These Terms of Service were most recently updated on [27 th October, 2016].

Introduction

www.intellistocks.com ("Website") is a web-portal, owned by ‘Rothmans Investment Advisory’, holding a valid license as a SEBI Investment Adviser bearing license no.:INA100004798 and having its principal place of business located at18TH Floor, One Horizon Center, Golf Course Road, Gurgaon 122002 (hereinafter referred to as “Intellistocks”) Subject to all the terms and conditions contained hereunder, the Website is offered to you for your fair usage.

1. Acceptance

Please read the following terms and conditions of Service provided by Intellistocks (“Terms of Service”) carefully before you use the Website. By using the Website, you indicate that you accept these Terms of Service and that you agree to abide by them. Your use of the Website constitutes your acceptance of these Terms of Service which takes effect on the date on which you use the Website. If you do not agree with these Terms of Use, you should cease using the Website immediately.

Services

The term “Services” includes, without limitation, use of the Website which provides individuals with investment advisory in terms of the SEBI (Investment Advisers) Regulations, 2013 (“Regulations”). The Services provided shall not be misunderstood to be those of a mutual fund distributor, stock broker, investment portfolio manager, etc. Intellistocks may change, suspend or discontinue the Services at any time, including the availability of any feature, database, or content on the Website. Intellistocks may also impose limits on certain features and services or restrict your access to parts or all of the Services without notice or liability. Intellistocks makes no representations or warranties regarding the accuracy of descriptions anywhere on the Services, or regarding suggestions or recommendations of services. Intellistocks further makes no representation or warranty that the Services will be free of bugs, viruses, trojan horses or other codes that might contaminate of destroy Information.

3.1 Eligibility

Use of the Website is available only to persons who can form legally binding contracts under applicable law. Persons who are "incompetent to contract" within the meaning of the Indian Contract Act, 1872 including un-discharged insolvents etc. are not eligible to use the Website. You represent and warrant to IntelliStocks that: you are an individual (i.e.,not a corporation) who is at least 18 years

• i) capable of entering into a legally binding agreement;
• ii) all registration information you submit is accurate and truthful;
• iiI) you shall not impersonate any person or entity, or falsely state or otherwise misrepresent identity, age or affiliation with any person or entity; and
• iv) you will maintain the accuracy of such information. You also certify that you are legally permitted to use and access the Services and take full responsibility for the selection and use of and access to the Services. This Agreement is void where prohibited by law, and the right to access the Services is revoked in such jurisdictions.

Registration

As a condition to using some aspects of the Services, you may be required to register with Intellistocksand select a password and user name (“Intellistocks Account”). At the time of registration, you agree to provide to Intellistocks accurate personal and financial information including but not limited to name, age, email id, mobile number, income details etc. You shall provide Intellistocks with accurate, complete, and updated registration information. Failure to do so shall constitute a breach of this Agreement, which may result in immediate termination of your account. The information provided by you to Intellistocks shall be liable to be verified as per the Know Your Client (“KYC”) applicable on Intellistocks under the Regulations. You shall not (i) select or use the Intellistocks Account of another person with the intent to impersonate that person; or (ii) use the Intellistocks Account as a name subject to any rights of a person other than you without appropriate authorization. Intellistocks reserves the right to refuse registration of or cancel a Intellistocks Account in its discretion. You shall be responsible for maintaining the confidentiality of your password. You are responsible for all activity on your account, whether or not you authorize it.

1) Description of Services

The Services and its contents are intended solely for the personal, non-commercial use of Services by the users and may only be used in accordance with the terms contained herein. Intellistocks shall analyze the financial information, investment profile, investment objectives, investment purpose provided by you and based upon the analysis, Intellistocks shall provide you with investment recommendations with respect to the securities as defined under the Securities (Contract) Regulation Act, 1956 , mutual funds, individual securities, ETF, fixed income bonds, derivatives, commodities, international stocks markets, etc (“Securities”) and any other investment advise sought by you as per the subscription plan availed by you as published on our website and the details for the same will be sent via mail. In order to ensure that you receive the maximum benefits from the services of Intelli Stocks, Intelli Stocks may recommend you to change your subscription plan, depending upon your risk profiling ascertained by Intelli Stocks. The investment recommendations shall signify the recommended price or the exit price and the percentage of your total investment portfolio that you should invest.You acknowledge and agree that Intellistocks only offers you with investment advise but does not enter into the principal transaction on your behalf in any manner whatsoever. You may, in your sole discretion, accept or reject or act upon the investment recommendations offered by Intellistocks and may buy/sell the securities recommended. However, Intellistocks shall consider all the investment recommendations provided by it for the purpose of calculating the returns on investment as per your subscription plan. All investment recommendations will be communicated to you either via SMS, e-mail or both as well as your Intellistocks Account. The number of recommendations that you shall receive during a month and the duration shall be as per the subscription plan availed by you as published on our website and the details for the same will be sent via mail. You shall immediately implement the investment recommendations, unless, specifically mentioned in the recommendation itself. You shall invest the percentage of your total investment portfolio specified in the investment recommendation in order to achieve the targeted returns on Investment as per your subscription plan. You are advised to check your emails and inboxes (including the spam folder, if any) regularly to subscribe to all of our recommendations. In order to execute the investment recommendations offered, Intellistocks may recommend you a broker/sub-broker or any other intermediary on its panel to facilitate the implementation of the investment recommendations. You may in your sole discretion agree to engage the broker/sub-broker or any other intermediary so recommended to execute the investment recommendations. In case, the intermediary recommended is engaged, such intermediary shall maintain all records of the transactions of purchase and sale of securities, along with the brokerage/commission charged for each transaction. You understand and acknowledge that Intellistocks may receive certain commission or fees from the broker/sub-broker for recommending its services to you. In any case, Intellistocks shall not be held liable for any act or omission on the part of the broker or sub-broker that may cause any loss to you. Intellistocks shall endeavor to render investment recommendations to achieve the targeted returns on investment based upon the subscription plan availed by you under as published on our website and the details for the same will be sent via mail. The return on investment is mere projection of the profit which you desire to achieve, by availing the services under this Terms of Service. Intellistocks does not guarantee the achievement of the targeted returns on investment stated under the subscription plan availed by you. However, as part of our commitment, we may extend the duration of your services at no additional fees/charges in case the assured returns are not achieved within the stipulated time, provided you have acted upon our investment advice. Intellistocks shall maintain a log/tracksheet of all the investment recommendation made. The log/track sheet can be accessed by you at regular intervals or periodically through your Intellistocks Account. Intellistocks shall send you via email the log/ tracksheet of the recommendations made to you during along with the return that has been incurred on the recommendations periodically.In case, you have any complaints or you wish to put any issue forward with respect to the contents of the log/tracksheet, you shall revert to Intellistocks within seven days of receiving the log/tracksheet via e-mail.. Failure to respond within the above mentioned seven days, shall constitute deemed acceptance by you. The actual returns on investment shall be calculated on the basis of the recommended price and the percentage of the total investment portfolio recommended of securities, under the subscription plan. The return on investment shall be calculated on the value of the securities exclusive of any charges that are payable for buying or selling the securities, including but not limited to brokerage, taxes, surcharges, subscription charges of our service or any other charges. This method of calculation mentioned above will be the sole and final source for determining your profits or losses from using the services of Intellistocks, and there will be no deviation from it. In case you fail to invest or exit in or from any of the recommendations given by us, or opts not to trade in, then you shall forfeit your right to claim the assured returns on investment, Intellistocks shall not be held liable for the failure to achieve targeted returns on investments made by you, if the investment recommendations were not duly followed. The actual returns shall be calculated upon the total investment recommendations that were offered to you throughout the subscription plan availed by you and not on the actual investment made by you. Intellistocks shall not be held liable for any discrepancy between the actual return on investment accrued by you and the targeted returns on investment stated in our subscription plan as we calculate the actual returns on investments on the basis of the total investment recommendation communicated to you by us. Upon the achievement of the targeted returns on investment as stated in the subscription plan availed by you as published on our website, Intellistocks shall not be obliged to provide any further investment recommendations even if the term for which the services have been subscribed has not expired. You further understand and acknowledge that if the plan subscribed by you is for assured return on investment, then the duration of the subscription plan is only for indicative purposes. Your services shall be deemed to be terminated upon the achievement of the assured return on investment, irrespective of the period in which such assured returns are achieved. You understand and acknowledge the following: investment recommendations offered by Intellistocks is based upon the research and analysis of the stock market by the investment adviser for which the data is procured from various sources and are susceptible to stock market risks and fluctuations. Investment advisory is subject to market risk. Therefore, Intellistocks shall not be held responsible for deficiency in service in the event the actual return on investment is not achieved as per the assured returns of investment stated under subscription plan. the investment recommendations shall be communicated to you by means of electronic communication. Intellistocks shall not be held liable for any loss or liability resulting, directly or indirectly, from delays or interruptions due to human, electronic or mechanical equipment failures, telephone interconnect problems. the investment recommendations that are offered by Intellistocks are dependent upon the behavior of the stock market and the risk involved. Intellistocks does not guarantee periodic or regular investment recommendations. Intellistocks shall endeavor to provide the number of recommendations during your subscription as per the subscription plan availed by you as published on our website, however, Intellistocks shall not be bound and cannot be held liable for not rendering the number of recommendations as per the subscription plan availed. Intellistocks offers you investment recommendations which are calculated as per the financial information provided by you. Therefore, you agree to provide Intellistocks accurate and updated financial information. Intellistocks does not render any legal or tax related advice, nor does it prepare any legal documents.If you wish to seek any advice for any legal or tax implications of the investment recommendations, you may seek the same from a qualified legal counsel, tax attorney or chartered accountant. Intellistocks or its employees may have an investment position or holding in the securities which are the subject matter of the investment recommendations. Intellistocks shall disclose such holding or position before making an investment recommendation regarding the same.

Fees and Payment

You agree to pay Intellistocks such fees, along with the applicable taxes, for the services as provided under this Terms of Services that shall be applicable upon you as per the subscription plan availed by you as published on our website. You shall pay the fees at the time of registration fees either by way of online transfer, by cheque or by NEFT transfer to the bank account of Intellistocks. Intellistocks shall upon the receipt of payment of the fees shall generate and email you the invoice. Intellistocks shall commence its services after 2 (two) days of sending you the invoice. You also acknowledge and understand that Intellistocks may receive certain commission/fees for recommending the services of a broker/sub-broker or any other intermediary to you, in case the service so recommended are availed by you.

Duration of service

Intellistocks will render you investment recommendations for the period as stated under the subscription plan availed by you as published on our website of this Terms of Service. Your services shall terminate upon the expiry of the period for which the services have been availed under the subscription plan.

Termination

Termination by you

During the subsistence of period under the subscription plan availed by you, you may terminate the services at any point of time, by sending a termination notice of 2 months by an email to Intellistocks at support@intellistocks.com containing the intention to terminate the services along with the reason of such termination. The termination shall be effective after two months from the receipt of the said email, only if this notice is not recalled by you and if eligible, the money back guarantee (as mentioned below) shall trigger. Intellistocks shall not be liable to provide any further investment recommendations after the receipt of the email.

Termination by Intellistocks

Intellistocks may terminate and/or suspend your registration immediately, without notice, if there has been a violation of these Terms of Service or other policies and terms posted on the Website by you or by someone using your credentials. Intellistocks may also cancel or suspend your registration for any other reason, including inactivity for an extended period, but will attempt to notify you in advance of such cancellation or suspension. Intelli shall not be liable to you or any third party for any termination of user’s access to the Website. Further, user agrees not to attempt to use the Website after any such deletion, deactivation or termination.

Termination due to expiry of Period

Upon the expiry of the period stated under the subscription plan availed by you as published on our website, the obligation of Intellistocks to provide investment recommendations shall automatically terminate. Upon termination due to expiry of Period, your access to your online Intellistocks Account shall at its sole discretion continue for a period of 30 (thirty) days or more from the date of expiry of the period stated in the subscription plan availed as published on our website.

Post termination obligations

Upon termination for cause, your account, your right to use the Services, access the Website, and any Content will immediately cease. All provisions of these Terms of Service which, by their nature, should survive termination, shall survive termination, including, without limitation, ownership provisions, warranty disclaimers, and limitations of liability.  Upon the termination for any reason whatsoever, all documents and information received by Intellistocks from you, may be returned to you upon a request being made for the same. Copies of documents, papers and other information may be retained by Intellistocks for its record and for compliance purposes. All information will be held confidential and not disclosed to third parties, except as agreed upon in writing or required by any regulatory authority or against any legal implications.

Money Back Guarantee

Intellistocks provides a money back guarantee of the residual fees paid for availing investment advisory under this Terms of Service for all subscription plans for a period of 12 (Twelve) months or more In the event of termination of this Terms of Service by you as termination for convenience and in case the subscription plan availed by you as published on our website is for a period of 12 (Twelve) months or longer, you shall submit a claim for a refund of the residual fees by emailing 2 months’ notice to support@intellistocks.com. Intellistocks shall, after deducting the fees for the number of quarters for which the investment recommendations were made, process the refund within 15 days from date of completion of notice period. For example, in case you opt for money back within 3 months of subscribing for the services, we will refund you the fee after deducting 3 months subscription fee. Similarly, if money back request is sent to us in 3-6 months, we will deduct for 6 months tariff and pay balance and if the request is sent in 6-12 months then 12 months will be deducted and the balance shall be paid. Needless to say, the taxes will not be refunded and the request needs to be made only by your registered email with us to our designated email ID.

General Terms of Use

You hereby agree to be bound by this Terms of Service by using the Website, whether such usage is for the purpose of any service or not; You are hereby authorized to use the Website for lawful purposes or for the purposes as mentioned under Intellistocks’ general usage policies only; Any violation to the policy will lead to strict legal action to be taken against you in terms of the policies and applicable laws; Intellistocks strives to provide accurate services and make accurate investment recommendations as per the prices retrieved from the stock exchange market. In the event that an investment recommendation is offered at an incorrect price, or due to an error in the interface of the stock exchange, Intellistocks may contact you to stop you from executing the investment recommendation, to avoid any loss to be caused to you. Intellistocks may require additional information and verifications for the compliance of the Know Your Client procedure under the Regulations, for which it may contact you at any point during the subsistence of this Terms of Service. Intellistocks reserves the right to amendtheseTerms of Service from time to time. In the event, any amendments are made to these Terms of Service, we will notify you via email or a sign-in notification or some other means). By continuing to use the Service after those changes become effective, you are agreeing to be bound by the revised Terms of Service; if you do not agree to the change, do not use the Service after the change is effective, in which case the change will not apply to you. Intellistocks Advisory is a proprietary concern, owned and operated by Nalini Jindal, a SEBI registered investment advisor. Intellistocks shall abide by the SEBI (Investment Adviser) Regulations, 2013 in its dealing with you at all times. It shall carry out all responsibilities under the Regulations and shall follow the code of conduct as prescribed by the Regulations in all its dealing and transaction with you.

AVAILABILITY OF THE WEBSITE, SECURITY & ACCURACY

The Website uses internet and internet usage costs apply solely to you. Intellistocks makes no warranty that your access to the Website will be uninterrupted, timely or error-free. Due to the nature of the internet, this cannot be guaranteed. In addition, we may occasionally need to carry out repairs, maintenance or introduce new facilities and functions which may cause temporary interruptions. Access to the Website may be suspended or withdrawn to or from you personally or all users temporarily or permanently at any time and without notice. We may also impose restrictions on the length and manner of usage of any part of the Website for any reason. If we impose restrictions on you personally, you must not attempt to use the Website under any other name or user or on any other mobile device. We do not warrant that the Website will be compatible with all hardware and software which you may use. We shall not be liable for damage to, or viruses or other code that may affect, any equipment (including but not limited to your mobile device), software, data or other property as a result of your access to or use of the Website or your obtaining any material from, or as a result of using the Website. We shall also not be liable for the actions of third parties. We make no representation or warranty, express or implied, that information and materials on the Website are correct, no warranty or representation, express or implied, is given that they are complete, accurate, up-to-date, fit for a particular purpose and, to the extent permitted by law, we do not accept any liability for any errors or omissions. This shall not affect any obligation which we may have under any contract that we may have with you to provide you with services. The Website are independent of any platform on which it is located. The Website is not associated, affiliated, sponsored, endorsed or in any way linked to any platform operator, including, without limitation, Apple, Google, Android or RIM Blackberry (each being an “Operator”). Your use of the Website is also bound by the terms of use of the Operator. You must comply with any applicable third party terms of agreement when using the (e.g. you must ensure that your use of the Website on any deviceis not in violation of your device agreement or any data service agreement

Ownership of rights

Intellistocksand its affiliate(s) owns all Intellectual Property Rights to and into the trademark “Intellistocks” AND "www.intellistocks.com", and the Website, including, without limitation, any and all rights, title and interest in and to copyright, related rights, patents, utility models, designs, know-how, trade secrets and inventions, goodwill, source code, meta tags, databases, text, content, graphics, icons, and hyperlinks. You acknowledge and agree that you shall not use, reproduce or distribute any content from the Website belonging to the Intellistocks without proper authorization. Intellistocks gives you permission to use the aforementioned content for personal, non-commercial purposes only and do not transfer any intellectual property rights to you by virtue of permitting your use of the services. You may print, download, and store information from the Website for your own convenience, but you may not distribute, republish (except as permitted in this paragraph), sell, or exploit any of the content, or exploit the site in whole or in part, for any commercial gain or purpose whatsoever. Except as is expressly and unambiguously provided herein, Intellistocks and its affiliates do not grant you any express or implied rights, and all rights in the Website and the services not expressly granted by Intellistocks to you are retained by Intellistocks. All components of the Website are protected by intellectual property laws and are the property of Intellistocks. You shall not acquire any rights, including rights in or to any software, trademarks or components of the Website, by using the Website. Copyright notices and trademarks may not be changed or removed. Components of the Website may not be reproduced in whole or in part in any manner or form (including electronic or printed form) without our prior written consent and unless full acknowledgement of the source is provided. Intellistocks and you acknowledge that, in the event of any third party claim that the Website or your use of the Website infringes that third party’s intellectual property rights, we, will be solely responsible for the investigation, defense, settlement and discharge of any such intellectual property infringement claim; provided such infringement was caused by us.

Privacy Policy

For information regarding Intellistocks treatment of personally identifiable information, please review Intellistocks’ current Privacy Policy, which is hereby incorporated by reference; your acceptance of this Agreement constitutes your acceptance and agreement to be bound by Intellistocks’ Privacy Policy. 

Disclaimer of Warranties

YOU ASSUME ALL RESPONSIBILITY AND RISK WITH RESPECT TO YOUR USE OF THE WEBSITE.  THE WEBSITE IS AVAILABLE “AS IS,” AND “AS AVAILABLE”.  YOU UNDERSTAND AND AGREE THAT, TO THE FULLEST EXTENT PERMITTED BY LAW, INTELLISTOCKS DISCLAIMS ALL WARRANTIES, REPRESENTATIONS AND ENDORSEMENTS, EXPRESS OR IMPLIED, WITH REGARD TO THE WEBSITE, INCLUDING, WITHOUT LIMITATION, IMPLIED WARRANTIES OF TITLE, MERCHANTABILITY, NON-INFRINGEMENT AND FITNESS FOR A PARTICULAR PURPOSE.  WE DO NOT WARRANT UNINTERRUPTED OR ERROR-FREE USE OF THE WEBSITE OR THAT ERRORS WILL BE DETECTED OR CORRECTED. WE DO NOT ASSUME ANY LIABILITY OR RESPONSIBILITY FOR THE ACCURACY, COMPLETENESS, RELIABILITY OR USEFULNESS OF THE INFORMATION DISCLOSED OR ACCESSED THROUGH THE WEBSITE.  WE HAVE NO DUTY TO UPDATE OR MODIFY THE WEBSITE AND WE ARE NOT LIABLE FOR OUR FAILURE TO DO SO.

Indemnification

Intellistocks disclaims all warranties or conditions, whether expressed or implied. Intellistocks shall not be liable to any person for any loss or damage which may arise from the use of any of the information contained in any of the materials on the Website. This Terms of Service and any contractual obligation between Intellistocks and any user will be governed by the laws of India, subject to the exclusive jurisdiction of Courts in Gurgaon, Haryana. You agree to defend, indemnify and hold harmless Intellistocks, its employees, agents and its successors and assigns from and against any and all claims, liabilities, damages, losses, costs and expenses, including attorney's fees, caused by or arising out of claims based upon user’s actions or inactions, which may result in any loss or liability to the Intellistocks or any third party including but not limited to breach of any warranties, representations or undertakings or in relation to the non-fulfillment of any of user’s obligations under this Terms of Service or arising out of the user’s violation of any applicable laws, regulations including but not limited to intellectual property rights, payment of statutory dues and taxes, claim of libel, defamation, violation of rights of privacy or publicity, loss of service by other subscribers and infringement of intellectual property or other rights

LIMITATION OF LIABILITY

IN NO EVENT SHALL INTELLISTOCKS ADVISORY, ITS EMPLOYEES, OR AGENTS, BE LIABLE FOR ANY CONSEQUENTIAL, INCIDENTAL, INDIRECT, PUNITIVE OR SPECIAL DAMAGES, HOWEVER CAUSED AND BASED ON ANY THEORY OF LIABILITY ARISING OUT OF OR RELATING TO THIS TERMS OF SERVICE, EVEN IF WE HAVE BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES, RESULTING FROM ANY ASPECT OF YOUR USE OF THE WEBSITE, INCLUDING WITHOUT LIMITATION WHETHER THE DAMAGES ARISE FROM USE OR MISUSE OF THE WEBSITE, FROM INABILITY TO USE THE WEBSITE, OR THE INTERRUPTION, SUSPENSION, MODIFICATION, ALTERATION OF THE WEBSITE. THESE LIMITATIONS SHALL APPLY TO THE FULLEST EXTENT PERMITTED BY LAW. YOU SPECIFICALLY ACKNOWLEDGE AND AGREE THAT INTELLISTOCKS ADVISORY SHALL NOT BE LIABLE FOR USER SUBMISSIONS OR THE DEFAMATORY, OFFENSIVE, OR ILLEGAL CONDUCT OF ANY USER OR THIRD PARTY AND THAT THE RISK OF HARM OR DAMAGE FROM THE FOREGOING RESTS ENTIRELY WITH YOU.

Electronic Contracting and Notices

Your affirmative act of using this Website, and/or registering for the Website constitutes your electronic signature to these Terms of Service and also your consent to enter into agreements with the Intellistocks electronically

MISCELLANEOUS

WAIVER: The failure of either party to exercise, in any respect, any right provided for herein shall not be deemed a waiver of any further rights hereunder. FORCE MAJEURE: Under no circumstances shall Intellistocks be held liable for any delay or failure in performance resulting directly or indirectly from acts of nature, forces, or causes beyond its reasonable control; including, without limitation, internet failures, computer equipment failures, payment processor failure, telecommunication equipment failures, and any other other equipment failures; electrical power failures, strikes, riots, insurrections, civil disturbances, fires, floods, storms, explosions, acts of God, war, governmental actions, orders of domestic or foreign courts or tribunals, non-performance of third parties, or loss of, or fluctuations in heat, light, or air conditioning.  SERVERABILITY: If any provision of theseTerms of Service is found to be unenforceable or invalid, that provision shall be limited or eliminated to the minimum extent necessary so that theseTerms of Service shall otherwise remain in full force and effect and enforceable. ASSIGNABILITY: These Terms of Service is not assignable, transferable or sub-licensable by you except with Intellistocks’ prior written consent and any such attempted assignment shall be void. Intellistocks may transfer, assign or delegate these Terms of Service and its rights and obligations to any third party, without providing any notice. ENTIRE AGREEMENT: Both parties agree that these Terms of Service is the complete and exclusive statement of the mutual understanding of the parties and supersedes and cancels all previous written and oral agreements, communications and other understandings relating to the subject matter of these Terms of Service, and that all modifications must be in a writing signed by both parties, except as otherwise provided herein. RELATIONSHIP: No agency, partnership, joint venture, or employment is created as a result of this Agreement and you do not have any authority of any kind to bind Intellistocks in any respect whatsoever. HEADINGS: Headings for each section have been included above for your convenience, but such headings do not have any legal meaning, and may not accurately reflect the content of the provisions they precede. You and Intellistocks agree there are no third party beneficiaries intended under this Agreement.

Governing Law

These terms shall be governed by and constructed in accordance with the laws of India without reference to conflict of laws principles, and disputes arising in relation hereto shall be subject to the exclusive jurisdiction of the courtsat Gurgaon, Haryana.

CONTACT

If you have any questions, complaints, or claims with respect to the Services, you may contact us at 0124 66 88 250or support@intellistocks.com

This Privacy Policy is effective as of October 27, 2016. This is our official Privacy Policy which forms part of your legal agreement with us. Please read our Privacy Policy carefully to be sure you understand how we collect and use information and under what circumstances we share information.

By accessing the services provided by us through the website www.intellistocks.com(“Website”), You agree to the collection and use of your data by Rothmans Investment Advisory (“Company”), in the manner provided in this Privacy Policy. This Policy does not apply to the procedures and practices followed by entities that are not managed, owned or controlled by the Company or to the people that are not engaged, employed or managed by the Company. Our objective is to make you:

• feel comfortable using our Websites;
• feel secure in submitting your information to us;

1. CHANGES TO THIS PRIVACY POLICY

We reserve the right, in our sole discretion, to modify, add or delete provisions of this Privacy Policy at any time. We will post the effective date of any change at the top of this Privacy Policy. Your use of our Website after the effective date of any such modification means you accept and agree to be bound by the Privacy Policy, as modified. We urge you to come back to this policy and review this Privacy Policy regularly so that you remain aware of the terms and conditions that apply to you.

2. WHAT INFORMATION WE COLLECT ABOUT YOU?

We collect information from you when you sign up on the Website - When registering on the Website, you may be asked to enter your personal information like your name, gender, age, mailing address, email ID, language preferences, location of residence, mobile number, pictures and financial information namely bank account and other payment instrument details, investment objectives alongwith the timelines,purposes of investment, income details, existing investments/ assets, risk tolerance, liability/borrowing details etc., and such other information as required under the SEBI (Investment Advisers) Regulations, 2013. The information collected shall be used by the Company for the purposes rendering investment advisory services to you.

Device information - We may automatically collect hardware information such as your hardware model and unique device identifiers, such as your handset’s IMEI number. This may be used to provide you with requested services.

Log information - When you use our services, we may automatically collect and store certain information. This may include details of how you used our services for example your responses to the advertisements shown to you; date and time of usage etc.

Cookies - We use third party operational service providers and technology that can collect and transmit information that is associated with computers and devices that visit our Website. Data gathered via these technologies do not personally identify you. Although the term “cookie” commonly is used to refer to a text file stored on a computer that can log visits to websites and/or can contain log-in information so you do not have to re-enter information each time you visit, we will use the term “cookie” to refer generically to any technology that can collect or transmit information about visits to the Website. “Cookie” information typically includes such data as the referral web domain, the type of operating system and browser you are using, mobile device identifiers, the date and time of your visit, location data, information relating to activities on our Website and other technical attributes of visits to Our Website . We use the information collected through the cookies to analyse trends, administer our Website, track movements on our Website and gather aggregate demographic information about visitors so we continually improve the Website and create a qualified audience pool.

Cookies store information that allows the Website to recognize a user’s computer or access device each time it is used to visit the Website and cookies can keep count of how often you return to our Website. Cookies can also track how you use our Website. And can store information such as your log-in information, so you do not have to re-enter them each time you return to the Website. We do not use cookies to retrieve information from your computer or device for purposes that are not related to the Website or your interaction with the Our Website.

You may stop or restrict cookies on your computer or purge them from your browser by adjusting your web browser preferences and you should consult the operating instructions that apply to your browser for instructions should you wish to do so and in general to determine how best to configure your browser setting to meet your requirements. Note that if you turn off, purge or disable cookies, although you may still use the Website, you may not be able to use all of the features, functions, or services available on the Website.

3. HOW WE USE THE INFORMATION

A. We use your personal information to:

• a) help us provide personalized features;
• b) tailor our Website/Application to your interest;
• c) to get in touch with you in the case of password retrieval and policy changes;
• d) to provide the services requested by you;
• e) to verify your identity and comply with the KYC requirement under SEBI (Investment Advisers) Regulations, 2013;
• f) Billing information

A. We use your personal information to:

• a) provide notifications for investment recommendations
• b) direct our efforts for product improvement;
• c) contact you as a survey respondent; and
• d)send you promotional materials from our contest sponsors or advertisers.

B. We use your financial information to:

• a) to make investment recommendations,
• b) to render services under the Terms of Service
• c) analyse the investment and market trends for the purposes of research

C. We use your personal information to:

• a) provide notifications for investment recommendations
• b) direct our efforts for product improvement;
• c) contact you as a survey respondent; and
• d)send you promotional materials from our contest sponsors or advertisers.

D. We use your personal information to:

• a) provide notifications for investment recommendations
• b) password reminder and registration confirmation;
• c) special offers;
• d) newsletters;
• e) invoices;
• f) changes in the service's policy or Terms of Service;
• g)event based communications such as order information, renewal notices, invites,reminders etc.

E.Other usage:We may use your information for legal requirements, which are as follows:

• a)to furnish any information or report to SEBI under the Regulations
• b)to meet any applicable law, regulation and legal process;
• c)in response to law enforcement authority or other governmental official request;
• d)to enforce applicable Terms of Service, including investigation of potential violations;
• e) to detect, prevent, or otherwise address fraud, security or technical issues;
• f)to protect against harm to the rights, property or safety of the Company, our users or the public as required or permitted by law; and
• g)in the event that the Company is subject to a merger or acquisition to the new owner of the business. Disclosure may also be required for Company audits or to investigate a complaint or security threat..

4. WHOM DO WE DISCLOSE YOUR INFORMATION?

A. We will not use your financial information for any purpose other than to complete a transaction with you.

B. We do not rent, sell or share your personal information and we will not disclose any of your personally identifiable information to third parties unless:

• a)we have your permission;
• b)to provide services you've requested;
• c)to help investigate, prevent or take action regarding unlawful and illegal activities, suspected fraud, potential threat to the safety or security of any person, violations of intellistocks.com Terms of Service or to defend against legal claims;
• d)special circumstances such as compliance with subpoenas, court orders,requests/order from legal authorities or law enforcement agencies requiring such disclosure.

5. ADVERTISERS, CO-SPONSORS AND LINKS TO OTHERS?

The Website may contain or display information from sponsors, co-sponsors, advertisers, operational service providers, or others that offer to make information, products and/or services available, and/or that provide opportunities to participate in promotions or engage in activities or that link or redirect your browser to other websites, web pages, materials, or organizations.

We encourage you to be aware when you leave the Website or take advantage of advertised offers, links or other references, many of which may direct you to your internet browser to websites or web pages of another party. You should read their privacy statements and the terms and conditions that apply because we are not responsible for any of the terms and conditions, privacy practices, the content, functions, features, activities, and/or transactions you may engage in when you are not using the Website. If we use operational service providers to serve advertisements when you visit the Website, the operational service provider, in connection with the Website, may use information about your visit to the Website in order to serve the advertisements about products and services that may be of interest to you. In the course of serving advertisements on the Website, our operational service providers may use cookies and other technologies.

6. SECURITY

As you may appreciate, the internet is a public network and we cannot guarantee that communications between you and the Company or others to, through or from the Website, will be free from unauthorized access or interference by third parties. By using the Website, you are agreeing to assume this risk and any and all responsibility and liability that may arise. We have put in place reasonable procedures to help safeguard information.

7. ACCESSING AND UPDATING YOUR INFORMATION:

The Company takes reasonable steps to keep your personal information accurate and complete. The information you provide to us during the sign-up process can be accessed and updated from within the Website.

You may have the right to request details about the information we collect and to correct inaccuracies in that information. Any further statutory user rights remain unaffected. We may decline to process requests that are unreasonably repetitive, require disproportionate technical effort, jeopardize the privacy of others, are extremely impractical, or for which access is not otherwise required by local law. If you would like to make a request to access your information, please contact us at support@intellistocks.com.

8.DATA RETENTION:

We take reasonable steps to ensure that we retain information about you only for so long as is necessary for the purpose for which it was collected, or as required under any contract or by applicable law.

9.CONTACT US

For questions relating to privacy, we can be contacted at support@intellistocks.com Address: 18 th Floor, One Horizon Center, Golf Course Road, Gurgaon 122002 Attention: Compliance Manager

10. CONSENT, AMENDMENTS AND GOVERNING LAW:

By using this Website, you consent to the terms of this Privacy Policy and to our use and management of Personal Information. Should a change be incorporated in this Privacy Policy, we will make all reasonable effort to inform you of the same. Your visit and any dispute over privacy are subject to this Privacy Policy. The said Policy shall be governed by and construed in accordance with the laws of the Republic of India. Further, it is irrevocably and unconditionally agreed that the courts of Gurgaon shall have exclusive jurisdiction to entertain any proceedings in relation to any disputes arising out of the same.

Investment advice is a regulated service. Intellistocks is an Sebi registered investment advisor. Please see our website's services section should you wish to receive advice from us. All the services on this website are marketed by Intellistocks Pvt Ltd. Our recommendations rely on historical data,past performance and backtests. Historical data, past performance and backtests does not guarantee future results, and the likelihood of investment outcomes is hypothetical in nature. Unless otherwise specified, all return figures shown above are for illustrative purposes only, and are not actual customer or model returns. Actual returns will vary greatly and depend on personal and market circumstances.

All investments entail risks. There is no guarantee that investment strategies will achieve the desired results under all market conditions and each investor should evaluate its ability to invest for a long term especially during periods of a market downturn. No representation is being made that any account, product, or strategy will or is likely to achieve profits, losses, or results similar to those discussed, if any.

The information contained herein is based on our analysis and upon sources that we consider reliable. We, however, do not vouch for the accuracy or the completeness thereof. This material is for personal information and we are not responsible for any loss incurred based upon it. This website is solely for the personal information of the visitor. The products discussed or recommended here may not be suitable for all investors. Investors must make their own informed decisions based on their specific objectives and financial position and using such independent advice, as they believe necessary.

By visiting our website, you agree that all the claims or causes of action arising out of or relating to your use of this Website will be at Gurgaon jurisdiction only. All Disputes are subjected to exclusive jurisdiction of the courts at Gurgaon.