PRIVACY POLICY AND TERMS OF USE

Last updated: June 14,2023

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of any natural or legal person who has visited the Bullsmart website(https://bullsmart.in)/platform and/or the mobile application, and/or who may or may not have further agreed to initiate the process of opening an account with Bullsmart shall come under the purview of the scope of this Privacy Policy. Bullsmart shall at all times follow all such rules prescribed under the Information Technology Act, 2000, and rules & procedural guidelines set by the Securities Exchange Board of India (“SEBI”) and/or any of its regulated entities/intermediaries that Bullsmart is a member. Bullsmart is a member of The Association of Mutual Fund (AMFI) having its Application Reference Number (ARN) 262524. We use Your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

Bullsmart encourages You to carefully review the privacy policies of all Third-Party Services You access through the Platform.

Definitions

For the purposes of this Privacy Policy:

Account means a unique account created for You to access our Service or parts of our Service.

Company (referred to as either "the Company", "We", "Us" or "Our" “Bullsmart” in this Agreement) refers to SKYWARDS INVESTEC PRIVATE LIMITED, having its registered office address at Ashoka Fortune, 3rd Floor, No.3/1-1 1st Main, Jakkasandra, Koramangala Bengaluru Bangalore- 560034 IN

Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.

Country refers to: India

Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.

Personal Data is any information that relates to an identified or identifiable individual.

Service refers to the Website.

Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.

Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

Website refers to Bullsmart, accessible from https://www.Bullsmart.in

You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

What information may be collected by Bullsmart

Bullsmart might collect your name, email, mobile number, phone number, street, city, state, pincode, country and IP address. We may collect demographic information about you, events you like, events you intend to participate in, which advertisement you find most useful, or any other information provided by your during the use of our website or mobile application (APP). We might collect this as a part of a survey also. We may collect information from Users at various stages from registration on the Platform by the Users to submission of content by the Users or while the User is accessing/using Services. You may choose to not provide the information if You do not wish to use the Platform and/or Services.

We collect information in different ways.

We collect information directly from you. We collect information directly from you when you use our website or mobile APP. We also collect information if you post a comment on our websites or ask us a question through phone or email or any other platform provided by us.

Third party sites

If you click on one of the links to third party websites, you may be taken to websites we do not control. This policy does not apply to the privacy practices of those websites. Read the privacy policy of other websites carefully. We are not responsible for these third-party websites.

Mere presence of the link or its listing on this website or mobile App should not be assumed as endorsement of any kind. We cannot guarantee that these links will work all the time and we have no control over availability of linked pages

Part of the Platform or the Services may contain advertising information or promotion material, or other material submitted to the Bullsmart by third parties. Responsibility for ensuring that material submitted for inclusion on the platform complies with applicable law is exclusively on the party providing the information/material.

Your correspondence or business dealings with, or participation in promotions of advertisers including payment and delivery of related goods or services, and any other terms, conditions, warranties or representations associated with such dealings, are solely between you and such advertiser. Before relying on any advertising material, you should independently verify its relevance for your purpose and should obtain appropriate professional advice. We shall not be responsible nor liable for any loss or claim that you may have against an advertiser or any consequential damages arising on account of your relying on the contents of the advertisement.

We do not sell or share any personally identifiable information volunteered on the Portal Website to any third party (public/private). Generally accepted best practices shall be user to protect any information provided to this website to protect from loss, misuse, unauthorized access or disclosure, alteration, or destruction.

However, at times, Bullsmart may be required by law or litigation to disclose personal information about the Users. Bullsmart may also disclose information about the Users if Bullsmart determines that for national security, law enforcement, or other issues of public importance that disclosure of information is necessary.

Bullsmart reserves the right to transfer Personal Information of users to another party as a result of business partnership, contractual engagement, merger, acquisition, or sale of all or a portion of Bullsmart is asset to another party, and under such a circumstance, the provisions of this privacy policy will continue to apply unless You are notified otherwise.

Bullsmart may use a Third-party technology partnership to provide this Platform and its Services to You, to enable such Services, User information including Profile Information, User Content, behavior, technical and/or transaction information may be shared with such third parties. You hereby agree to allow Bullsmart to share such information with such contracted third parties.

• Control over user information

access, correction and probability- edit your account information, ask for verification before enabling the information, the request may be rejected in cases where the request risks the privacy of other user or is unlawful

How We Protect Your Information

The security of your information is important to us. When you enter sensitive information in our website / App, we encrypt the transmission of that information using secure socket layer technology (SSL). We and our custodian also use third-party ID verification to ensure our users’ true identities are validated.

We take commercially reasonable technical, administrative, and physical safeguards to protect information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases or the databases of the third parties with which we may share such information, nor can we guarantee that the information you supply will not be intercepted while being transmitted over the Internet. In particular, email sent to us may not be secure, and you should therefore take special care in deciding what information you send to us via email. If you have any questions about security on our website, you can contact us at

Retention of Your Information

We will retain your Information for as long as it serves the purpose(s) for which it was initially collected as stated in this Privacy Policy, or subsequently authorized. We will also retain and use your Information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

We will retain non-public information such as Account Opening Documentation and Trading Activity Information per the SEBI requirements for books and records retention. Any request to delete such information is not able to be fulfilled until the regulatory retention periods have passed.

Data Deletion Requests

To request deletion of all your personal data, you will need to request to close your account. You can request to close your account by reaching out to the Customer Support team. Note that applicable non-public data will only be deleted once regulatory retention periods have passed (see “Retention of Your Information” above) following account closure.

COMMUNITY GUIDELINES

Bullsmart operates the Platform as an Intermediary under the IT Act. This document is published in accordance with the provisions of the Information Technology Act of 2000 read along with its relevant rules including Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 and Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021 and amendments if any. Bullsmart holds no control with respect to the content and does not warrant the correctness, validity or legality of the content. Bullsmart expressly disclaims all warranties and shall not be liable for any violations under civil or criminal law.

Acceptance- that the policy shall be the part of terms of services come into effect. The Platform facilitates aggregation of Content from various sources. Bullsmart merely provides access to various types of content as an intermediary.

• Bullsmart is not liable for any content uploaded or made accessible on the Platform because it is not its property.
• You must not access or post content through any unauthorised means, including but not limited to, by using an automated device, script, bot, spider, crawler, or scraper.
• You agree to post content in good faith only for legal and non-commercial purposes, including education, entertainment, criticism, or spreading information.
• Don't utilise illegal methods or upload content on the Platform with malicious intent.
• Don't utilise illegal methods or upload content on the Platform with malicious intent.
• You confirm that the material you post complies with all applicable laws, rules, regulations, policies, guidelines, and/or norms in the nations where it is published, made available to the public, or distributed by Bullsmart. You attest that You have the necessary rights to publish the content on the platform. Bullsmart is under no obligation to post any data or content on the Platform, and it is free to do so in its sole discretion, with or without giving users prior notice. Bullsmart aims to provide readers with a simple way to locate news from publications who regularly create independent and unique content, with a sizable supply of fresh and purposeful content.
• The content and conduct guidelines assist in ensuring a satisfying user and publishing partner experience. Content should adhere to best practices, such as those outlined in our standards, in order to be eligible to appear on the Platform, and it must not be:

1. Hate Speech and Discrimination – Show others on the platform respect, empathy, and dignity. On the platform, we support legitimate and well-intentioned expressions of constructive dissent. Any hateful, personal attacks, ad hominem remarks, or uncivil disagreement meant to injure another user or put them through mental or emotional hardship is not permitted. Comments that incite violence, are racially or ethnically offensive, or criticise somebody based on their national origin, sex, gender identity, sexual orientation, religious affiliation, impairments, or diseases are examples of hostile or discriminatory speech. Additionally, we forbid any content that would entice other users to share it. In your profile image or profile header, you are not allowed to use hateful imagery or symbols. Additionally, you are not allowed to change your username, display name, or profile bio in a way that makes it seem as though you are acting abusively, or that could be inferred to be spreading hate or harassing other users.
2. Religiously offensive Content- Regardless of whether they have the same opinions as you, you must always show respect for other people's religious faith and ideas. You must not publish anything that offends people's feelings or disparages their faith or culture.
3. Extremism and terrorism- On the Platform, you must not make any deadly threats or encourage risky behaviour. In particular, you are forbidden from using the Platform to encourage terrorism, secession, violent acts against people or property, threats to India's unity, integrity, defence, security, or sovereignty, or insults to other countries. You must not publish any material that supports or incites users to act in support of a terrorist organisation or an anti-national organisation, or that solicits members for, disseminates information for, or advances the goals of such organizations. Additionally, you must not establish networks on the site that incite violence or solicit support or sanction for carrying out violent activities during authorized protests.
4. Graphic and Violent Content- You are not permitted to threaten another individual with physical violence directly or indirectly through the Platform. This includes any danger of theft, vandalism, unlawful detention, physical harm, mental anguish, or financial loss. In particular, if vulnerable communities or groups are the principal targets or victims, the Platform does not permit its users to publish anything that refers to mass murder, violent events, or specific forms of violence, or that portrays or promotes any such activities. Platform strictly prohibits the promotion of violence in any form, including but not limited to acknowledging incidents that have wounded someone physically or their feelings. You must not upload anything that features torture, injury, mental suffering, death, bodily harm, abduction, kidnapping or other forms of violent content.
5. Child Sexual Abuse Content- Any sexually explicit or suggestive content involving children or individuals who appear to be minors is prohibited by Bullsmart or blocked. This includes depictions of child sexual abuse, child pornography, and any other material, even fictional material (such as stories or \"loli\" or anime cartoons), that sexualizes children or those who have the appearance of being children. Bullsmart has zero tolerance for any information, including articles, blogs, graphic posts, and comments, that supports child sexual abuse. Any users who intend to victimise, endanger, or otherwise exploit minors by publishing content on child sexual abuse.
6. Cyberbullying and Harassment- Users should feel safe to express themselves so we don’t allow bullying or harassment content. We intend to give our users the freedom to express their opinions without fear of emotional or psychological distress. We also do not tolerate abusive content or behaviour on our platform.
7. Privacy invasion- Bullsmart anticipates that its users will respect the privacy of others. You must not share, publish, or promote the publication of any other person's personal information or information that violates their privacy settings. without their explicit consent and authorization. We forbid threatening to do so by disclosing personal information.
8. Sensitive media information including graphic and explicit material- Extremely graphic information is not permitted, nor is sharing violent or explicit material in comments, articles, or photographs. It is prohibited to display sexual violence or assault in the media. Bullsmart does not permit any content, including non-consensual sexual acts, intimate images of such acts, or adult sexual solicitation.
9. Misinformation and Fake News- We don't permit audio, video, or image information that has been altered to deceive, defraud, or mislead by portraying acts or events that can be proven to have not actually occurred. This includes situations when such content might provide a reasonable person a fundamentally incorrect idea or perception, giving rise to the possibility of major harm to persons or organisations, or seriously undermining participation or trust in political or civic processes. Users must refrain from generating traffic or increasing their following, views, comments, or shares using artificial or manipulative means.
10. Self-harm and suicide- On the platform, there can be no content that promotes self-harm, suicide, or other risky behaviours. Posts that even give instructions on how to commit suicide or self-harm in any way are not allowed, nor is content that shows self-harm, glorifies self-injury or suicide. Content that helps those going through serious problems is permitted.
11. Identity theft and impersonation- You may not pretend to be someone else, a company, or another entity in order to mislead consumers about the source of the information. You are invited to voluntarily verify your identity to make sure that all the information you have supplied is true and does not, in any way, amount to misrepresentation.
12. Profanity and vulgar language: We do not permit anything that is overly gory or disturbing, particularly material that encourages or glorifies horrific violence or suffering. For specific situations, such as content that is newsworthy or intended to raise awareness about issues, we do accept exceptions. We prohibit the account and, if there is a real risk of violence or a harm to the public's safety, we cooperate with the proper legal authorities as required and as appropriate.
13. Malicious Programmes- Do not knowingly post or distribute material that is untrue, misleading, or inaccurate but may be taken as fact. We have a strict no-tolerance policy for altered or morphing media, including videos and edited images. We do not support material that could harm citizen-centric procedures. Additionally, we forbid any content that might tamper with the outcome of political elections. To the greatest extent practicable, you must ensure that the material you publish on the Platform is true and comes from a reputable, verifiable source.
14. Regulated and illegal activities- We forbid the use, trade, sale, and advertising of some restricted commodities as well as the portrayal or encouragement of illegal activity. Even if the activities or items in question are lawful in the jurisdiction in which the content was posted, certain content may be removed if it refers to things that are prohibited or controlled in most of the region or the world. For information that benefits the public, such as scholarly, artistic, and journalistic materials, we permit exceptions.

Please ensure that the content posed by You is not illegal, immoral or unethical.

• Please ensure that the content posed by You is not illegal, immoral or unethical.
• Any content promoting or selling weapons, firearms, explosives, illegal goods or services, regulated goods, drugs, controlled substances, soliciting or selling sexual services is not allowed on the platform and is strictly prohibited.
• Content that is related to or encourages money laundering or gambelling are strictly prohibited.
• Content containing computer viruses, malware, or any other kind of computer code aimed at restricting the functionality of a computer resource is not allowed to be uploaded on the Platform.

C. Intellectual Property

You acknowledge, confirm and agree that all intellectual property rights in the Content You post vests with You or You have a valid license to post, display, reproduce, make copies, broadcast, communicate to the public such Content on the Platform.

You acknowledge, confirm and agree that all intellectual property rights in the Platform, whether registered or unregistered, including but not limited to its software, interface, webpages, database, name and logo vest in Bullsmart. You shall not claim any right in any of the aforementioned forms of intellectual property.

You own the content posed by You. Bullsmart owns all the rights in the Platform.

When You post content on the Platform, You grant Bullsmart a non-exclusive, perpetual, worldwide, transferable, irrevocable, royalty-free, unlimited license to use, commercially use, cache, store, publish, display, distribute, and store such Content, including underlying works in the content, posted by You. You agree, understand and confirm that You are liable to pay any license fee, royalty, or any other consideration applicable to the content posted by You.

You grant Bullsmart a right to use the content posed by You on the Platform.

Other than as expressly set forth in this Policy, You shall not copy, modify, publish, transmit, upload, participate in the transfer or sale of, reproduce (except as provided in this Section), create derivative works based on, distribute, perform, display, or in any way exploit, any of the Content, software, materials, or Services in whole or in part.

Do not use any content posted on the Platform for unauthorized purposes.

If You remove any Content from the Platform or terminate Your use of the Platform, Bullsmart may keep and use Your Content on its sole discretion and for any lawful purpose. Bullsmart and its users may retain and continue to use, store, any of Your Content even after the date of termination of Your use.

BULLSMART retains the right to use content even after You remove it from the Platform.

D. Representations and Warranties

You represent, covenant and warrant that the content posted by You does not violate any term of this Policy or any law in force in the territory in which You are posting the content or any law in force in the territory in which content can be displayed, broadcasted, published, used, communicated to public, reproduced or copied.

You further represent, covenant and warrant that You own or have a valid license to post the content, including underlying works in the content, on the platform and fulfil Your obligations under this Policy.

You confirm that the You post is legal and You have a right to post it.

Bullsmart makes no warranties under this Policy. And Bullsmart expressly disclaims all warranties, expressed or implied, including but not limited to:

• express or implied warranties of merchantability, fitness for a particular purpose and non-infringement with respect to the Platform(s) or any other aspect;
• Warranties with respect to the any and all content;
• warranties as to the quality or performance of the Platform(s), services, technology including but not limited to the availability of any advertisement; and
• warranties that the Platform(s) and/or the services offered by it will be uninterrupted, timely, or error-free.

Bullsmart makes no warranties with respect to the Platform.

E. Indemnity

You will indemnify and hold Bullsmart and its affiliates, business partners, and their directors, officers and employees, harmless, including costs and attorneys' fees, harmless from any claim or demand made by any third party arising out of or in connection with the Content posted by You, any violation of this policy by You, or any other illegal act done by You.

If Bullsmart is sued because of anything You do on the Platform, you have to pay the costs.

To the maximum extent permitted by law, Bullsmart and/or its affiliates shall not be liable for any indirect, incidental, special, consequential or punitive damages, or any loss of profits or revenues, whether incurred directly or indirectly, or any loss of data, use, goodwill, or other intangible losses, resulting from (a) Your access to or use of or inability to access or use the platform; (b) any conduct or content of any third party on the platform, including without limitation, any defamatory, offensive or illegal conduct of other users or third parties; or (c) unauthorized access, use or alteration of Your transmissions or content. In no event shall Bullsmart 's aggregate liability for all claims relating to the platform exceeds ₹5000/- (Rupees five thousand only).

F. Our liability is limited.

This limitation of liability is part of the basis of the bargain between You and Bullsmart and shall apply to all claims of liability (e.g. warranty, tort, negligence, contract, law) and even if Bullsmart or its affiliates have been told of the possibility of any such damage, and even if these remedies fail their essential purpose.

Acceptance of this Policy

By downloading, installing, and accessing/using the Platform and Services, You are signifying Your acceptance of this Privacy Policy. If You do not agree to this Privacy Policy, You shall not download, install, access or use the Platform and Services. Your continued Access or Use of the Platform and Services following the posting of changes to this Privacy Policy will be deemed to be the acceptance of such changes.

G. Grievances

If you have any grievances in relation to the Application or its content, you may send a notice to Grievance Redressal Officer at the below-mentioned email and address.

Details of Grievance officer

Name: Ms. SUBHRA SIMANTINEE

Address: Ashoka Fortune, 3rd Floor, No.3/1-1 1st Main, Jakkasandra, Koramangala Bengaluru 560034

Email: [email protected]

SKYWARDS INVESTEC PRIVATE LIMITED

CIN: U67110KA2023PTC169866

AMFI Registration Number: ARN - 262524

Registered Office: Ashoka Fortune, 3rd Floor, No.3/1-1 1st Main, Jakkasandra, Koramangala Bengaluru 560034

Disclaimer:  Investments in securities market are subject to market risk, read all the related documents carefully before investing.

Email: [email protected]