This Privacy Policy is issued in compliance with applicable laws including the provisions of the Securities and Exchange Board of India (Research Analysts) Regulations, 2014 and other applicable regulations, guidelines, circulars, and directions issued by SEBI.

1. Scope and Applicability

This policy applies to all users accessing the website and services provided by Neeraj Shah ("Research Analyst", "RA", "we", "us"). By accessing our platform, you agree to the collection and use of information in accordance with this policy.

2. Information We Collect

a. Personal Information:

• Full Name
• Email Address
• Mobile Number
• Date of Birth
• PAN Card Details (mandatory as per SEBI regulations)

b. KYC & Regulatory Information:

• Identity Proof (PAN, Aadhaar, etc.)
• Address Proof
• Bank Details
• Income/Financial Details (if required)
• IPV (In-Person Verification) / Video KYC Data
• E-signature records

c. Technical Data:

• IP Address
• Device Information
• Browser Type
• Cookies and usage logs

3. Purpose of Data Collection

• To comply with SEBI regulations and KYC norms
• To onboard clients and maintain records as per regulatory requirements
• To provide research reports and advisory services
• To process subscription payments
• To prevent fraud, unauthorized access, and misuse
• To maintain audit trails and records for inspection by regulatory authorities

4. Regulatory Compliance & Record Maintenance

As a SEBI Registered Research Analyst, we are required to maintain records of client information, KYC data, communication, and transactions for a minimum period as prescribed under applicable regulations.

Such data may be disclosed to SEBI, stock exchanges, or other regulatory authorities during audits, inspections, or investigations without prior consent of the user.

5. Data Sharing and Disclosure

We do not sell personal data. Information may be shared strictly with:

• KYC Registration Agencies (KRA)
• Payment gateway providers and banking partners
• E-sign and verification service providers
• Cloud storage and IT service providers
• Regulatory authorities (including SEBI)

6. Data Security

• SSL encryption
• Secure data storage systems
• Restricted access to sensitive data
• Periodic audits and monitoring

While we take reasonable security measures, no system can guarantee absolute security. Users are responsible for safeguarding their login credentials.

7. Cookies Policy

We use cookies and similar tracking technologies to improve user experience, analyze traffic, and enhance functionality. Users may disable cookies through browser settings.

8. User Rights

• Access and review personal data
• Request correction of inaccurate information
• Withdraw consent (subject to regulatory obligations)

Certain data cannot be deleted due to mandatory SEBI record-keeping requirements.

9. Data Retention

Data is retained for a minimum period as required under SEBI regulations and applicable laws, even after termination of services.

10. Third-Party Links

Our website may contain links to third-party platforms. We are not responsible for their privacy policies or practices.

11. Disclaimer (Mandatory SEBI Clause)

Registration granted by SEBI, membership of BASL (if applicable), and certification from NISM does not in any way guarantee performance of the intermediary or provide any assurance of returns to investors.

Investments in securities markets are subject to market risks. Read all related documents carefully before investing.

The Research Analyst does not provide any assured or guaranteed returns.

12. Grievance Redressal

Name: Neeraj Shah

Address: WZ-3-A/62, (F.F), Plot No-62, Vishnu Garden, Extn No-III, Block-A, Near Guru Dawara, New Delhi-110018, India

Phone: 7827748896

Email: Neerajshah1010@gmail.com

If not satisfied, clients may lodge complaints with SEBI through SCORES platform.

13. Updates to Policy

This Privacy Policy may be updated periodically. Users are advised to review this page regularly.