Privacy Policy

This Privacy Policy applies to:

1. visitors of www.eqtpulse.in;
2. registered users of the EqtPulse platform;
3. subscribers to EqtPulse research services;
4. users receiving research reports, market analysis, trading signals, model portfolio suggestions, alerts, or other communications;
5. users who contact EqtPulse for support, billing, grievance, privacy, or service-related queries.

This Policy does not apply to third-party websites, brokers, payment gateways, data vendors, analytics providers, or external platforms that may be linked to or integrated with EqtPulse. Such third parties are governed by their own privacy policies, terms, and security practices.

For the purpose of applicable Indian data protection law, including the Digital Personal Data Protection Act, 2023 and rules made thereunder, EquityPulse Tech Private Limited may act as a Data Fiduciary in relation to personal data collected and processed through the EqtPulse platform.

Users whose personal data is collected and processed may be treated as Data Principals under applicable law.

Where EqtPulse engages third-party vendors, technology providers, KYC providers, payment gateways, cloud service providers, or other service providers to process user data on its behalf, such third parties may act as data processors or service providers, subject to applicable contractual, confidentiality, security, and legal obligations.

EqtPulse may collect and process the following categories of information.

EqtPulse does not ask users for:

1. broker login passwords;
2. Demat account passwords;
3. trading terminal passwords;
4. OTPs;
5. UPI PINs;
6. net banking passwords;
7. card PINs;
8. payment authentication credentials;
9. API secrets or broker access tokens, unless specifically required under a separate authorised technical integration arrangement and subject to explicit user consent.

Users must not share such credentials with EqtPulse or with any person claiming to represent EqtPulse.

If any user receives a request for such credentials, the user should immediately report it to EqtPulse at hello@eqtpulse.in and, where necessary, to the relevant authorities.

Where required under applicable law, EqtPulse shall provide users with a clear consent notice explaining:

1. the personal data being collected;
2. the purpose for which such data is collected;
3. how the data may be used;
4. whether the data may be shared with third-party service providers;
5. how the user may withdraw consent;
6. how the user may raise a privacy-related request or grievance.

By submitting personal data, creating an account, subscribing to services, using the platform, or communicating with EqtPulse, the user provides consent for collection and processing of personal data for the purposes described in this Privacy Policy and any applicable consent notice.

Where processing is based on consent, users may withdraw such consent in accordance with this Policy.

EqtPulse may collect and process user information for the following purposes:

1. account creation and user verification;
2. KYC, onboarding, and regulatory checks;
3. providing access to research services;
4. delivering research reports, trading signals, alerts, model portfolio suggestions, and market analysis;
5. managing subscriptions, billing, renewals, cancellations, and refunds;
6. issuing invoices, receipts, and payment confirmations;
7. providing customer support;
8. resolving service grievances;
9. handling privacy-related requests;
10. sending service updates and important notices;
11. maintaining regulatory and compliance records;
12. maintaining investor communication and audit trails;
13. preventing fraud, misuse, unauthorised access, scraping, credential sharing, or security breaches;
14. improving website and platform performance;
15. analysing usage trends and user behaviour;
16. testing and improving platform features;
17. complying with applicable laws, regulations, court orders, SEBI requirements, RAASB guidelines, exchange requirements, or government directions;
18. enforcing legal rights, agreements, and platform terms.

EqtPulse processes personal data based on one or more of the following grounds:

1. user consent;
2. performance of contractual or service obligations;
3. compliance with legal and regulatory obligations;
4. permitted uses under applicable law;
5. fraud prevention and platform security;
6. dispute resolution, recordkeeping, audit, and legal enforcement.

The information collected may be used to:

1. identify and authenticate users;
2. activate and manage subscriptions;
3. send research-related communication;
4. send alerts and service notifications;
5. process payments and refunds;
6. respond to support requests;
7. investigate complaints or grievances;
8. process privacy-related requests;
9. improve research delivery and platform functionality;
10. detect misuse, scraping, unauthorised access, account sharing, or credential sharing;
11. maintain audit trails and compliance records;
12. meet obligations under applicable laws and regulations.

EqtPulse may share user information on a need-to-know basis with:

1. payment gateways, banks, and payment service providers;
2. cloud hosting and infrastructure providers;
3. technology vendors and software service providers;
4. analytics and platform performance tools;
5. customer support and ticketing service providers;
6. KYC, compliance, or verification service providers, where applicable;
7. legal, tax, audit, or compliance professionals;
8. regulators, government authorities, courts, tribunals, law enforcement agencies, SEBI, RAASB, stock exchanges, or other authorities, where legally required;
9. any successor entity in case of merger, restructuring, acquisition, investment, asset sale, business transfer, or corporate reorganisation, subject to applicable law.

EqtPulse does not sell user personal information to third parties.

Where EqtPulse engages third-party service providers or data processors, such parties shall be required to process personal data only for authorised purposes and subject to confidentiality, security, contractual, and legal obligations.

EqtPulse may use third-party providers for cloud hosting, analytics, customer support, payment processing, KYC verification, compliance support, communication delivery, security monitoring, and platform operations.

EqtPulse shall take reasonable steps to ensure that such service providers follow appropriate security and confidentiality standards. However, EqtPulse does not control independent third-party platforms that users access directly.

EqtPulse does not require access to the user’s broker login password, trading account password, Demat account password, OTP, UPI PIN, or transaction authorisation credentials.

If any future product or integration requires broker-related technical access, such access shall be subject to separate user consent, separate terms, and applicable law.

For EqtPulse research services, all investment and trading decisions remain solely with the user.

EqtPulse does not execute trades on behalf of users, operate user broker accounts, manage user funds, or control user trading decisions.

EqtPulse may retain user information for as long as necessary to:

1. provide services;
2. maintain user accounts;
3. comply with legal, regulatory, tax, audit, and accounting obligations;
4. resolve disputes;
5. enforce agreements;
6. maintain security and fraud-prevention records;
7. satisfy SEBI, RAASB, or other applicable regulatory recordkeeping requirements.

Certain records may be retained even after account closure, subscription cancellation, consent withdrawal, or deletion request where retention is required for legal, regulatory, tax, audit, contractual, dispute-resolution, or securities market compliance purposes.

After the applicable retention period expires, EqtPulse may delete, anonymise, archive, or securely restrict access to such data, subject to applicable law.

EqtPulse takes reasonable technical, organisational, and administrative measures to protect user information against unauthorised access, misuse, alteration, disclosure, or destruction.

Such measures may include:

1. access controls;
2. encryption where appropriate;
3. secure hosting infrastructure;
4. restricted employee access;
5. internal confidentiality controls;
6. monitoring and logging;
7. data backup and recovery controls;
8. security reviews and updates;
9. vendor access controls;
10. incident detection and response procedures.

However, no digital platform, internet transmission, cloud system, or electronic storage system can be guaranteed to be completely secure. Users access and use the platform with this understanding.

In the event of a personal data breach, EqtPulse shall take reasonable steps to assess, contain, investigate, and remediate the breach.

Where required under applicable law, EqtPulse shall notify affected users and applicable authorities. Such notification may include:

1. the nature of the breach;
2. the type of personal data affected;
3. the likely consequences of the breach;
4. steps taken by EqtPulse to address the breach;
5. steps users may take to protect themselves;
6. contact details for assistance.

Users should immediately report any suspected unauthorised access, suspicious communication, phishing attempt, or account compromise to hello@eqtpulse.in.

Users are responsible for:

1. maintaining confidentiality of account login credentials;
2. using strong passwords;
3. not sharing account access with others;
4. keeping registered email and mobile number updated;
5. immediately reporting suspicious activity;
6. not sharing OTPs, UPI PINs, broker credentials, passwords, or payment authentication information;
7. using secure devices and networks while accessing the platform;
8. providing accurate and updated information;
9. not impersonating another person;
10. not submitting false, misleading, or fraudulent information.

EqtPulse shall not be responsible for losses caused by user negligence, compromised devices, shared credentials, phishing, malware, unauthorised access caused by the user’s own conduct, or failure to follow reasonable security practices.

Subject to applicable law, users may request to:

1. access their personal information;
2. obtain information about how their personal data is processed;
3. correct inaccurate or outdated information;
4. update contact details;
5. withdraw consent where processing is based on consent;
6. request deletion or erasure of information, subject to regulatory retention requirements;
7. request clarification on how their information is used;
8. raise a privacy-related grievance;
9. nominate another individual to exercise their data-related rights in the event of death or incapacity, where permitted under applicable law.

Certain information may not be deleted immediately if retention is required under law, regulation, tax, audit, contractual obligation, dispute-resolution process, or SEBI-related compliance requirement.

Users may withdraw consent by writing to:

hello@eqtpulse.in

Users may also withdraw consent through any account, privacy, or consent-management feature made available on the EqtPulse platform.

Withdrawal of consent may affect EqtPulse’s ability to provide certain services, including account access, research service delivery, regulatory compliance, billing, support, or investor grievance handling.

Withdrawal of consent shall not affect processing already carried out lawfully before such withdrawal.

EqtPulse may continue to retain or process certain data where required for legal, regulatory, tax, audit, security, contractual, dispute-resolution, or SEBI-related obligations.

Privacy requests shall be handled by the Chief Information Security Officer of EquityPulse Tech Private Limited.

Users may write to:

EqtPulse shall endeavour to respond to valid and complete privacy-related requests within 30 days from the date of receipt.

If a request is incomplete, unclear, unverifiable, excessive, legally restricted, or requires additional information from the user, the response timeline may begin from the date on which the required information is received.

EqtPulse may send users service updates, research-related notifications, platform alerts, educational content, subscription updates, offers, or other communications through email, SMS, WhatsApp, phone, in-app notification, or other permitted channels.

Users may opt out of promotional communication where legally permitted.

However, users may still receive essential service, legal, compliance, billing, security, investor grievance, privacy, or account-related communication.

EqtPulse may use cookies and similar technologies for authentication, analytics, performance monitoring, personalisation, security, fraud prevention, and service improvement.

Users can manage cookie preferences through browser settings. Disabling cookies may affect website or platform functionality.

EqtPulse may update its cookie practices from time to time and may provide additional cookie notices or settings where required.

EqtPulse services are intended only for users who are legally competent to enter into contracts and participate in securities market-related services.

The platform is not intended for minors.

EqtPulse does not knowingly collect or process personal data of individuals below 18 years of age.

If EqtPulse becomes aware that personal data of a child has been collected without lawful basis or required consent, it shall take reasonable steps to delete, anonymise, or restrict such data, subject to applicable law.

EqtPulse may use cloud, technology, analytics, communication, or support service providers located in India or other jurisdictions.

Where personal data is processed or transferred outside India, EqtPulse shall take reasonable steps to ensure that such processing is subject to applicable law, contractual safeguards, security controls, and any restrictions notified by the Government of India from time to time.

The EqtPulse website or platform may contain links to third-party websites, payment gateways, broker platforms, data providers, analytics services, or external services.

EqtPulse is not responsible for the privacy practices, security standards, content, policies, or conduct of such third parties.

Users should review the privacy policies and terms of third-party platforms before submitting information to them.

In case of merger, acquisition, restructuring, investment, asset sale, business transfer, or corporate reorganisation, user information may be transferred to the relevant successor, acquiring entity, investor, or transferee, subject to applicable law and confidentiality obligations.

The receiving entity may continue to process user information in accordance with this Privacy Policy or any updated privacy policy notified to users.

EqtPulse may disclose user information where required to:

1. comply with applicable law;
2. respond to lawful requests from regulators or authorities;
3. comply with SEBI, RAASB, exchange, court, tribunal, or government directions;
4. enforce legal agreements;
5. protect rights, property, or safety of EqtPulse, users, or the public;
6. investigate fraud, misuse, unauthorised access, cybersecurity incidents, or security breaches;
7. respond to audit, inspection, inquiry, or investigation requirements.

For privacy-related questions, data correction requests, consent withdrawal, data deletion requests, or privacy grievances, users may contact:

EqtPulse shall endeavour to respond to privacy-related grievances within 30 days from the date of receipt of a valid and complete grievance.

Privacy grievances are different from securities market-related investor grievances.

For securities market-related complaints, service issues, subscription concerns, research service grievances, or investor grievances, users should first contact EqtPulse through the official grievance channel:

Email: hello@eqtpulse.in

If the grievance is not resolved satisfactorily, users may escalate the matter through SEBI SCORES or other applicable dispute resolution mechanisms, subject to applicable SEBI rules, circulars, and procedures.

EquityPulse Tech Private Limited reserves the right to modify, update, or replace this Privacy Policy at any time.

The updated Privacy Policy shall be published on www.eqtpulse.in with the revised effective date or last updated date.

Continued use of the website or platform after publication of the revised Privacy Policy shall constitute acceptance of the updated terms.

For privacy-related questions, support issues, data correction requests, consent withdrawal, or grievances, users may contact: