Privacy Policy — Research Analyst Services
Last updated: 17-September-2026 | Version 1.1
1. Introduction
- Tradeswift Broking Private Limited (“the Company”, “Tradeswift”, “we”, “us”, “our”) respects the privacy of visitors to www.tradeswift.net (the “Website”) and of clients of its Research Analyst services. This Privacy Policy explains what personal data we collect, how we use it, who we share it with, how long we keep it, and what rights you have.
- Please read this policy carefully. If you do not agree with it, please do not use the Website or subscribe to our services. By using the Website or our services, you consent to the handling of your personal data as described here.
- We may revise this policy from time to time. The “Last updated” date above tells you when it was last changed. Material changes will be notified to registered clients. You are encouraged to review this page periodically.
2. Who is responsible for your data
Tradeswift Broking Private Limited is the data fiduciary in respect of the personal data described in this policy.
3. Scope of this policy
- This policy applies to anyone who visits the Website, and to clients of our Research Analyst services.
- Where you are also a broking or depository client of Tradeswift, the privacy policy applicable to those services continues to apply to that relationship, in addition to this policy.
- This policy does not apply to any third-party website you reach through a link on our Website.
4. Information we collect
4.1 Information you give us
| Category |
Examples |
Why we collect it |
| 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, postal address |
Delivery of research reports and regulatory communication |
| Financial |
Bank account or UPI ID used to pay fees, invoice and transaction 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, version of the document consented to |
Evidence of consent to the Terms and Conditions and the MITC |
| Technical data |
IP address, browser type, operating system, device, access times, pages viewed, referring page |
Site security, fraud prevention, and understanding how the site is used |
You are under no obligation to provide personal data. However, if you do not provide the data required for KYC and onboarding, we will not be able to provide research services to you, because those requirements are imposed on us by law.
4.2 Information collected automatically
When you access the Website, our servers automatically record certain technical information, including your IP address, browser type, operating system, device type, access times, the pages you view, and the page you visited immediately before and after our Website. This information is used for site security, fraud prevention, and to understand how the Website is used. It is not used to identify you personally unless combined with data you have given us.
4.3 Payment information
- Online 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. Card and payment instrument data is stored by our payment processor. We encourage you to read that processor's own privacy policy and to contact it directly with any question about the handling of your card data.
- We retain only the transaction reference, the payment method, the last four digits of the instrument, the amount and the date, which we need for the fee register required under Regulation 25(1)(vi) and for issuing refunds.
- Where you pay by net banking, UPI or bank transfer, your bank account number or UPI ID is retained for the same purposes and to process refunds to the same instrument.
4.4 Information from other sources
We may receive personal data about you from KYC Registration Agencies, the Central KYC Records Registry, depositories, stock exchanges, government agencies, fraud prevention agencies and publicly available records, where this is required for KYC, for verification, or to meet our obligations under the Prevention of Money Laundering Act, 2002.
4.5 Cookies and similar technologies
- Strictly necessary cookies, which allow the Website to function, keep your session active and protect against fraud. The Website will not work properly without these.
- Preference cookies, which remember choices you make, such as your language or display settings.
- Analytics cookies, which help us measure how the Website is used so that we can improve it.
You can control or delete cookies through your browser settings. Disabling strictly necessary cookies may prevent parts of the Website from working. We do not use cookies to serve third-party advertising.
5. How we use your information
We use the personal data we collect in order to:
- Verify your identity and complete your KYC as required by law.
- Create and manage your account and process your subscription.
- Deliver research reports and recommendations to you.
- Process payments, issue invoices and process refunds.
- Maintain the client register, fee register and communication records required under the SEBI (Research Analysts) Regulations, 2014.
- Respond to your queries, requests, complaints and grievances.
- Notify you about changes to our services, our policies or these terms.
- Detect and prevent fraud, unauthorised access, money laundering and other unlawful activity.
- Comply with our obligations to SEBI, RAASB, stock exchanges, tax authorities and other regulators, and to respond to lawful directions.
- Operate, secure, maintain and improve the Website, and analyse how it is used.
- Establish, exercise or defend legal claims, and resolve disputes.
We do not use your personal data to make solely automated decisions that produce legal or similarly significant effects on you.
6. Legal basis for processing
- Consent, given by you 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 Prevention of Money Laundering Act, 2002, or tax law require us to collect and retain data. Consent cannot be withdrawn in respect of data we are required by law to retain.
7. Who we share it with
- 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, courts 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, and our legal and professional advisers, to the extent they need the data to advise us.
- Our payment gateway, and our technology, hosting, email 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.
- Where we reasonably believe disclosure is necessary to investigate or prevent fraud, to protect the rights, property or safety of any person, or to enforce our Terms and Conditions.
We do not sell your personal data. We do not share it with advertisers, investors or any third party for that third party's own marketing purposes.
8. Where your data is stored
- Your personal data is stored on systems located within India.
- Payment system data is stored in India in accordance with the data localisation requirements applicable to payment systems.
- We do not transfer your personal data outside India except where permitted by law and subject to appropriate safeguards.
9. 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.
- Data that we are not required to retain is deleted or anonymised once the purpose for which it was collected is complete.
10. Security
- Data is protected by administrative, technical, procedural and physical safeguards, including 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.
- No method of transmission over the internet or of electronic storage is completely secure. While we take reasonable steps to protect your personal data, we cannot guarantee absolute security.
11. 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, completed 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 advisory@tradeswift.net from your registered email ID. We will respond within 30 days. We may need to verify your identity before acting on a request.
12. Marketing communications and how to opt out
- Where you have consented, we may send you information about our research services, market updates and offers. You may withdraw that consent at any time.
- To stop receiving marketing communications, use the unsubscribe link in any such message, or write to advisory@tradeswift.net from your registered email ID. We will action your request promptly.
- Opting out of marketing does not stop service messages, regulatory communications, or research reports under a subscription you have paid for, since we are required to send those.
13. 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.
- Where we process the personal data of a child, we will do so only with verifiable consent of a parent or lawful guardian as required by the Digital Personal Data Protection Act, 2023.
14. Third-party websites
- The Website may contain links to third-party websites, including the website of our payment gateway.
- We do not control and are not responsible for the privacy practices or content of any third-party website. This policy does not apply to them.
- We encourage you to read the privacy policy of every website you visit.
15. Legal disclaimer
We reserve the right to disclose your personal data where required to do so by law, or where we believe in good faith that disclosure is necessary to comply with a judicial proceeding, court order, regulatory direction or legal process, or to protect our rights or the rights and safety of others.
16. Changes to this policy
- We may amend this policy to reflect changes in law, regulation, technology or our services. The revised version will be published on this page with a new version number and date.
- Where a change is material, we will notify registered clients by email.
- Your continued use of the Website or our services after a revised policy is published means you accept the revision.
17. Grievance redressal and escalation
- Grievance Officer: Ajay Mundhra, complianceofficer.ra@tradeswift.net, 0141-4050505, 4th Floor, Baid House, 1, Tara Nagar, Ajmer Road, Jaipur – 302006, Rajasthan.
- For any grievance relating to your personal data, write to the Grievance Officer. We will acknowledge your grievance and endeavour to resolve it within the timelines prescribed under applicable law.
- If your privacy grievance is not resolved to your satisfaction, you may approach the Data Protection Board of India.
- For grievances relating to our Research Analyst services, write to our Compliance Officer, Ajay Mundhra, at complianceofficer.ra@tradeswift.net or call 0141-4050505. If you are not satisfied, you may lodge a complaint with SEBI on the SCORES portal at https://scores.sebi.gov.in, or refer the dispute to the Online Dispute Resolution portal at https://smartodr.in. SEBI toll-free helpline: 1800 22 7575 / 1800 266 7575.
Tradeswift Broking Private Limited, 4th Floor, Baid House, 1, Tara Nagar, Ajmer Road, Jaipur – 302006, Rajasthan, India. Telephone: 0141-4050517 | Email: advisory@tradeswift.net | Website: www.tradeswift.net | Support hours: Monday to Friday, 10:00 AM to 6:00 PM IST
This page is the website version of the Privacy Policy, published for the Website and for online fee collection. It does not replace the Terms and Conditions including the MITC, the Disclosure Document or the Investor Charter provided at onboarding, each of which continues to apply.
