PRIVACY AND COOKIE POLICY
TIKLE Last Updated: 19 August 2026
This Privacy and Cookie Policy (“Policy”) explains how M/S DECIFINX LLP, a company incorporated in India (the “Company”, “we”, “us”, or “our”), collects, uses, stores, shares, transfers, and protects personal information when you use TIKLE (the “Platform”). It also explains the cookies we use and how you can manage them.
This Policy sits alongside our Software Licence and Subscription Agreement and Terms of Service. It has a common core that applies to everyone, and region-specific sections for the United States, the European Union / United Kingdom, and India, which apply depending on where you are. Read the core together with the section for your region. This Policy does not create rights beyond those the law of your region gives you.
1. Who We Are and How This Policy Works
1.1. The Company is based in India and is the entity responsible for your personal data (the data controller / “business” / Data Fiduciary, depending on your region). Our contact details are in Section 20.
1.2. The Platform is offered to users in the United States and in the European Union. This Policy covers the data protection laws of India, the United States (federal and state privacy laws), and the EU/UK (once the Platform is live there).
1.3. Where a rule or right applies only in one region, it applies only to users to whom that region’s law applies. We honour your rights to the extent the law that applies to you requires.
2. Scope
This Policy applies to all users of the Platform, registered users, subscribers, trial users, and website visitors. It does not apply to third-party websites or services we link to, which have their own policies.
3. Personal Data We Collect
Categories of Personal Data
We collect the following categories of personal data:
Registration Data
Examples: Name, email, company name, job title, phone, country Purpose: Account creation, verification, communication
Usage Data
Examples: Pages viewed, features used, searches, reports downloaded, time spent Purpose: Improving the Platform, analytics
Device and Technical Data
Examples: IP address, browser, operating system, device identifiers, language Purpose: Security, fraud prevention, troubleshooting
Cookie Data
Examples: Session identifiers, cookie preferences, analytics identifiers Purpose: Website functionality and analytics (Section 10)
User Content
Examples: Saved searches, watchlists, notes, preferences Purpose: Providing and personalising the service
Communication Data
Examples: Emails, support tickets, feedback Purpose: Customer support and service improvement
Sensitive Data and Minors
We do not intentionally collect sensitive personal data (such as health, biometric, precise geolocation, or financial account numbers). Payment card details are entered directly with our payment processor and are not stored by us. We do not knowingly collect data from anyone under 18. We do not collect data for cross-context behavioural advertising.
4. Where the Data Comes From
Sources
We collect personal data: (a) directly from you, when you register, subscribe, contact us, or use the Platform; (b) automatically, through cookies and similar technologies as you use the Platform; and (c) from service providers who help us operate the Platform (for example, our payment processor and analytics providers).
Note
Note that the financial Data on the Platform about BDCs comes from public filings and is company information, not personal data about you.
5. How We Use Your Data
We use personal data to:
• provide, operate, maintain, and improve the Platform; • manage your account and process subscriptions and payments; • communicate with you about your account, updates, and support; • keep the Platform secure, prevent fraud, and enforce our terms; • carry out analytics and research to improve the Platform; • comply with our legal, tax, and regulatory obligations; • send marketing communications, only where you have opted in, with an easy opt-out; and • establish, exercise, or defend legal claims.
6. Our Legal Bases for Processing
Most processing is necessary to provide the service you asked for (contract) or to meet our legal duties. We rely on your consent only for optional things such as marketing emails and non-essential cookies. For EU/UK users, we also rely on our legitimate interests (for example, security, fraud prevention, and improving the Platform), balanced against your rights. In the US, we process personal data as described in this Policy and give you the choices your state law provides.
7. How We Share Your Data
7.1. We may share data with:
• Service providers (sub-processors) who process data on our behalf under contract, hosting, payments, email, analytics, and support providers, restricted to processing for our specified purposes; • Professional advisers (legal, accounting, audit, insurance) as needed; • Authorities and courts where required by law, legal process, or governmental request, or to protect our rights, users, or the public; • A buyer or successor in a merger, acquisition, financing, reorganisation, or sale of assets, provided they take on equivalent data protection obligations; and • Others with your consent or at your direction.
7.2. A current list of our sub-processors and the categories of recipients is available on request at info@tikle.in. We will update this Policy if we make material changes to our sub-processors.
8. We Do Not Sell or Share Your Personal Information
We do not sell your personal information, and we do not share it for cross-context behavioural advertising, as those terms are defined under US state privacy laws (including the CCPA/CPRA). We have not done so in the preceding 12 months. Because we do not sell or share, there is no financial incentive offered in exchange for personal information.
9. Where Your Data Is Stored and Cross-Border Transfers
9.1. Your data is collected and stored in India, unless we are required by law to store certain data in the United States and India.
9.2. Because the Company is in India and users are in the US (and later the EU/UK), your data will be transferred to India for processing and storage. Where we use infrastructure or providers outside India, data may also move to those locations. By using the Platform, US users understand that their data will be processed in India and other locations described here.
9.3. For transfers of EU/UK personal data to India (once the Platform is live in the EU), and for any onward transfers, we rely on Standard Contractual Clauses together with a transfer risk assessment and safeguards such as encryption and access controls. We do not rely on the EU–US Data Privacy Framework.
9.4. Under India’s DPDP Act, 2023, cross-border transfer is permitted to all countries except those the Central Government restricts by notification. As at the date of this Policy, no country has been restricted. We monitor for changes and will update this Policy if needed.
10. Cookies and Similar Technologies
10.1. We use cookies and similar technologies (pixels, local storage) for functionality, analytics, and preferences.
Essential
Purpose: Log-in, security, load balancing. Cannot be switched off. Duration: Session / persistent Consent needed?: No
Functional
Purpose: Remember your preferences and settings. Duration: Up to 1 year Consent needed?: Yes
Analytics
Purpose: Understand how users interact with the Platform and improve it. Duration: Up to 2 years Consent needed?: Yes
Advertising
Purpose: Not currently used by the Platform. Duration: N/A Consent needed?: Yes (if introduced)
10.2. Some cookies may be set by third-party providers, who have their own privacy policies. You can manage cookies through the banner, the cookie settings link in the footer, or your browser settings. Disabling some cookies may affect how the Platform works. See the Consent Mechanism document for how consent is collected and recorded.
11. Data Security
11.1. We use reasonable administrative, technical, and physical safeguards, including encryption in transit and at rest, access controls, multi-factor authentication for administrative access, regular assessments, and incident-response procedures.
11.2. No system is completely secure. We cannot guarantee absolute security and, to the extent permitted by law, are not liable for unauthorised access that occurs despite reasonable measures.
12. Data Breach Notification
If a breach affects your personal data, we will notify you and the relevant authorities without undue delay and within the timeframes required by the law that applies to you. For EU/UK users, we will notify the relevant supervisory authority within 72 hours where required. For India, we will notify the Data Protection Board of India as prescribed. For US users, we will notify affected users and, where required, state authorities in line with the applicable state breach-notification law.
13. Data Retention
13.1. We keep personal data only for as long as needed for the purpose it was collected, to provide the service, meet legal, tax, and regulatory obligations, resolve disputes, and enforce our agreements. In general: account and registration data is kept for the life of the account; billing records are kept for the period required by tax and accounting law; usage and analytics data is kept for a limited period and then aggregated or deleted; and marketing consent records are kept until you opt out.
13.2. After your account closes, we delete or anonymise your personal data within thirty (30) days, unless a longer period is required by law or you ask us to export your data first. We may keep anonymised, aggregated data indefinitely. Backups are kept for a reasonable period under our disaster-recovery process. Data under a legal hold is kept until the matter is resolved.
14. Your Rights, Core
Depending on where you are, you may have rights to access, correct, delete, or receive a copy of your personal data, to opt out of certain processing, and to withdraw consent. The region-specific sections below explain how these apply to you. To make a request, contact info@tikle.in. We will not discriminate against you for exercising your rights.
15. United States, State Privacy Disclosures
The section applies to US residents to the extent their state’s privacy law applies to us.
15.1. Your Rights:
Subject to your state’s law, you may have the right to: • Know / access the categories and specific pieces of personal information we have collected, the sources, the purposes, and the categories of recipients; • Delete the personal information we hold about you; • Correct inaccurate personal information; • Portability, receive a copy in a portable, machine-readable format; • Opt out of the sale or sharing of personal information for targeted advertising (we do not do this) and of certain profiling; and • Limit the use of sensitive personal information (we do not use sensitive information beyond what is necessary to provide the service and as permitted by law).
15.2. How to exercise your rights, and verification:
Submit requests to info@tikle.in. To protect your data, we will verify your identity before acting, using information we already hold; we may decline a request we cannot reasonably verify. You may use an authorised agent, who must provide proof of authorisation. We will acknowledge and respond within the time your state law allows, generally within 45 days, extendable by a further 45 days with notice.
15.3. Right to appeal:
If we decline your request, you may appeal by replying to our decision or writing to info@tikle.in. We will respond to the appeal within the time your state law requires (typically 45–60 days). If we deny the appeal, we will tell you how to complain to your state Attorney General.
15.4. Exceptions:
We may keep or decline to delete personal information where the law allows or requires, for example, to complete a transaction, comply with legal or tax obligations, keep records required for financial or securities-related purposes, detect security incidents, or establish or defend legal claims.
15.5. California, additional disclosures:
This Policy serves as our Notice at Collection for California residents. The categories of personal information we collect are listed in Section 3; the sources in Section 4; the business and commercial purposes in Section 5; and the categories of recipients in Section 7. We do not sell or share personal information and have not done so in the past 12 months. Under California’s “Shine the Light” law, you may request information about disclosures to third parties for their direct marketing (we do not make such disclosures). California residents also have the rights set out above and the right not to receive discriminatory treatment for exercising them.
15.6. Neveda:
Nevada residents may opt out of the sale of certain personal information. We do not sell personal information as defined under Nevada law, but you may contact info@tikle.in with any request.
16. European Union/United Kingdom (GDPR), applies once the Platform is live in the EU/UK
You may have the right to: access your data; correct it; erase it; restrict or object to processing (including processing based on our legitimate interests, and any direct marketing); receive it in a portable format; withdraw consent at any time; and complain to your data protection authority. We will respond within one month, extendable by two further months for complex requests.
As the Company has no establishment in the EU/UK, we will appoint a representative under Article 27 GDPR (and a UK representative) whose contact details will be added here before the EU launch. Transfers of your data to India rely on Standard Contractual Clauses and the safeguards in Section 9.
17. India (DPDP Act, 2023)
If the DPDP Act applies to you, you have the right to: access information about your personal data; correct and erase it; grievance redressal with us and, if unresolved, with the Data Protection Board of India; and nominate another person to exercise your rights in the event of death or incapacity. Before or at the time we seek consent, we give a clear notice of the data collected and the purpose, in English and other listed languages where required. Contact info@tikle.in to exercise these rights or raise a grievance.
18. Children’s Privacy
The Platform is for users aged 18 and over and is not intended for anyone under 18. We do not knowingly collect data from minors. If we learn that we have, we will delete it promptly.
19. Do Not Track and Global Privacy Control
We recognise and respond to Global Privacy Control (GPC) signals and other universal opt-out mechanisms where required by applicable state law, and treat a valid GPC signal as an opt-out of any sale or sharing for cross-context behavioural advertising. Because browser “Do Not Track” signals are not standardised, we respond to them only as required by law.
20. Accessibility and Third-Party Links
We aim to make this Policy and our consent tools reasonably accessible. If you need this Policy in an alternative format, contact info@tikle.in. The Platform may link to third-party sites, which have their own privacy practices we do not control.
21. Changes to this Policy
We may update this Policy from time to time. We will tell registered users of material changes by email and by notice on the Platform at least fourteen (14) days before they take effect. The date at the top shows the latest update.
22. Contact Us
For questions, to exercise your rights, or to raise a complaint, contact: M/s DECIFINX LLP Attn: Data Protection Officer / Privacy Team ADD: 4th floor Golf course Road Sector-42, Golf View Tower, DLF QE, Gurgaon, Dlf Qe, Haryana, India, 122002 Email: info@tikle.in US users may also contact the California Privacy Protection Agency (cppa.ca.gov) or their state Attorney General. India users may contact the Data Protection Board of India. EU/UK users may contact their local supervisory authority.