IMPORTANT NOTICE

PLEASE READ THESE TERMS CAREFULLY BEFORE USING THE BULLSMART PLATFORM OR PARTICIPATING IN THE BETA ACCESS PROGRAM.

INVESTMENTS IN SECURITIES MARKETS ARE SUBJECT TO MARKET RISKS. READ ALL RELATED DOCUMENTS CAREFULLY BEFORE INVESTING.

1. ABOUT THE BETA ACCESS PROGRAM

The Bullsmart Beta Access Program is a limited, invitation-only program under which selected users may be granted access to the Bullsmart trading platform prior to or during its broader public rollout.

Participation in the Program is entirely at Bullsmart's discretion and may be offered, withdrawn, suspended, or modified at any time.

The Beta Access Program is intended to allow Bullsmart to evaluate platform functionality, user experience, operational processes, and system performance. Participation in the Program does not create any right to continued access, future benefits, or permanent eligibility.

2. BETA PLATFORM DISCLOSURE

The Platform is being made available on a beta or early-access basis.

You acknowledge and agree that:

• certain features may be incomplete, modified, suspended, discontinued, or unavailable;
• the Platform may contain software defects, bugs, errors, delays, interruptions, or inaccuracies;
• market data, reports, analytics, portfolio values, charges, positions, and other information displayed on the Platform may occasionally be delayed or contain errors;
• Bullsmart may modify platform functionality without prior notice; and
• you are solely responsible for reviewing and verifying all order details before placing any trade.

Nothing in this clause limits any rights that cannot be excluded under applicable law.

3. ELIGIBILITY

To participate in the Program, you must:

• be an individual resident of India and at least 18 years of age;
• possess a valid PAN;
• complete KYC and onboarding requirements as prescribed under applicable laws and regulations; and
• satisfy all eligibility criteria determined by Bullsmart from time to time.

Only one trading account per PAN shall be eligible for participation.

Any attempt to create, operate, or benefit through multiple accounts may result in suspension or termination from the Program.

4. EARLY ACCESS BROKERAGE BENEFIT

Selected users may be offered a promotional brokerage waiver for a period of ninety (90) days or such other duration as communicated during onboarding.

The following conditions apply:

• no predefined daily order limit applies during the promotional period, subject always to Clauses 6 and 7 of these Terms;
• all eligible orders placed during the promotional period shall qualify for the brokerage waiver;
• the waiver applies solely to brokerage charges;
• statutory and regulatory charges, including but not limited to STT, GST, exchange transaction charges, SEBI fees, clearing charges, DP charges, and stamp duty shall continue to apply at prevailing rates;
• the benefit is personal, non-transferable, non-assignable, and has no cash value; and
• Bullsmart reserves the right to modify, extend, reduce, suspend, or terminate the benefit with reasonable notice where practicable.

5. LIFETIME FREE BROKERAGE BENEFIT

Bullsmart may, at its sole discretion, offer a Lifetime Free Brokerage benefit to selected users.

The following conditions shall apply:

• eligibility shall be determined solely by Bullsmart based on business, operational, promotional, compliance, risk-management, or other criteria determined by Bullsmart;
• participation in the Beta Access Program does not guarantee eligibility;
• where awarded, the benefit shall apply to a maximum of one hundred (100) orders per trading day per account;
• orders exceeding such limit may be charged brokerage at prevailing rates;
• the benefit is personal and non-transferable; and
• Bullsmart may suspend or revoke the benefit due to misuse, regulatory requirements, operational considerations, risk concerns, or material business changes.

Where reasonably practicable, prior notice shall be provided.

6. FAIR USE POLICY AND PROHIBITED ACTIVITIES

The Program is intended solely for genuine trading activity.

Users shall not:

• engage in wash trades, self-trades, circular trading, synchronized trading, or other non-genuine transactions;
• engage in spoofing, layering, quote stuffing, market manipulation, fraudulent conduct, or any activity prohibited under applicable laws or exchange rules;
• operate multiple accounts to obtain additional promotional benefits;
• use automated systems, scripts, bots, APIs, or technological means to generate artificial activity or circumvent program restrictions;
• engage in abusive, excessive, or non-genuine order activity intended primarily to exploit promotional benefits; or
• undertake any activity that may violate SEBI regulations, exchange rules, clearing corporation requirements, or applicable law.

7. MONITORING AND ENFORCEMENT

Bullsmart may monitor and review account activity for compliance, fraud prevention, risk management, operational, regulatory, and surveillance purposes.

Where Bullsmart reasonably determines that activity is inconsistent with the intent of the Program or applicable regulations, Bullsmart may:

• impose trading or order limits;
• suspend promotional benefits;
• revoke promotional benefits;
• restrict account functionality;
• suspend or close the trading account, subject to regulatory requirements; and/or
• report or refer the matter to relevant exchanges, depositories, clearing corporations, law enforcement authorities, or regulatory agencies.

Bullsmart shall not be liable for actions taken in good faith under this clause.

8. PROGRAM CHANGES

Bullsmart may modify, suspend, discontinue, or replace any aspect of the Program at any time.

Material changes shall be communicated through the Platform, email, website publication, or other reasonable means.

Continued use of the Platform after such communication shall constitute acceptance of the revised Terms.

9. REGULATORY DOCUMENTS AND CLIENT AGREEMENTS

Participation in the Program remains subject to execution and acceptance of all applicable regulatory and contractual documentation, including but not limited to:

• Account Opening Form
• Rights and Obligations Document
• Risk Disclosure Document
• Policies and Procedures
• Tariff Sheet
• Nomination-related declarations
• Running Account Authorizations (where applicable)
• Any other documents prescribed by SEBI, stock exchanges, clearing corporations, depositories, or applicable law.

In the event of any conflict between these Terms and any regulatory document or client agreement, the regulatory document or client agreement shall prevail to the extent required by law.

10. INVESTMENT RISK DISCLAIMER

MANDATORY DISCLOSURE

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

Trading in securities, derivatives, commodities, and other market-linked products involves substantial risk, including the risk of loss of capital.

Derivatives involve leverage and may result in losses exceeding initial margins deposited.

Past performance is not indicative of future results.

Lower brokerage costs do not reduce investment risk and do not increase the likelihood of profits.

Skywards Investec Private Limited is registered with the Securities and Exchange Board of India ("SEBI") as a Stock Broker under Registration No. INZ000315235.

Nothing on the Platform constitutes investment advice, research advice, tax advice, legal advice, or a recommendation to buy, sell, or hold any security unless expressly identified and regulated as such under applicable law.

All investment decisions are solely the responsibility of the user.

11. PRIVACY AND DATA PROCESSING

Participation in the Program is subject to Bullsmart's Privacy Policy.

By using the Platform, you consent to the collection, processing, storage, sharing, and use of your information in accordance with Bullsmart's Privacy Policy.

Bullsmart may share information with regulators, exchanges, depositories, clearing corporations, service providers, and government authorities where required by law or regulatory obligation.

12. LIMITATION OF LIABILITY

To the maximum extent permitted by law, Bullsmart, its directors, officers, employees, affiliates, vendors, and service providers shall not be liable for any indirect, incidental, consequential, special, exemplary, or punitive damages arising from:

• use of or inability to use the Platform;
• software bugs, errors, or interruptions;
• delays in market data or order execution;
• exchange, depository, clearing corporation, OMS, RMS, telecommunications, internet, power, or third-party service failures; or
• suspension, modification, or termination of the Program.

Nothing in these Terms shall exclude liability where such exclusion is prohibited by law.

13. FORCE MAJEURE

Bullsmart shall not be responsible for any delay, interruption, or failure in performance resulting from events beyond its reasonable control, including natural disasters, war, civil disturbances, governmental actions, cyberattacks, telecommunications failures, exchange outages, power failures, epidemics, or other force majeure events.

14. GOVERNING LAW, GRIEVANCES AND DISPUTE RESOLUTION

These Terms shall be governed by and construed in accordance with the laws of India.

Nothing in these Terms limits any rights available to clients under applicable SEBI regulations, exchange investor grievance mechanisms, arbitration frameworks, or statutory remedies.

Users may raise complaints through Bullsmart's designated grievance redressal mechanism and may also approach the SEBI SCORES platform or applicable exchange grievance forums.

Subject to applicable regulatory requirements, courts located in Bengaluru, Karnataka shall have jurisdiction over matters arising from these Terms.

15. CONTACT INFORMATION

For questions regarding these Terms or the Program, please contact:

Compliance Officer
Skywards Investec Private Limited
Email: [email protected]