1. Introduction
Sleeping Trade ("we", "us", "our") operates the website sleepingtrade.in. This Privacy Policy describes how we collect, use, store, and protect your personal data in connection with our services. Our practices are designed to be consistent with the Digital Personal Data Protection Act, 2023 (DPDP Act 2023) of India, the Information Technology Act, 2000 and associated rules, and other applicable laws. For users accessing the Service from outside India, comparable data-protection regimes (such as GDPR for EU residents) may also apply.
2. Data We Collect
We collect only the data required to provide the Service.
Personal data you provide
- Full name
- Email address
- Phone number (for WhatsApp alerts and account contact)
Broker API credentials (trading only)
- API keys and tokens from your supported Indian broker (Zerodha, Upstox, Angel One, 5Paisa, Fyers).
- API credentials are encrypted at rest and transmitted only over TLS 1.3.
- API keys are scoped to trade-only permissions. They do not allow fund withdrawals or transfers.
Trading activity data
- Trades executed via the platform, positions, orders, and performance metrics relevant to the Service.
Usage data
- Pages visited, features used, device information (browser, OS), IP address, approximate location, access timestamps.
3. Data We Do NOT Collect
- We do not collect or hold your bank account details.
- We do not custody or hold your funds — they remain in your broker account.
- We do not collect your PAN, Aadhaar, income, net worth, or other personal financial information beyond what is strictly required to operate the Service.
- We do not collect your broker login password.
4. How We Use Your Data
- Service delivery: To provide and maintain the Service, including executing trades through your broker API.
- Notifications: To send WhatsApp/email alerts and daily P&L summaries relating to your trading activity.
- Account communications: To contact you about billing, service updates, security events, and support requests.
- Model improvement: To analyse aggregated, anonymised data to improve the platform. Individual user data is not used for the benefit of other users.
- Legal compliance: To comply with applicable laws, including tax, anti-fraud, and data-protection obligations.
Communications Consent
By providing your phone number and email, you consent to receive:
- Trade execution alerts via WhatsApp and email
- Daily and weekly performance summaries
- Account and billing notifications
- Security alerts
You can opt out of marketing communications anytime by replying STOP to WhatsApp messages or clicking unsubscribe in emails. Transactional messages (trade alerts, security notifications) continue as long as your account is active, as these are essential to the Service.
All WhatsApp messages are sent using the WhatsApp Business API with pre-approved templates compliant with WhatsApp's commerce policy.
5. Data Storage and Security
- Encryption at rest: API credentials and sensitive data are encrypted at rest.
- Encryption in transit: All data exchanges use TLS 1.3.
- Access controls: Role-based, least-privilege access. No individual employee can view raw API keys.
- Security audits: Regular internal audits and dependency monitoring.
- Breach response: If we become aware of a personal data breach, we will notify affected users and, where applicable, the Data Protection Board of India in accordance with DPDP Act 2023 timelines.
6. Data Sharing
- We do not sell your personal data to any third party.
- Third-party service providers: We use third-party services (such as payment processing, cloud infrastructure, analytics, email/SMS/WhatsApp delivery) strictly to operate the Service. These providers process data on our instructions and under appropriate contractual safeguards. We describe the categories of providers here rather than naming specific vendors, since vendors may change.
- Legal requirements: We may disclose data if required by Indian law or by a lawful order from a competent authority.
7. Your Rights Under the DPDP Act 2023
As a Data Principal, you have the following rights:
- Right to access: Request a summary of the personal data we process about you and the purposes of processing.
- Right to correction: Request correction of inaccurate or misleading personal data, and completion of incomplete data.
- Right to erasure: Request deletion of your personal data, subject to our legal obligation to retain certain records (for example, for tax or audit purposes).
- Right of grievance redressal: Raise complaints about our handling of your data. We will acknowledge and respond within a reasonable time.
- Right to nominate: Nominate an individual to exercise these rights on your behalf in the event of your death or incapacity.
To exercise any right, email hello@sleepingtrade.in.
8. Cookies
Our website uses essential cookies required for authentication, session management, and core functionality. Analytics cookies, if used, are placed with your consent and can be disabled. Full details are in our Cookie Policy.
9. Data Retention
- Active accounts: Retained while the account is active and for a reasonable period thereafter.
- Account closure: Personal data (name, email, phone, API credentials) will be deleted within a reasonable period after closure, typically within 30 days, subject to legal retention requirements.
- Trading records: Retained for the period required under Indian tax and record-keeping rules.
- Aggregated / anonymised data: May be retained indefinitely.
10. Children's Privacy
The Service is not intended for persons under 18. We do not knowingly collect personal data from minors. Parents/guardians who believe a minor has provided data to us should contact us for deletion.
11. Cross-Border Transfers
Sleeping Trade is operated by a US-based software company. As permitted by the DPDP Act 2023, personal data may be processed on systems located outside India where our infrastructure providers are based. Where this occurs, we apply appropriate contractual and technical safeguards.
12. Changes to This Policy
We may update this Privacy Policy from time to time. Material changes will be communicated via email or a prominent notice on the website. The "Last updated" date above reflects the current version.
13. Contact and Grievance Officer
- Email (grievance / data requests): hello@sleepingtrade.in
- WhatsApp: See Contact.