Privacy Policy

How Probulls Stockbroking Private Limited collects, uses, stores and protects your personal data.

Last Updated: May 2025 | Effective Date: May 21, 2025
This policy is published in compliance with the Digital Personal Data Protection Act, 2023 (DPDP Act), DPDP Rules 2025, SEBI regulations, and applicable data protection laws. It governs the processing of personal data by Probulls Stockbroking Private Limited ("Probulls", "we", "us"), a SEBI-registered stock broker (Reg. No.: INZ000210932) with its registered office at Chatterjee International Center, 5th Floor, Unit No. 9, 33A, Jawaharlal Nehru Road, Kolkata – 700071.

1. Data We Collect

We collect the following categories of personal data ("Personal Data") when you use our services or interact with us:
• Identity & KYC Data: Name, PAN, Aadhaar number, date of birth, photograph, signature, nationality.
• Contact Data: Residential and correspondence address, email address, mobile number.
• Financial Data: Bank account details, income details, net worth, demat account number, trading history, fund balances.
• Technical Data: IP address, browser type, device information, cookies and usage data when you visit our website.
• Communication Data: Records of correspondence with us (emails, phone calls, support tickets).
• Compliance Data: Politically Exposed Person (PEP) status, FATCA/CRS declarations, PMLA risk categorisation data.

2. Lawful Basis and Purpose of Processing

We process your Personal Data on the following lawful bases:
• Contractual necessity: Account opening, KYC, order execution, trade confirmation, fund settlement, depository services.
• Legal obligation: PMLA/AML compliance, SEBI reporting, Income Tax reporting, exchange disclosures, FATCA/CRS obligations.
• Consent (freely given, specific, informed, unambiguous): Marketing communications, newsletters, research reports — you may withdraw consent at any time.
• Legitimate interest: Fraud prevention, cybersecurity, improving our services, dispute resolution.
We do not use your Personal Data for any purpose beyond what is stated above without your explicit consent.

3. Data Sharing and Disclosure

We may share your Personal Data with the following categories of recipients:
• Regulators and Exchanges: SEBI, NSE, BSE, CDSL, FIU-IND, Income Tax Department — as required by law.
• Technology Service Providers: Cloud hosting, trading platform vendors, KYC/eKYC service providers — under data processing agreements.
• Banks and Payment Systems: For fund transfers, margin collection and settlement.
• Auditors and Legal Advisors: For compliance and legal purposes under confidentiality obligations.
We do not sell, rent or commercially exploit your Personal Data. We do not share data with third parties for their own marketing purposes without your explicit consent.

4. Data Retention

We retain your Personal Data for the following periods:
• KYC and account records: 8 years from account closure (as required by PMLA).
• Trade records and contract notes: 5 years from date of transaction.
• Communications and correspondence: 5 years.
• Website usage data (logs): 90 days.
• Marketing consent records: Until consent is withdrawn plus 3 years.
After the applicable retention period, data is securely deleted or anonymised.

5. Your Rights as a Data Principal

Under the DPDP Act, 2023, you have the following rights:
• Right to Access: Request a summary of Personal Data held about you and the purposes of processing.
• Right to Correction: Request correction of inaccurate or incomplete Personal Data.
• Right to Erasure: Request deletion of Personal Data (subject to legal retention obligations).
• Right to Grievance Redressal: Lodge a complaint with our Data Protection Officer or with the Data Protection Board of India.
• Right to Withdraw Consent: Withdraw consent for marketing communications at any time without affecting the lawfulness of prior processing.
• Right to Nominate: Nominate another person to exercise rights in case of death or incapacity.
To exercise any of these rights, contact: compliance@probulls.in

6. Your Rights as a Data Principal

Our website uses cookies for the following purposes:
• Strictly Necessary: Session management, security tokens — these cannot be disabled.
• Analytics: Anonymous usage statistics to improve the website (requires consent).
• Marketing/Preferences: Personalisation cookies (requires consent).
You may manage cookie preferences via the cookie consent banner on your first visit, or by adjusting your browser settings. Withdrawing consent for non-essential cookies does not affect site functionality.

7. Data Security

We implement appropriate technical and organisational measures to protect your Personal Data against unauthorised access, disclosure, alteration or destruction. These include:
• SSL/TLS encryption for data in transit.
• Access controls and role-based permissions for data access.
• Regular security audits and vulnerability assessments.
• Incident response procedures per CERT-In Direction (April 2022) — reportable incidents reported within 6 hours.
• SEBI Cybersecurity & Cyber Resilience Framework (CSCRF) compliance.

8. Contact — Data Protection Officer

For privacy-related queries, requests or complaints:
Data Protection Officer / Compliance Officer
Samrendra Tibarewalla
Probulls Stockbroking Private Limited
Chatterjee International Center, 5th Floor, Unit No. 9, 33A, Jawaharlal Nehru Road, Kolkata – 700071
Email: compliance@probulls.in
Phone: +91 98310 01983

If your concern is not resolved, you may escalate to the Data Protection Board of India (once operational under the DPDP Act, 2023) or to SEBI SCORES 2.0 for investment-related matters.

9. Updates to This Policy

We may update this Privacy Policy periodically to reflect changes in law, our practices, or our services. Material changes will be communicated via email or a prominent notice on our website. The date of the last update is shown at the top of this page. Continued use of our services after updates constitutes acceptance of the revised policy.