Privacy Policy

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Privacy Policy

SHERASIYA RIYAZUDIN RASUL (SEBI Reg. No.: INH000022057)

This Privacy Policy explains how we collect, use, store, share and protect your personal data when you visit www.researchsultan.com, use the Research Sultan mobile app, or subscribe to our research services. We are the data fiduciary in respect of that data. By using this website or availing our services, you consent to the practices described below.

Last updated: October 2026

1. Information We Collect

  1. Identity and KYC data: name, date of birth, PAN, Aadhaar-based identifiers where required, photograph, signature and proof of address, collected only from fee-paying clients as mandated by SEBI and RAASB.
  2. Contact data: postal address, email address and mobile number.
  3. Financial and suitability data: income range, investment experience and risk profile, where required to assess the appropriateness of research services.
  4. Transaction data: subscription plan, fees paid, payment dates and payment reference numbers. We do not collect or store your card number, CVV, UPI PIN, net-banking credentials or any other payment authentication data — these are handled entirely by the payment gateway.
  5. Communication records: emails, calls, messages and other interactions with you, including with prospective clients before onboarding. SEBI requires research analysts to maintain records of all such interactions.
  6. Technical data: IP address, browser type and version, device information, pages viewed and referring URLs, collected automatically through cookies and similar technologies.

2. How We Use Your Information

  1. To onboard you as a client, complete KYC and verify your identity through a KYC Registration Agency (KRA).
  2. To deliver research reports, recommendations and related services you have subscribed to.
  3. To process fees, issue receipts and process pro-rata refunds where applicable.
  4. To respond to your queries and to receive, investigate and redress grievances.
  5. To meet our legal, regulatory and audit obligations under the SEBI (Research Analysts) Regulations, 2014 and directions issued by SEBI and RAASB.
  6. To maintain the security and integrity of our website and to improve its content and performance.
  7. To send you service communications. We send promotional messages only where you have consented, and you may withdraw that consent at any time.

3. When We Share Your Information

We do not sell, rent or trade your personal data. We share it only in the following circumstances:

  1. Regulators and supervisory bodies: SEBI, the Research Analyst Administration and Supervisory Body (RAASB / BSE Limited), and KYC Registration Agencies, as required by law.
  2. Payment service providers: our payment gateway and banking partners, strictly to process your fee payment.
  3. Professional advisers: our auditors and legal advisers, bound by confidentiality obligations.
  4. Service providers: hosting, email and IT support providers who process data on our instructions only.
  5. Legal compulsion: where disclosure is required by a court, regulator or applicable law.

4. Cookies, Analytics and Advertising

  1. We use cookies and similar technologies that are necessary for the website to function, and others that help us understand how the site is used.
  2. Meta Pixel: our Join Telegram page loads the Meta (Facebook) Pixel. Simply opening that page does not send a page view to Meta. An event is sent to Meta Platforms only if you click a link to join our Telegram channel, so that we can measure the effectiveness of our advertising. This involves your IP address and cookie identifiers being processed by Meta under its own privacy policy. No other page of this website loads the pixel.
  3. You can block or delete cookies through your browser settings, and you can manage advertising preferences through your Meta account settings. Blocking cookies may affect how parts of this website work.
  4. We do not use cookies to collect your KYC, financial or payment credentials.

5. How We Protect Your Data

  1. This website is served over an encrypted HTTPS connection.
  2. Access to client records is restricted to authorised personnel who need it to perform their duties.
  3. Records are stored on access-controlled systems with reasonable technical and organisational safeguards.
  4. We will never ask for your trading account, demat account or bank account login credentials, passwords or OTPs. Never share these with anyone, including anyone claiming to represent us.
  5. No method of transmission or storage is completely secure. While we take reasonable steps to protect your data, we cannot guarantee absolute security.

6. How Long We Keep Your Data

We retain client records, KYC documents, research reports, rationale and records of client interactions for at least five years, or such longer period as SEBI or other applicable law requires. Where a matter is under investigation, audit or dispute, records are retained until it is concluded. Data no longer required is securely deleted or anonymised.

7. Your Rights

  1. To ask what personal data we hold about you and obtain a summary of it.
  2. To have inaccurate or incomplete data corrected or updated.
  3. To withdraw consent for non-essential processing, such as promotional messages.
  4. To request erasure of data that we are not legally required to retain.
  5. To raise a grievance about how your data has been handled.

Please note that we cannot delete records we are obliged to preserve under SEBI regulations, and that withdrawing consent for essential processing may mean we can no longer provide the service. To exercise any of these rights, write to us using the contact details below.

8. The Research Sultan Mobile App

This section applies in addition to the rest of this policy when you use the Research Sultan mobile app on Android or iOS. It describes the app-specific data we collect and the service providers we rely on.

  1. Account registration: when you sign up we collect your mobile number, a username, your name and a password, which is stored only as a one-way hash. A one-time password is sent to your mobile number on WhatsApp to verify it; to deliver it we share your mobile number with Meta Platforms, Inc. through the WhatsApp Business Platform.
  2. PAN verification (Cashfree): to onboard you as a client, the app asks for your full name, date of birth, PAN and email address. We send your name, date of birth and PAN to Cashfree Payments India Private Limited (Secure ID), which checks them against Income Tax Department records and returns the result. We store your PAN with the verification result and display it to you only in masked form.
  3. Client consent by Aadhaar eSign (Cashfree and eMudhra): SEBI requires a signed client consent and Most Important Terms and Conditions before research services begin. The app prepares this document with your name, PAN, date of birth, email address, the time you accepted it and the IP address used, and sends it to Cashfree's eSignature service. You sign it with an Aadhaar-based one-time password on the eSign provider's secure page, and the digital signature is issued by eMudhra Limited, a Certifying Authority licensed under the Information Technology Act, 2000. We do not receive or store your Aadhaar number or the OTP. We receive and keep the signed consent document and the signer confirmation returned with it.
  4. Payments (Cashfree): subscription fees paid in the app are collected through Cashfree's hosted checkout. We share your name, mobile number, the plan and the amount with Cashfree to create the order. Card, UPI and net-banking details are entered on Cashfree's page and never reach our servers. We receive only the payment status, amount and reference number.
  5. Push notifications (Firebase): if you allow notifications, the app registers a device push token with our server. We use it with Firebase Cloud Messaging (Google), and Apple or Expo push services where applicable, to deliver research updates, polls and messages. The token identifies your device, not you personally. It is deleted when you delete your account, and you can stop notifications at any time in your device settings.
  6. Photos you attach: photos or screenshots you attach in the app, for example in chat or when submitting a proof, are uploaded to and stored on our server together with any caption, your name and mobile number. They are used only for the purpose for which you submitted them and for record-keeping. If you expressly consented to marketing use when submitting a proof, we may show it in our promotional material. You can withdraw that consent by contacting us.
  7. Messages: direct messages and broadcasts exchanged through the app are stored on our server, because SEBI requires us to keep records of client communications.
  8. Deleting your account: you can delete your account at any time, either from the account section inside the app or by using the Delete App Account form on this website, where you confirm with your login details. Deletion removes your name, mobile number, email address and password from your account, disables your login, deletes your push tokens and in-app notifications, and cancels any active subscription. Signed consent, KYC and payment records are retained for the period set out in section 6, as SEBI requires, and are then destroyed.

9. Third-Party Links

This website links to external sites including SEBI, SCORES, SMART ODR, BSE and our official social media and Telegram channels. We are not responsible for the privacy practices or content of those sites, and we encourage you to read their privacy policies.

10. Minors

Our services are not directed at persons under 18 years of age and we do not knowingly collect their personal data. If you believe a minor has provided us with personal data, please contact us and we will delete it.

11. Changes to This Policy

We may update this Privacy Policy to reflect changes in law, regulation or our practices. The revised version will be posted on this page with an updated date, and material changes will be notified on the website or by email. Continued use of our services after such a change indicates your acceptance of it.

12. Contact and Privacy Grievances

For any question, request or grievance relating to your personal data, please contact:

We aim to acknowledge privacy grievances promptly and resolve them within the timelines set out in our Grievance Redressal policy. If you are not satisfied with our response, you may escalate through SEBI SCORES or the SMART ODR portal.

Investments in the securities market are subject to market risks. Please read all related documents carefully before investing. Research reports do not carry any assurance of profit or return.