Terms and Conditions
TERMS AND CONDITIOND FOR SERVICE
THE FOLLOWING terms of service MUST BE READ IN ITS ENTIRETY BEFORE PURCHASING/ordering AND/OR USING ANY INFORMATION, PRODUCTS, AND SERVICES CONTAINED ON the pbshruti.com website.
The website, pbshruti.com (the “Website”) is owned, controlled and operated by Mrs PB Shruti (“Research Analyst”), who is registered with the Securities and Exchange Board of India (SEBI) as a research analyst having Security & Exchange Board of India (SEBI) Registration Number INH000008358 and is enlisted with Bombay stock Exchange (BSE) under Enlistment Number 5446. By accessing or using this the website, you are agreeing to be bound by all the terms and conditions provided in this agreement below.
By accessing this Site, you agree to adhere to the terms of service established by Research Analyst, as well as all applicable laws and regulations. You also acknowledge that you are solely responsible for complying with any relevant local laws. If you do not consent to these terms, you are prohibited from using or accessing this Website. Research Analyst reserves the right to amend or update the terms and conditions of this agreement at any time by publishing the changes or the revised Agreement on this Website. These terms do not in any way modify the conditions outlined in any other written agreements you may have with Research Analyst concerning other products or services.
MANDATORY TERMS AND CONDITIONS
Most Important Terms and Conditions (MITC): [forming part of Annexure A of SEBI circular]
These terms and conditions, and consent thereon are for the research services provided by the Research Analyst (RA) and RA cannot execute/carry out any trade (purchase/sell transaction) on behalf of, the client. Thus, the clients are advised not to permit RA to execute any trade on their behalf.
The fee charged by RA to the client will be subject to the maximum of amount prescribed by SEBI/ Research Analyst Administration and Supervisory Body (RAASB) from time to time (applicable only for Individual and HUF Clients).
Note:
The current fee limit is Rs 1,51,000/- per annum per family of client for all research services of the RA.
The fee limit does not include statutory charges.
The fee limits do not apply to a non-individual client / accredited investor.
RA may charge fees in advance if agreed by the client. Such advance shall not exceed the period stipulated by SEBI; presently it is one (1) year. In case of pre-mature termination of the RA services by either the client or the RA, the client shall be entitled to seek refund of proportionate fees only for unexpired period.
Fees to RA may be paid by the client through any of the specified modes like cheque, online bank transfer, UPI, etc. Cash payment is not allowed. Optionally the client can make payments through Centralized Fee Collection Mechanism (CeFCoM) managed by BSE Limited (i.e. currently recognized RAASB).
The RA is required to abide by the applicable regulations/ circulars/ directions specified by SEBI and RAASB from time to time in relation to disclosure and mitigation of any actual or potential conflict of interest. The RA will endeavour to promptly inform the client of any conflict of interest that may affect the services being rendered to the client.
Any assured/guaranteed/fixed returns schemes or any other schemes of similar nature are prohibited by law. No scheme of this nature shall be offered to the client by the RA.
The RA cannot guarantee returns, profits, accuracy, or risk-free investments from the use of the RA’s research services. All opinions, projections, estimates of the RA are based on the analysis of available data under certain assumptions as of the date of preparation/publication of research report.
Any investment made based on recommendations in research reports are subject to market risks, and recommendations do not provide any assurance of returns. There is no recourse to claim any losses incurred on the investments made based on the recommendations in the research report. Any reliance placed on the research report provided by the RA shall be as per the client’s own judgement and assessment of the conclusions contained in the research report.
The SEBI registration, Enlistment with RAASB, and NISM certification do not guarantee the performance of the RA or assure any returns to the client.
For any grievances:
Step 1: the client should first contact the RA using the details on its website or following contact details: (RA to provide details as per ‘Grievance Redressal / Escalation Matrix’)
Step 2: If the resolution is unsatisfactory, the client can also lodge grievances through SEBI’s SCORES platform at www.scores.sebi.gov.in
Step 3: The client may also consider the Online Dispute Resolution (ODR) through the Smart ODR portal at https://smartodr.in
Clients are required to keep contact details, including email id and mobile number/s updated with the RA at all times.
The RA shall never ask for the client’s login credentials and OTPs for the client’s Trading Account Demat Account and Bank Account. Never share such information with anyone including RA.
Disclosure of Minimum Mandatory Terms and Conditions to Clients (MMTC)
Availing the research services: By accepting delivery of the research service, the client confirms that he/she has elected to subscribe the research service of the Research Analyst (RA) at his/her sole discretion. RA confirms that research services shall be rendered in accordance with the applicable provisions of the RA Regulations.
Obligations on Research Analyst: RA and client shall be bound by SEBI Act and all the applicable rules and regulations of SEBI, including the RA Regulations and relevant notifications of Government, as may be in force, from time to time.
Client Information and KYC: The client shall furnish all such details in full as may be required by the RA in its standard form with supporting details, if required, as may be made mandatory by RAASB/SEBI from time to time. RA shall collect, store, upload and check KYC records of the clients with KYC Registration Agency (KRA) as specified by SEBI from time to time.
Standard Terms of Service: The consent of client shall be taken on the following understanding:
“I / We have read and understood the terms and conditions applicable to a RA as defined under regulation 2(1)(u) of the SEBI (Research Analyst) Regulations, 2014, including the fee structure.
I/We are subscribing to the research services for our own benefits and consumption, and any reliance placed on the research report provided by research analyst shall be as per our own judgement and assessment of the conclusions contained in the research report.
I/We understand that –
Any investment made based on the recommendations in the research report are subject to market risk.
Recommendations in the research report do not provide any assurance of returns.
There is no recourse to claim any losses incurred on the investments made based on the recommendations in the research report.”
Declaration of the Research Analyst that:
It is duly registered with SEBI as a RA pursuant to the SEBI (Research Analysts) Regulations, 2014 and its registration details are: (registration number, registration date);
It has registration and qualifications required to render the services contemplated under the RA Regulations, and the same are valid and subsisting;
Research analyst services provided by it do not conflict with or violate any provision of law, rule or regulation, contract, or other instrument to which it is a party or to which any of its property is or may be subject;
The maximum fee that may be charged by RA is ₹1.51 lakhs per annum per family of client.
The recommendations provided by RA do not provide any assurance of returns.
Additionally, if RA is an individual, declaration that, it is not engaged in any additional professional or business activities, on a whole-time basis or in an executive capacity, which interfere with/influence or have the potential to interfere with/influence the independence of research report and/or recommendations contained therein.
Consideration and Mode of Payment: The client shall duly pay to RA, the agreed fees for the services that RA renders to the client and statutory charges, as applicable. Such fees and statutory charges shall be payable through the specified manner and mode(s)/ mechanism(s).
Risk Factors: The RA provides investment research and analysis based on publicly available data and reasonable assumptions. However, investments in securities involve inherent risks, including but not limited to market fluctuations, economic conditions, regulatory changes, and unforeseen events that may impact the value of investments. Investors are strongly advised to conduct their own due diligence and consult with a financial advisor before making investment decisions. The RA shall not be liable for any financial loss or adverse outcomes resulting from reliance on research reports, recommendations, or market analysis.
Conflict of Interest: The RA shall disclose any financial interest, shareholding, or other material relationships with companies covered in their research reports, including but not limited to investment banking relationships, advisory services, and any direct or indirect compensation received. Such disclosures shall be made in a clear and prominent manner in accordance with SEBI guidelines to ensure transparency and investor protection. The RA shall take appropriate steps to mitigate conflicts of interest, including maintaining independence in research reporting, avoiding biased recommendations, and implementing internal controls to prevent undue influence on research analysis. Investors are encouraged to review these disclosures and consider them when evaluating research recommendations.
Termination of Service and refund of fees: Disclosure that the RA may suspend or terminate rendering of research services to client on account of suspension/ cancellation of registration of RA by SEBI and shall refund the residual amount to the client.
In case of suspension of certificate of registration of the RA for more than 60 (sixty) days or cancellation of the Research Analyst registration, Research Analyst shall refund the fees, on a pro rata basis for the period from the effective date of cancellation/ suspension to end of the subscription period.
Grievance Redressal and Dispute resolution:
Any grievance related to:
nonreceipt of research report or
missing pages or inability to download the entire report, or
any other deficiency in the research services provided by RA, shall be escalated promptly by the client to the person/employee designated by RA, in this behalf (RA to provide name and e-mail ID of the designated person/employee).
The RA shall be responsible to resolve grievances within 7 (seven) business working days or such timelines as may be specified by SEBI under the Research Analyst Regulations.
Research Analyst shall redress grievances of the client in a timely and transparent manner. Any dispute between the Research Analyst and his client may be resolved through arbitration or through any other modes or mechanism as specified by SEBI from time to time.
Additional clauses: All additional voluntary clauses added by the Research Analyst should not be in contravention with rules/ regulations/ circulars of SEBI. Any changes in such voluntary clauses/document(s) shall be preceded by a notice of fifteen (15) days.
Mandatory notice: Clients shall be requested to go through Do’s and Don’ts while dealing with Research Analyst as specified in SEBI master circular no. SEBI/HO/MIRSD-POD- 1/P/CIR/2024/49 dated May 21, 2024 or as may be specified by SEBI from time to time.
Optional Centralised Fee Collection Mechanism: Research Analyst Shall provide the guidance to their clients on an optional ‘Centralised Fee Collection Mechanism for IA and RA’ (CeFCoM) available to them for payment of fees to Research Analyst.
PRODUCTS
This Website offers certain products for sale (the “Products”). Research Analyst provides Research and Recommendation services on a monthly subscription basis, designed to assist and enable prospective clients/clients in making informed decisions regarding their engagement with these services before investing.
By placing an order for Products through this Website, you agree to the terms outlined in this Agreement. Unless you notify the Research Analyst or their representative of your wish to opt out of further direct communications and solicitations, you consent to continue receiving emails and call solicitations from the Research Analyst or their designated representative. If you wish to opt out of future solicitations, you must send an email to shruti.pb14@gmail.com.
The Research Analyst retains proprietary rights and trade secrets related to the services provided. You are prohibited from copying, reproducing, reselling, or redistributing any product provided by the Research Analyst. The Website holds rights to its trademarks, trade dress, and specific webpage layout.
WEBSITE
Content and its Intellectual property:
The primary focus of this Website is its Content and Intellectual Property. This Website provides essential information through paid subscriptions about Research and Recommendation services, designed to assist and enable prospective clients/clients in making informed decisions about engaging with these services before investing. The content and information regarding Research and Recommendation services are protected under the intellectual property laws of India. Unauthorized use of this material may infringe upon copyright, trademark, or other applicable laws. You acknowledge that your use of the content on this Website is solely for personal, non-commercial purposes.
Any links to third-party websites are provided solely for your convenience. The Research Analyst does not endorse the content of any such third-party websites, and if you choose to access them, you do so at your own risk.
Use of Website:
The Research Analyst is not responsible for any damages resulting from the use of this Website by anyone. You agree not to use the Website for any unlawful purposes. Specifically, you agree to:
Comply with all applicable local, state, national, and international laws and regulations in your use of the Website (including intellectual property laws).
Refrain from interfering with or disrupting the use and enjoyment of the Website by other users.
Avoid reselling or redistributing material found on the Website.
Abstain from engaging, directly or indirectly, in the transmission of spam, chain letters, junk mail, or other types of unsolicited communication.
Not defame, harass, abuse, or disrupt other users of the Website.
License:
By using this Website, you are granted a limited, non-exclusive, non-transferable right to use the content and materials on the Website in connection with your normal, non-commercial, use of the Website. You may not copy, reproduce, transmit, distribute, or create derivative works of such content or information without express written authorization from the Research Analyst.
RESEARCH SERVICES:
Acknowledgement of Risk:
Trading and investing in the stock market involve risks, including the potential for partial or complete capital loss. The Research Analyst does not guarantee profits or returns.
Clients acknowledge they are fully aware of the risks involved and take complete responsibility for all their trading or investment decisions.
Nature of Services:
The Research Analyst provides research reports and recommendations based on fundamental and technical analysis. These are strictly informational and do not constitute personalized investment advice.
Final decisions on trading and investment, including the number of lots or stocks, rest solely with the client.
Accuracy of Service:
Any accuracy level communicated (whether written, verbal, or through advertisements) is indicative and not guaranteed. Accuracy may vary based on market conditions.
Liability:
Clients take full responsibility for the outcomes of their trading and investing activities and agree not to hold the Research Analyst or its employees liable for any financial losses.
Confidentiality:
The Research Analyst does not request or manage clients’ Demat/Trading account credentials. Clients must ensure the confidentiality of their login details.
Subscription:
The subscription fee is exclusively for research alerts and does not involve any stock market investments made by the Research Analyst on behalf of the client.
Declaration of Independent Decision making:
Clients confirm they are not using borrowed funds or third-party capital for trading or investing activities.
No longer action for losses:
Clients agree that losses incurred from trades based on the Research Analyst’s services will not lead to legal action against the firm, its employees, or affiliates.
The research Analyst provides general buy, sell, or hold recommendations designed for a broad audience, not tailored to individual clients.
Accuracy & Profitability:
The Research Analyst does not guarantee the accuracy, profitability, or success of any research recommendations. These recommendations are strictly informational and not personalized investment advice.
Research alerts provide transparency with clear entry prices, stop losses, and target levels.
Client Responsibility:
The decision to act on any recommendation is at the client’s sole discretion.
Client must evaluate their risk tolerance and financial situation before trading.
Risk Awareness:
Acknowledge that stock market trading involves substantial risk and accept full responsibility for their trading outcomes.
No Assurance of Returns:
The Research Analyst does not offer guaranteed or fixed returns from its research services, clients are advised to exercise caution and diligence in their trading decisions.
Compliance with SEBI regulations:
All recommendations and regulations are compliant with SEBI guidelines for Research Analyst.
UASAGE OF THIRD-PARTY DATA & PLATFORMS
Definition of third-party data:
For the purposes of this Agreement, “Third-Party Data” refers to any data, information, reports, or materials sourced from external platforms or providers. This includes but not limited to Moneycontrol, Screener, or similar third-party sources used in the preparation of research reports and related content.
Citation of Sources:
The Research Analyst ensures that all Third-Party Data utilized in research reports is properly cited and attributed to the respective platform or source.
Citations will include the name of the platform or provider and the date on which the data was accessed or retrieved. For example: “Data sourced from [Platform Name] on [Date].”
Acknowledgment and Client Responsibility:
The Research Analyst acknowledges the use of Third-Party Data and declares that such data is utilized solely for the preparation of research deliverables for the client’s informational purposes.
The client agrees to acknowledge the limitations of Third-Party Data and assumes responsibility for verifying its suitability for their intended use.
Intellectual property Rights and Usage Restriction:
All Third-Party Data remains the intellectual property of the respective data provider or platform. The client agrees not to reproduce, redistribute, or use Third-Party Data for any purpose beyond the scope of the engagement without obtaining appropriate permissions from the respective data providers.
The Research Analyst affirms that all intellectual property rights of the original research report belong exclusively to the Research Analyst, except for data sourced from third-party platforms, which remain the property of the respective data providers.
Indemnification:
The client agrees to indemnify and hold harmless the Research Analyst against any claims, damages, or liabilities arising from the misuse, unauthorized distribution, or improper citation of Third-Party Data.
The Research Analyst shall indemnify the client against any claims or liabilities resulting from the improper use of Third-Party Data, including infringement of intellectual property rights due to failure to cite the source or obtain necessary permissions.
COPYRIGHT & NO-RETRANSMISSION OF INFORMATION
The Website, including its design, layout, and the information contained within, is the valuable and exclusive property of the Research Analyst or expert with whom the Company has an agreement. This Agreement does not transfer or assign any ownership rights of the Website or its contents to you or any other individual or entity.
You are prohibited from copying, reproducing, modifying, distributing, transmitting, publishing, or creating derivative works of any material from the Website without explicit written consent from the Research Analyst or the authorized owner. Any unauthorized use may result in legal action and potential penalties under applicable intellectual property laws.
Additionally, any attempt to decompile, reverse-engineer, or otherwise extract proprietary codes, algorithms, or any intellectual property associated with the Website is strictly forbidden.
DISCLAIMER AND WARRANTIES
The materials on Site are provided on an “as is” and “as available” basis. The Research Analyst makes no warranties, whether expressed or implied, and disclaims all other warranties including but not limited to implied warranties or conditions of merchantability, fitness for a particular purpose, or non-infringement of intellectual property or other violation of rights.
The Research Analyst shall not be held accountable for the accuracy, reliability, performance, completeness, comprehensiveness, correctness, functionality, continuity, or timeliness of the information, data, or any other content available on this Site.
The Research Analyst does not warrant that:
materials on the Site are accurate, or complete, or up to date.
The results derived from the use of the products or services will meet expectations or deliver guaranteed outcomes.
Any Defects, error, or omissions in the products, services, or materials will be identified and corrected.
LIMITATION OF LIABILITY
The Research Analyst’s ENTIRE LIABILITY, AND YOUR EXCLUSIVE REMEDY, IN LAW, IN EQUITY, OR OTHWERWISE, WITH RESPECT TO THE WEBSITE CONTENT AND PRODUCTS AND ANY BREACH OF THIS AGREEMENT, SHALL BE LIMITED TO THE AMOUNT YOU PAID, EXCLUDING SHIPPING AND HANDLING COSTS, FOR PRODUCTS PURCHASED VIA THE WEBSITE.
The Research Analyst is not responsible or liable, whether directly or indirectly, for any losses or damages sustained as a result of investments made, investments not made, or any actions taken or not taken. This includes, but is not limited to:
Fluctuations in the prices of shares, derivatives, or bonds.
Changes in currency exchange rates.
Diminution in the NAVs (Net Asset Values).
Reductions in dividends or income.
Lost profits or lost opportunities, among other possible outcomes.
Additionally, the Research Analyst assumes no responsibility for the improper or delayed functioning of external websites or software for which access may have been provided to the user.
Users should note that certain jurisdictions may not permit the limitation or exclusion of liability for incidental or consequential damages. Therefore, some of the above limitations may not apply to you.
INDEMNIFICATION
You agree to release, indemnify, defend, and hold harmless the Research Analyst, along with its contractors, agents, employees, officers, directors, shareholders, affiliates, and assigns, from any and all liabilities, claims, damages, costs, and expenses, including reasonable attorneys’ fees and expenses, arising from or related to:
This Agreement or the breach of your warranties, representations and obligations under this Agreement;
The Website content or your use of the Website content;
The Products or your use of the Products (including Trial Products);
Any intellectual property or other proprietary right of any person or entity;
Your violation of any provision of this Agreement; or
Any information or data you supplied to the Research Analyst.
If the Research Analyst is threatened with legal action or is sued by a third party, they may request written assurances from you regarding your obligation to indemnify them. Failure to provide such assurances may constitute a material breach of this Agreement.
The Research Analyst reserves the right to participate in the defense of any third-party claim related to your use of the Website content or Products, with counsel of their choosing and at their expense. The Research Analyst will also cooperate reasonably in your defense of such claims at your request and expense.
However, you are solely responsible for defending the Research Analyst against any claim and must obtain the Research Analyst’s prior written consent before agreeing to any settlement related to such claims.
The terms outlined in this provision will survive any termination or cancellation of this Agreement, as well as your use of the Website or Products.
PRIVACY
The Research Analyst is committed to safeguarding user privacy while providing access to essential information on the website pbshruti.com . PB Shruti collects personal information (name, email, phone) via email communications and non-personal information (browser type, location) through cookies to provide and improve our services. Your information may be shared with third-party service providers as necessary for service delivery and marketing purposes. Detailed information on how user data is collected, used, and protected, please refer to the Privacy Policy full document in ANNEXURE-A, which is incorporated by reference into this Agreement.
AGREEMENT TO BE BOUND
By accessing this Website or placing an order for Products, you confirm that you have read, understood, and agree to be bound by this Agreement, including all terms and conditions outlined on this Website.
GENERAL
Force Majeure:
The Research Analyst shall not be deemed in default under this Agreement or held responsible for any cessation, interruption, or delay in fulfilling its obligations due to events beyond its control, including but not limited to earthquakes, floods, fires, storms, natural disasters, acts of God, war, terrorism, armed conflicts, labour strikes, lockouts, or boycotts.
Cessation of Operation:
The Research Analyst reserves the right to cease operation of the website and distribution of products at any time, at its sole discretion, and without prior notice to users.
Entire Agreement:
This Agreement represents the entire understanding between you and the Research Analyst, superseding any prior agreements or understandings related to the subject matter contained herein.
Effect of Waiver:
The failure of the Research Analyst to exercise or enforce any right or provision within this Agreement shall not constitute a waiver of such rights or provisions. Should any provision of this Agreement be deemed invalid by a court of competent jurisdiction, the remaining provisions shall remain in full force and effect. The court will strive to interpret the invalid provision in alignment with the parties’ original intentions.
Statute of Limitation:
You agree that any claim or cause of action arising out of or related to the use of the Website, Products, or this Agreement must be initiated within one (1) year from when the claim or cause of action arose. Failure to do so will render the claim or cause of action permanently barred.
Termination:
The Research Analyst reserves the right, at its sole discretion, to terminate your access to the Website if it believes you have breached any terms or conditions of this Agreement. Upon termination, you will no longer have access to the Website, and the Research Analyst may cancel any outstanding orders for Products without prior notice. It further reserves the right to implement measures to prevent unauthorized access to the Website. Unless explicitly terminated by the Research Analyst, this Agreement will remain in effect indefinitely.
Assignment: You are prohibited from assigning your rights or obligations under this Agreement to any other party. The Research Analyst, however, may assign its rights and obligations under this Agreement at its sole discretion and without providing prior notice to you.
REFUND POLICY
No partial month refunds are provided under any circumstances. Eligible pro-rata refunds apply only for subscription-based equity newsletters. Mutual Funds newsletters are one-time downloads with no refunds after purchase. KYC validation failure entitles clients to full refunds, with subscription reinstated after KYC completion. No trial periods are currently offered. Cancellation occurs through non-payment/non-consent at subscription end or through written request. The Research Analyst offers no guarantees on investment results. Duplicate payments will be refunded within seven (7) to ten (10) working days. Force majeure circumstances exempt the Research Analyst from obligations. Services may be modified with reasonable notice; substantial changes may qualify for refunds. All refund requests must be submitted in writing with required details and will be processed within 14 working days through the original payment method. Subscribing constitutes acceptance of this policy, which is subject to updates. For complete details, please refer to the full Refund Policy document in ANNEXURE-B.
ARTIFICIAL INTELLIGENCE (AI) SERVICES-USE AND RESPONSIBILITY:
Definition: For the purpose of this agreement, “AI Tool” refers to any software, application, or algorithm powered by Artificial Intelligence that assists in various tasks such as language processing, grammar correction, content generation, reference image creation, or other automated functions. AI Tools do not include software used solely for the execution of non-analytical or purely mechanical tasks
Use of AI tools: The Research Analyst utilizes AI tools strictly for limited purposes, including report writing (such as grammar checks and rephrasing), reference image generation, and data representation or content writing.
The interpretation and analysis of data are exclusively performed by the Research Analyst without reliance on any AI tools.
AI tools are not employed for the analysis of data or formulation of recommendations to clients.
All work involving AI tools is subject to human oversight and critical review to ensure accuracy, reliability, and adherence to professional standards.
Client data protection:
The Research Analyst commits to safeguarding the confidentiality of all client data and agrees not to use such data to train any AI models or algorithms without the prior written and express consent of the client.
Client data will only be utilized for purposes explicitly agreed upon in writing and within the scope of the professional engagement.
Intellectual property compliance:
The Research Analyst ensures that the usage of AI tools does not infringe upon any third-party Intellectual property rights.
The Research Analyst shall indemnify and hold harmless the client against any claims, damages, or liabilities arising from any infringement of third-party intellectual property rights caused by the usage of AI tools.
Liability:
The Research Analyst shall not be liable for any damages arising from inaccuracies, errors, or omissions resulting from the usage of AI tools, provided such damages are not due to wilful misconduct or gross negligence. The liability for any damages arising from the use of the AI tools shall be limited to the amount of fees paid by the Client for the relevant services. Further, the Research Analyst shall not be liable for any indirect, incidental, special, consequential or exemplary damages, including damages for loss of profit, goodwill, use, or data or other losses.
Human Oversight: The Research Analyst ensures comprehensive human oversight of all outputs produced by AI tools.
All AI-assisted content is critically reviewed by the Research Analyst to ensure its compliance with relevant laws, regulations, and professional standards.
Any errors or discrepancies identified in AI outputs are corrected promptly to maintain the accuracy and integrity of the work.
SEBI Guidelines:
The Research Analyst affirms that the use of AI tools is in strict compliance with SEBI guidelines and regulations, including the circular titled “Assigning Responsibility for the Use of Artificial Intelligence Tools by Market Infrastructure Institutions, Registered Intermediaries, and Other Persons Regulated by SEBI” issued in November 2024.
Client Acknowledgement: Client Acknowledgment By engaging with the services of the Research Analyst, the client acknowledges and accepts the scope and limitations of the usage of AI tools as outlined in this clause.
KNOW YOUR CUSTOMER (KYC)
B Shruti is fully committed to adhering to all prevailing regulatory requirements related to Know Your Customer (KYC) norms. As part of our commitment to compliance and transparency, we ensure that all necessary KYC details are collected, verified, and maintained in accordance with applicable laws and regulations. Our rigorous adherence to these standards is designed to uphold the highest levels of integrity and security in our operations, safeguarding both our clients and our business. In case the KYC is not updated in any KRA then the client is requested to avail a refund from the Research Analyst by sending an email to customer-care@pbshruti.com. The client is requested to complete the KYC using any other intermediary such as a broker, CAMS, bank, etc. and then reapply for the services.
Note: The services shall be held until the KYC is completed. This is in line with the regulatory compliance requirement.
SERVICE LICENSE
License Grant and Restriction: Consent is granted for using the strategies and/or indicators provided on the Site for private, non-commercial transitory observation only. This is the grant of a license, not a transfer of title, and under this license, you shall not:
change or reproducing the materials;
use the materials for any commercial purpose, or for any public display (commercial or non-
commercial);
attempt to decompile or reverse engineer the indicator/strategy sold through this Website;
remove any copyright or other proprietary notations from the materials; or
transfer the materials to another person or “mirror” the materials on any other server; or
redistribute, publish, broadcast, circulate or email to any friends, clients, investors, or sell
third party as a part of any commercial service, including trading advisory services or live chat rooms.
Termination of License: This license will automatically terminate if any of the stated limitations are violated. Additionally, the Research Analyst may terminate this license at any time, at their sole discretion. Upon termination, you are required to cease viewing the materials and destroy any downloaded copies in your possession, whether in electronic or printed format.
Disclaimer of Liability: The information Provided on this website serves as a resource for members and subscribers and does not constitute legal or financial advice. No assurances, claims, promises, or guarantees are made regarding the accuracy, completeness, or adequacy of the information provided or linked to on this Website.
MODIFICATIONS
These terms of service, along with its supplements, may be updated periodically. The Research Analyst will indicate the changes by updating the “last updated” date to notify users of revisions. It is your responsibility to review these terms regularly and stay informed about any updates.
By continuing to use this Website after any updates, you agree to be bound by the most current version of these Terms of Service.
GOVERNING LAW/DISPUTE RESOLUTION
This Website originates from the Bengaluru, Karnataka. This Agreement will be governed by the laws of the State of Karnataka, India without regard to its conflict of law principles.
Neither you nor the Research Analyst shall initiate or prosecute any suit, proceeding, or claim to enforce the provisions of this Agreement, to recover damages for breach or default of this Agreement, or for any other matter arising from this Agreement, except in courts located in the State of Karnataka.
By using this Website or purchasing Products, you expressly consent to the jurisdiction and venue of such courts in connection with any actions, suits, proceedings, or claims arising out of or in connection with this Agreement. Furthermore, you waive any right to a trial by jury concerning any disputes related to this Agreement or associated documents.
ANNEXURE-A
PRIVACY POLICY
This is the Privacy Statement and Policy (“Privacy Policy”) for PB Shruti and its affiliates (“PB Shruti”). This Privacy Policy was last updated in March 2025.
PB Shruti understands the importance of your privacy and is committed to protecting the personal information you provide as you access and use materials on www.pbshruti.com (the “Site”), including subscription pages or other websites or applications that link to this Privacy Statement. Any information you submit to PB Shruti in response to an email request or other outreach will also be handled in accordance with this Privacy Statement.
PB Shruti may amend this Privacy Statement at its sole discretion from time to time. To ensure that you remain informed, material changes to the Privacy Statement will be updated and reflected here. This Site may include links to external websites that are not governed by this Privacy Statement. PB Shruti assumes no responsibility for the privacy practices of such third-party websites. We encourage you to review the privacy policies of any external sites before submitting information.
The website www.pbshruti.com is owned and operated by PB Shruti, with a focus on utilizing Fundamental and Technical Analysis to understand Financial Markets. The website is committed to safeguarding your privacy by keeping your personal information private, secure, and protected. This Privacy Policy provides you with the necessary details to help you decide if and how you wish to use the website’s services. It also outlines how your information is collected, stored, and used.
1. Consent to Use Information
This Policy is a legally binding agreement between you (“you” or “user”) and PB Shruti and its affiliates (“us”). By visiting, accessing or using the Website, or providing information to us in any other format, you agree to and accept the terms of this Privacy Policy, as amended from time to time. You also consent to the collection and use of your information as described in this Policy.
We strongly encourage you to review this privacy Policy carefully and to periodically revisit it to stay informed about its terms and any subsequent changes. IF YOU DO NOT AGREE TO THE TERMS OF THIS PRIVACY POLICY, PLEASE STOP USING THE SERVICE IMMEDIATELY.
2. What Information Do We Collect
We collect two types of information from you:
a) Non-Personal Information – Non-Personal Information refers to data that does not directly identify you. This includes:
Your approximate location.
The type of browser you are using.
The pages you visit before or after accessing our Site, URLs, clicks, landing pages, and the duration spent on each page.
This data is collected to enhance security, monitor how the Site is used, track affiliate activity, and calculate payments to partners.
We also use “cookies” to collect this type of information. Cookies are small text files stored on your device that help websites remember your preferences.
b) Personal Information – “Personal Information” includes data that may be sensitive or private, such as your:
Name
Gender
Phone Number
Email address or mailing address
IP Address
All Personal Information is collected through email communication with the PB Shruti, as there is no account creation functionality on the website.
3. What is the Purpose of Collecting this Information
To access our services, users may be required to provide certain personal information via email. While responses to questions regarding Personal Information are optional, fields marked with an asterisk (*) in our email communications are mandatory. Providing information in optional fields is not required to access the services and information on the Site unless explicitly indicated. However, failure to provide mandatory information or providing incorrect Personal Information may limit our ability to fully deliver the requested services or information.
The information we collect serves the following purposes:
a) Non-Personal Information:
Collected for research and statistical purposes to enhance the quality, security, and usability of our services.
Used to analyse user preferences, usage patterns, and interactions to develop, customize, and improve our offerings.
Helps process your requests for information and provide relevant services and offers.
We collect Non-Personal Information using cookies in collaboration with third-party partners. Cookies are small text files stored on your device to gather data about your interactions with the Site.
b) Personal Information:
Enables us to provide features, services, capabilities, offers, and marketing materials tailored to your interests.
Supports us in offering technical assistance and user support.
Legal References: The definitions outlined in the Terms and Conditions apply to this Privacy Policy unless stated otherwise.
IN ADDITION TO THIS POLICY, PLEASE REVIEW OUR TERMS AND CONDITIONS, WHICH ARE INCORPORATED HEREIN BY REFERENCE, AS WELL AS ANY OTHER POLICIES THAT MAY BE COMMUNICATED TO YOU FROM TIME TO TIME.
4. Who Else Receives this Information
Additionally, Personal and Non-Personal Information may be shared with third parties in the following circumstances:
When required to provide, maintain, or improve our services and operations.
In collaboration with third-party advertisers and affiliates to present you with advertisements and offers that we, or third parties, believe may interest you.
a) Third-Party Recipients: We share your Personal and Non-Personal Information with:
Third parties providing services to the PB Shruti to enable us to deliver our Service, including email service providers and data verifiers.
Third parties assisting the PB Shruti in the operation of the Website.
Auditors, contractors, or advisers involved in auditing the PB Shruti ‘s business processes.
Potential purchasers or investors in the PB Shruti ‘s business.
b) Data Processing and Legal Compliance: Any processing by third-party service providers (“Recipients”) will, where required by law, be governed by a data processing agreement. This agreement ensures your statutory data protection rights under applicable laws, such as the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011. The Recipients are obligated to:
Maintain the confidentiality of your information.
Use your Personal Information exclusively for the purposes outlined by PB Shruti.
c) Special Cases for Disclosure: We may share your Personal Information and other relevant information if we have a valid reason to believe that it is necessary to:
Comply with applicable laws, regulations, subpoenas, or court orders.
Detect, prevent, or address fraud, security concerns, policy violations, or technical issues.
Protect the rights, property, or safety of the PB Shruti, its partners, affiliates, users, or the public.
5. Use of Information and Data Retention
We collect and use your personal information to:
Provide our services.
Send you marketing offers that we believe may interest you.
Fulfill other purposes as outlined in this Privacy Policy.
Your personal data will be retained as long as necessary to manage and deliver our services. If you choose to share your information with us, it may be disclosed to third parties for the purposes you intended, and we will treat your consent as implied.
By providing your phone number, you consent to being contacted through various communication methods, including phone calls, WhatsApp, SMS, or other channels, for notifications, marketing, or promotional purposes.
pbshruti.com may share, rent, or sell your personal information to third parties, including non-affiliated companies, for service delivery or agreed-upon purposes. Additionally, we may disclose your data in the following situations:
To comply with legal obligations, such as court orders or legal processes.
To protect our legal rights.
To investigate illegal activities or fraud.
In the event that pbshruti.com merges with or is acquired by another entity.
6. Right of Access, Rectification, Cancellation and Objection
You hold the right to:
Access: Review the Personal Information we have about you.
Rectification: Request corrections or updates to any inaccurate or incomplete Personal Information.
Cancellation: Request the removal of your Personal Information from our records.
Objection: Object to the processing or usage of your Personal Information in specific scenarios.
How to Exercise These Rights: To exercise your rights, you must submit a written request to PB Shruti via email with the subject line: “Denying Access to Personal Information.” In your request, please clearly specify the nature of the action you wish to take, whether it’s access, rectification, cancellation, or objection.
Commitment to Compliance: the PB Shruti will address your requests promptly and in a professional manner, in accordance with applicable laws and regulations, including but not limited to the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011.
Limitations and Legal Requirements: Certain legal requirements or obligations may limit our ability to fulfil all types of requests (e.g., where information is required for compliance with laws or legitimate business purposes). However, we are dedicated to balancing your rights with legal and operational obligations to ensure fairness and transparency.
Additional Provisions: In cases where your Personal Information is removed or processing is restricted upon request, PB Shruti may retain limited data as permitted by law, such as for compliance, audit, or record-keeping purposes.
7. Security and Confidentiality
The PB Shruti is committed to treating your Personal Information with strict confidentiality. Data is stored on servers equipped with industry-standard security measures designed to prevent accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access.
Despite our efforts to implement robust security measures, it is important to note that no system can be entirely secure. As such, we cannot guarantee the absolute security of your information, which may, in rare cases, be accessed, disclosed, modified, or destroyed.
You acknowledge that sharing your information with us is done at your own risk, and we encourage you to take precautions when disclosing sensitive information online.
8. Links to Other Websites
This Privacy Policy applies exclusively to the Service and to our web tools that are integrated or implemented on third-party websites. It does not extend to third-party websites linked to our website.
Third-party websites or services may have their own privacy policies, and we strongly encourage you to review them carefully. The inclusion of a link to a third-party website or service on our website does not constitute an endorsement or recommendation of that website or service.
Please note that third-party websites may contain content or services that are illegal, inappropriate, or offensive to some individuals. Before engaging with such third-party sites, services, or making purchases, we advise you to thoroughly read and understand their privacy policies, terms and conditions, and product warranties.
By accessing and using third-party sites, you knowingly and voluntarily assume all associated risks, including those related to the purchase of products or services. You acknowledge and agree that we bear no liability for any actions, content, or outcomes related to your use of third-party websites or services.
9. Assignment
We reserve the right to transfer or assign your information to any third party without prior notice or the need for your consent in the event of a change of control, consolidation, merger, acquisition, or reorganization.
You acknowledge that, in circumstances such as bankruptcy, insolvency, or receivership, we may have limited or no control over the usage and transfer of your Personal Information. In such events, your data may be subject to the policies and practices of the acquiring or restructuring entity.
10. Updates to this policy
This Privacy Policy is subject to periodic modifications. To stay informed, please refer to the “Last Modified Date” heading at the bottom of this document to verify when the Privacy Policy was last updated.
Any changes to this Privacy Policy will take effect once the revised version is posted on the Website. By continuing to use the Website, the Service, or by providing personal information following such updates, you signify your acceptance of the revised Privacy Policy.
11. Privacy & Cookies
What are cookies? Cookies are small pieces of information sent to your browser and stored on your computer’s hard drive, mobile phone, or other device. Cookies may be:
First-party cookies: Placed directly on your device by the website you are visiting.
Third-party cookies: Placed on your device through the website but managed by third parties, such as Google.
Purpose of Cookies: We use cookies and similar technologies to collect information, including personal data as outlined in this Notice. Cookies are used for the following purposes:
Necessary Cookies: These are essential for using key features of our website. These cookies do not collect Personal Data.
Functionality Cookies: These enhance usability and allow for personalized features.
Analytics Cookies: These track the usage and performance of our website and services.
Advertising Cookies: These deliver advertisements that are relevant to your interests, limit ad frequency, and remember your visits to the website. Advertising cookies are generally placed by advertising networks with the website operator’s consent. These cookies may also link to site functionality provided by such networks.
Analytics Cookies: Our analytics cookies allow us to monitor and analyse how the Website is used. These cookies store:
Randomly assigned user identification numbers.
Pages visited, time spent on each page, and clicks.
Demographic information such as the visitor’s country, IP address, device, and operating system. They help us differentiate between users and sessions, identify new users, track traffic sources, and throttle request rates to limit data requests within a specific timeframe.
Consent and Preferences: When you arrive on our website, a pop-up message will appear, seeking your consent to place cookies on your device. You can review details about the types of cookies used and set your preferences before clicking “OK.” Once consent is provided, the message will not appear on future visits.
Withdrawal of Consent: If you or another user of your device wishes to withdraw consent at any time, this can be done easily through the cookie settings available on the Website.
12. Children’s Privacy
Our services are not intended for children under the age of 18. We do not knowingly collect personal information from children under 18. If we become aware that we have collected personal information from a child under 18 without verification of parental consent, we will take steps to remove that information from our servers.
13. Governing Law
This Privacy Policy and any disputes arising out of or in connection with its interpretation, implementation, or enforcement shall be governed by and construed in accordance with the laws of the State of Karnataka, India, without regard to its conflict of law principles.
Any legal actions or proceedings related to this Privacy Policy shall be brought exclusively in the courts located in Karnataka, India. By using this Website, you consent to the jurisdiction and venue of these courts and waive any objections to such jurisdiction or venue.
Last Modified Date: March 2025
ANNEXURE-B
REFUND POLICY
1. Refund Conditions
Partial month refunds will not be provided under any circumstances. Clients are eligible for pro-rata refunds for the remaining period after deducting any partial month charges. This policy applies only for subscription-based equity newsletters.
MF newsletter is a one-time download product and thus no refund shall be issued once the product is purchased and downloaded. Research Analysts are required to ensure KYC compliance of all clients, and KYC validation process is done after the purchase of the subscription. In case the KYC validation fails for the client, the client is eligible for a full refund. The subscription will be reinitiated only after the client successfully completes their KYC requirements.
2. Trial Periods
Currently, no trial periods are offered, either free or paid. Clients are encouraged to carefully review service descriptions and sample reports before subscribing.
3. Subscription Renewal and Cancellation
The Research Analyst currently does not use automated payment gateways for recurring payments. At the end of the subscription period, the Research Analyst will send a reminder link for payment with a UPI code which will be valid until the current subscription expires.
Cancellation will occur under two circumstances:
If the client does not provide consent for continuation of service and/or does not make payment before the subscription ends, resulting in automatic cancellation. To continue the subscription after expiry of service, the client must complete the entire onboarding process again, including KYC.
If a communication for request for cancellation is sent to customer-care@pbshruti.com before the expiry of the subscription.
For mutual fund newsletters, the service terminates immediately after the user is given access to the latest edition. In order to download the mutual fund newsletter again, the client must complete the onboarding process as well as payment again.
4. No Guarantee of Results
The Research Analyst does not guarantee any specific results for clients based on the information, products, or services provided.
All services are provided for informational purposes only, and the client must exercise independent judgment when using the services.
No rights can be derived from the information provided on the Research Analyst’s website or services.
5. Duplicate Transactions
In the event of duplicate payments for a single transaction, the excess amount will be refunded via the original payment source within seven (7) to ten (10) working days.
6. Force Majeure
The Research Analyst shall not be liable for any delay or failure to perform obligations under this agreement due to circumstances beyond reasonable control, including but not limited to acts of God, natural disasters, pandemic, epidemic, war, civil unrest, terrorism, labour disputes, or government regulations.
In such events, no refunds will be issued for services already rendered.
7. Modification of Services
The Research Analyst reserves the right to modify, suspend, or discontinue any part of the services offered at any time with reasonable notice to clients.
In the event of a substantial and material change to the service that fundamentally alters what was originally purchased, clients may be eligible for a pro-rata refund for the unused portion of their subscription, subject to the other terms of this policy.
8. Communication of Refund Requests
All refund requests must be submitted in writing to customer-care@pbshruti.com.
Refund requests must include the client’s full name, subscription details, and reason for requesting a refund.
The Research Analyst will review all refund requests within seven (7) business days and communicate the decision to the client via email.
9. Processing of Approved Refunds
Approved refunds will be processed within fourteen (14) working days of approval.
Refunds will be issued through the original payment method whenever possible.
Any taxes or fees that cannot be recovered by the Research Analyst will be deducted from the refund amount.
10. Acceptance of Policy
By subscribing to any service offered by the Research Analyst, clients acknowledge that they have read, understood, and agreed to this Refund Policy.
This Refund Policy may be updated from time to time, and the most current version will be posted on the Research Analyst’s website.