PRIVACY POLICY

Last updated: 16/08/2024


This privacy policy shall be made available on the Bullsmart website (https://bullsmart.in)/ platform/ or the mobile application for the information of the Users. This Privacy Policy describes our policies and procedures on the collection, use and disclosure to any natural or legal person who has visited 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.


At Bullsmart, we are committed to ensuring the confidentiality, integrity, and security of your personal information. 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.

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 means SKYWARDS INVESTEC PRIVATE LIMITED “Bullsmart”, registered under Companies Act 2013 bearing CIN U67110KA2023PTC169866 having its registered office at Ashoka Fortune, 3rd Floor, No.3/1-1 1st Main, Jakkasandra, Koramangala Bangalore- 560034 IN, Skywards Investec Private Limited is a SEBI Registered stock broker bearing its SEBI Registration No. INZ000315235, AMFI Registration Number (ARN) 262524 as a Mutual Fund Distributor from an Association of Mutual Funds in India (AMFI), and a BSE Mutual Fund Distributor code: 57425


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 cell phone or a digital tablet.


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


Service refers to the Website and the mobile application.


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 analysing 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


Client means the person includes Natural person and legal person, however in case of natural person, the person who has attended the age of 18 years of age, accessing the Services, or the company, or other legal entity on behalf of which such individual (attained age of 18 years) is accessing or using the Services, as applicable.


In this policy, “you” or “your” means the person accepting these Terms and the company (if any) on whose behalf he/she is acting, and “we,” “us,” “our,” or the “Company” means SKYWARDS INVESTEC PRIVATE LIMITED “Bullsmart” and its affiliates.


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.


Changes to This Policy

This Privacy Policy may be updated by Bullsmart at any time without prior notice. It is your responsibility to check for updates regularly. The last updated date is provided above for your reference.


If you disagree with the terms of this Privacy Policy or any changes to it, please stop using all Bullsmart products and services immediately and contact us.


Data Collection and Usage

We collect personal information at various stages to provide and improve our services:


  • Pre-registration: We collect anonymous visitor data to understand usage patterns and enhance our platform.
  • Registration: To access our services, you will need to provide contact details, demographic data, and financial information.
  • Investment: Additional information such as bank details and KYC documents are required for investment services.


Most features of our website require you to enroll or register; these actions involve providing necessary information and details like email ID, password, address, IP address or any other kind of information. If you utilize online services regarding mutual fund transactions by visiting our website, you need to provide necessary personal information such as name, bank account number, telephone number, or PAN to enable online dealings with AMCs.


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 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 (hereinafter” mobile app”). We might collect this as a part of a survey also.


All personal information about customers will be shared, accessed, and recorded with any other party like AMCs, RTAs, or any licensed approved service provider as required to complete online transactions.


We collect information in different ways.

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.


WhatsApp/Email/RCS/SMS and Voice Communications:

By registering on our site, user agree, acknowledge, and accept this terms & Condition / policy. Even if registered under NDNC (National Do Not Call) or DND (Do Not Disturb), by accepting the policy, user are authorizing Bullsmart to call and assist you and/or contact you via WhatsApp, RCS, SMS, and email due to your voluntary registration on https://bullsmart.in/. Bullsmart will not be responsible for any NDNC (National Do Not Call) Registry regulations that may come into play.


Marketing Communications

With your explicit consent, we may send you marketing materials. You can opt out of these communications at any time by contacting us. We in no case intend to use your information for any marketing purpose without your consent and make sure that the information provided by you is kept in a protective and encrypted environment.


Security Measures

We employ a range of security measures, including firewalls, data encryption, and SSL, to protect your data. We advise users to take personal security measures, such as using strong passwords and securing their devices.


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.


Post-Termination Data Handling

Even after your relationship with us ends, we continue to protect your personal information in accordance with this policy. You may request us to stop sharing your data with others by notifying us. When you choose to close your account, your personal information and data will be permanently deleted from our servers, and in the future, accessing or reopening your account will not be possible.

CONSENT FROM CLIENT FOR COMMUNICATION AND INFORMATION SERVICES

User hereby giving their consent to Skywards Investec Private Limited (Bullsmart) to send us, either directly or indirectly i.e. through any third-party service provider, various information, alerts, SMS, other messages, calls, or commercial communications from time to time. The consent applies whether my numbers are registered with the National Do Not Call Registry or listed in the National Customer Preference Register. user also confirm that they will not hold Bullsmart or its third-party service provider liable or file a complaint under the Telecom Commercial Communications Customer Preference (TRAI) Regulations, 2010, or any other applicable regulations, including amendments. The consent will auto-renew every month. To stop this service, please email [email protected] and call our support number +91-8069160860.


User Information Access, Correction, and Approval Process

Users are provided with the ability to modify their account information and request verification prior to the alteration of such information. Requests for modifications may be declined in instances where they pose a risk to the privacy of other users or contravene applicable laws.


How We Protect Your Information

The security of your information is important to us. When you enter sensitive information in our website / mobile 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.


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.


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.


Cookies and Tracking Technologies

We use cookies and similar technologies to enhance user experience and analyze website activity. Cookies help us understand how you use our site and improve our services. You can manage your cookie preferences through your browser settings.


Grievances

If you have any inquiries regarding this Privacy Policy or wish to report any grievances regarding the use or management of your sensitive personal data, please direct them to our Compliance Officer Ms. Subhra Simantinee at [email protected]


Investors/clients/customers shall have expressly consented to the terms of this Policy if they enter and use this website or provide any information while transacting with us.


Details of Compliance / Grievance officer

Name: Ms. SUBHRA SIMANTINEE

Email: [email protected]


SKYWARDS INVESTEC PRIVATE LIMITED is a member of NSE bearing SEBI Registration No. INZ000315235, AMFI Registration Number: ARN – 262524, BSE Mutual Fund Distributor code: 57425, CIN: U67110KA2023PTC169866, having registered office situated at 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.