Bullsmart AI - Terms and Conditions

1. DEFINITIONS

Unless the context otherwise requires, the following terms shall have the meanings assigned below.

1.1 "AI" or "Artificial Intelligence" - means computational technologies, including machine learning, natural language processing, large language models, predictive analytics, statistical models, automation tools and other artificial intelligence technologies used by the Company for providing Bullsmart AI.

1.3 "Bullsmart" - means the brand name, website, mobile application and digital investment platform operated by Skywards Investec Private Limited.

1.4 "Bullsmart AI" - means the suite of artificial intelligence-powered analytical tools, features and services made available through the Bullsmart platform, including any enhancements, modifications or future AI-enabled services.

1.5 "Company" - means Skywards Investec Private Limited, a company incorporated under the provisions of the Companies Act, 2013, having its registered office at Startup Huts, 3rd Floor, Unit-2, #109, 27th Main, Sector-2, HSR Layout, Bengaluru, Bangalore KA 560102, and registered with the Securities and Exchange Board of India as a Stock Broker and Depository Participant under the applicable registrations.

1.6 "Registered User" means a User who has successfully completed the Company's account opening and KYC requirements and maintains an active Bullsmart trading account with a valid Unique Client Code ("UCC") and PAN linked with the Company.

1.7 "Guest User" means a person accessing Bullsmart AI without an active Bullsmart trading account, without a valid UCC, or whose PAN is not linked with the Company.

1.8 "Portfolio Data" means information relating to a Registered User's holdings, positions, watchlists, transactions, investment preferences or any other information authorised by the User for AI-based analysis.

1.9 "User Data" - means any information provided by or relating to the User, including account information, Portfolio Data, AI prompts, interaction history, preferences and other information processed in connection with Bullsmart AI.

1.10 "AI Output" - means any response, analysis, summary, explanation, chart, notification, market insight, screening result, sentiment analysis, portfolio observation or other information generated by Bullsmart AI.

2. ELIGIBILITY

3. GUEST USER ACCESS

4. ABOUT BULLSMART AI

Bullsmart AI is an artificial intelligence-enabled analytical assistance service designed to help Users better understand financial markets through data-driven insights and contextual analysis.

Bullsmart AI leverages advanced analytical technologies to process Market Data, publicly available information and, where authorised by the User, Portfolio Data to generate AI Outputs that assist Users in evaluating securities, market developments and investment opportunities.

Bullsmart AI is designed to enhance the User's investment experience by presenting complex financial information in a structured, accessible and user-friendly manner.

Bullsmart AI may be updated periodically to introduce new analytical capabilities, improve existing features or comply with evolving regulatory and technological requirements.

Bullsmart AI is an ancillary technology-enabled feature integrated within the Bullsmart Mobile Application to enhance the User experience. Bullsmart AI does not constitute the primary brokerage service offered by the Company and shall always remain subject to the Company's regulatory obligations as a SEBI-registered intermediary.

5. SCOPE OF BULLSMART AI

Subject to these Terms and the availability of the relevant services, Bullsmart AI may provide one or more of the following features:

• Stock Deep Analysis;
• F&O Smart Analysis;
• AI Stock Screener;
• AI News Sentiment Analysis;
• Market Alerts and Notifications;
• Educational Market Insights;
• AI Chat Assistance;
• Voice Search;
• Portfolio Analysis and Portfolio Briefings (available only to eligible Registered Users); and
• such other AI-enabled features as may be introduced by the Company from time to time.

The availability, functionality and content of any AI Service may vary depending upon the User category, regulatory requirements, product eligibility, subscription limits and technical availability.

6. USAGE LIMITS

Bullsmart AI is provided subject to fair usage limits established by the Company.

Unless otherwise notified, each eligible Registered User shall be entitled to fixed limit of thirty (30) AI analyses during each monthly usage cycle at no additional charge. Bullsmart AI is currently offered free of charge, and there are no tiered subscription plans active at present. The monthly usage cycle shall be determined by the Company and may not necessarily correspond to a calendar month.

Once the monthly limit has been exhausted:

• no further AI analyses shall be available during that monthly cycle;
• access shall automatically resume at the commencement of the next monthly cycle; and
• any unused analyses shall not be carried forward unless expressly permitted by the Company.

The Company reserves the right, at its sole discretion, to revise, increase, decrease or otherwise modify usage limits, introduce higher usage allowances, or introduce fee-based subscription plans in the future upon publishing updated terms or notifications on the Bullsmart platform.

7. VOICE SEARCH

Bullsmart AI provides an optional voice-based search facility currently supporting English and Hindi.

The accuracy of voice-based AI responses depends upon factors including pronunciation, accent, speech clarity, background noise, recording quality and language selection.

Users are responsible for ensuring that voice inputs are clear and accurate. The Company does not warrant that every voice input will be correctly interpreted or that the resulting AI Output will accurately reflect the User's intended query.

Where any AI Output generated through voice search appears inaccurate or inconsistent, Users are encouraged to verify the query by using text-based search or by re-submitting the voice request.

The Company may add, modify or discontinue supported languages and voice functionalities at its discretion.

8. NATURE OF BULLSMART AI SERVICES

9. REGULATORY STATUS OF BULLSMART AI

By using Bullsmart AI, the User acknowledges and agrees that:

10. USER ACKNOWLEDGEMENTS

10.7 The User acknowledges that the Company shall have no obligation to monitor, validate or correct every AI Output generated by Bullsmart AI.

11. RESPONSIBILITIES OF THE COMPANY

12. COLLECTION AND PROCESSING OF USER DATA

To enable the operation of Bullsmart AI, and governance of Bullsmart AI, the Company logs and records all interactions between the User and Bullsmart AI.

Such User Data may include:

• user queries and AI prompts;
• AI-generated responses and output;
• voice search inputs and audio processing logs;
• interaction history and timestamp;
• session logs;
• usage analytics;
• technical information;
• device identifiers; and
• other information reasonably required for the operation and audit of Bullsmart AI.

The collection, logging and processing of such information shall be carried out in accordance with Applicable Laws and the Company's Privacy Policy.

13. AI MODEL IMPROVEMENT AND DATA RETENTION

The User acknowledges and agrees that AI prompts, responses, voice interactions, feedback, usage analytics and related interaction data may be processed by the Company for:

• improving Bullsmart AI;
• refining AI models;
• enhancing response quality;
• quality assurance;
• product development;
• debugging;
• security monitoring;
• fraud prevention;
• regulatory compliance; and
• developing future AI-powered services.

The Company may retain AI prompts, AI responses, interaction logs and related records for such period as may be required under Applicable Laws, regulatory requirements, internal governance policies or for the establishment, exercise or defence of legal claims.

Where third-party technology providers are engaged for providing AI infrastructure or related services, such providers shall process User Data only for authorised purposes and in accordance with contractual confidentiality, security and data protection obligations.

Nothing contained in this Clause shall limit or override the rights available to Users under Applicable Laws or the Company's Privacy Policy.

14. USER RESPONSIBILITIES

15. PROHIBITED USE

The User shall not:

• use Bullsmart AI for any unlawful, fraudulent or prohibited purpose;
• attempt to manipulate securities markets or obtain assistance relating to insider trading, front running, circular trading, market manipulation or any activity prohibited under Applicable Laws;
• submit malicious software, viruses or harmful code;
• interfere with or disrupt the operation or security of Bullsmart AI;
• attempt to gain unauthorised access to Bullsmart AI or any related systems;
• use automated scripts, bots, crawlers or scraping tools to extract AI Outputs without the Company's prior written consent;
• reverse engineer, decompile or otherwise attempt to discover the source code, algorithms or underlying AI models of Bullsmart AI, except to the extent expressly permitted by Applicable Laws;
• impersonate any person or entity;
• use AI Outputs to create false, misleading or deceptive investment communications;
• upload content that infringes the intellectual property or other proprietary rights of any person;
• attempt to obtain confidential, proprietary or material non-public information through Bullsmart AI; or
• use Bullsmart AI in any manner that may impair its availability or performance for other Users.
• attempt prompt injection or manipulation of AI behaviour;
• use Bullsmart AI to generate misleading or fraudulent financial content.

The Company reserves the right to suspend, restrict or terminate access to Bullsmart AI where it reasonably believes that a User has violated these Terms or Applicable Laws.

16. INDEMNITY

The User agrees to indemnify, defend and hold harmless the Company, its directors, officers, employees, affiliates, agents, service providers and licensors from and against any losses, liabilities, claims, damages, penalties, costs, expenses (including reasonable legal fees), actions or proceedings arising out of or in connection with:

(a) the User's breach of these Terms or any other policies governing the use of Bullsmart AI;

(b) any misuse, unlawful use or unauthorised use of Bullsmart AI by the User;

(c) any violation by the User of Applicable Laws or the rights of any third party while using Bullsmart AI;

(d) any content, information, prompts, inputs or materials submitted, uploaded or transmitted by the User through Bullsmart AI that infringe the intellectual property, privacy or other legal rights of any person; or

(e) any fraudulent, negligent or wilful act or omission of the User in connection with the use of Bullsmart AI.

The foregoing indemnity shall not apply to the extent that any claim, loss or liability arises directly from the Company's fraud, gross negligence, wilful misconduct or any liability that cannot be excluded or limited under Applicable Laws.

17. AVAILABILITY AND MODIFICATIONS

Bullsmart AI is a technology-enabled service and may occasionally be unavailable due to scheduled maintenance, system upgrades, technical issues, network failures, regulatory requirements or circumstances beyond the Company's reasonable control.

The Company may, at its discretion and without prior notice where reasonably necessary:

• introduce, modify or discontinue any AI feature;
• revise AI models, analytical methodologies or response formats;
• introduce new functionalities or subscription plans;
• impose or revise usage limits;
• suspend access for maintenance, security or regulatory reasons; or
• restrict access to particular Users or categories of Users.

The Company shall use reasonable efforts to minimise service interruptions but does not guarantee uninterrupted or error-free availability of Bullsmart AI.

18. INTELLECTUAL PROPERTY

Bullsmart AI, including its software, interface, design, algorithms, AI models, databases, trademarks, logos, graphics, documentation and other intellectual property, are owned by or licensed to the Company and are protected under Applicable Laws relating to intellectual property.

Subject to these Terms, the Company grants Users a limited, non-exclusive, non-transferable and revocable licence to access and use Bullsmart AI solely for their personal and lawful use.

Nothing contained in these Terms shall be construed as transferring or assigning any intellectual property rights to the User.

19. REFERENCE MATERIALS

Bullsmart AI has been developed using the Company's independent research, analytical methodologies and licensed or publicly available reference materials, including educational content, regulatory publications, market data, financial reference materials and other lawful information sources. AI Outputs represent the Company's independently generated analytical work product and shall not be construed as reproducing or claiming ownership over the intellectual property of any third-party reference source.

20. LIMITATION OF LIABILITY

Bullsmart AI is provided on an "as available" and "as is" basis.

To the maximum extent permitted under Applicable Laws, the Company shall not be liable for any direct, indirect, incidental, consequential, special or punitive loss or damage arising from or in connection with:

• reliance on any AI Output;
• inaccuracies, omissions or delays in AI Outputs;
• interruptions, downtime or unavailability of Bullsmart AI;
• technical failures, system errors or communication failures;
• interpretation of voice search inputs;
• market fluctuations or investment losses;
• any decision made by the User based on AI Outputs; or
• any event beyond the reasonable control of the Company.

Nothing contained herein shall exclude or limit any liability that cannot be excluded or limited under Applicable Laws.

21. SUSPENSION AND TERMINATION

The Company may suspend or terminate access to Bullsmart AI where:

• required by law;
• directed by a regulatory authority;
• fraudulent activity is detected;
• misuse is identified;
• cybersecurity concerns arise;
• the User breaches these Terms.

22. FORCE MAJEURE

The Company shall not be liable for any delay, interruption, suspension, failure or inability to perform any of its obligations under these Terms or to provide Bullsmart AI where such delay, interruption or failure results from events or circumstances beyond its reasonable control, including but not limited to:

• acts of God, natural disasters, floods, earthquakes, storms, pandemics or epidemics;
• war, terrorism, civil unrest, riots or governmental actions;
• changes in Applicable Laws or regulatory directions issued by SEBI, stock exchanges, depositories or any other competent authority;
• cyber-attacks, denial-of-service attacks, hacking incidents, malware, ransomware or other cybersecurity events;
• failures, outages or disruptions affecting electricity, telecommunications, internet services, cloud infrastructure, data centres or third-party technology providers;
• failure, interruption or unavailability of third-party AI models, cloud service providers, market data vendors or other service providers on whom Bullsmart AI reasonably relies; or
• any other event beyond the reasonable control of the Company.

During the continuance of any such event, the Company may suspend, restrict or modify the availability or functionality of Bullsmart AI to the extent reasonably necessary. The Company shall use commercially reasonable efforts to restore the services as soon as practicable after the relevant event ceases.

Nothing contained in this Clause shall exclude or limit any obligation or liability that cannot be excluded or limited under Applicable Laws.

23. GRIEVANCE REDRESSAL

Any grievance, complaint or query relating to Bullsmart AI may be addressed to the Company's designated Grievance Officer or Customer Support through the contact details published on the Bullsmart platform.

The link for the same: https://bullsmart.in/contact

The Company shall endeavour to address grievances in accordance with Applicable Laws and the timelines prescribed by the applicable regulatory authorities.

24. AMENDMENTS

The Company may revise these Terms from time to time to reflect changes in Applicable Laws, regulatory requirements, technology, business operations or Bullsmart AI Services.

Updated Terms shall become effective upon publication on the Bullsmart platform or through such other mode of communication as the Company may determine.

Continued use of Bullsmart AI after such publication shall constitute acceptance of the revised Terms.

25. GOVERNING LAW AND JURISDICTION

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

Subject to Applicable Laws, the courts and tribunals having jurisdiction at Bengaluru, Karnataka, shall have exclusive jurisdiction over any dispute arising out of or in connection with these Terms.

26. MISCELLANEOUS

By accessing or using Bullsmart AI, the User confirms that they have read, understood and agreed to be bound by these Terms and Conditions, the Bullsmart Platform Terms and Conditions, the Bullsmart AI Privacy Policy, the Privacy Policy and all other applicable policies published by the Company from time to time.