Privacy Policy

Last Updated: April 2025

Introduction

At Camel Finance, we are committed to protecting and respecting your privacy. This Privacy Policy explains how Variance Technologies Private Limited (“Company”, “we”, or “us”), the operator of CamelFinance.co.uk, collects, uses, shares, and safeguards your personal information. It also outlines your rights regarding your personal data and how you can contact us with questions or concerns. We adhere to applicable privacy laws and regulations, including the Information Technology Act, 2000 of India and its applicable rules, as well as relevant global standards where applicable (e.g., GDPR for users in the European Economic Area, and UK data protection laws for UK users).

By using our website and services, including signing up for an account or subscribing to our CF Cycle Trading Indicator, you agree to the collection and use of information in accordance with this Privacy Policy. If you do not agree, please do not use the site or service.

Information We Collect

We collect personal and usage information to provide and improve our Service. The types of information we may collect include:

• Personal Information You Provide: When you create an account or subscribe on CamelFinance.co.uk, we collect information such as your name, email address, and a username. During signup, you will also choose a password (which is stored in an encrypted/hash form in our system for security). We may also request additional information necessary to provide the service, for example your TradingView username (to grant you access to the invite-only Indicator on TradingView) and your country or region (to comply with localization or legal requirements). If you contact us or submit a support ticket, we will collect the information you provide in that correspondence (e.g. your email and the contents of your message).

• Payment Information: We do not collect or store your full credit/debit card numbers or bank account details on our servers. Payments for our subscription service are processed by third-party payment gateways:

• Razorpay: For most new customer transactions (especially in INR or credit/debit card payments), we use Razorpay. When you enter your payment details at checkout, that information is transmitted directly to Razorpay over secure SSL encryption. Razorpay may collect your card number, expiration date, CVV, UPI ID, or other payment details as needed to process the transaction. We receive a confirmation of payment and basic details like the last four digits of your card or an anonymized token, but we never see or store your sensitive payment data.

• PayPal: Some legacy subscribers use PayPal for recurring payments. In such cases, you are redirected to PayPal (https://www.paypal.com) to complete the transaction. We do not receive your PayPal login or payment details, only confirmation of payment and necessary info to update your account status.

• Both Razorpay and PayPal have their own privacy policies and security measures. We recommend reviewing Razorpay’s Privacy Policy and PayPal’s Privacy Policy on their websites. We only share with these payment processors the information required to process your payment (such as your order amount, currency, and email/Customer ID to tie the payment to your account).

• Automatically Collected Information: When you visit our website, certain data gets collected automatically:

• Log Data: Our web servers and/or analytics tools may log standard technical information when you access CamelFinance.co.uk. This can include your IP address, browser type and version, device type, operating system, referral URL (the page you came from), pages or content you view on our site, the dates/times of access, and other diagnostic data. We use this information to ensure the website functions properly, to analyze usage trends, and to secure the site.

• Cookies and Similar Technologies: We use cookies (small text files stored on your device) and similar technologies to enhance user experience. For example, when you log in to your account, cookies help remember your session so you don’t have to re-enter credentials on every page. We may also use cookies for analytics (to understand how users navigate our site) and for tracking the effectiveness of any promotions. You can manage or disable cookies through your browser settings; however, please note that if you disable essential cookies, some features of our Service (like maintaining your login session) may not function correctly.

• Analytics: We may use third-party analytics services (such as Google Analytics or similar) to collect information on site usage. These services may set cookies or use other identifiers to compile reports for us on how users interact with our site. This information is generally aggregated and does not identify you personally. It helps us improve site content and usability. Google Analytics, for instance, provides options for users to opt-out (e.g., via a browser add-on).

• Information from TradingView: Our product requires your TradingView username to grant you access to the Indicator. Apart from that username, we do not pull any personal data from TradingView. We may receive a notification from TradingView once we have granted you access (for instance, TradingView might show your account as having our script enabled), but we do not have access to your TradingView account data or any of your activity on TradingView except what you explicitly share with us. Any data you provide to TradingView is governed by TradingView’s privacy policy.

• Communication Data: If you subscribe to our newsletter or request to receive updates, we will collect your name and email for that purpose. We record whether you have given consent to receive marketing communications (e.g., by checking a signup box). We also track email engagement (such as opens or clicks) using email service provider analytics to gauge the relevance of our content. You can opt out of marketing emails at any time (see Your Rights and Choices below).

We do not intentionally collect any sensitive personal data such as passwords for other services, financial information (aside from what’s handled by processors), health data, etc., beyond what is necessary for account creation and payment. We also do not solicit or knowingly collect personal information from children. Our Service is not intended for individuals under the age of 18. If you are a parent or guardian and believe your child has provided personal data to us, please contact us so we can remove it.

How We Use Your Information

We use the collected information for various purposes in line with providing and improving our Service, as well as legal compliance:

• To Provide the Service: We use your personal information (name, email, TradingView username) to create and manage your account, to communicate with you about your subscription, and to grant you access to the CF Cycle Trading Indicator. For example, your TradingView username is used to add you to the invite-only script’s access list, and your email is used to send you login details or important account notices.

• To Process Transactions: We use information like your email and an internal user ID to coordinate with our payment processors (Razorpay or PayPal) when you make a purchase. This ensures your subscription is activated, payments are linked to your account, and receipts can be sent. We may also send you transactional emails, such as payment confirmations, invoices, trial expiration reminders, or notices of subscription renewal.

• To Communicate with You:

• Service and Account Communication: We may send you administrative emails or messages related to your use of the Service. These include welcome emails, password reset emails, billing alerts, support responses, important updates about the platform or policies, and reminders (e.g., notice before your free trial ends or subscription renews). These communications are considered part of the Service and you may not opt out of them as long as you maintain an account, except by canceling your account.

• Marketing and Newsletter: If you have opted in (for example, by ticking a box to receive updates), we will send you our newsletter, product announcements, educational content, or special offers. These are opt-in only. If you no longer wish to receive marketing emails, you can unsubscribe at any time by clicking the “unsubscribe” link in any such email or by contacting us. We will honor unsubscribe requests promptly.

• For Customer Support: When you contact us with a question, feedback, or issue (via our support ticket system or other means), we will use your contact information and any details you provide to help resolve your inquiry. We may also keep records of support requests to better assist you in the future and to improve our support processes.

• To Improve and Personalize the Service: We analyze usage data (like website analytics and user feedback) to understand how our Service is used. This helps us troubleshoot problems, identify usage trends, determine what features are popular or where users encounter difficulties, and guide our decisions for new features or improvements. We may also use cookies to remember your preferences on the site (e.g., whether you prefer a light or dark mode if such option exists, or to keep you logged in if you selected “remember me”).

• Security and Fraud Prevention: Information such as IP addresses, logs, and account activity is used to monitor for suspicious or fraudulent behavior. This helps us protect the integrity of our Service and the security of user accounts. For example, we might detect if multiple IP addresses from different regions are trying to access your account, and take steps to verify if it’s really you. We also use this data to enforce our Terms of Service (e.g., detecting sharing of accounts or other prohibited activities).

• Legal Compliance: We may process and retain personal information to comply with our legal obligations. For instance:

• Accounting/tax regulations may require us to keep records of transactions (which include personal identifiers like name or email on invoices).

• Indian Information Technology law and e-commerce rules may require us to have certain data retention or disclosure practices. If we are required by law enforcement or regulatory authorities to retain or disclose certain data, we will do so in accordance with the law (see also Disclosure of Your Information below).

• If you exercise any data subject rights (like requesting deletion or access), we will use your information to fulfill those requests.

• Testing and Research: On occasion, we may use certain data for internal testing, research, and analysis to develop new features or ensure our security measures are working. When possible, we use anonymized or aggregated data for these purposes (so individuals are not identified). For example, before a new feature launch, we might simulate user data through a test to ensure it functions properly.

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason that is compatible with the original purpose and permitted by law. If we need to use your personal data for an unrelated purpose, we will notify you and obtain your consent or ensure there is a lawful basis for that new use.

Disclosure of Your Information

We understand the importance of keeping your personal information confidential. We do not sell your personal data to third parties. We may share or disclose information in the following situations:

• With Service Providers and Partners: We use trusted third-party service providers to perform certain functions on our behalf, and they may have access to the information necessary to perform their tasks. These include:

• Payment Processors: as discussed, Razorpay and PayPal process payments. They receive relevant billing information and identifiers to complete transactions. (They are not allowed to use your info for anything beyond processing payments and complying with legal obligations.)

• Hosting and IT Infrastructure: Our website and databases may be hosted on third-party servers or cloud services. For example, if our site is hosted on a platform like Amazon Web Services or a managed WordPress host, the hosting provider technically processes data (including any stored personal info) on our behalf. We ensure any hosting provider we use has appropriate security measures and is contractually bound to protect data.

• Email Service Providers: If we send emails (newsletters or transaction emails) via a service like SendGrid, MailChimp, or similar, your name and email address will be processed by that service for sending the communication. These providers are only allowed to use that information under our instructions and not for their own purposes.

• Analytics Providers: Analytics tools like Google Analytics will process usage data (as described in “Automatically Collected Information”). This usually does not include personally identifying info like your name, but may include IP address and cookie identifiers. These analytics providers provide insights to us and are not allowed to use the data except as needed to provide those insights.

In all cases, we choose reputable providers and strive to ensure they have privacy and security practices in place. We share only the minimum information necessary and have agreements in place (like Data Processing Addendums where applicable) to ensure they protect your data.

• With TradingView (to Provide Service): The only information we share with TradingView is your TradingView username (to grant you access to our private script) and the fact that you should have access. TradingView’s system will know that your account has been given permission for our script. We do not share any other personal info (name, email, etc.) with TradingView, nor do we receive personal data from them about you. However, please note that if you engage with us on TradingView’s platform (e.g., via comments or messages on TradingView), those interactions are subject to TradingView’s terms.

• For Legal Reasons: We may disclose your information if required to do so by law or in response to valid requests by public authorities (e.g., a court order, government demand, or regulatory requirement). We will always ensure such requests are legitimate and will limit any disclosure to what is legally required.

• For instance, under Indian law, we might be required to provide information to government agencies for the purposes of verification of identity or for prevention, detection, and investigation of offences (Cybersecurity or otherwise) or for prosecution. We will comply with such requests in accordance with the IT Act and other applicable laws.

• If we are compelled to disclose your data, we will try to notify you (for example, via the email on file) unless legally prohibited from doing so.

• Business Transfers: If Variance Technologies Pvt. Ltd. undergoes a business transition such as a merger, acquisition by another company, or sale of all or a portion of its assets, user information (including personal data) might be among the assets transferred. If such a transfer occurs, we will ensure that the successor entity either is bound to the same privacy commitments or we will notify you and give you an opportunity to opt-out or delete your data if required by applicable law.

• Enforcing Our Rights: We may disclose personal information to enforce our policies, Terms of Service, or agreements, or to collect amounts owed to us, or to assist with an investigation or prevention of illegal activity (for example, suspected fraud). This may involve sharing information with law enforcement, regulatory bodies, or other authorities or external advisors (like attorneys or auditors) as necessary.

• With Your Consent: In cases where you have explicitly consented to some form of data sharing that is not covered by the above (for instance, if we want to use a testimonial along with your name, or you participate in a joint promotion with a partner where you consent to us sharing contact info with that partner), we will share your information only in line with that consent. If you change your mind, you may contact us to withdraw such consent at any time.

We want to reassure you that outside of the scenarios above, your personal information stays with us. We do not share or disclose lists of our users or any personal details to advertisers or other third parties for their own marketing.

Data Storage and Security

We take reasonable and industry-standard measures to secure your personal information and protect it from unauthorized access, alteration, disclosure, or destruction. However, please understand that no method of transmission over the internet or method of electronic storage is 100% secure. We strive to use commercially acceptable means to protect your personal data, but we cannot guarantee absolute security.

Security Measures we implement include:

• Encryption: Our website is secured via HTTPS, ensuring that data transmitted between your browser and our site (such as login credentials or form submissions) is encrypted in transit. Passwords that you set for your account are stored in a hashed (one-way encrypted) form; even our own team cannot read your actual password. We encourage you to choose a strong, unique password and keep it confidential.

• Access Controls: Personal data stored in our system is accessible only by authorized personnel who need access to perform their job (for example, customer support or technical staff). We restrict access to database and administrative panels, and use authentication steps for our internal systems.

• Firewalls and Monitoring: We employ firewalls and monitoring services to guard against malicious traffic and to detect unusual activities on our site (such as repeated failed login attempts or potential breaches). Our systems are regularly updated with security patches and our software (including WordPress or any CMS we use) is kept up-to-date to mitigate vulnerabilities.

• Third-Party Security: We ensure that our third-party service providers (hosting, payment, etc.) are reputable and have robust security practices. For example, Razorpay and PayPal are PCI-DSS compliant for handling payment data. We also utilize secure platforms for support tickets and emails.

• Backup and Recovery: We routinely back up critical data to prevent data loss. Backups are stored securely and are protected from unauthorized access. In case of any security incident or data breach, we have procedures in place to promptly address and mitigate the issue and will notify affected users and authorities as required by law.

While we work hard to protect your information, you also play an important role. Please keep your account credentials safe and do not share them. If you believe your account has been compromised (for example, if you notice unauthorized access or strange activity), contact us immediately so we can help secure your account.

In the unlikely event of a data breach involving your personal information, we will follow applicable laws and regulations regarding notification. This may include notifying you via email and informing the relevant data protection authorities, as required.

Data Retention

We retain personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. In general:

• Account Information: We keep your account profile information (name, email, username, etc.) for as long as your account is active. If you cancel your subscription or your account becomes inactive, we may retain your information for a reasonable period in case you reactivate or for record-keeping purposes. If you request deletion of your data (see Your Rights below), we will delete or anonymize your personal info, except for data we are required or permitted to keep by law.

• Payment and Transaction Records: We retain records of payments, invoices, and related transactional information as required for financial reporting and audits. For example, Indian tax laws may require us to keep invoices for a certain number of years. Even if you delete your account, we might need to keep invoice data (which includes your name, email, and transaction details) for the legally mandated period, after which it will be deleted or anonymized.

• Support Communications: We may retain communications you have with us (such as emails or support tickets) for a period of time after your issue is resolved. This helps us in case of follow-up issues and to improve our support process. These records will typically be purged periodically if no longer needed.

• Analytics Data: Aggregated analytics data that does not directly identify you may be retained longer for historical analysis. However, any usage logs that can be tied to personal data (like IP addresses in logs) are typically rotated or deleted within a shorter timeframe unless needed for security analysis. For instance, server logs might be kept for a few weeks to a few months and then automatically overwritten or deleted.

• Backups: Our system backups might inadvertently store pieces of personal information (e.g., a daily backup of the database). These backups are stored securely and are typically retained for a limited time in a rolling fashion (say, backups for the last X days). Even after data is removed from the main system, it might remain in backups until those backups are cycled out.

When we have no ongoing legitimate business need or legal obligation to process your personal information, we will either delete it or anonymize it. If deletion is not immediately feasible (for example, because the data is stored in archives), we will securely store the data and isolate it from further use until deletion is possible.

Please note that even after you delete your account or request deletion, residual copies might remain in our backup media for a short period, but they will be purged in the normal course of the backup cycle.

Your Rights and Choices

We respect your rights regarding your personal data. Depending on your jurisdiction (e.g., under India’s emerging data protection frameworks, the EU’s GDPR, the UK’s data protection laws, etc.), you may have some or all of the following rights:

• Right to Access: You can request information about the personal data we hold about you and obtain a copy of it. For example, you can ask us to confirm whether we’re processing your personal data and have us send you a copy of the data we have on record (we can usually provide this electronically).

• Right to Rectification: If any of your personal information is inaccurate or incomplete, you have the right to ask us to correct it. You can also update certain information directly by logging into your account (for instance, you can change your profile details except for certain locked fields like username; if you need to change something like your TradingView username associated with your account, you can contact support).

• Right to Erasure (Right to be Forgotten): You may request deletion of your personal data. For example, if you decide to stop using our Service, you can ask us to delete your account and personal info. Keep in mind we might need to retain certain data for legal reasons as noted in the Data Retention section (we will inform you if that is the case). When we honor deletion requests, we will delete or anonymize your personal data so it no longer identifies you.

• Right to Withdraw Consent: If we are processing your information based on consent (e.g., for sending marketing emails), you have the right to withdraw that consent at any time. Withdrawing consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, and it won’t affect processing of your data under other legal bases (for instance, we might still process data to fulfill a contract or comply with a law). You can withdraw consent from marketing emails by unsubscribing, or by contacting us for other consent withdrawals.

• Right to Object: You may have the right to object to certain types of processing. For example, you can object to processing of your data for direct marketing (which we will always honor). If we were processing your data based on legitimate interest, you can object if you have grounds relating to your particular situation. We will then consider whether our legitimate grounds override your rights and freedoms.

• Right to Restrict Processing: You can ask us to restrict or ‘pause’ processing of your personal data in certain circumstances: for instance, if you contest the accuracy of the data, or if the processing is unlawful but you do not want it erased, or if you have objected and are awaiting verification of our grounds. When processing is restricted, we will still store your data but not use it further until the restriction is lifted (unless necessary for legal claims or protection of others’ rights, etc.).

• Right to Data Portability: If applicable, you have the right to request a copy of certain personal data in a machine-readable format (for example, a CSV file), and you can request that we transmit that data to another data controller where technically feasible. This generally applies to data you provided to us and which we process by automated means based on your consent or to perform a contract. In practice, this might include account information you provided.

• Right to Lodge a Complaint: If you believe your privacy rights have been violated or that we have not handled your personal information lawfully, you have the right to lodge a complaint with a supervisory authority. If you are in India, you can approach the grievance officer (contact details below) or potentially relevant IT Ministry officials. If you are in the EU/EEA, you can contact your local Data Protection Authority. If in the UK, you can contact the Information Commissioner’s Office (ICO). We encourage you to contact us first so we have the opportunity to address your concerns directly.

To exercise any of these rights, please contact us using the details provided in the Contact Us section of this Privacy Policy. For security purposes, we may need to verify your identity (for example, by confirming control of your email address or other verification) before fulfilling certain requests. We will respond to your request within a reasonable timeframe, and in any event within any timeframe required by law (for example, under GDPR we typically have one month to respond, which can be extended in certain cases).

Your Choices:

• Account Profile: You can review and update certain personal information by logging into your Camel Finance account and visiting your profile or account settings.

• Emails: As mentioned, you can opt out of marketing emails at any time by unsubscribing. Note that you will still receive transactional or account-related emails as long as you have an active subscription or account (unless you delete the account).

• Cookies: You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can modify your browser setting to decline cookies if you prefer. There are also tools to selectively disable analytics (like the Google Analytics opt-out plugin). Be aware that disabling cookies may affect functionality of our Service.

• Do Not Track: Our site currently does not respond to “Do Not Track” signals from browsers. If you have DNT enabled, we will still use cookies and tracking as described (since there’s no industry standard for DNT interpretation). However, we only use your data as outlined here and you can opt-out of certain tracking as noted.

• Third-Party Links: Our website or communications may occasionally contain links to third-party websites (for example, a blog post might link to a news article, or our site might link to TradingView or social media). If you follow those links, you will be subject to the third party’s privacy practices. We are not responsible for the content or privacy practices of external sites. We encourage you to read the privacy policies of any website you visit via links from our site.

International Data Transfers

Camel Finance is operated by an Indian company (Variance Technologies Pvt. Ltd.) and our servers may be located in India or other jurisdictions. If you are accessing the Service from outside of India (for example, from the United Kingdom, European Union, or elsewhere), be aware that your information will be transferred to, stored, and processed in India (and possibly on servers located in other countries, depending on our hosting arrangements). India may not have the same data protection laws as your home country. However, we will protect your personal information in accordance with this Privacy Policy no matter where it is processed.

For users in the European Economic Area (EEA), United Kingdom, or other regions with data transfer restrictions: whenever we transfer your personal data out of your region, we will take steps to ensure appropriate safeguards are in place. For example, if our hosting provider is outside the EEA, we will rely on mechanisms such as Standard Contractual Clauses (SCCs) or other approved measures to ensure data protection. Our third-party service providers, like our email or analytics providers, are also chosen in part based on their adherence to global privacy standards (e.g., some may be certified under frameworks like EU-U.S. Data Privacy Framework or bound by equivalent safeguards).

By using our Service or providing information to us, you explicitly consent (where required) to the transfer of your data to India and other jurisdictions as described. We will ensure such transfers are lawful and that your data continues to be protected under standards comparable to those in your country.

Changes to This Privacy Policy

We may update our Privacy Policy from time to time. If we make material changes to how we treat your personal information or to the policy itself, we will notify you by updating the “Last Updated” date at the top of this Privacy Policy and, if significant changes are made, by providing a prominent notice on our website or via email notification. We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting the information we collect.

Your continued use of Camel Finance after any modifications to this Privacy Policy will constitute your acknowledgment of the changes and your consent to abide and be bound by the updated policy. If you do not agree with any changes to the policy, you should stop using the Service and you may contact us to have your account and data deleted.

Got it — all user contact regarding privacy, grievances, or support must be done exclusively through the Contact Page ticket system on your website, and not via direct emails. Here’s the revised Contact Us (Privacy Queries & Grievance Officer) section that reflects this change:

Contact Us (Privacy Queries & Grievance Officer)

If you have any questions, concerns, or requests regarding this Privacy Policy, your personal data, or to report a grievance, please submit a support ticket through our official Contact Page:

Contact Page

All privacy-related communications (including data access requests, deletion requests, or consent withdrawals) must be submitted via the Contact Page. This helps us maintain proper records, ensure secure communication, and route your request to the appropriate team.

In accordance with Rule 5(9) of the Indian IT (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, we have appointed a Grievance Officer:

• Grievance Officer: Designated Privacy & Data Protection Lead

• Company: Variance Technologies Pvt. Ltd.

• Address: 7, Vrajbhumi Society, Dary Road, Palanpur, Banaskantha, Gujarat 385001, India

We will acknowledge your privacy-related concern within 48 hours of receiving the support ticket and aim to resolve the issue within 30 days, or sooner where possible, in line with applicable data protection regulations.

Please do not send emails for privacy or grievance matters. All queries must go through the contact ticket system on our website for secure and trackable resolution.

Thank you for your understanding and for choosing Camel Finance.