (section 2.3) and we cannot price or read one of them, we log that instrument's identifier (its ISIN, or the exchange or fund code we look it up by) and the reason, without your user ID. Logs are kept for no more than 90 days.

2.9 Connecting other AI apps

You can connect another AI app — for example, an AI assistant that supports connectors — to FinSharpe's data tools by signing in with your FinSharpe account. A connection works only while access has been granted to your account. When you use one, we keep:

• the access granted to your account, with when it was requested, approved and expires;
• a record of each sign-in token issued to the connected app, and when it was last used;
• a record of each call the app makes to our data tools: which tool, the inputs it sent (which can include holdings or other details you gave that app), when, how long it took and whether it worked, together with your account ID;
• running totals of how much the access is used, per day and per tool, with the stocks and funds it asked about stored only in scrambled (hashed) form.

We use these to run and secure the connection, to decide how much use it allows, and to understand demand. Our data-tool servers know which account a connected app's call is for. What you type into the other AI app is covered by that app's own privacy policy: we receive only its calls to our tools. When you delete your account, we delete the access and its tokens and remove your account ID from the call records; the records and the usage totals are kept (section 6).

2.10 Rating and reporting answers

Under each chat answer you can choose Rate answer, then Good answer or Bad answer. Nothing is sent unless you choose one.

We keep a copy of the answer with a report because conversations are deleted automatically (section 6) and a report must still show what was reported.

If the answer described your connected investments. An answer can restate figures from investments you connected through the Account Aggregator (section 2.3), whether chat fetched them or a question the app wrote for you carried them. The copy kept with a report then includes what the answer said about them. That copy is kept for the report's year like the rest of the report: after the conversation is deleted, after you revoke the consent, and, if you delete your account, without your account ID (section 6). The email that tells our support team about a report, below, carries none of it. We also record on each report whether chat had fetched your connected investments earlier in that conversation; a report can include figures from them without that record, when they reached the conversation only in a question the app wrote for you. So we treat every report as one that may include them, whatever that record says.

Who receives a report. Our support team reviews reports in our administration tool. When you send a report, an email also tells our support address, info@finsharpe.com, that there is one to review, through Amazon Web Services Simple Email Service (Mumbai region). The email carries only the reason you picked, the app version and platform, and a reference to the report in our administration tool. It carries nothing you wrote and no part of the answer, and it does not carry your name, your email address or any part of your account ID. The report itself is kept only in our database, where the one-year deletion (section 6) reaches it and where your account ID is removed from it if you delete your account. Good ratings are not emailed.

2.11 Your Investment Policy Statement (IPS)

If you build an Investment Policy Statement, we keep your answers to its questions (for example your income, expenses, loans, what you own, your goals and your answers about risk) and the risk profile and plan we compute from them.

• Your draft. Every answer is saved on our servers as you give it, so you can continue on another device. Figures we prefill from investments you connected through the Account Aggregator (section 2.3) are saved only once you confirm them.
• Accepted versions. When you accept your IPS together with the investment advisory agreement, we keep that version: your answers, the plan, the PDF you accepted, and the versions of our methodology and the agreement it was made under. We also keep the evidence of your acceptance: the time, your IP address, your device, the name you typed, a reference to the one-time code we emailed you, and a fingerprint (SHA-256 hash) of the PDF.
• A change log. We record each change to your answers (what changed, from what, to what, where and when), each version saved, each acceptance and each time a version is replaced.
• In chat. Once you have accepted an IPS, a short summary of it (your risk profile, equity range, the areas you avoid, your rule on investing outside India, your holding limits and its version) goes with each chat message you send to the AI model, and your full plan (goals, SIPs and assumptions) goes when a question needs it. They are handled like the rest of your chat (section 2.2).

We keep accepted versions, their acceptance evidence and the change log because, as a SEBI-registered Investment Adviser, we must keep records of our clients' risk profiles and of the advice we give, and be able to produce them to SEBI. Only our compliance team can see the change log; you can download the PDF of your current accepted IPS in the app.

3. What stays on your phone or in your browser

Uninstalling the app removes all of the above from the phone. None of it is included in phone backups or device-to-device transfers: on Android the app is excluded from cloud backups and transfers, and on an iPhone its files are excluded from iCloud and computer backups and its Keychain items stay on that phone. So nothing it stores is copied to your Google Drive or iCloud, or carried to a new phone.

On the web. If you use the FinSharpe web app, your browser keeps: sign-in cookies (your session tokens, which the page's scripts cannot read, and a cookie with your user ID, name and account role so the page can show who is signed in); your chat preferences, saved watchlists and similar settings; and, while you connect an account, a note of the connection in progress, which the browser drops when you close the tab. Signing out removes the sign-in cookies. An earlier version of the web app also saved in your browser a copy of the financial data from investments you connected there, so your portfolio opened quickly, and a record of each connection (including its consent ID and your mobile number). The web app no longer saves either. Signing out or deleting your account in that browser removes both, revoking a connection there removes that connection's copy, and opening Import removes the connection records. If your sign-in ends some other way, for example because you deleted your account in the mobile app, the web app removes the copy the first time it opens in that browser after the browser's sign-in has expired, which is at most 7 days after you last used the web app there. You can also clear this site's data in your browser at any time. The web app is hosted by Vercel, which passes your requests to our servers.

4. Who we share data with

We share personal data only with the service providers named in section 2, to run the features you use:

• AI routing, model and hosting providers: OpenRouter; Together AI, Fireworks AI and DigitalOcean, which run Z.ai's GLM models; Microsoft (Azure), Google (Google Cloud) and Amazon Web Services (Bedrock), which run the AI models from OpenAI, Anthropic and Google; OpenAI, directly, for our data tools' searches; LangChain (LangSmith).
• Account Aggregator: MoneyOne (OneMoney), and through it the financial institutions you approve.
• Infrastructure: Amazon Web Services (database and email, Mumbai), Railway (data-tool servers, Singapore), Google Firebase (notification delivery, and the mobile app's crash reports and usage events), Apple (delivery of notifications to iPhones), Vercel (the web app, and the web address that hands you back to the app after an Account Aggregator consent), and our market-data provider, which we ask for the prices of the instruments you hold, one instrument at a time, and which is not told who holds them.
• Reading answers aloud: Google, when the mobile app reads an answer aloud with Google's online voice (section 2.2).

We may also disclose data when required by law, a court order or a regulator (including SEBI and RBI), or to protect the rights and safety of our users and the service.

We do not sell personal data, and we do not share it for advertising.

Links to other sites. News articles and filings open the publisher's own site, which has its own privacy policy. Videos play inside the app through YouTube's privacy-enhanced embedded player (youtube-nocookie.com), and video thumbnails load directly from YouTube; YouTube's own privacy policy covers both. Versions of the mobile app released before in-app playback open videos on YouTube itself.

5. Where your data is processed

Our database and email service are in India (AWS Mumbai). Our data-tool servers run in Singapore (Railway). Our application servers — which handle sign-in, chat, reports and credits, pass your Account Aggregator data from MoneyOne to the app, and look up prices for the investments you hold — run in the United States (LangChain), as do our AI routing (OpenRouter), the web app (Vercel) and our data tools' searches (OpenAI). The AI models run in data centres that OpenRouter chooses for each request, in the United States, the European Union or other regions (Together AI, Fireworks AI, DigitalOcean, Microsoft Azure, Google Cloud and Amazon Web Services). When the mobile app reads an answer aloud with Google's online voice, Google turns the text into speech on its own servers, which may be outside India. Under section 16 of the DPDP Act, personal data may be transferred outside India except to countries the Government of India restricts by notification; we will not transfer data to such a country.

6. How long we keep data

When you delete your account, we delete your personal data as described in how to delete your account. A few records outlive it: records of data-tool calls, usage totals for any AI apps you connected, and your credit history, all without your account ID; reports you made about chat answers, with their copy of the answer (which can include what it said about your connected investments), without your account ID, until a year after you made them; AI monitoring records and server logs, until they expire on the schedule above; search text held by OpenAI, for up to 30 days; and database backups, for up to 2 days. Your accepted Investment Policy Statements, the evidence of each acceptance and the change log (section 2.11) are kept for at least 5 years from the date your investment advisory agreement ends (longer while a dispute is pending or SEBI directs) and then deleted automatically, because the law requires us to keep them; your IPS draft is deleted at once. A copy of your financial data that an earlier version of the web app saved in a browser is removed when you delete your account in that browser, and from any other browser the first time the web app opens there after that browser's sign-in has expired, which is at most 7 days after you last used the web app there (section 3).

7. Your rights

Under the DPDP Act you have the right to:

• Access — ask what personal data we hold about you, how we use it, and who we have shared it with (section 11).
• Correct, complete, update or erase your personal data (section 12). You can delete your account yourself; see how to delete your account.
• Withdraw consent at any time, as easily as you gave it (section 6(4)). Withdrawing consent does not affect processing that already happened. For Account Aggregator data, revoke the connection as described in section 2.3.
• Grievance redressal — have your complaint handled by our Grievance Officer (section 13).
• Nominate someone to exercise these rights if you die or become incapable (section 14).

To use any of these rights, email info@finsharpe.com from the address on your account, or write to the Grievance Officer below. We will confirm who you are before acting, and respond within 21 days of receiving your request.

If you are not satisfied with our response, you may complain to the Data Protection Board of India.

8. Security

• All traffic between the app and our servers is encrypted in transit (HTTPS).
• Sign-in credentials on your phone are kept in the Android Keystore / iOS Keychain. Every signed-in request also carries a per-session security key, so a stolen token alone cannot be replayed.
• The copy of your financial data, the list of connections it belongs to, and the last prices your investments were valued at sit in the app's private storage, which only this app can read, on top of the encryption your phone already applies to everything it holds. We do not encrypt those files a second time. They are removed when you sign out or your session expires, the copy of your financial data is also removed once it has been on your phone for more than 30 days without being synced again (the next time you open your portfolio in the app), and they are never copied into a backup or a device transfer.
• Passwords, verification codes and refresh tokens are stored on our servers only as hashes.
• Using a refresh token twice signs out every session on the account.

No system is perfectly secure. If a personal data breach affects you, we will inform you and the Data Protection Board of India as the DPDP Act requires.

9. Children

FinSharpe is for people aged 18 and over. We do not knowingly process the personal data of children. If you believe a child has created an account, contact us and we will delete it.

10. Changes to this policy

We will update this policy when what we collect or how we use it changes — for example, before we change what the app's crash reports or usage events carry. We will change the date at the top and, for material changes, tell you in the app or by email before the change applies.

11. Contact and grievances

Support: info@finsharpe.com

Grievance Officer
Mr. Sabir Bakir Jana
FinSharpe Private Limited, Office No. 506, S. No. 128, Seasons Business Square, Aundh, Haveli, Pune 411007, Maharashtra
Email: info@finsharpe.com · Phone: +91 7028004994

Complaints about our investment advisory services follow the grievance redressal process in our Investor Charter:

1. Write to us. Contact the Grievance Officer above. We respond within 21 days of receiving your complaint.
2. Escalate to SEBI. If you are not satisfied, lodge the complaint on SCORES 2.0 (https://scores.sebi.gov.in), where it is reviewed first by the designated body (IAASB) and then by SEBI.
3. Online dispute resolution. If it is still unresolved, take it to SmartODR (https://smartodr.in) for online conciliation or arbitration.

You can also write to the Office of Investor Assistance and Education, Securities and Exchange Board of India, SEBI Bhavan, Plot No. C4-A, G Block, Bandra Kurla Complex, Bandra (E), Mumbai 400051.