Privacy
Privacy Policy
Komal Mirani (“Research Analyst”, “we”, “us” or “our”) is a SEBI
Registered Research Analyst bearing Registration No.
INH000028200.
We respect your privacy and are committed to handling personal information
responsibly, transparently and securely. This Privacy Policy explains how
information relating to you may be collected, used, stored, processed,
shared and protected when you visit our website, subscribe to our research
services, communicate with us, access research reports or use any other
services or digital platforms operated by us (collectively, the “Services”).
Privacy at a Glance
Information We May Collect
Depending upon how you interact with us, we may collect different categories of information.
Personal & Contact Information
- Name
- Email address
- Mobile number
- Residential or correspondence address
- Other information voluntarily provided when you contact us
KYC & Regulatory Information
Where required for providing research services or complying with applicable SEBI or other regulatory requirements, we may collect information and documents necessary for client identification, KYC, onboarding, record keeping and compliance.
This may include information contained in identification, address, PAN, KYC or other regulatory records, to the extent required or permitted by applicable law.
Subscription & Transaction Information
- Service or subscription selected
- Subscription period
- Amount paid
- Transaction reference
- Billing information
- Payment status
Payments may be processed through third-party payment service providers. We do not necessarily receive or store your complete debit card, credit card, UPI credentials or banking authentication information when such information is processed directly by the relevant payment provider.
Communications & Service Records
We may retain communications and interactions with clients or prospective clients where required for providing Services, resolving queries, maintaining records or complying with regulatory obligations.
Website & Technical Information
- IP address
- Browser and device type
- Operating system
- Pages visited
- Date and time of access
- Referring pages or websites
- Website usage and interaction information
- Cookie and similar technology information
Why We Collect & Use Your Information
We may process personal information where reasonably necessary to:
- Provide and administer our research services;
- Complete client onboarding and KYC requirements;
- Verify client information;
- Manage subscriptions and payments;
- Deliver research reports, recommendations and service communications;
- Respond to queries, requests, complaints and grievances;
- Maintain records of client and prospective-client interactions where applicable;
- Provide regulatory, operational and service-related communications;
- Improve website functionality and user experience;
- Detect, investigate or prevent fraud, misuse or security incidents;
- Maintain internal business and compliance records;
- Comply with applicable SEBI and other legal or regulatory requirements; and
- Respond to lawful requests from courts, regulators or governmental authorities.
Consent & Choice
Where consent is required under applicable law, we may seek your consent before collecting or using personal information for the relevant purpose.
You should provide information that is accurate, complete and up to date.
Where processing is based on consent, you may request withdrawal of that consent, subject to applicable law and any legal or regulatory requirement that requires continued retention or processing of certain information.
Withdrawal of consent may affect our ability to provide Services where the relevant information is necessary for providing those Services.
KYC & Regulatory Records
As a SEBI Registered Research Analyst, we may be required to collect, verify, maintain or preserve certain client information and records under applicable securities laws, regulations, circulars or other regulatory requirements.
Accordingly, certain information may need to be retained even after you discontinue our Services.
Where a legal or regulatory requirement applies, such requirement will prevail over a request for deletion or erasure to the extent required by law.
Payments
Payments for our Services may be facilitated through banks, payment gateways or other authorized payment service providers.
Such providers may collect and process payment information in accordance with their own terms and privacy policies.
We encourage you to review the privacy and security practices of the relevant payment provider before submitting sensitive financial information.
Cookies & Similar Technologies
Our website may use cookies and similar technologies to ensure functionality, remember preferences, understand website usage, improve performance and enhance security.
These technologies may collect information relating to your browser, device, website interactions and session.
You may be able to control or disable cookies through your browser settings. However, disabling certain cookies may affect the functionality or performance of parts of the website.
Where required, appropriate consent mechanisms may be used for non-essential cookies.
How We May Share Information
We do not sell or rent your personal information.
We may, however, share limited personal information where reasonably necessary with:
- Technology and website service providers;
- Hosting and cloud-service providers;
- Payment gateways and payment processors;
- KYC or verification service providers;
- Communication and customer-support providers;
- Professional advisers, auditors or compliance service providers;
- Regulatory or supervisory bodies;
- Courts, governmental authorities or law-enforcement agencies where legally required; and
- Other service providers necessary for operating our Services.
Where third-party service providers process personal information on our behalf, we expect such information to be handled only for the relevant purpose and subject to appropriate confidentiality, privacy and security obligations.
Third-Party Websites & Services
Our website or communications may contain links to third-party websites, platforms or services.
Once you leave our website or interact with a third-party service, that third party's privacy policy and terms may apply.
We do not control the privacy practices of independent third parties and encourage you to review their privacy policies before providing personal information.
Data Retention
We retain personal information only for as long as reasonably necessary for the purpose for which it was collected or for such longer period as may be required under applicable legal, regulatory, accounting, audit or compliance requirements.
Different categories of information may therefore be retained for different periods.
Where information is no longer required and no legal or regulatory obligation requires its continued retention, we may securely delete, anonymise or otherwise dispose of it in accordance with our applicable processes.
Data Security
We take reasonable administrative, technical and organizational measures designed to protect personal information against unauthorized access, disclosure, alteration, misuse, loss or destruction.
Access to personal information is intended to be limited to persons and service providers who reasonably require such access for legitimate business, operational or regulatory purposes.
However, no internet transmission, electronic system or method of storage can be guaranteed to be completely secure. Accordingly, we cannot guarantee absolute security of information transmitted or stored electronically.
Your Privacy Rights
Subject to applicable law and regulatory requirements, you may request to:
- Access information relating to your personal data;
- Correct or update inaccurate or incomplete information;
- Request deletion or erasure where legally permissible;
- Withdraw consent where processing is based upon consent;
- Raise a grievance regarding the handling of personal information; or
- Seek information regarding the manner in which your information is being handled.
Certain requests may be subject to identity verification and applicable legal or regulatory restrictions.
We may be unable to delete information that we are legally or regulatorily required to retain.
Artificial Intelligence
We may use Artificial Intelligence (“AI”) or technology-assisted tools in connection with certain research, operational, analytical or administrative activities.
Where such tools are used, we endeavour to use them responsibly and in accordance with applicable regulatory, confidentiality, data-protection and information-security requirements.
Use of AI does not remove our responsibility for complying with obligations applicable to us as a Research Analyst.
Children's Privacy
Our research services are not intended to be independently subscribed to or used by persons who are not legally eligible to enter into the relevant relationship or transaction.
We do not knowingly seek to collect personal information from children except where permitted and appropriately authorized under applicable law.
If you believe that personal information relating to a child has been provided to us inappropriately, please contact us.
Legal & Regulatory Disclosure
We may disclose personal information where such disclosure is required or permitted:
- Under applicable law;
- Pursuant to a court order or legal process;
- In response to a lawful request from SEBI or another regulator;
- For investigation or prevention of fraud, unlawful activity or security incidents;
- To protect our legal rights or the rights and safety of others; or
- For compliance, audit, inspection or enforcement purposes.
Only information reasonably necessary for the applicable purpose should be disclosed.
Changes to This Privacy Policy
We may revise this Privacy Policy periodically to reflect changes in our Services, technology, business practices or applicable legal and regulatory requirements.
The revised Privacy Policy will be published on this website with an updated “Last Updated” date.
Where required by applicable law, we may provide additional notice or seek fresh consent for material changes.
Privacy Queries & Grievances
If you have a question, request or grievance regarding this Privacy Policy or the handling of your personal information, you may contact:
Komal Mirani
SEBI Registered Research Analyst
SEBI Registration No. INH000028200
Email: komal@komalmirani.com
Support: helpdesk@komalmirani.com
Phone: +91 7974365568
Registered Address:
Flat No. 401,
Muktagiri Colony, Kourinbhatha,
Durg, Chhattisgarh – 491441, India.
We will endeavour to review and address privacy-related requests or grievances in accordance with applicable legal and regulatory requirements.
Investment in securities market is subject to market risks. Read all the related documents carefully before investing.
Registration granted by SEBI, enlistment with BSE and certification from NISM in no way guarantee performance of the intermediary or provide any assurance of returns to investors.
Most Important Terms & Conditions
These Most Important Terms & Conditions (“MITC”) govern the research services provided by Komal Mirani, a SEBI Registered Research Analyst. Clients are requested to read and understand these terms carefully before availing any research service.
Scope of Research Services
These terms and conditions, and the consent thereon, are for the research services provided by the Research Analyst (“RA”).
The Research Analyst cannot execute or carry out any trade, including any purchase or sale transaction, on behalf of the client.
Fees
Fees charged by the Research Analyst shall be fair and reasonable and shall remain subject to the maximum amount prescribed by the Securities and Exchange Board of India (“SEBI”) and/or the Research Analyst Administration and Supervisory Body (“RAASB”) from time to time.
For Individual and Hindu Undivided Family (“HUF”) clients, other than accredited investors, the current maximum fee prescribed for research services is ₹1,51,000 per annum per family of client for all research services of the Research Analyst.
In the case of non-individual clients, accredited investors, and institutional investors seeking recommendations of a proxy adviser, applicable fee-related terms and conditions may be governed through bilaterally negotiated contractual terms.
Advance Fees, Termination & Refund
Where agreed by the client, the Research Analyst may charge fees in advance. Such advance shall not exceed fees for a period of one year, subject to applicable SEBI and RAASB requirements from time to time.
In the event of premature termination of research services in accordance with the agreed terms and conditions, the client shall be entitled to a proportionate refund of fees for the unexpired period.
Modes of Payment & CeFCoM
Fees may be paid by clients through permitted modes such as cheque, online bank transfer, UPI or such other banking channels as may be permitted under the applicable regulatory framework.
Clients may also use the optional Centralised Fee Collection Mechanism for IA and RA (“CeFCoM”), where the facility is available and the Research Analyst has opted for the mechanism.
CeFCoM facilitates payment of research fees through a designated platform administered under the recognised Administration and Supervisory Body framework. BSE Limited is presently the recognised RAASB and manages the CeFCoM mechanism for Research Analysts.
The Research Analyst shall provide clients with appropriate guidance regarding the availability and use of CeFCoM in accordance with applicable SEBI and RAASB requirements.
Conflict of Interest
The Research Analyst shall abide by applicable regulations, circulars and 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 Research Analyst shall endeavour to promptly inform the client of any conflict of interest that may affect the research services being rendered to the client.
Prohibition on Assured or Guaranteed Returns
Any assured, guaranteed or fixed-return scheme, or any other scheme of a similar nature, is prohibited by law.
No Guarantee of Returns, Profits or Accuracy
The Research Analyst cannot guarantee returns, profits, accuracy or risk-free investments arising from the use of the Research Analyst's research services.
Opinions, projections and estimates contained in research material are based on the analysis of available information and assumptions prevailing as of the date of preparation or publication of the relevant research report.
Market conditions, prices, volatility, liquidity, company-specific developments and other relevant factors may subsequently change.
Investment Risk & Client Responsibility
Any investment or trading decision made on the basis of recommendations contained in research reports is subject to market risks. Research recommendations do not provide any assurance of returns.
There is no recourse to claim losses incurred on investments made on the basis of recommendations contained in a research report.
Any reliance placed upon a research report provided by the Research Analyst shall be based on the client's own judgement and assessment of the conclusions contained therein.
SEBI Registration & RAASB Enlistment
Komal Mirani is registered with SEBI as a Research Analyst under Registration No. INH000028200.
The Research Analyst is enlisted with the recognised Research Analyst Administration and Supervisory Body (“RAASB”). BSE Limited is presently recognised by SEBI as the RAASB.
SEBI registration, enlistment with RAASB and NISM certification do not guarantee the performance of the Research Analyst or provide any assurance of returns to the client.
Grievance Resolution
For any complaint relating to research services, including non-receipt of research reports, service deficiencies or other client grievances, the client should first approach the Research Analyst.
Clients may initially raise their grievance with:
If the grievance remains unresolved or the client is dissatisfied with the response, the matter may be escalated to:
Komal Mirani
SEBI Registered Research Analyst
Email: komal@komalmirani.com
Phone: +91 7974365568
Registered Address:
Flat No. 401, Muktagiri Colony, Kourinbhatha,
Durg, Chhattisgarh – 491441, India.
If the resolution provided by the Research Analyst is
unsatisfactory, the client may lodge a grievance through the
SEBI Complaints Redress System (“SCORES”).
Visit SEBI SCORES
The client may also consider the Online Dispute Resolution
mechanism through the SMART ODR platform in accordance with
the applicable regulatory framework.
Visit SMART ODR
Keeping Client Information Updated
Clients are required to keep their contact information, including email address and mobile number, updated with the Research Analyst at all times.
Clients should promptly communicate any change in information that may be relevant to their research-service relationship or applicable regulatory requirements.
Protection of Trading, Demat & Banking Credentials
The Research Analyst shall never ask for the client's login credentials or OTPs relating to the client's Trading Account, Demat Account or Bank Account.
Never disclose your trading password, demat password, banking password, PIN, OTP or other confidential authentication information to anyone, including the Research Analyst or any person claiming to represent Komal Mirani.
Impersonation & Cyber Fraud
Clients and investors should remain vigilant against fake websites, impersonation accounts, unauthorized Telegram or WhatsApp groups, fraudulent social-media profiles, unauthorized payment requests and persons falsely claiming association with Komal Mirani.
Before making any payment or acting on any communication, investors should verify that the communication originates from an official channel of the Research Analyst.
Suspected online financial fraud may be reported through the Government of India's National Cyber Crime Reporting Portal or through the national cyber financial-fraud helpline 1930.
Changes in Applicable Regulatory Requirements
These terms shall be read together with the SEBI (Research Analysts) Regulations, applicable SEBI circulars, master circulars, directions and requirements issued by RAASB from time to time.
Where any fee limit, payment mechanism, advance-fee requirement, refund provision, grievance mechanism or other regulatory requirement is amended by SEBI or RAASB, the applicable regulatory requirement prevailing at the relevant time shall apply.
Acceptance of Terms
Clients availing research services are required to read and understand the applicable terms and conditions, including these Most Important Terms & Conditions, before commencement of the research-service relationship.
Appropriate client consent shall be obtained in accordance with applicable SEBI and RAASB requirements.
Refund & Cancellation Policy
Komal Mirani is committed to maintaining a fair and transparent approach
to fees, cancellations and refunds in accordance with the applicable
SEBI Research Analyst regulatory framework.
This policy explains when a client may discontinue a research service,
how refunds for an unexpired service period are treated, and circumstances
that do not independently give rise to a refund.
Refund Policy at a Glance
Cancellation of Research Services
A client may request premature termination or cancellation of research services in accordance with the terms and conditions governing the client relationship and the applicable SEBI and RAASB requirements.
Once a valid cancellation or termination request is processed, access to the relevant research service may cease in accordance with the effective termination date.
Any future renewal, where applicable and under the control of the Research Analyst, shall not be processed after effective cancellation.
Proportionate Refund for Unexpired Period
In the event of premature termination of research services in terms of the agreed terms and conditions, an eligible client shall be refunded the proportionate fees attributable to the unexpired period of the research service, in accordance with applicable SEBI requirements.
The refund relates to the unused or unexpired portion of the applicable research-service period. It is not calculated on the basis of whether individual recommendations generated profits or losses.
Market Performance Is Not a Basis for Refund
Research recommendations are subject to market risks and do not carry any assurance or guarantee of profit, return, accuracy or investment outcome.
A loss arising from an investment or trade, a recommendation not reaching an expected target, market volatility, adverse price movement or underperformance of a security does not by itself create an entitlement to a refund of fees already attributable to the period during which the research service was provided.
Fees Relating to an Expired or Completed Service Period
No proportionate refund is ordinarily due for a research-service period that has already expired or been fully completed.
Where only part of the agreed service period remains unexpired at the effective date of premature termination, the refund shall relate only to the eligible unexpired portion, subject to applicable regulatory requirements.
Advance Fees
Where agreed by the client, the Research Analyst may collect fees in advance subject to the period and conditions permitted by SEBI from time to time.
Under the presently applicable framework, advance fees may be collected for a period of up to one year, subject to the applicable client category and regulatory requirements.
Collection of fees in advance does not affect an eligible client's regulatory entitlement to a proportionate refund for the unexpired period upon premature termination.
Client Categories & Applicability
SEBI's fee-related provisions, including provisions relating to fee limits, advance fees, refunds and breakage fees, apply to Individual and Hindu Undivided Family (“HUF”) clients where such clients are not accredited investors.
In the case of non-individual clients, accredited investors and other client categories excluded under the applicable SEBI framework, fee-related terms may be governed by bilaterally negotiated contractual terms and applicable law.
How to Request Cancellation or Refund
A client wishing to terminate a research service or seek an eligible refund should submit the request through the official support channel.
To assist us in processing the request, clients should use their registered email address or mobile number and provide sufficient information to identify the applicable subscription or research service.
Refund Processing
Eligible refunds shall be reviewed and processed in accordance with the applicable SEBI and RAASB requirements and the terms governing the research service.
Where reasonably practicable, refunds shall be made through an appropriate banking or electronic payment channel. Additional information may be requested where necessary to verify the client, subscription or payment transaction.
Refund-Related Grievances
If a client has a grievance concerning cancellation or refund processing, the matter may first be raised with Customer Support and subsequently escalated to the Research Analyst.
Komal Mirani
SEBI Registered Research Analyst
Email: komal@komalmirani.com
Phone: +91 7974365568
Registered Address:
Flat No. 401, Muktagiri Colony, Kourinbhatha,
Durg, Chhattisgarh – 491441, India.
If the grievance remains unresolved, the client may use the grievance redressal mechanisms prescribed under the applicable SEBI framework, including SEBI SCORES and, where applicable, SMART ODR.
Regulatory Changes
This Refund & Cancellation Policy shall be read together with the SEBI (Research Analysts) Regulations, applicable SEBI circulars, master circulars and RAASB requirements, as amended from time to time.
If the applicable requirements relating to refunds, advance fees, client categories or termination are subsequently amended, the regulatory requirements prevailing at the relevant time shall apply.
Website Terms of Use
These Website Terms of Use govern your access to and use of this website, its content, research material, digital resources and related online services made available by Komal Mirani, a SEBI Registered Research Analyst.
Acceptance & Applicability
These Terms apply to all visitors, users, prospective clients and clients who access this website or any digital content made available through it.
By continuing to access or use the website, you acknowledge that you have read, understood and agreed to be bound by these Terms, subject to applicable law and regulatory requirements.
Nature of the Website & Services
This website provides information about research services, market-related content, research publications, regulatory disclosures, investor information and other material relating to the activities of the Research Analyst.
Nothing on this website should be interpreted as portfolio management, trade execution, discretionary account management, brokerage or any service that the Research Analyst is not authorised to provide.
Research Content & Market Risk
Research reports, market views, technical analysis, fundamental analysis, educational content and other information made available through the website are based on information, analysis and assumptions considered relevant at the time of preparation or publication.
Market conditions, prices, liquidity, volatility, company-specific developments and other factors may change after publication.
Client Responsibility
Users and clients remain responsible for their own investment and trading decisions and should evaluate research material in light of their own financial circumstances, objectives, risk tolerance and suitability.
Any reliance placed on research content shall be based on the user's or client's own judgement and assessment.
Intellectual Property
Unless otherwise stated, the content made available through this website, including text, graphics, layouts, logos, research reports, analysis, presentations, charts, images, videos, educational material and other proprietary content, belongs to or is lawfully used by Komal Mirani.
Such content may be protected by applicable copyright, trademark and other intellectual-property laws.
Personal Use & Restrictions on Redistribution
Research material supplied to a client is intended for the use of the entitled recipient unless expressly stated otherwise.
Without prior written authorization, users shall not reproduce, copy, republish, distribute, forward, upload, transmit, commercially exploit, resell or create derivative commercial material from proprietary research content made available by the Research Analyst.
User Conduct
When using this website, users agree to act lawfully and responsibly. Users shall not:
- misuse the website or attempt to gain unauthorized access to any system, account or restricted area;
- interfere with the security, operation or availability of the website;
- introduce malicious code, viruses or harmful technology;
- impersonate the Research Analyst or falsely claim association with Komal Mirani;
- use website content in a misleading, deceptive, unlawful or unauthorized commercial manner; or
- infringe the intellectual-property, privacy or other lawful rights of any person.
Subscriptions & Restricted Content
Certain research services, reports, digital resources or communication channels may be available only to eligible or subscribed clients.
Access credentials, private links or subscriber-only research content should not be shared with unauthorized persons.
The Research Analyst may restrict or discontinue access where there is reasonable evidence of misuse, unauthorized redistribution, fraud, violation of these Terms or other conduct inconsistent with applicable service terms or law.
Third-Party Websites & Platforms
This website may contain links to third-party websites, payment providers, communication platforms, social-media services, regulatory portals or other external services.
Such third-party services are operated independently and may be subject to their own terms, privacy policies and security practices. The inclusion of a link does not, by itself, constitute an endorsement of every statement, product or service offered by the third party.
Website Availability
Reasonable efforts may be made to maintain the availability, accuracy and security of the website; however, uninterrupted or error-free access cannot be guaranteed.
Website access may occasionally be interrupted because of maintenance, technical issues, third-party service failures, security measures or circumstances beyond reasonable control.
No Warranty
To the extent permitted by applicable law, the website and its content are made available on an “as is” and “as available” basis.
While reasonable care is taken in preparing research and website content, no representation or warranty is made that all information will at all times be complete, error-free, uninterrupted, current or suitable for every user's individual circumstances.
Limitation of Liability
To the extent permitted by applicable law, the Research Analyst shall not be liable for indirect, incidental, consequential or special losses arising solely from use of or inability to access this website.
Nothing in these Terms is intended to exclude, restrict or waive any right, remedy, duty or liability that cannot lawfully be excluded under applicable law, SEBI regulations or other regulatory requirements.
Cybersecurity & Impersonation
Users should remain vigilant against fake websites, fraudulent social media profiles, unauthorized Telegram or WhatsApp groups, impersonation attempts and fraudulent payment requests.
Privacy & Personal Information
The collection, use, storage and handling of personal information through this website is governed by the applicable Privacy Policy .
Client-Specific Regulatory Documents
Where a user becomes a client of the Research Analyst, the research relationship may additionally be governed by client-specific and regulatory documents, including:
- Most Important Terms & Conditions (MITC)
- Refund & Cancellation Policy
- Disclosures
- Investor Charter
- Grievance Redressal
Changes to These Terms
These Website Terms of Use may be revised from time to time to reflect changes in website functionality, business practices, legal requirements or regulatory obligations.
The latest version will be made available on this website together with an updated revision date.
Governing Law & Jurisdiction
These Terms shall be governed by and interpreted in accordance with the laws of India, subject to applicable securities laws, SEBI regulations, dispute-resolution mechanisms and other mandatory legal or regulatory requirements.
Subject to any applicable statutory or regulatory dispute-resolution mechanism, matters arising in relation to these Terms shall be subject to the jurisdiction of the competent courts in India.
Contact
For questions regarding these Website Terms of Use, you may contact:
Komal Mirani
SEBI Registered Research Analyst
SEBI Registration No.: INH000028200
Email: komal@komalmirani.com
Support: helpdesk@komalmirani.com
Phone: +91 7974365568
Registered Address:
Flat No. 401, Muktagiri Colony, Kourinbhatha,
Durg, Chhattisgarh – 491441, India.