Privacy Policy

Last Updated:
3 September 2026

This Privacy Policy (“Privacy Policy”) describes how Simple RA Solutions Pvt. Ltd. (“Simple RA Solutions”, “Company”, “we”, “us” or “our”) collects, receives, uses, stores, processes, discloses and protects information relating to users of www.simplyra.com, including its web application, mobile application, software, technology infrastructure and associated services (collectively, the “Platform” or “Simply RA”).

Simple RA Solutions Pvt. Ltd. operates Simply RA as a technology and software platform that enables registered and eligible Research Analysts and other permitted users to manage, publish, distribute, communicate and/or facilitate access to their research-related services and content through the Platform.

Simple RA Solutions Pvt. Ltd. is a technology platform provider and does not itself act as a Research Analyst, Investment Adviser, broker, portfolio manager or other regulated financial intermediary merely by operating the Platform.

Research reports, research analysis, recommendations, trading calls, opinions, content, services or other regulated services made available through the Platform are provided by the respective Research Analyst or other applicable service provider, who remains independently responsible for compliance with applicable laws, regulations and regulatory requirements.

This Privacy Policy forms part of and is incorporated into the Terms and Conditions governing your use of the Platform.

By accessing, registering on, browsing or otherwise using the Platform, or by voluntarily providing your Personal Data to us, you acknowledge that you have read and understood this Privacy Policy and agree to the collection, use, processing, storage and disclosure of your Personal Data as described herein, subject to applicable law.

If you do not agree with this Privacy Policy, you must discontinue use of the Platform.

1. DEFINITIONS

For the purposes of this Privacy Policy:

1.1 “Applicable Law”

means all applicable laws, rules, regulations, notifications, circulars, directions, orders and guidelines in force in India relating to privacy, data protection, information technology, cybersecurity, electronic communications, financial services and regulatory compliance, as applicable to the Platform and its users, including the Digital Personal Data Protection Act, 2023, the Digital Personal Data Protection Rules, 2025, the Information Technology Act, 2000, applicable rules made thereunder, and applicable SEBI requirements.

1.2 “Personal Data”

means any data about an individual who is identifiable by or in relation to such data, to the extent recognised under Applicable Law.

1.3 “Processing”

includes any operation or set of operations performed on Personal Data, including collection, recording, organisation, structuring, storage, alteration, retrieval, use, disclosure, transmission, sharing, restriction, erasure or destruction.

1.4 “User”

means any individual or entity accessing or using the Platform, including Research Analysts, their authorised personnel, subscribers, investors, customers, visitors and other permitted users.

1.5 “Research Analyst”

means a person or entity registered with or otherwise permitted by SEBI, as applicable, to provide research services and/or research-related services through the Platform.

2. INFORMATION WE COLLECT

Depending upon how you use the Platform, we may collect the following categories of information.

2.1 Information You Provide Directly

When you register, subscribe, communicate with us, use the Platform or otherwise interact with us, we may collect:

  • Full name;
  • Email address;
  • Mobile/telephone number;
  • Date of birth, where required;
  • Residential or correspondence address;
  • Gender, where voluntarily provided or legally required;
  • Login credentials and authentication information;
  • Profile information;
  • Photograph or profile image, where voluntarily uploaded;
  • Professional information;
  • Organisation/company details;
  • SEBI registration details and related regulatory information, where applicable;
  • PAN and other tax-related information, where required;
  • KYC information and documentation, where required;
  • Bank/payment information where necessary to process payments, settlements, refunds or payouts;
  • Information relating to subscriptions, transactions, invoices and payment history;
  • Communications and correspondence with us;
  • Information submitted through forms, support tickets, surveys, feedback or complaints; and
  • Any other information you voluntarily provide to us.

We may request additional information where reasonably necessary to provide particular Platform features, conduct verification, comply with Applicable Law, prevent fraud or satisfy regulatory or contractual requirements.

3. INFORMATION PROVIDED BY RESEARCH ANALYSTS

If you register or operate an account as a Research Analyst or other professional/service provider, we may collect and process additional information including:

  • Name and professional details;
  • SEBI registration number and registration status;
  • Regulatory and compliance information;
  • Registration certificates and supporting documents;
  • Business/organisation details;
  • Authorised-person details;
  • Professional contact information;
  • Bank and settlement information;
  • Subscription/product/service information;
  • Research-related content uploaded to the Platform;
  • Client/subscriber information provided by you in connection with your legitimate use of the Platform;
  • Transaction and subscription records;
  • Complaints, disputes and compliance-related information; and
  • Information reasonably necessary to support regulatory, audit, legal and compliance obligations.

Where you provide Personal Data of another individual to us, including information relating to your clients, subscribers, employees or representatives, you represent and warrant that you have the necessary authority, permission or lawful basis to provide such information to us and that you are entitled to instruct us to process such information for the relevant purpose.

4. INFORMATION COLLECTED AUTOMATICALLY

When you access or use Simply RA, we may automatically collect certain technical and usage information.

This may include:

  • Internet Protocol (“IP”) address;
  • Browser type and version;
  • Device type and model;
  • Operating system and version;
  • Application version;
  • Language preferences;
  • Time zone;
  • Device identifiers;
  • Advertising identifiers, where applicable;
  • Network information;
  • Referring and exit pages;
  • Pages, features and content accessed;
  • Date and time of access;
  • Session information;
  • Clickstream and interaction information;
  • Crash reports;
  • Diagnostic information;
  • Approximate location derived from IP address;
  • Log files; and
  • Other technical information generated through your use of the Platform.

We use this information primarily to operate, secure, maintain, analyse and improve the Platform and to detect unauthorised, fraudulent or abusive activity.

5. LOCATION INFORMATION

Where a feature of the Platform requires location information and you provide the relevant permission, we may collect location information from your device.

Depending upon the permissions granted by your device or browser, this may include precise location information or approximate location information.

We may also derive an approximate location from your IP address.

Location information may be used for purposes including:

  • Providing location-dependent functionality;
  • Security and fraud prevention;
  • Improving Platform functionality;
  • Analytics;
  • Regulatory or legal compliance; and
  • Providing services specifically requested by you.

You may withdraw location permissions through your device or browser settings. Certain features may become unavailable if location information is required for their operation.

6. DEVICE AND TECHNICAL INFORMATION

We may collect information about the device through which you access the Platform, including, where available:

  • Device manufacturer and model;
  • Operating system and version;
  • Browser/application information;
  • Unique device identifiers;
  • Mobile network information;
  • IP address;
  • Device configuration;
  • Network connection information;
  • Application version;
  • Security and diagnostic information;
  • Crash and performance information; and
  • Other technical information necessary to operate and secure the Platform.

We use this information to maintain Platform security, troubleshoot technical issues, understand usage patterns, prevent fraud and improve performance.

7. COOKIES AND SIMILAR TECHNOLOGIES

We may use cookies, pixels, SDKs, local storage and similar technologies to operate and improve the Platform.

These technologies may be used for:

  • Authentication and account management;
  • Maintaining login sessions;
  • Remembering preferences;
  • Security;
  • Fraud prevention;
  • Analytics;
  • Measuring Platform performance;
  • Understanding how users interact with the Platform; and
  • Providing relevant communications or marketing, where legally permitted.

You may be able to control certain cookies through your browser or device settings. Disabling certain cookies may affect the functionality of the Platform.

8. HOW WE USE PERSONAL DATA

We may process Personal Data for the following purposes:

8.1 Providing and Operating the Platform

Including to:

  • Create and manage accounts;
  • Authenticate users;
  • Provide Platform functionality;
  • Facilitate subscriptions and transactions;
  • Enable communication between users and Research Analysts;
  • Display profiles, research content and other information;
  • Provide customer support; and
  • Maintain and improve the Platform.

8.2 Payments and Transactions

We may process information necessary to:

  • Process payments;
  • Process refunds;
  • Facilitate settlements and payouts;
  • Maintain transaction records;
  • Generate invoices;
  • Detect suspicious transactions; and
  • Comply with payment, taxation and financial obligations.

Payment information may be processed by third-party payment processors and financial institutions. We may not directly store complete payment-card information where the relevant payment processor handles such information.

8.3 Identity Verification and KYC

Where required, we may process identity, KYC, PAN, regulatory and related information to:

  • Verify identity;
  • Verify eligibility;
  • Verify Research Analyst or professional credentials;
  • Prevent fraud;
  • Comply with legal and regulatory requirements; and
  • Maintain Platform integrity.

8.4 Research Analyst and Regulatory Compliance

Where applicable, information may be processed to facilitate compliance with applicable SEBI requirements and other regulatory obligations.

This may include maintaining records concerning:

  • Research Analyst registration;
  • Professional credentials;
  • User/subscriber relationships;
  • Transactions;
  • Communications;
  • Complaints;
  • Content;
  • Regulatory disclosures; and
  • Other information reasonably required for compliance.

Nothing in this Privacy Policy transfers the regulatory responsibilities of a Research Analyst to Simple RA Solutions Pvt. Ltd.

Each Research Analyst remains responsible for its own regulatory obligations, disclosures, suitability requirements, client communications and compliance under Applicable Law.

8.5 Security and Fraud Prevention

We may process Personal Data to:

  • Detect and prevent fraud;
  • Detect unauthorised access;
  • Protect accounts;
  • Investigate security incidents;
  • Prevent abuse of the Platform;
  • Protect users and our systems; and
  • Enforce our Terms and Conditions.

8.6 Communications

We may use Personal Data to send:

  • Transactional communications;
  • Account notifications;
  • Security alerts;
  • Service announcements;
  • Regulatory or compliance communications;
  • Support communications; and
  • Promotional or marketing communications, where permitted by Applicable Law and subject to applicable consent or opt-out requirements.

You may opt out of promotional communications using the unsubscribe mechanism provided in the communication or by contacting us.

8.7 Analytics and Platform Improvement

We may analyse usage and technical information to:

  • Understand Platform usage;
  • Improve products and services;
  • Develop new functionality;
  • Measure performance;
  • Diagnose technical problems; and
  • Improve user experience.

Where reasonably possible, analytics information may be aggregated or otherwise de-identified.

8.8 Legal and Regulatory Compliance

We may process and retain information where reasonably necessary to:

  • Comply with Applicable Law;
  • Respond to lawful requests from authorities;
  • Meet regulatory obligations;
  • Establish, exercise or defend legal claims;
  • Resolve disputes;
  • Enforce contractual terms; and
  • Protect our legal rights and interests.

10. YOUR CHOICE REGARDING INFORMATION

In certain circumstances, providing Personal Data is optional.

However, if you choose not to provide information that is reasonably necessary to:

  • create or maintain your account;
  • verify your identity;
  • process a transaction;
  • provide a requested service;
  • comply with legal or regulatory requirements; or
  • maintain Platform security,

we may be unable to provide the relevant functionality or service.

You are responsible for ensuring that information provided by you is accurate, complete and up to date.

11. INFORMATION RECEIVED FROM THIRD PARTIES

We may receive information from third parties, including:

  • Payment processors;
  • KYC/identity verification providers;
  • Authentication providers;
  • Analytics providers;
  • Research Analysts;
  • Business partners;
  • Service providers;
  • Publicly available sources;
  • Regulatory or governmental authorities; and
  • Other users, where permitted by Applicable Law.

Where a Research Analyst or other user provides Personal Data to us concerning another individual, that user is responsible for ensuring that such disclosure is lawful and appropriately authorised.

12. SHARING AND DISCLOSURE OF PERSONAL DATA

We do not sell Personal Data in the ordinary sense of the term.

We may disclose or provide access to Personal Data where reasonably necessary for lawful purposes, including to the following categories of recipients:

12.1 Research Analysts and Service Providers

Where necessary to provide functionality requested by you, including enabling you to access or subscribe to services, content or research provided by a Research Analyst.

12.2 Technology and Infrastructure Providers

Including providers of:

  • Cloud hosting;
  • Data storage;
  • Cybersecurity;
  • Authentication;
  • Communications;
  • Analytics;
  • Customer support;
  • Software infrastructure; and
  • Other technology services.

12.3 Payment and Financial Service Providers

Including payment gateways, banks, payment processors and other financial institutions involved in processing transactions.

12.4 Professional Advisers

Including lawyers, auditors, accountants, consultants and other professional advisers where reasonably necessary.

12.5 Governmental and Regulatory Authorities

Where disclosure is required or permitted by Applicable Law, including lawful requests from courts, regulators, law-enforcement authorities and other governmental bodies.

12.6 Corporate Transactions

Personal Data may be disclosed as reasonably necessary in connection with a merger, acquisition, restructuring, financing, sale of assets, business transfer or similar corporate transaction, subject to Applicable Law.

12.7 Protection of Rights and Security

We may disclose information where reasonably necessary to:

  • Protect the rights, property or safety of Simple RA Solutions;
  • Protect users or other persons;
  • Investigate fraud or abuse;
  • Enforce our Terms and Conditions; or
  • Prevent or address security incidents.

13. DATA SHARED WITH RESEARCH ANALYSTS

Simply RA is a technology platform that may facilitate interactions between users and Research Analysts.

When you voluntarily subscribe to, communicate with, purchase or otherwise interact with a Research Analyst through the Platform, certain information may be made available to that Research Analyst to the extent reasonably necessary to provide the relevant service.

Depending on the feature used, this may include:

  • Name;
  • Contact details;
  • Subscription information;
  • Transaction information;
  • Relevant account/profile information;
  • Communications;
  • Information submitted by you; and
  • Other information reasonably necessary for providing the requested service.

The Research Analyst receiving such information is independently responsible for its handling of Personal Data and for complying with Applicable Law.

You should review the privacy practices of the relevant Research Analyst where applicable.

14. PUBLICLY AVAILABLE INFORMATION

Information that you voluntarily publish through public-facing portions of the Platform may become accessible to other users or the public.

This may include:

  • Public profile information;
  • Name;
  • Professional information;
  • Research content;
  • Articles;
  • Reports;
  • Posts;
  • Reviews;
  • Comments; and
  • Other content that you intentionally make publicly available.

You should not publish Personal Data or confidential information that you do not wish to make publicly accessible.

Information voluntarily made publicly available may be copied, accessed or redistributed by third parties beyond our control.

15. SENSITIVE AND CONFIDENTIAL INFORMATION

You should not provide sensitive, confidential or unnecessary Personal Data through the Platform unless specifically requested or required for a legitimate purpose.

Where Applicable Law imposes enhanced obligations regarding particular categories of Personal Data, we will process such information in accordance with Applicable Law.

We do not intentionally seek to collect sensitive information unless it is reasonably necessary for a lawful and specified purpose.

16. CHILDREN'S DATA

The Platform is not intended to be used by children in circumstances where such use would violate Applicable Law.

Where Applicable Law requires verifiable parental consent or imposes additional requirements for processing the Personal Data of children, we will comply with those requirements.

If we become aware that Personal Data of a child has been collected in circumstances contrary to Applicable Law, we may take reasonable steps to delete or restrict such information.

If you believe that a child has provided Personal Data to us inappropriately, please contact us at support@simplyra.com.

17. DATA RETENTION

We retain Personal Data only for as long as reasonably necessary for the purposes for which it was collected or processed, including:

  • Providing the Platform;
  • Maintaining user accounts;
  • Processing transactions;
  • Meeting contractual obligations;
  • Complying with legal and regulatory requirements;
  • Maintaining financial and transaction records;
  • Resolving disputes;
  • Preventing fraud;
  • Enforcing our agreements; and
  • Protecting our legal rights.

Certain information may be required to be retained for prescribed periods under Applicable Law, regulatory requirements, accounting requirements, taxation requirements or other legitimate purposes.

Accordingly, deletion of your account does not necessarily result in immediate deletion of every record relating to you.

18. DELETION OF YOUR INFORMATION

You may request deletion of your account and/or Personal Data by contacting us at:

We will process deletion requests in accordance with Applicable Law.

Where there is no legal, regulatory, contractual, security or other lawful requirement to retain particular information, we will take reasonable steps to delete or anonymise such information.

We may retain certain information where necessary for:

  • Compliance with legal or regulatory obligations;
  • Prevention, detection or investigation of fraud;
  • Establishing, exercising or defending legal claims;
  • Financial, accounting or taxation requirements;
  • Security purposes;
  • Enforcement of contractual obligations; or
  • Other purposes permitted under Applicable Law.

19. YOUR DATA PROTECTION RIGHTS

Subject to Applicable Law and any applicable conditions or limitations, you may have rights relating to your Personal Data, including:

  • The right to obtain information about processing of your Personal Data;
  • The right to access information relating to your Personal Data;
  • The right to correction or updating of inaccurate or incomplete Personal Data;
  • The right to request deletion of Personal Data where legally permissible;
  • The right to withdraw consent where processing is based on consent;
  • The right to grievance redressal;
  • The right to nominate another individual to exercise applicable rights on your behalf, where provided under Applicable Law; and
  • Any other rights available under Applicable Law.

Requests may be submitted to:

We may require reasonable information to verify your identity and protect against fraudulent or unauthorised requests.

20. ACCURACY OF INFORMATION

You represent and warrant that the Personal Data and other information provided by you is accurate, complete and not misleading.

You must promptly update your information if it changes.

Simple RA Solutions shall not be responsible for consequences arising from inaccurate, incomplete, outdated or misleading information provided by you.

21. SECURITY OF PERSONAL DATA

We implement reasonable technical and organisational safeguards designed to protect Personal Data against unauthorised access, disclosure, alteration, destruction, loss or misuse.

These measures may include, as appropriate:

  • Access controls;
  • Authentication mechanisms;
  • Encryption or equivalent security measures;
  • Secure data transmission;
  • Logging and monitoring;
  • Network and application security;
  • Backup and recovery mechanisms;
  • Role-based access;
  • Security testing;
  • Incident management procedures; and
  • Employee and contractor access controls.

However, no electronic transmission, storage system or security measure can be guaranteed to be completely secure.

Accordingly, while we take reasonable measures to protect Personal Data, we cannot guarantee absolute security.

22. DATA BREACHES AND SECURITY INCIDENTS

In the event of a Personal Data breach or security incident, we will take steps required under Applicable Law, which may include:

  • Investigating and containing the incident;
  • Taking remedial measures;
  • Notifying relevant authorities where required;
  • Notifying affected individuals where required; and
  • Cooperating with lawful regulatory or governmental requirements.

23. INTERNATIONAL DATA TRANSFERS

Certain service providers engaged by us may process or store information outside India.

Where Personal Data is transferred outside India, we will undertake such transfer subject to Applicable Law and any restrictions, conditions or safeguards applicable to such transfer.

By using the Platform, you acknowledge that certain service providers supporting the Platform may operate infrastructure in jurisdictions outside India.

24. THIRD-PARTY SERVICES AND LINKS

The Platform may contain links to third-party websites, applications, payment gateways, social media services or other external services.

Such third parties operate independently of Simple RA Solutions and may have their own privacy policies and terms.

We are not responsible for the privacy practices, security, content or policies of third-party services.

You should review the applicable privacy policy of a third-party service before providing information to it.

25. PAYMENT INFORMATION

Payments made through the Platform may be processed through third-party payment gateways or payment service providers.

Depending upon the payment method, these providers may independently collect and process payment information.

We may receive transaction-related information such as:

  • Transaction reference;
  • Amount;
  • Payment status;
  • Date and time;
  • Payment method;
  • Refund information; and
  • Other information necessary to reconcile and manage transactions.

We do not intend to store complete card numbers, CVV information or other sensitive payment credentials where the payment processor is responsible for handling such information.

26. RESEARCH CONTENT AND USER-GENERATED CONTENT

The Platform may allow users and Research Analysts to upload, publish, submit or transmit content.

Such content may contain Personal Data.

You are responsible for ensuring that you have the necessary rights, permissions and lawful basis to upload or disclose any Personal Data contained in such content.

Simple RA Solutions may process such content for purposes including:

  • Hosting;
  • Displaying;
  • Delivering;
  • Storing;
  • Moderating;
  • Securing;
  • Backing up;
  • Analysing;
  • Improving Platform functionality; and
  • Complying with legal and regulatory obligations.

27. REGULATORY RECORDS AND AUDIT TRAILS

Given the nature of the Platform and the regulatory environment applicable to Research Analysts, we may maintain records relating to:

  • Account creation;
  • Login and authentication events;
  • Transactions;
  • Subscriptions;
  • Communications;
  • Research content;
  • Changes to content;
  • Complaints;
  • Support requests;
  • Regulatory disclosures;
  • Consent records;
  • System activity; and
  • Other information required for security, audit or compliance purposes.

Such records may be retained for periods required under Applicable Law or reasonably necessary for legitimate legal, regulatory, security or business purposes.

28. MARKETING COMMUNICATIONS

Subject to Applicable Law, we may communicate with you regarding:

  • New Platform features;
  • Product updates;
  • Service information;
  • Research-related offerings;
  • Events;
  • Educational content;
  • Promotional communications; and
  • Other information that may be relevant to your use of the Platform.

You may opt out of promotional communications by using the unsubscribe mechanism contained in the relevant communication or by contacting support@simplyra.com.

You may continue to receive essential transactional, security, legal or service-related communications even after opting out of promotional communications.

29. BUSINESS COMMUNICATIONS

If you provide your professional or business contact information, we may use it to communicate with you regarding:

  • Your account;
  • Platform services;
  • Transactions;
  • Compliance;
  • Business relationships;
  • Technical matters; and
  • Other legitimate business purposes.

30. ACCOUNT SECURITY

You are responsible for maintaining the confidentiality of your account credentials.

You must immediately notify us if you believe that:

  • Your account has been compromised;
  • Your credentials have been disclosed;
  • Unauthorised activity has occurred; or
  • Any Personal Data associated with your account has been accessed without authorisation.

We will not be responsible for losses resulting from your failure to maintain the security of your credentials, except to the extent otherwise required under Applicable Law.

31. FRAUD PREVENTION AND PLATFORM INTEGRITY

We may process Personal Data to identify and prevent:

  • Fraud;
  • Money laundering or other prohibited activity where applicable;
  • Account abuse;
  • Identity theft;
  • Unauthorised access;
  • Manipulation of Platform functionality;
  • Automated abuse;
  • Suspicious transactions;
  • Misrepresentation;
  • Regulatory violations; and
  • Other unlawful or prohibited conduct.

Where legally permitted, we may share relevant information with payment processors, financial institutions, regulators, law-enforcement agencies or other authorised parties for these purposes.

32. AUTOMATED SYSTEMS AND ANALYTICS

We may use automated systems, algorithms, analytics tools and technology-assisted processes to:

  • Detect fraud;
  • Identify security threats;
  • Analyse Platform performance;
  • Personalise certain Platform functionality;
  • Recommend relevant Platform features;
  • Identify technical issues; and
  • Improve our services.

Where Applicable Law grants you specific rights concerning automated decision-making, we will comply with those requirements.

33. DATA OF RESEARCH ANALYST CLIENTS AND SUBSCRIBERS

Where Simply RA processes Personal Data on behalf of a Research Analyst or other business user, the relevant Research Analyst/business user may determine the purposes for which such information is collected.

In such cases, Simple RA Solutions may process such information as a technology/service provider acting on the instructions of the relevant business user, subject to the applicable contractual arrangements and Applicable Law.

The relevant Research Analyst remains responsible for ensuring that:

  • Appropriate notices are provided to its clients/users;
  • Required consent or permissions are obtained;
  • Personal Data is collected lawfully;
  • Regulatory obligations are complied with; and
  • Instructions given to Simple RA Solutions are lawful.

34. GRIEVANCE REDRESSAL

If you have any complaint, concern or grievance relating to:

  • Your Personal Data;
  • Privacy;
  • Data security;
  • Unauthorised use of information;
  • A suspected breach of this Privacy Policy; or
  • Any privacy-related issue concerning the Platform,

you may contact:

Data Protection / Grievance Officer

Simple RA Solutions Pvt. Ltd.

Email: support@simplyra.com

We will endeavour to acknowledge and address grievances within the timelines prescribed under Applicable Law.

Where Applicable Law requires appointment or designation of a specific Data Protection Officer, Grievance Officer or other responsible person, the relevant details will be made available through the Platform and/or updated in this Privacy Policy.

35. CHANGES TO THIS PRIVACY POLICY

We may modify this Privacy Policy from time to time to reflect:

  • Changes in Applicable Law;
  • Regulatory requirements;
  • Changes to the Platform;
  • New services or functionality;
  • Changes in our data-processing practices; or
  • Security and operational requirements.

The updated version will be published on the Platform with an updated “Last Updated” date.

Where Applicable Law requires prior notice or consent for a material change, we will provide such notice or obtain such consent in the manner prescribed by law.

Your continued use of the Platform after the effective date of an updated Privacy Policy constitutes your acknowledgement of the updated policy to the extent permitted by Applicable Law.

36. GOVERNING LAW

This Privacy Policy shall be governed by and interpreted in accordance with the laws of India.

Subject to any mandatory statutory rights, regulatory mechanisms or other remedies available to an individual under Applicable Law, disputes relating to this Privacy Policy shall be subject to the dispute-resolution and jurisdiction provisions contained in the Terms and Conditions governing the Platform.

Nothing in this Privacy Policy is intended to exclude or restrict any right or remedy that cannot lawfully be excluded or restricted under Applicable Law.

37. SEVERABILITY

If any provision of this Privacy Policy is determined by a competent authority to be invalid, unlawful or unenforceable, such provision shall be modified or interpreted to the minimum extent necessary to make it valid and enforceable, and the remaining provisions shall continue in full force and effect.

38. NO WAIVER

Any failure or delay by Simple RA Solutions in exercising any right under this Privacy Policy shall not constitute a waiver of that right.

39. ENTIRE PRIVACY POLICY

This Privacy Policy, together with the Terms and Conditions and any other policies expressly incorporated by reference, constitutes the complete privacy framework governing the processing of Personal Data by Simple RA Solutions through the Platform, subject to Applicable Law.

40. CONTACT INFORMATION

For privacy-related questions, requests, complaints, deletion requests, correction requests or other concerns, please contact:

Simple RA Solutions Pvt. Ltd.

Platform: www.simplyra.com

Email: support@simplyra.com

For matters specifically relating to your relationship with a Research Analyst, including the research services, recommendations, reports, trading calls or other services provided by that Research Analyst, you should also contact the relevant Research Analyst directly.

IMPORTANT REGULATORY DISCLAIMER

Simply RA is a technology platform operated by Simple RA Solutions Pvt. Ltd. The Company does not, merely by providing the Platform, itself provide investment advice, research analysis, research recommendations, trading calls, portfolio management, brokerage or other regulated financial services.

Research Analysts and other service providers using the Platform are independently responsible for the legality, accuracy, suitability, disclosures and regulatory compliance of the services and content they provide, including compliance with applicable SEBI regulations and other Applicable Law.

Nothing contained in this Privacy Policy shall be construed as creating an advisory, fiduciary, agency, broker-client, investment-adviser-client or research-analyst-client relationship between Simple RA Solutions Pvt. Ltd. and any user merely by virtue of the user's use of the Platform.

This Privacy Policy does not constitute investment advice, a recommendation, an offer to buy or sell securities, or a solicitation to undertake any investment activity.