Legal

Privacy Policy

This Privacy Policy describes how TitanTrustee collects, uses, stores, and protects your personal data. Compliant with India's Digital Personal Data Protection Act, 2023 (DPDPA) and applicable RBI/PMLA guidelines.

Effective: 26 June 2026Version 1.0TEAVE BUSINESS SOLUTIONS PRIVATE LIMITEDCIN: U74999UP2018PTC101502

1. About This Policy

1.1 TEAVE BUSINESS SOLUTIONS PRIVATE LIMITED (“TitanTrustee”, “we”, “us”) is the Data Fiduciary for personal data collected through the Platform. We are committed to protecting your privacy and handling your personal data responsibly, lawfully, and transparently.

1.2 This Policy applies to all individuals whose personal data we process, including registered users, directors of client companies, beneficiaries, visitors to our website, and counter-parties to escrow transactions.

2. Data We Collect

2.1 Data you provide directly

  • Identity data: Full name, date of birth, government-issued ID (PAN Card — mandatory; Aadhaar — masked last 4 digits), passport.
  • Business data: Company name, CIN, GSTIN, trade licence, director/UBO details.
  • Contact data: Email address, mobile number, correspondence address.
  • Financial data: Bank account details (account number, IFSC, UPI VPA) for beneficiary validation.
  • KYC documents: PAN card, Aadhaar (masked), passport, business registration documents, GST certificate.
  • Transaction data: Escrow amounts, counterparty details, milestones, conditions, release/refund instructions.
  • Communication data: Support tickets, dispute submissions, email correspondence, chat logs.

2.2 Data collected automatically

  • Technical data: IP address, device type, browser, OS, cookies, session tokens.
  • Usage data: Pages visited, API calls, timestamps, feature usage patterns.
  • Log data: Access logs, error logs, security event logs (retained for 5 years for PMLA compliance).

3. Legal Basis for Processing

We process your personal data on the following lawful grounds under the DPDPA, 2023 and applicable law:

  • Consent: Where you have provided free, informed, specific, and unambiguous consent.
  • Contractual necessity: Processing necessary to perform the escrow services agreement and related contracts.
  • Legal obligation: KYB/KYC and AML/PMLA obligations under the Prevention of Money Laundering Act, 2002, RBI Master Directions, and FEMA.
  • Legitimate interest: Fraud prevention, platform security, business analytics — where our interests are not overridden by your rights.

4. How We Use Your Data

  • To verify your identity and business (KYB/KYC) as required by law.
  • To create, manage, and settle escrow transactions on your behalf.
  • To conduct AML screening, sanctions checks, and transaction monitoring.
  • To process payments, release funds, and issue settlement statements.
  • To handle disputes and complaints.
  • To send transactional communications (OTPs, status updates, settlement notices).
  • To send service announcements and policy updates (not marketing, unless consented).
  • To comply with legal, regulatory, and tax obligations (including filing STRs with FIU-IND if required).
  • To improve Platform security, detect fraud, and prevent abuse.
  • To generate aggregated, anonymised analytics for product improvement.

5. Data Sharing & Disclosure

We do not sell your personal data. We share data only in the following circumstances:

5.1 With service providers

  • Partner Banks (for escrow account operation, virtual account issuance, payouts).
  • KYB/KYC vendors (for identity and business verification — data shared under confidentiality agreements).
  • AML/screening providers (for sanctions and PEP screening).
  • Cloud infrastructure providers (AWS — data hosted in India, ap-south-1 region).
  • Communication service providers (email, SMS, WhatsApp — for transactional notifications only).

5.2 With legal / regulatory authorities

  • Financial Intelligence Unit – India (FIU-IND): Suspicious Transaction Reports (STRs) as required under PMLA.
  • Income Tax Department, GSTN, RBI, SEBI, or any other competent authority upon lawful demand.
  • Courts and law enforcement agencies pursuant to a valid court order or legal process.

5.3 Business transfers

In the event of a merger, acquisition, or sale of all or a portion of our assets, your data may be transferred as part of the transaction, subject to the acquirer honouring this Privacy Policy.

6. Data Retention

  • KYC/KYB records: 5 years from the date of cessation of the business relationship (PMLA requirement).
  • Transaction records: 5 years from the date of the transaction (PMLA/tax law).
  • Dispute records: 3 years from the date of resolution or closure.
  • Security & audit logs: 5 years.
  • Account data: Duration of the account plus 5 years after closure.

After the applicable retention period, data is securely deleted or anonymised.

7. Your Rights (Under DPDPA 2023)

As a Data Principal, you have the following rights:

  • Right to Access: Request a summary of personal data we hold about you.
  • Right to Correction: Request correction of inaccurate or incomplete data.
  • Right to Erasure: Request deletion of your personal data, subject to legal retention obligations.
  • Right to Grievance Redressal: Lodge a complaint with our Grievance Officer (see Section 10).
  • Right to Nominate: Nominate an individual to exercise your rights in the event of your death or incapacity.
  • Right to Withdraw Consent: Withdraw consent at any time for consent-based processing (note: withdrawal does not affect prior lawful processing).

To exercise your rights, email: legal@titantrustee.com with subject line ‘DPDPA Rights Request’.

8. Data Security

We implement industry-standard technical and organisational measures to protect your data:

  • Encryption at rest (AES-256, AWS KMS) and in transit (TLS 1.2+).
  • Role-based access controls; least-privilege principle; MFA for privileged access.
  • Regular security audits, vulnerability assessments, and penetration testing.
  • Data hosted exclusively in India (AWS ap-south-1, Mumbai).
  • Incident response plan; data breach notification within the timeframes required by law.

No method of transmission over the internet is 100% secure. While we strive to protect your data, we cannot guarantee absolute security.

9. Cookies & Tracking

Please refer to our separate Cookie Policy for details on how we use cookies and tracking technologies on our website.

10. Grievance Officer

For privacy-related complaints or queries, contact our Grievance Officer:

Abhishek, Director
TEAVE BUSINESS SOLUTIONS PRIVATE LIMITED
First Floor, Plot No. 13, Nawada Housing Complex, Uttam Nagar, New Delhi – 110059, India
Email: grievance@titantrustee.com

We will acknowledge your complaint within 48 hours and endeavour to resolve it within 30 days.

11. Changes to This Policy

We may update this Privacy Policy periodically. Material changes will be notified via email and published at titantrustee.com/legal/privacy. Continued use of the Platform after the update constitutes acceptance.

12. Contact

Email: legal@titantrustee.com
Website: https://titantrustee.com
Address: First Floor, Plot No. 13, Nawada Housing Complex, Uttam Nagar, New Delhi – 110059, India
Phone: +91-11-4118-6363

All policies are governed by Indian law. Disputes are subject to the exclusive jurisdiction of courts at New Delhi. Latest version always at titantrustee.com/legal.