Last updated: 06-08-2026

This Privacy Policy explains how Heed Unlisted collects, uses, shares, and protects your personal information when you visit or use heedunlisted.com.

1. Introduction

This policy is issued by Heed Securities (“Heed Unlisted,” “we,” “us,” “our”), registered office at L-2/114, New Mahavir Nagar, Tilak Nagar, New Delhi–110018.

This policy is prepared with reference to the Digital Personal Data Protection Act, 2023 and the Digital Personal Data Protection Rules, 2025, which together form India’s primary personal data protection framework, along with the Information Technology Act, 2000 and rules made under it. Note that the DPDP Act’s provisions are being phased in over 2025–2027, so certain mechanisms described below (such as the Data Protection Board’s grievance process) will become fully operative as those provisions take effect.

By using the Website, you consent to the collection and use of your information as described here. If you do not agree, please do not use the Website.

2. Who This Policy Covers

This policy applies to all visitors to the Website and to anyone who registers, submits an enquiry, or transacts with us (“you,” “User”).

3. Information We Collect

3.1 Information you give us directly

  • Contact details: name, email, phone number, address
  • Identity and KYC information: PAN, and where relevant to a transaction, Aadhaar or other proof of identity
  • Demat account details, needed to credit or debit shares as part of a transaction
  • Bank account or payment details, needed to process a transaction
  • Investment-related information you share with our team, such as your interests or the transaction you’re enquiring about
  • Anything you submit through contact forms, email, phone calls, or chat with our team

3.2 Information collected automatically

When you browse the Website, we (and analytics tools we use) may automatically collect your IP address, browser and device type, pages viewed, time spent, referring pages, and similar usage data, generally through server logs and cookies (see Section 6).

3.3 Information from third parties

We may receive limited information from analytics providers (such as Google Analytics) or, where you choose to interact with us via a linked platform, from that platform.

4. How We Use Your Information

We use your information to:

  • Respond to your enquiries and coordinate a transaction with you, including verifying your identity, discussing pricing, processing payment through our disclosed official channels, and arranging Demat settlement
  • Maintain your account, if you register one
  • Send you service-related communications, such as transaction confirmations or updates to our policies
  • Send you market updates or newsletters, where you’ve opted in
  • Improve the Website and understand how it’s used
  • Detect and prevent fraud, and meet our legal and regulatory obligations (including KYC and anti-money-laundering requirements)
  • Enforce our Terms of Use and protect our rights

5. How We Share Your Information

5.1 We do not sell your personal information.

5.2 We may share information with:

  • Service providers who support our operations — for example, hosting, analytics, payment processing, and customer support tools — under obligations to keep it confidential and use it only for the purpose we’ve engaged them for.
  • Legal and regulatory authorities, where required by law, court order, or a valid government request, or to investigate suspected fraud or illegal activity.
  • A successor entity, if we’re involved in a merger, acquisition, or sale of business assets — we’ll notify you if this affects your data.
  • Anyone else, with your explicit consent.

We do not share your information with data brokers or with unrelated third parties for their own marketing purposes.

6. Cookies and Tracking

We use cookies and similar technologies to keep the Website functional, understand how it’s used (for example, via Google Analytics), and remember your preferences. You can control or disable cookies through your browser settings, though some Website features may not work properly without them.

7. Data Security

We use reasonable technical and organisational measures to protect your information, including encrypted data transmission (SSL/TLS), access controls limiting who on our team can see sensitive data, and secure storage. That said, no method of transmission or storage over the internet is completely secure, and we cannot guarantee absolute security. You’re responsible for keeping your own account credentials confidential and for telling us promptly if you suspect unauthorised access.

If a data breach affecting your personal information occurs, we will notify you and the relevant authorities as required under applicable law.

8. Data Retention

We retain your information for as long as needed to provide our services, comply with legal and tax record-keeping obligations, resolve disputes, and enforce our agreements. When information is no longer needed for these purposes, we will delete it or render it anonymous, except where longer retention is required by law (for example, transaction and tax records).

9. Your Rights

Consistent with the DPDP Act, 2023, you have the right to:

  • Access the personal information we hold about you
  • Request correction of inaccurate or incomplete information
  • Request erasure of your information, subject to our legal retention obligations
  • Withdraw consent for processing that relies on your consent (such as marketing), without affecting processing already carried out
  • Nominate another individual to exercise these rights on your behalf in the event of your death or incapacity
  • Raise a grievance with us, and if unresolved, escalate it to the Data Protection Board of India as that mechanism becomes operative

To exercise any of these rights, contact us using the details in Section 12. We aim to respond within 30 days.

10. Marketing Communications

We will only send you promotional or marketing communications if you’ve opted in. You can opt out at any time by clicking “unsubscribe” in any marketing email, or by contacting us directly. You cannot opt out of essential service communications, such as transaction confirmations, security alerts, or updates to our legal policies.

11. Children’s Privacy

The Website is not intended for anyone under 18. We do not knowingly collect personal information from minors. If you believe a minor’s information has been shared with us, please contact us and we will take steps to delete it.

12. Third-Party Links

The Website may link to third-party sites. We aren’t responsible for their content or privacy practices, and encourage you to review their policies separately.

13. Where Your Data Is Stored

Your information is stored and processed primarily in India. If we ever need to transfer data outside India, we will do so only in accordance with the DPDP Act’s requirements for cross-border data transfer at that time.

14. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be reflected by an updated “Last updated” date and, where appropriate, a notice on the Website. Continued use of the Website after a change constitutes acceptance of the revised policy.

15. Grievance Officer

In accordance with the Information Technology Act, 2000 and applicable rules, we have designated a Grievance Officer to address privacy-related concerns:

  • Name: [insert name]
  • Email: [insert grievance officer email, or info@heedsecurities.com]
  • Phone: +91 971 694 1383 / +91 767 844 4704
  • Address: L-2/114, New Mahavir Nagar, Tilak Nagar, New Delhi–110018

We will acknowledge grievances within 48 hours and aim to resolve them within 30 days.

16. Governing Law

This policy is governed by the laws of India. Any dispute relating to it is subject to the exclusive jurisdiction of the courts of [insert city, e.g., New Delhi].

17. Contact Us

For any questions about this Privacy Policy or how we handle your data:

  • Email: info@heedsecurities.com
  • Phone: +91 971 694 1383 / +91 767 844 4704
  • Registered Office: L-2/114, New Mahavir Nagar, Tilak Nagar, New Delhi–110018

18. Acknowledgment

By using this Website, you confirm that you have read and understood this Privacy Policy and consent to the collection, use, and sharing of your information as described here.

This is a starting draft, not a substitute for legal review. Since Heed Unlisted collects sensitive data — PAN, Demat details, bank details — as part of coordinating transactions, it’s worth having a lawyer confirm this against the DPDP Act’s phased compliance requirements (some obligations, like consent manager rules, only bind from November 2026), and against how you actually store and secure that data, before publishing.