Privacy Policy (Research Analyst Services)

Last updated: 17-Sept-2026 | Version [1.0]

This policy explains how Tradeswift Broking Private Limited collects and handles personal data in connection with its Research Analyst services. It supplements the Company's general privacy policy. Where you are also a broking or depository client, the privacy policy applicable to those services continues to apply to that relationship.

1. Who is responsible for your data

Tradeswift Broking Private Limited, 4th Floor, Baid House, 1, Tara Nagar, Ajmer Road, Jaipur – 302006, Rajasthan, is the data fiduciary in respect of the personal data described below. For any question about this policy, contact our Compliance Officer at complianceofficer.ra@tradeswift.net or 0141-4050505.

2. What we collect and why

Category	Examples	Why it is collected
Identity and KYC	Name, PAN, address proof, photograph, date of birth, signature	Mandatory KYC for fee-paying clients under the RA Regulations and the PMLA
Contact	Mobile number, email ID, messaging number	Delivery of research reports and regulatory communication
Financial	Bank account or UPI ID used to pay fees, invoice records	Fee collection and the fee register required under Reg. 25(1)(vi)
Family declaration	Names of dependent family members	Fee cap per family and client-level segregation checks
Communication records	Emails, messages, call recordings, dispatch logs	Mandatory record under Reg. 25(1)(vii)
Consent evidence	Timestamp, IP address, device, document version consented to	Evidence of consent to the Terms and Conditions and MITC

We collect only what is needed to provide research services, to collect fees, and to meet our obligations under the SEBI (Research Analysts) Regulations, 2014, the SEBI RA Master Circular, and the Prevention of Money Laundering Act, 2002.

3. Payment information

Card payments are processed by a PCI DSS compliant payment gateway. We do not collect, see or store your full card number, CVV or card PIN at any time.
We retain only the transaction reference, the payment method, the last four digits of the instrument, the amount and the date, which are needed for the fee register required under Regulation 25(1)(vi) and for issuing a refund.
Your bank account number or UPI ID, where you pay by those methods, is retained for the same purposes and to process refunds to the same instrument.

4. Legal basis

Your consent, given at onboarding and recorded with a timestamp, under the Digital Personal Data Protection Act, 2023.
Compliance with a legal obligation, where the SEBI Regulations, the PMLA or tax law require us to collect and retain the data. Consent cannot be withdrawn in respect of data we are required by law to retain.

KYC Registration Agencies and the Central KYC Records Registry, as required for KYC.
SEBI, RAASB, stock exchanges, depositories, the Financial Intelligence Unit-India, tax authorities and other competent authorities, where required by law or in response to a lawful direction.
Our auditors, including the auditor conducting the annual compliance audit required under the RA Regulations.
Our payment gateway, and our technology and communication service providers, who are bound by contract to use the data only for the services they provide to us and to keep it confidential.
We do not sell your personal data. We do not share it with third parties for their own marketing.

6. How long we keep it

Records relating to your onboarding, the recommendations issued to you, our communication with you, and the fees you paid are retained for at least five years, as required by Regulation 25 of the SEBI (Research Analysts) Regulations, 2014. Where a dispute has been raised, records are retained until the dispute is resolved, or for such longer period as SEBI may direct. This retention continues after your subscription is cancelled.

7. Security

Data is stored on systems within India and is protected by access controls, encryption in transit and at rest, logging, and periodic vulnerability assessment and penetration testing.
Access is restricted to employees who need it for their role. Research staff are kept separate from sales and dealing staff as required by the RA Regulations.
Our information security controls are maintained in line with the SEBI Cyber Security and Cyber Resilience Framework applicable to us.
If a personal data breach occurs, we will notify the Data Protection Board of India and affected individuals as required under the Digital Personal Data Protection Act, 2023.

8. Your rights

Access — obtain a summary of the personal data we hold about you and how it is processed.
Correction — have inaccurate or incomplete data corrected or updated.
Erasure — have data erased where it is no longer needed, except where we are required by law to retain it.
Withdraw consent — withdraw consent for processing that rests on consent alone. This does not affect processing required by law, and withdrawal may mean we can no longer provide the service.
Nominate — nominate a person to exercise your rights in the event of your death or incapacity.
Grievance — raise a complaint with our Grievance Officer. To exercise any of these rights, write to complianceofficer.ra@tradeswift.net from your registered email ID.

9. Cookies

Our website uses cookies necessary for the site to function and for security, and may use analytics cookies to understand how the site is used. You can control cookies through your browser settings. Disabling necessary cookies may prevent parts of the site from working.

10. Children

Our research services are not offered to persons below 18 years of age and we do not knowingly collect the personal data of children. If we learn that we hold such data, it will be deleted.

11. Changes to this policy

We may update this policy from time to time. The revised version will be published on this page with a new version number and date.

12. Contact and escalation

Compliance Officer: Ajay Mundhra, complianceofficer.ra@tradeswift.net, 0141-4050505, 4th Floor, Baid House, 1, Tara Nagar, Ajmer Road, Jaipur – 302006. If your privacy grievance is not resolved to your satisfaction, you may approach the Data Protection Board of India. For grievances relating to research services, you may also use SEBI SCORES at https://scores.sebi.gov.in.

These policies are drafted for publication on the Company's website in connection with online fee collection. They do not replace the Terms and Conditions including the MITC, the Disclosure Document or the Investor Charter, each of which continues to apply.