Privacy Policy

WhoHolds (“we,” “us”) is operated by Meet Shah, an individual (sole proprietor) based in India. For any privacy question or request, contact our Grievance Officer at grievance@whoholds.com.

You can browse and search WhoHolds without creating an account. We collect:

• Usage & device data — pages viewed, approximate location (from IP), browser/device type, and referring site, via privacy-respecting analytics and server logs.
• Cookies & similar technologies — essential cookies (e.g. your light/dark theme), and, where enabled, analytics and advertising cookies (see below).
• Account data (only if you sign up) — your email address and authentication identifier, used to provide and bill any paid features. We never ask for, store, or import your brokerage or demat credentials or personal portfolio.

• To operate, secure, and improve the website and its search/lookup features.
• To understand aggregate usage so we can prioritise coverage and features.
• To provide, bill, and support paid (Pro) features, if and when you subscribe.
• To comply with legal obligations.

Where the DPDP Act requires it, we rely on your consent (for example, for non-essential analytics and advertising cookies), which you may withdraw at any time.

Today we set only essential cookies (for example, to remember your light/dark theme). We do not currently run third-party advertising, and we use only privacy-respecting, aggregate analytics.

• Advertising (when enabled): if we later introduce ads through networks such as Google AdSense, those partners may use cookies/identifiers to serve and measure ads. We will update this policy and ask for your consent to non-essential cookies before enabling them. You can manage Google ad personalisation at google.com/settings/ads.
• Affiliate links: some outbound links (e.g. to brokers) are affiliate links. If you sign up or transact, we may earn a commission at no extra cost to you. This never influences the factual data we show.
• Analytics: we use aggregate analytics to measure traffic. We do not sell your personal data.

We share data only with service providers that help us run the site — for example our hosting provider, database provider, analytics, payment processor, and advertising/affiliate partners — under their respective terms, and where required by law. We do not sell your personal data.

Under the DPDP Act, 2023 you may:

• Access the personal data we hold about you and request a summary of processing.
• Request correction, completion, updating, or erasure of your personal data.
• Withdraw consent for processing that relies on consent.
• Nominate another person to exercise your rights in case of death or incapacity.
• Raise a grievance with our Grievance Officer, and escalate to the Data Protection Board of India.

To exercise any right, email our Grievance Officer (below). Tell us your name, the email associated with any account, and what you would like us to do. We aim to acknowledge within 7 days and resolve within 30 days (or tell you why we need longer). If unsatisfied, you may escalate to the Data Protection Board of India.

In line with the DPDP Act, 2023, you can reach our Grievance Officer at:

• Name: Meet Shah
• Email: grievance@whoholds.com
• Location: Ahmedabad, Gujarat, India

• Server logs (IP, pages, device) are retained for up to 90 days for security and abuse-prevention, then deleted or anonymised.
• Account data (e.g. email) is kept while your account is active and deleted within 30 days of closure, unless we must keep it longer by law.
• Payment records, if you subscribe, are retained as long as tax/financial law requires (typically several years) by us and our payment processor.
• We use reasonable technical and organisational measures to protect your data, though no method is perfectly secure.
• WhoHolds is not designed or intended for children under 18. If we learn we have collected a minor's data without verifiable parental consent, we will delete it promptly — a parent/guardian can contact our Grievance Officer.

We may update this policy from time to time. Material changes will be reflected by the “Last updated” date above. Continued use of the site after a change means you accept the updated policy.