Last Updated on -16 July 2025

SmartBulls (“SmartBulls” or “we” or “us” or “our”), with its registered office at A-419, Siddhi Vinayak Business Towers, Off S G Highway, Makaraba 380051, operates the web-portal www.smartbulls.com (and Uniform Resource Locators (URLs) that redirect thereto) and the mobile application known as ‘SmartBulls’ in India (collectively referred to as the “Portal”), offers a ‘Virtual Stock Trading Platform’’. This Privacy Policy governs the collection, use, and disclosure of information provided by any person ('User' or 'you' or 'your') utilizing the Portal or any of its features, including participation in the various PracTests, competitions, or any social activity being conducted on SmartBulls ('Services') and shall be legally binding on you.

Please read this Privacy Policy carefully before using the Portal or any of its features. By accessing or using the Portal or any of its features, you agree to be bound by the terms of this Privacy Policy. If you do not agree to the terms of this Privacy Policy, please DO NOT use the Portal or any of its features.

This Privacy Policy is to be read together with our Terms and Conditions and all other applicable terms and disclaimers made available on the Portal, all of which constitute legally binding agreements between you and SmartBulls and all of which you agree to be legally bound by.

At SmartBulls, we value your privacy and are dedicated to protecting it in every way possible. As a provider of a virtual stock trading platform, we offer various services to our users. We urge you to read the 'About Us' section to learn more about SmartBulls. In order to provide an enriching and holistic experience to our users, we collect information about them through the following means:

1)Information provided by Users: This includes any information that is shared by users during the registration process or otherwise.

2)Information automatically tracked during navigation: This refers to any information that is automatically collected as users navigate the SmartBulls platform.

We take the privacy and security of your personal information seriously and will always strive to ensure that your data is protected. This Privacy Policy explains how we collect, use, share, and protect your personal information.

Please read the Privacy Policy carefully before submitting any information to the Portal. By using the Portal, you consent to the collection, use, disclosure, and transfer of your personal information for the purposes outlined in this Privacy Policy. If you do not agree, please do not use the Portal. Your use of the Portal indicates your acceptance of this Privacy Policy. If you choose not to provide us with certain information, you may not be able to access all of the features and Services we offer, and we reserve the right not to provide you with our Services.

Purpose and Usage of information collected by SmartBulls:

To operate, provide, improve, and market our Services, SmartBulls needs to receive and collect certain information from Users. The type of information collected depends on how the Services are used. Some information is required for us to provide our Services, such as a mobile phone number to create an account. In order to register for certain Services on the App and Portal, Users must provide their username, password, mobile number, and grant access to their contact list.

To enhance the functionality of our Services, SmartBulls provides optional features that may require us to collect additional information. We will notify you about the collection of such information, as appropriate. If you choose not to provide the necessary information to use a feature, you may be unable to use that feature.

Additional information may be required from you to access certain features of the Services in the future, including your Date of birth, Email, Location, access to SMS, Permanent Account Number, and Know Your Customer (KYC) information, including bank account details for money transfers. Sensitive Personal Information (SPI) such as financial information may also be collected during payment transactions to complete your payment quickly. However, other SPI is not collected by SmartBulls, and any collected SPI will not be disclosed to third parties without your consent or as required by law. This does not apply to publicly available information on the Portal.

When you create a SmartBulls account, you are required to provide your mobile phone number and basic information, including a username of your choice. Without this information, you won't be able to use our Services.

If permitted by applicable laws, you can use our contact upload feature to provide us with the phone numbers in your address book, including those of users of our Services and your other contacts. If any of your contacts are not using our Services, we'll handle this information in a way that ensures those contacts cannot be identified by us. You can use this feature to invite other users to participate in any of the Services provided by SmartBulls. We may use this information to contact the Invited User and invite them to register with SmartBulls on the Portal and participate in the activity in which they were invited by you.

Users may also invite other existing Users or other users ('Invited Users') to participate in any of the Services by providing their email address, Facebook username, Whatsapp handle, or phone number. SmartBulls may use this information to contact the Invited User and invite them to register with SmartBulls on the Portal and participate in the activity in relation to which they were invited by the User. Invited Users' participation in any of the league/competition/activity shall be subject to the terms of this Privacy Policy and the Terms and Conditions for the use of the Portal.

The User represents that the Invited Users have consented and agreed to such disclosure and use of their contact details by SmartBulls. We collect specific information based on the kind of league/competition/activity the User wishes to participate in or access, which will be utilized for the purpose of providing services, including but not limited to the Services requested by the User. The information provided by the Users enables us to improve our Services and provide the most user-friendly competition experience.

In limited circumstances, we may share such information with affiliates and third parties for the purpose of providing services (including but not limited to the Services requested by the User), complying with legal process, preventing fraud or imminent harm, and ensuring the security of our network and services.

Disclosure/sharing of information:

usage of the Services and Portal and your participation in competitions, PracTests, or activities on the Portal, with third-party service providers engaged by SmartBulls. This is done for the purpose of data analytics or other similar purposes, to improve the services, and to enhance your experience with SmartBulls. If we plan to use your personal information (i.e. information that can be used to identify you and is not publicly available) for any other purposes, we will notify you beforehand.

usage of the Services and Portal and your participation in competitions, PracTests, or activities on the Portal, with third-party service providers engaged by SmartBulls. This is done for the purpose of data analytics or other similar purposes, to improve the services, and to enhance your experience with SmartBulls. If we plan to use your personal information (i.e. information that can be used to identify you and is not publicly available) for any other purposes, we will notify you beforehand.

Use of Cookies:

In order to improve the functionality and user experience of the Portal, SmartBulls uses electronic tools such as 'cookies' to collect information and assign each visitor a unique random number as a User Identification (User ID) to understand the User's individual interests using the identified computer. Please note that SmartBulls cannot identify you unless you voluntarily identify yourself (e.g., through registration), and the only personal information a cookie can contain is information that you have supplied. SmartBulls's advertisers may also assign their own cookies to your browser (if you click on their ad banners), which SmartBulls cannot control.

In addition, SmartBulls's web servers automatically collect limited information about your computer's connection to the Internet, including your IP address, when you visit the Portal. This information is used by SmartBulls to deliver web pages to you upon request, to tailor the Portal to your interests, to measure traffic within the Portal, and to provide advertisers with information about the geographic locations from where SmartBulls's visitors come.

Links:

SmartBulls provides links to other websites which are governed by their own privacy policies that are beyond our control. When users leave SmartBulls's servers, any information they provide is subject to the privacy policy of the operator of the site they are visiting, which may differ from SmartBulls's policy. If users cannot find the privacy policy of a linked site, they should contact the site directly. SmartBulls is not responsible for the privacy practices or content of these linked sites.

Advertising:

SmartBulls uses aggregated statistics on traffic to various pages within our site to present information to our online advertisers, which helps them understand our audience and confirm the value of advertising on SmartBulls. From time to time, we may contact you to update your content and provide features that we believe may benefit you. Please be aware that there may be deceptive emails, websites, and blogs circulating on the Internet claiming to be from or associated with SmartBulls. These materials are not associated with SmartBulls and may include our logo, photos, links, content, or other information. Some of these materials may call on you to provide personal information, login names, passwords, or payments, or to commit illegal or unauthorized acts. We strongly recommend that you do not respond to these materials or use these websites, blogs, etc. We may use the information you provide to contact you about the Services you have availed from us, or to inform you of any updates to our Services.

User account deletion, Retention of data & Data deletion:

Users can request to delete their account by sending an email to support@smartbulls.com.

We will do our best to respond promptly and in any event within one month of the following:

Our receipt of your written request; or

Our receipt of any further information we may ask you to provide to enable us to comply with your request, whichever is later.

Once the account is deleted, the user will permanently lose their user data and associated information. However, SmartBulls may retain the user's personal information until the relevant purposes for using the information are no longer applicable or until they are no longer required by applicable law or legitimate business purposes to retain the information.

If a user accidentally deletes their account, it is possible to restore it for up to 30 days. After that, SmartBulls begins the process of deleting the user's personal information from its systems, unless there are outstanding issues, claims, or disputes requiring the information to be kept. Additionally, copies of the user's information may still be viewable or accessible if they were previously shared with others or stored by others. SmartBulls cannot control this, nor can they be held liable for it. If a user has given third-party applications or websites access to their personal information, those parties may retain the information to the extent permitted under their terms of service or privacy policies.

Security Procedure:

SmartBulls takes the security of all information gathered on the Portal seriously and implements reasonable security practices and procedures to protect it. The data is stored in a SmartBulls-controlled database on servers that are secured behind a firewall and accessed only by authorized personnel on a need-to-know basis. However, no security system is completely foolproof, and we cannot guarantee that our database will never be breached, nor can we ensure the safety of information transmitted to us over the internet.

Any information you post on the Portal may be accessible to anyone with internet access, unless stated otherwise on the Portal. By using the Portal, you agree that your information may be transferred to and used in countries other than India.

SmartBulls may revise this Privacy Policy from time to time to reflect changes in the evolving nature of the internet. Any updates to our Privacy Policy will be posted on this page. Our use of any information we collect will always be consistent with the policy in place when the information was collected, regardless of any changes to the policy.

Limitation:

SMARTBULLS WILL NOT BE HELD RESPONSIBLE FOR ANY DAMAGES, INCLUDING BUT NOT LIMITED TO COMPENSATORY, DIRECT, INDIRECT, INCIDENTAL, PUNITIVE, SPECIAL, AND CONSEQUENTIAL DAMAGES, LOSS OF DATA, GOODWILL, BUSINESS OPPORTUNITY, INCOME OR PROFIT, LOSS OF OR DAMAGE TO PROPERTY, AND CLAIMS OF THIRD PARTIES ARISING FROM THE USE OF THIS PORTAL. IN NO EVENT WILL SMARTBULLS BE LIABLE FOR ANY DAMAGES WHATSOEVER IN AN AMOUNT IN EXCESS OF AN AMOUNT OF INR 100.

Applicable Law and Jurisdiction:

By visiting this Portal, you hereby agree that this Privacy Policy shall be governed by and construed in accordance with the laws of India, without giving effect to its conflict of laws principles. Any dispute, controversy, or claim arising out of or relating to this Privacy Policy, including its interpretation, performance, breach, termination, validity or enforceability, or the use of the Portal, shall be subject to and governed by the dispute resolution process set out in the Terms and Conditions.

Updation of information:

If there are any changes, updates, or modifications to your personal information, you are required to promptly notify SmartBulls. Additionally, you have the ability to review, correct, update, or modify your personal information and user preferences by logging into your Profile page on SmartBulls.

Contact us:

Any questions or clarifications with respect to this Policy or any complaints, comments, concerns or feedback can be sent to our Grievance Officer at:

Contact details:

Email: support@SmartBulls.com

Address: A 419 Siddhivinayk Towers, Off S G Highway, Makarba, Ahmedabad - 38 0051