Privacy Policy

1. Personal data we collect

• When you contact us (email, phone, WhatsApp): your name, email address, phone number and the content of your message.
• When you subscribe to a paid plan: KYC details required by SEBI (such as name, PAN, address, date of birth and identity documents), contact details, payment records, your consent to our terms, and records of our communications with you.
• When you browse this website: only if you accept analytics cookies, Google Analytics collects usage data (pages viewed, approximate location, device and browser type). If you decline, no analytics data is collected.
• Preferences stored on your device: your theme, text-size, contrast and cookie choices are saved in your browser's local storage. They never leave your device.

This website has no sign-up or contact forms and does not collect payment card details.

2. Why we use it

• To reply to your queries and grievances.
• To onboard you as a client, complete KYC and deliver the research service you subscribed to.
• To meet our obligations under the SEBI (Research Analysts) Regulations, 2014, SEBI circulars and other applicable law, including record-keeping and audit.
• With your consent only: to understand website usage through Google Analytics.

We process personal data on the basis of your consent, or for legitimate uses permitted under Section 7 of the DPDP Act, such as complying with a legal obligation. We do not use your data for marketing without your consent, and we never sell it.

3. Who we share it with

• Regulators and statutory bodies: SEBI, BSE Limited (RAASB) and KYC Registration Agencies (KRAs), as required by law.
• Service providers acting on our instructions: website hosting, email, and (if you consent) Google Analytics. Some of these may process data outside India, subject to any restrictions notified under the DPDP Act.
• WhatsApp: if you join our free community, your phone number is visible to other members and is handled under WhatsApp's own privacy policy.
• Law enforcement: when required by a valid legal order.

4. Cookies and analytics

We use Google Analytics only after you click "Accept analytics" in the cookie banner. You can change your choice at any time: Cookie preferences. No advertising or cross-site tracking cookies are used.

5. How long we keep it

• Client records (KYC, terms and consent, payment records, research reports provided and client communications): kept for at least five years as required by the SEBI (Research Analysts) Regulations, 2014, or longer if a regulator or court requires.
• Queries from non-clients: deleted once resolved and no longer needed, unless the conversation related to our research services, in which case SEBI requires us to keep a record.
• Analytics data: kept only for the retention period configured in Google Analytics, after which it is deleted automatically.

6. Security

We use reasonable security safeguards, including encrypted connections (HTTPS) and access-restricted storage, to protect personal data. If a personal data breach occurs, we will inform affected persons and the Data Protection Board of India as required by the DPDP Act.

7. Your rights

Under the DPDP Act you may:

• ask for a summary of the personal data we hold about you and how it is processed;
• ask us to correct, complete, update or erase your data (except where the law requires us to keep it);
• withdraw consent at any time — as easily as you gave it;
• nominate another person to exercise your rights in the event of your death or incapacity;
• have your grievance redressed by us, and if unsatisfied, complain to the Data Protection Board of India.

8. Children

Our services are meant for adults (18+). We do not knowingly collect data from children. If you think we have, please contact us and we will delete it.

9. Contact & privacy grievances

For any privacy request or grievance, contact the person responsible for data protection:

We will respond within 7 business working days, and in any case within 21 calendar days.

10. Changes to this policy

When we change this policy we will update the date at the top of this page. Material changes affecting clients will also be communicated by email.