Aashish Research Analyst (“Company”, “we”, “us”, or “our”) operates the website https://aashishresearchanalyst.com/ (the “Site”). We are a SEBI-registered research analyst (Registration No. [Insert Your SEBI Reg. Number]) and are committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you visit our website or use our services. By accessing the Site, you consent to the practices described in this policy.
1. Information We Collect
We may collect the following types of personal and non-personal information:
- Personal Identification Information: Name, email address, phone number, date of birth, PAN, residential address, bank account details, trading account details, and any other information you voluntarily provide when registering, subscribing, or contacting us.
- Financial Information: Investment objectives, risk profile, existing portfolio details, and transaction history (where necessary for providing research services).
- Technical Data: IP address, browser type, operating system, device information, pages visited, time and date of access, and other diagnostic data collected via cookies and similar tracking technologies.
- Communication Data: Records of your correspondence with us, including emails, chat logs, and call recordings (where permitted by law).
2. How We Use Your Information
We use the collected information for the following lawful purposes:
- To provide, maintain, and improve our research reports, recommendations, and advisory services.
- To verify your identity and comply with SEBI’s Know Your Client (KYC) requirements.
- To process payments, issue invoices, and manage refunds (where applicable).
- To communicate with you regarding your account, service updates, and promotional offers (where consent is obtained).
- To respond to your queries, complaints, or grievances.
- To detect, prevent, and address technical, security, or fraudulent issues.
- To comply with legal obligations, court orders, or regulatory directives (e.g., SEBI, Income Tax authorities).
3. Legal Basis for Processing (for Indian Users)
Under Indian law, including the Information Technology Act, 2000 and the proposed Digital Personal Data Protection Act, we process your data based on:
- Consent: Where you have explicitly agreed to the collection and use of your data.
- Contract: Where processing is necessary for the performance of our service agreement with you.
- Legal Obligation: Where processing is required to comply with SEBI regulations, tax laws, or anti-money laundering rules.
- Legitimate Interests: For improving our services, preventing fraud, and ensuring network security.
4. Sharing Your Information
We do not sell, rent, or trade your personal information. However, we may share your data with:
- Service Providers: Third-party vendors who assist us with payment processing, email delivery, hosting, analytics, and customer support (they are contractually bound to protect your data).
- Regulatory Authorities: SEBI, stock exchanges, or government agencies when required by law or for investigation of suspected illegal activity.
- Professional Advisors: Lawyers, auditors, or insurers for risk management and compliance purposes.
- Business Transfers: In the event of a merger, acquisition, or asset sale, your information may be transferred (subject to same privacy protections).
5. Data Security
We implement reasonable physical, technical, and administrative security measures to protect your personal information, including:
- Encryption of sensitive data during transmission (SSL/TLS).
- Access controls and authentication mechanisms.
- Regular security audits and vulnerability scanning.
- Secure storage of physical records (where applicable).
However, no method of transmission over the Internet or electronic storage is 100% secure. While we strive to protect your data, we cannot guarantee absolute security.
6. Data Retention
We retain your personal information only for as long as necessary to:
- Fulfill the purposes outlined in this policy.
- Comply with SEBI record-keeping requirements (typically 8 years for client-related records).
- Resolve disputes and enforce our agreements.
Once the retention period expires, we will securely delete or anonymize your data.
7. Your Rights
Depending on applicable law (including the proposed Indian data protection regime), you may have the following rights:
- Right to Access: Request a copy of the personal information we hold about you.
- Right to Rectification: Correct inaccurate or incomplete data.
- Right to Erasure: Request deletion of your data (subject to legal retention requirements).
- Right to Withdraw Consent: Withdraw previously given consent at any time.
- Right to Grievance Redressal: Lodge a complaint with our Grievance Officer (details below).
To exercise these rights, please contact us using the details in Section 10.
8. Cookies and Tracking Technologies
We use cookies and similar technologies to enhance your browsing experience, analyze site traffic, and personalize content. You can control cookie preferences through your browser settings. Disabling cookies may affect certain features of the Site.
9. Third-Party Links
Our website may contain links to third-party websites (e.g., payment gateways, stock exchanges). We are not responsible for the privacy practices or content of such sites. We encourage you to read their privacy policies.
10. Grievance Officer & Contact Information
In compliance with SEBI (Research Analysts) Regulations, 2014 and the Information Technology Act, 2000, we have appointed a Grievance Officer to address your concerns:
Name: [Insert Name of Grievance Officer]
Designation: [e.g., Compliance Officer]
Email: [Insert Official Email Address]
Phone: [Insert Phone Number]
Address: [Insert Registered Office Address]
Time to respond: We will acknowledge your complaint within 24 hours and resolve it within 7 working days.
If you are not satisfied with our resolution, you may lodge a complaint on SEBI SCORES 2.0 platform (https://scores.sebi.gov.in) or with the National Stock Exchange / BSE as applicable.
11. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. Any changes will be posted on this page with a revised “Last Updated” date. We encourage you to review this policy periodically. Continued use of the Site after changes constitutes acceptance of the revised policy.
12. Jurisdiction
This Privacy Policy shall be governed by and construed in accordance with the laws of India. Any disputes arising under this policy shall be subject to the exclusive jurisdiction of the courts in [Insert City, e.g., Indore], Madhya Pradesh.
By using our website and services, you acknowledge that you have read and understood this Privacy Policy and agree to be bound by its terms.