Privacy Policy

1. Introduction

Nilesh Sarda, a SEBI Registered Research Specialist (Registration No. INH000014711), is committed to protecting the privacy and confidentiality of personal information provided by our clients and website visitors. This Privacy Policy outlines how we collect, use, store, and protect your personal data in compliance with SEBI regulations and applicable privacy laws.

2. Information We Collect

2.1 Personal Information:

• Complete name, residential address, and contact information
• Email address and telephone numbers
• Date of birth and age verification details
• PAN number and other tax identification details
• Bank account information for service payments
• Trading and investment experience details
• Financial information relevant to investment advisory services

2.2 Technical Information:

• IP address and browser information
• Device information and operating system
• Website usage patterns and preferences
• Cookies and tracking data

2.3 Investment-Related Information:

• Investment objectives and risk tolerance assessment
• Trading account details (for service delivery)
• Portfolio information and investment history
• Communication preferences and requirements

3. How We Use Your Information

• Providing professional investment research and advisory services
• Customizing investment recommendations based on your profile
• Communicating market insights and trading opportunities
• Maintaining client records as required by SEBI
• Compliance with KYC (Know Your Customer) requirements
• Risk assessment and suitability analysis
• Invoicing and payment processing
• Responding to queries and providing customer support
• Regulatory reporting and compliance obligations

4. Information Sharing and Disclosure

4.1 We May Share Information With:

• SEBI and other regulatory authorities (when legally required)
• Authorized service providers (under strict confidentiality agreements)
• Payment processors for transaction processing
• Legal advisors and auditors (for compliance purposes)
• Courts or tribunals (under legal compulsion)

4.2 We Never Share Information For:

• Marketing purposes by third parties
• Sale to data brokers or aggregators
• Unauthorized commercial activities
• Non-compliance purposes

5. Data Security Measures

• Encryption of sensitive data during transmission and storage
• Secure servers with multi-factor authentication
• Regular security audits and vulnerability assessments
• Employee training on data protection protocols
• Access controls limiting data access to authorized personnel only
• Regular backup and disaster recovery procedures
• Compliance with industry-standard security practices

6. Data Retention Policy

• Client information: Minimum 5 years from service termination
• Research reports and recommendations: 5 years from publication
• Communication records: 3 years from last communication
• Financial transaction records: 5 years from transaction date
• Compliance records: As required by applicable regulations
• Website analytics: 2 years for performance analysis

7. Your Rights and Choices

7.1 Access Rights:

• Request access to your personal information
• Obtain copies of data we hold about you
• Inquire about data processing activities

7.2 Correction Rights:

• Update or correct inaccurate information
• Complete incomplete data records
• Modify communication preferences

7.3 Limitations:

8. Cookies and Tracking Technologies

8.1 Essential Cookies:

• Login and authentication cookies
• Security and fraud prevention
• Service delivery optimization

8.2 Analytics Cookies:

• Website performance monitoring
• User experience improvement
• Content optimization

Cookie Control: You can manage cookie preferences through your browser settings, though this may affect website functionality.

9. Third-Party Services

• Payment gateways for secure transactions
• Email service providers for communications
• Cloud storage providers (with data residency compliance)
• Analytics tools for website improvement

10. International Data Transfers

• Primary data storage in Indian data centers
• Adequate protection measures for any overseas transfers
• Compliance with RBI and SEBI data localization requirements
• Client notification for any significant data transfers

11. Children's Privacy

12. Privacy Policy Updates

• Regular review and updates as needed
• Client notification of material changes
• 30-day notice period for significant modifications
• Version control and change documentation
• Regulatory compliance updates

13. Contact Information for Privacy Matters

14. Grievance Redressal

For Privacy-Related Complaints:

• Contact our Privacy Officer directly
• File complaint through SEBI SCORES portal
• Escalate to appropriate regulatory authorities
• Expected resolution time: 30 days