1. Introduction
We are committed to protecting Your privacy. This Privacy Policy outlines how We collect, use, disclose, and safeguard Your personal information through Our Platform.
Money Bells Research Analyst (“Money Bells”, “we”, “us”, or “our”) is a SEBI Registered Research Analyst engaged in providing independent research, analysis, and recommendations in relation to securities markets. We value the trust placed in us by our clients and users, and protecting your personal information is one of our highest priorities.
This Privacy Policy (“Privacy Policy” or “Policy”) explains how we collect, use, process, store, and disclose your personal data when you access our website, mobile application, subscribe to our research services, or otherwise interact with us. This Policy reflects our commitment to maintaining transparency and safeguarding your information.
We are committed to complying with applicable data protection and privacy laws in India, including but not limited to:
Securities and Exchange Board of India (Research Analysts) Regulations Information Technology Act, 2000 and applicable rules Digital Personal Data Protection Act, 2023 (as applicable)
As a SEBI Registered Research Analyst, we adhere strictly to regulatory standards relating to confidentiality, data handling, and record maintenance.
This Privacy Policy applies to:
Retail clients subscribing directly to our research services (B2C) Users accessing our website or mobile application Individuals interacting with us through business associations or referrals Prospective clients making inquiries
Money Bells provides research and recommendation services only. We do not undertake stock broking activities under the Research Analyst registration.
Where a client chooses to avail brokerage services through a separately registered stock broker (including cases where there may be a separate business association), such services are governed by the respective broker’s terms and privacy policies, and are independent of our research services.
At the time of collection of personal data, we provide a clear notice specifying the purpose of processing, categories of data collected, and details of grievance redressal, in accordance with applicable law.
2. Consent and acceptance of terms
By accessing our website or mobile application (“Platform”) or by using any of our research services (“Services”), you confirm that you have read, understood, and agreed to the terms of this Privacy Policy.
By using our Platform or Services, you provide your explicit consent for the collection, use, processing, storage, and disclosure of your personal data in accordance with this Policy and applicable laws.
If you do not agree with any part of this Privacy Policy, you should refrain from accessing our Platform or availing our Services.
Where the processing of your personal data is based solely on your consent, you have the right to withdraw such consent at any time, subject to applicable legal and regulatory obligations. Withdrawal of consent may affect our ability to provide certain services where retention of records is required under SEBI Research Analyst Regulations.
Your access to the Platform and use of our Services is subject to this Privacy Policy read together with:
Client application forms Service agreements Risk disclosures and undertakings Terms and Conditions available on our Platform
In case of any inconsistency between this Privacy Policy and the Terms and Conditions, this Privacy Policy shall prevail only with respect to matters relating to personal data protection.
In accordance with the Digital Personal Data Protection Act, 2023, you are recognised as a “Data Principal” and are entitled to exercise the rights granted under applicable law.
Right to nominate
You may nominate another individual to exercise your data protection rights in the event of your death or incapacity, in accordance with applicable law.
3. Definitions
All capitalized terms used but not defined in this Privacy Policy shall have the meaning assigned to them in our Terms and Conditions, unless otherwise defined below:
“Data protection laws” mean the applicable laws in India governing the protection and processing of personal data, including but not limited to the Information Technology Act, 2000, the rules framed thereunder, the Digital Personal Data Protection Act, 2023, and any amendments or re-enactments thereof. “Personal data” means any information relating to an identified or identifiable natural person, whether collected in digital form or converted into digital form after collection. “Processing” means any operation or set of operations performed on personal data, whether automated or otherwise, including collection, recording, organization, structuring, storage, adaptation, retrieval, use, disclosure, dissemination, alignment, restriction, erasure, or destruction. “Platform” means our official website, mobile application, or any digital interface operated by Money Bells Research Analyst for providing research-related services. “Services” mean the research, analysis, reports, recommendations, market insights, and related support services provided by Money Bells Research Analyst through the Platform or through authorized communication channels, including email, customer support, or other official modes of interaction. * “You” or “your” refers to any individual who accesses, browses, registers on, subscribes to, or otherwise uses our Platform or Services.
4. Kinds of personal data we collect
We collect only such personal data that is relevant, necessary, and proportionate to the purposes for which it is processed, in accordance with applicable data protection laws and SEBI Research Analyst Regulations.
Depending on the nature of interaction or services subscribed, we may collect the following categories of personal data:
Identity data: Full name, Date of birth, Gender, PAN (where required for regulatory compliance), Photograph (if required for records), Signature (digital or physical), and any government-issued identification submitted voluntarily or as required under applicable law. Contact data: Residential or correspondence address, Email address, Mobile number, Alternate contact details (if provided). Financial and risk profiling data: Basic income range (for suitability assessment, where applicable), Investment objectives, Risk appetite and risk profiling responses, Existing investment exposure (if voluntarily disclosed for research suitability purposes). *We do not collect or hold client trading balances or execute trades on behalf of clients.* Regulatory and compliance data: Information collected for fulfilling regulatory obligations, including client declarations, risk profiling records, consent records, and documents required under SEBI Research Analyst Regulations. *Biometric authentication data is not collected directly by us unless mandated by law and processed through authorized mechanisms.* Transactional data: Subscription plan details, Payment confirmation details, Invoice records, and Service usage history. Technical data: When you access our Platform, certain technical information may be collected automatically, including: IP address, Browser type and version, Device type, Operating system, Login timestamps, Application crash logs and diagnostic data. Usage data: Information about how you use our Platform and Services, including pages viewed, features accessed, time spent on the Platform, and interaction patterns. Profile data: Username and login credentials, Subscription preferences, Service history, and Communication preferences. Marketing and communication data: Preferences regarding receiving updates, newsletters, or promotional communications, and Consent for email, SMS, push notifications, or messaging applications. *You may opt out of marketing communications at any time.* Voluntarily provided data: Any additional information you provide through feedback forms, customer support interactions, surveys or communications. * Mobile application permissions: If you use our mobile application, we may request access to certain device permissions strictly for functional purposes, such as: Storage access (for downloading reports), Notification access (for research alerts), and Basic device information (for security and fraud prevention). *We do not access contacts, SMS, microphone, or installed applications unless specifically required for a clearly disclosed feature and with your explicit consent.*
5. Sources of personal data collection
We collect your personal data through lawful and transparent means, using secure channels appropriate to the nature of our research services.
Direct interactions: This is the primary way in which we collect personal data. You may provide information to us when you: Subscribe to our research services; Fill out online or offline registration forms; Complete risk profiling questionnaires; Register for webinars, seminars, or educational sessions; Participate in surveys or feedback programs; Contact our customer support team via phone, email, chat, or other official communication channels; Communicate with us through email or submit queries through our Platform. Automated technologies and digital interactions: When you access or use our Platform, certain technical and usage data may be collected automatically. This may include: IP address, Device type and operating system, Browser type, Login timestamps, Pages visited and interaction patterns. Such information is collected through cookies and similar tracking technologies to enhance user experience, improve security, and analyze Platform performance. Mobile application permissions: If you use our mobile application, we may request access to limited device permissions strictly for functional purposes, such as Storage access (for downloading research reports), Notification access (for research alerts and updates), and Basic device information (for security and fraud prevention). Permissions are requested contextually and only when necessary for enabling specific features. Data is collected only upon your explicit consent and in accordance with applicable laws. *We do not access contacts, SMS, call logs, microphone, or installed applications unless clearly disclosed and specifically required for a defined feature.* * Third-party sources: In limited circumstances and where legally permissible, we may receive personal data from Payment gateway providers (for transaction confirmation), Identity verification service providers (where compliance checks are required), and Publicly available sources, such as government databases or public registries. We ensure that any third party sharing personal data with us has appropriate legal authority to do so and adheres to applicable data protection standards.
6. Purposes of processing personal data
We process your personal data only where we have a lawful basis to do so under applicable data protection laws and SEBI Research Analyst Regulations.
Your personal data may be processed for the following purposes:
Providing access to the platform and delivery of services: To create and manage your user account and login credentials, To generate your profile on our Platform, To provide research reports, recommendations, alerts, and related services, To process subscription requests and payments, To send invoices, confirmations, and service-related communications, To fulfil obligations under agreements entered into with you. *Money Bells Research Analyst does not open or manage trading, Demat, lending, or other financial intermediation accounts.* Regulatory compliance and legal obligations: To comply with SEBI Research Analyst Regulations, To maintain records of recommendations, risk profiling, and client communications, To fulfil obligations under applicable laws, including anti-money laundering requirements where applicable, To respond to lawful requests from courts, regulatory authorities, or government bodies, To conduct internal compliance reviews and audits. Client relationship management and support: To respond to your queries, complaints, or service requests, To provide technical assistance related to the Platform, To notify you about changes to policies, terms, or services, To maintain accurate and updated client records. Service improvement and platform development: To analyse usage patterns and improve user experience, To enhance functionality, stability, and security of the Platform, To develop new research features or tools, To assess service performance and user engagement. Communication and marketing: To send research updates, newsletters, educational material, and service announcements, To inform you about new research offerings or subscription plans, To customise communications based on your preferences. *You may opt out of promotional communications at any time, subject to regulatory communication requirements.* Risk management, fraud prevention and security: To verify user identity and prevent unauthorised access, To detect and prevent fraudulent or unlawful activity, To protect the integrity and security of our systems and data, To monitor compliance with our Terms and Conditions. Internal operations and audit readiness: To maintain internal records and documentation, To conduct compliance assessments and internal audits, To prepare for regulatory inspections or supervisory reviews, To maintain records of user consent and preferences. Legal proceedings and protection of rights: To investigate or resolve disputes, To establish, exercise, or defend legal claims, To protect legitimate business interests in regulatory or legal proceedings. Mobile application functionality: Where you use our mobile application, personal data collected through device permissions may be processed strictly to: Enable secure login and authentication, Support document upload or download features, Deliver notifications and research alerts, and Improve security and prevent misuse. Permissions are requested only when necessary and in accordance with data minimisation principles. * Other lawful purposes: For any additional purpose required under applicable law or based on your explicit consent.
7. Use and disclosure of personal data
We treat your personal data as confidential and share it only when necessary, for lawful purposes, and with appropriate safeguards.
Your personal data may be disclosed in the following circumstances:
Regulatory and statutory authorities: We may disclose personal data where required under applicable law or regulatory directions, including to: Securities and Exchange Board of India (SEBI), Income tax authorities, Courts, tribunals, or law enforcement agencies, Any other government or statutory authority empowered under law. Such disclosures are made strictly to comply with legal obligations, regulatory reporting requirements, or lawful requests. Service providers and operational partners: We may engage trusted third-party service providers to support our operations and research services. These may include: Payment gateway providers (for processing subscription payments), Cloud hosting and infrastructure providers, IT support and cybersecurity service providers, Customer relationship management (CRM) system providers, Email, SMS, and notification service providers, Data analytics or technology solution providers, Auditors, legal advisors, and compliance consultants, Digital document execution or e-signature service providers. These service providers are contractually bound to process personal data only as instructed by us, maintain confidentiality, implement appropriate security safeguards, and comply with applicable data protection laws. *We do not sell or rent your personal data to third parties. You may request further details regarding categories of service providers by contacting us through the details provided in this Policy.* Professional advisors: Personal data may be shared with auditors, legal advisors, compliance professionals, or consultants where necessary for: Regulatory compliance, Internal audits, Legal advice, Risk management. Such disclosures are subject to confidentiality obligations. Corporate restructuring or business transfers: In the event of a merger, acquisition, restructuring, investment transaction, or transfer of assets involving Money Bells Research Analyst, personal data may be shared with potential or actual acquiring entities, investors, or advisors as part of due diligence or transaction implementation. In such cases, the receiving party will be required to maintain confidentiality, use personal data only for legitimate transaction-related purposes, and adopt data protection standards consistent with this Privacy Policy. * Legal protection and enforcement: We may disclose personal data where necessary to: Enforce our Terms and Conditions, Protect our legal rights, Prevent fraud or unlawful activity, and Defend against legal claims.
8. Data retention and storage
We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, including compliance with legal, regulatory, accounting, and regulatory reporting requirements.
Retention periods are determined based on:
SEBI Research Analyst Regulations and related compliance requirements Applicable Indian laws, including anti-money laundering and taxation laws Internal record-keeping, dispute resolution, and risk management needs
Where processing is based solely on your consent and such consent is withdrawn, we will delete or anonymize the relevant personal data unless retention is required under applicable law.
Upon expiry of the applicable retention period, personal data is securely deleted or anonymized.
Personal data is stored on secure servers and systems owned by us or authorized service providers in accordance with applicable laws and industry standards.
Personal data may be processed and stored in India or in other jurisdictions permitted under applicable law. Where cross-border processing occurs, we ensure that such transfers are undertaken in compliance with the Digital Personal Data Protection Act, 2023 and applicable safeguards.
9. Cookies and tracking technologies
We use cookies and similar technologies to enhance user experience, improve platform performance, and maintain security.
Types of cookies used:
Essential cookies – Required for core platform functionality and security. Analytics cookies – Help us understand usage patterns and improve performance. Functional cookies – Remember user preferences.
We do not engage in invasive third-party behavioural advertising practices inconsistent with our role as a Research Analyst.
You may manage cookie preferences through your browser or device settings. Disabling cookies may impact certain platform features.
10. Third-party links
Our Platform may contain links to third-party websites or services. We are not responsible for the privacy practices, content, or security of such third-party platforms.
Users are advised to review the privacy policies of any third-party websites they access.
11. Information security framework
We implement appropriate technical, administrative, and physical safeguards to protect personal data from unauthorized access, misuse, alteration, or loss.
Our security framework includes:
Role-based access controls Encryption of data in transit (e.g., SSL/TLS) and at rest Secure hosting infrastructure Regular vulnerability assessments and penetration testing Internal audits and compliance reviews Incident response and data breach procedures Employee confidentiality obligations
While we take reasonable steps to protect personal data, no system can guarantee absolute security.
Users are encouraged to maintain confidentiality of login credentials and use strong passwords.
12. Your data protection rights
Subject to applicable laws, you may have the right to:
Access and review personal data held by us Request correction of inaccurate or incomplete data Withdraw consent where processing is consent-based Request erasure, subject to regulatory retention requirements Lodge a grievance regarding data processing
Requests may require identity verification before processing.
13. Grievance redressal mechanism
If you have concerns regarding this Privacy Policy or the processing of your personal data, you may contact:
Grievance Officer: Money Bells Research Analyst Email: compliance@moneybells.info Registered Office Address: D-1-C 1124, Gali no: -1, Ratiya Marg, Sangam Vihar, South Delhi-110080
We aim to resolve grievances within timelines prescribed under applicable laws and SEBI regulations.
If you are not satisfied with the resolution of your grievance, you may escalate the matter to the Data Protection Board of India in accordance with the Digital Personal Data Protection Act, 2023.
14. Limitation of liability
While we implement reasonable security measures, we shall not be liable for:
Unauthorized access caused by user negligence Disclosure resulting from lawful regulatory directions Security breaches beyond reasonable control
Nothing in this section limits liability where such limitation is prohibited by applicable law.
15. Important disclosures
16. Governing law and jurisdiction
This Privacy Policy shall be governed by the laws of India.
Any disputes arising in connection with this Policy shall be subject to the jurisdiction of competent courts in New Delhi, India.
17. Policy review and updates
We reserve the right to update this Privacy Policy from time to time.
Users are encouraged to review this Policy periodically. Continued use of the Platform after updates constitutes acceptance of the revised Policy.
This Privacy Policy constitutes an electronic record under applicable laws and does not require physical signature.
This electronic record complies with the IT Act, 2000 and does not require a physical or digital signature.
Your Privacy, Our Priority — Helping You Research with Confidence
Revision Audit Log History
v1.02026-02-28
Compliance Officer Sagar Goel
"Initial formulation and regulatory publication of the SEBI-compliant Privacy Policy."
* SEBI (Research Analyst) Regulations, 2014 एवं डिजिटल व्यक्तिगत डेटा संरक्षण अधिनियम (DPDPA), 2023 के अधीन जारी। Money Bells Global Research Services Private Limited.