Privacy policy

Privacy policy

Effective date: date of launch — to be confirmedLast updated: October 2026

This policy explains how personal data is handled under the Digital Personal Data Protection Act, 2023 and the rules made under it, the Information Technology Act, 2000 and the rules made under it, and the record-keeping and confidentiality obligations of the SEBI (Research Analysts) Regulations, 2014. By using this website or subscribing to the research services, you agree to the processing described here.

1. Who we are

The website equitiesnagain.com and the research services offered through it are operated by Nirav Dilip Desai, an individual SEBI Registered Research Analyst (Registration No. INH000004440, BSE Enlistment No. 5205), of Shop No. 1, Gokul Horizon, Thakur Village, Behind Gokul Concorde, Kandivali (E), Mumbai – 400101 ("we", "us"). For the purposes of data protection law, Nirav Dilip Desai is the Data Fiduciary for your personal data.

2. Data we collect

Data you give us

• When you subscribe: full name as per PAN, email address, mobile number, PAN, date of birth, the plan you choose, and your consent to the terms.
• For KYC: the KYC details required by SEBI, which we verify with and upload to a SEBI-registered KYC Registration Agency (KRA).
• When you contact us: your name, mobile number, email, the topic and message you send through the contact form, by email, phone, SMS or WhatsApp.
• When you raise a grievance: the details of your complaint and our correspondence about it.

Data created when you use our services

• Records of payments made (amount, date, plan, Razorpay order and payment IDs). We do not receive or store your card number, CVV, UPI PIN or net-banking password.
• Records of our interactions with you, including calls and messages about the research services, which SEBI requires research analysts to keep for clients and prospective clients.
• Your membership of the SMS or WhatsApp research group for your plan.

Data collected automatically by the website

• Standard server logs kept by our web host (IP address, browser type, pages requested, date and time), used for security and to keep the site working.
• Small settings saved in your own browser (see section 7). We do not use advertising or analytics cookies.

3. How we use your data

• To register you as a client, complete KYC, and provide the research services you subscribed to.
• To process payments, issue receipts and maintain accounts and tax records.
• To add you to, and remove you from, the research group for your plan.
• To respond to your enquiries and to handle and resolve grievances.
• To meet our legal and regulatory obligations, including SEBI record-keeping, the annual compliance audit, reporting to SEBI and the RAASB (BSE Limited), and requests from authorities.
• To protect clients and the public from fraud and impersonation, and to keep this website secure.

We do not sell your personal data, and we do not use it for advertising by third parties. We do not make decisions about you using automated profiling.

4. Consent and legal basis

We process your personal data on the basis of the consent you give when you submit the checkout or contact form, and, where the law permits, for legitimate uses such as complying with SEBI regulations, KYC requirements and other legal obligations. You may withdraw your consent at any time by writing to us (see section 14). Withdrawal does not affect processing already carried out, and we may need to stop providing services that depend on that data. Records we are required by law to keep will be retained for the period the law requires.

5. Who we share your data with

We share personal data only as needed to provide the services or comply with law:

These service providers process data on our instructions and only for the purposes above. Some of them, such as Google, may store data on servers outside India, subject to the safeguards required by Indian law.

6. Payments

Online payments are processed by Razorpay, a payment aggregator authorised by the Reserve Bank of India. Your card, UPI and bank details are entered directly with Razorpay and are handled under Razorpay's own privacy policy and security standards. We receive only confirmation of the payment and its reference IDs. We never ask for your card details, OTPs, UPI PIN or the login credentials of your trading, demat or bank accounts.

7. Cookies and browser storage

This website does not use advertising or tracking cookies. It saves a few small settings in your own browser's storage, which never leave your device:

• that you have accepted the investor disclaimer, so it is not shown on every visit;
• that you have seen the investor alert in the current session;
• your choices in the accessibility menu (text size, contrast and similar).

You can clear these at any time through your browser settings. The embedded Google Map on the contact page and the fonts loaded from Google may set or read cookies under Google's own policies; the address is always also given in text.

8. How long we keep your data

We keep client records, including KYC, agreements, payment records, records of interactions and research provided, for at least five years, or longer where SEBI, tax law or another law requires, or while a grievance, dispute or regulatory proceeding is pending. Contact-form enquiries that do not lead to a subscription are kept for as long as SEBI requires records of interactions with prospective clients, and then deleted. When data is no longer needed, it is deleted or anonymised.

9. Security

We use reasonable security practices to protect personal data, including encrypted (HTTPS) connections, payment processing through an RBI-authorised aggregator, access limited to the Research Analyst and service providers who need it, and verification of payment confirmations using cryptographic signatures. No method of transmission or storage is completely secure. If a personal data breach occurs, we will inform affected users and the Data Protection Board of India as the law requires.

10. Your rights

Subject to the law, you have the right to:

• obtain a summary of the personal data we hold about you and how we process it;
• correct, complete or update inaccurate or incomplete data;
• request erasure of data that is no longer needed, except where we are required by law to retain it;
• withdraw your consent;
• have your grievance about our handling of your data addressed;
• nominate another person to exercise these rights on your behalf in the event of your death or incapacity.

To exercise any of these rights, write to us using the details in section 14. We may ask you to verify your identity first.

11. Children

The research services are meant only for persons aged 18 and above. We do not knowingly collect personal data of children. If you believe a child has given us personal data, contact us and we will delete it.

12. Refund and cancellation

You may stop the research services at any time. If the services are terminated early by you or by us, you are entitled to a refund of fees, in proportion to the unexpired period of your subscription, with no breakage fee. If SEBI suspends the Research Analyst's registration for more than 60 days or cancels it, fees are refunded pro rata from the effective date of suspension or cancellation to the end of the subscription period. Refunds are made to the original payment method. The full terms are in the Most Important Terms and Conditions and minimum mandatory terms.

13. Changes to this policy

We may update this policy to reflect changes in law or in how we work. The "Last updated" date at the top shows when it last changed. Material changes will be notified to existing clients by email or message before they take effect.

14. Grievances and contact

For any question, request or complaint about your personal data, contact the Grievance Officer:

We will acknowledge your request promptly and respond within the time the law allows. If you are not satisfied with our response about your personal data, you may complain to the Data Protection Board of India. Complaints about the research services themselves follow the grievance redressal process, including SEBI SCORES and SMART ODR.