1. Introduction
Equisights Research IFSC LLP (“Equisights,” “we,” “our,” or “us”) is a limited liability partnership incorporated in India and registered with the International Financial Services Centres Authority (“IFSCA”) as a Research Entity under the IFSCA (Capital Market Intermediaries) Regulations, 2025 (the “CMI Regulations”), bearing Certificate of Registration No. CMI2025RA0918. Our registered office is located at GIFT SEZ, GIFT City, Gandhinagar, Gujarat-382050, India.
This Privacy Policy describes how we collect, use, disclose, store, and protect personal information when you visit equisights.com (the “Website”), subscribe to our newsletters, complete our contact or registration forms, or otherwise interact with our research products and services (collectively, the “Services”).
By accessing or using the Website or Services, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with any part of this policy, please refrain from using the Website or Services.
2. Scope and Applicability
This Policy applies to all visitors to our Website and all users of our Services, regardless of their geographic location.
As an IFSCA-registered Research Entity, research relating to securities listed or proposed to be listed on a stock exchange in India is offered exclusively to non-resident clients (as defined under the Foreign Exchange Management Act, 1999 and the rules and regulations made thereunder), in accordance with Section 4.1 of the IFSCA Master Circular for Research Entities dated August 5, 2025, read with Regulation 4 of the SEBI (Research Analysts) Regulations, 2014, and circulars issued thereunder.
This Policy is intended to comply with:
- The Digital Personal Data Protection Act, 2023 (“DPDPA”) of India and rules and regulations made thereunder;
- The Information Technology Act, 2000 and the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011;
- The IFSCA (Capital Market Intermediaries) Regulations, 2025 and the Master Circular for Research Entities dated August 5, 2025;
- The IFSCA (Anti Money Laundering, Counter-Terrorist Financing and Know Your Customer) Guidelines, 2022, as amended from time to time;
- The IFSCA circular titled “Direction for all Regulated Entities” dated April 3, 2025;
- The IFSCA Complaint Handling and Grievance Redressal framework dated December 2, 2024 (as extended);
- The IFSCA Guidelines on Cyber Security and Cyber Resilience for Regulated Entities in IFSCs dated March 10, 2025; and
- Generally accepted privacy standards applicable to international users, including reasonable expectations under U.S. state privacy laws.
3. Information We Collect
We collect the following categories of personal information:
3.1 Information You Provide Directly
- Contact Form Submissions: Name, email address, subject, and the contents of your message.
- Newsletter Subscriptions: Email address and any other information you choose to provide.
- Client Onboarding / Access Requests: Name, organization, professional designation, contact details, investor classification, country of residence, jurisdiction of incorporation (if applicable), and other information reasonably required to (a) verify that you qualify as a non-resident client where applicable, (b) provide the Services, and (c) discharge our obligations under the IFSCA (Anti Money Laundering, Counter-Terrorist Financing and Know Your Customer) Guidelines, 2022 and any related guidance issued by the Authority from time to time.
- Correspondence: Records of communications you exchange with us via email or other channels.
3.2 Information Collected Automatically
When you visit our Website, we automatically collect certain technical information through Google Analytics and similar tools, including:
- IP address (which may be truncated or anonymized);
- Browser type, operating system, and device identifiers;
- Pages visited, time spent on pages, referring URL, and clickstream data;
- Approximate geographic location derived from IP address; and
- Cookies and similar tracking technologies (see Section 8 on Cookies).
3.3 Information We Do Not Knowingly Collect
Our Services are directed at sophisticated non-resident investors. We do not knowingly collect personal information from individuals under the age of 18. If you believe we have inadvertently collected information from a minor, please contact us at info@equisights.com so we may delete it.
4. How We Use Your Information
We use personal information for the following purposes:
- To provide, operate, and improve the Website, our research products, and other Services;
- To respond to enquiries submitted through our contact or registration forms, including forwarding internal access requests to our team for manual review, eligibility verification, and follow-up;
- To deliver newsletters, research reports, and other communications that you have requested or that are reasonably related to our Services;
- To verify the identity, residency status, and eligibility of prospective clients in accordance with the IFSCA (AML/CFT/KYC) Guidelines, 2022, the CMI Regulations, the Master Circular for Research Entities, and other applicable regulatory requirements;
- To monitor and record analyst personal trading activities and other internal controls as required under Section 11 of the IFSCA Master Circular for Research Entities;
- To analyze usage of the Website and improve user experience;
- To detect, investigate, and prevent fraudulent, unauthorized, or unlawful activity;
- To enforce our Terms of Use and protect the rights, property, or safety of Equisights, our clients, or others; and
- To comply with legal, regulatory, audit, reporting, and supervisory obligations, including quarterly reporting and annual compliance audit obligations under Chapter XI of the IFSCA Master Circular for Research Entities.
5. Legal Basis for Processing
Where the DPDPA or other applicable law requires a legal basis for processing personal data, we rely on the following:
- Consent: Where you have voluntarily submitted information through a form, subscribed to a newsletter, or otherwise consented to processing.
- Performance of a Contract / Steps Prior to Contract: Where processing is necessary to provide Services you have requested or to take steps at your request prior to entering into a contract.
- Legal and Regulatory Obligations: Where processing is required to comply with the CMI Regulations, IFSCA Master Circular for Research Entities, IFSCA (AML/CFT/KYC) Guidelines 2022, FIU-IND reporting obligations, IFSCA quarterly and annual compliance reporting obligations, taxation laws, or other applicable legal requirements.
- Legitimate Uses: Where processing is necessary for our legitimate business interests — such as ensuring Website security, preventing market abuse, or improving our Services — and such interests are not overridden by your rights.
6. How We Share Information
We do not sell your personal information. We may share information in the following limited circumstances:
- Service Providers: With trusted third-party vendors who support our operations — such as website hosting, email delivery, analytics (including Google Analytics), customer relationship management, and IT security — subject to contractual confidentiality and data protection obligations consistent with our outsourcing policy maintained under Chapter VIII of the IFSCA Master Circular for Research Entities.
- Regulators and Authorities: With IFSCA, SEBI, the Financial Intelligence Unit – India (FIU-IND), and other regulatory, governmental, judicial, or law-enforcement authorities, where required by applicable law, regulation, court order, or legal process — including, without limitation, reporting under the IFSCA (AML/CFT/KYC) Guidelines, 2022.
- Professional Advisors: With our auditors (including the compliance auditor appointed under Regulation 25 of the CMI Regulations), lawyers, company secretaries, compliance consultants, and other professional advisors under duties of confidentiality.
- Corporate Transactions: In connection with a merger, acquisition, restructuring, or change in control of our business, subject to applicable IFSCA prior-approval or intimation requirements under Chapter X of the Master Circular and to confidentiality protections.
- With Your Consent: In any other case where you have provided your consent.
7. International Data Transfers
Equisights is located in India (GIFT City IFSC). Our clients and Website visitors are primarily located in the United States and other international jurisdictions. As a result, personal information may be transferred to, stored in, or accessed from countries outside of your country of residence, including India and the United States.
Such transfers are made only where appropriate safeguards are in place — including, where required, contractual protections — and only to the extent permitted by the DPDPA, the CMI Regulations, the IFSCA (AML/CFT/KYC) Guidelines, 2022, and other applicable law. India has not been designated as a restricted country under current DPDPA notifications; should this change, we will update our practices accordingly.
8. Cookies and Tracking Technologies
We use cookies and similar technologies on the Website. A cookie is a small text file that a website stores on your device. We use cookies for the following purposes:
- Strictly Necessary Cookies: Required for the Website to function (e.g., session management, security).
- Analytics Cookies (Google Analytics): Help us understand how visitors use the Website. Google Analytics may set cookies and collect information as described in Google’s Privacy Policy at https://policies.google.com/privacy. You may opt out of Google Analytics tracking by installing the Google Analytics Opt-Out Browser Add-On at https://tools.google.com/dlpage/gaoptout.
You can control cookies through your browser settings. Disabling certain cookies may impair Website functionality.
9. Data Retention
We retain personal information for as long as reasonably necessary to fulfill the purposes set out in this Policy and to comply with our legal and regulatory obligations. In particular:
- Eight (8) year minimum retention: In accordance with Section 13 of the IFSCA Master Circular for Research Entities (read with Regulation 16 of the CMI Regulations), we maintain books of account, records, and documents relating to our research activities — including communications with clients and prospective clients — in electronic retrieval form for a minimum of eight (8) years.
- Additional retention may apply where required under the Income-tax Act, Companies Act, Limited Liability Partnership Act, AML/CFT/KYC obligations, or for the resolution of disputes and enforcement of agreements.
When personal information is no longer required, we will securely delete, anonymize, or aggregate it.
10. Data Security and Cyber Resilience
Consistent with Regulation 21 of the CMI Regulations and the IFSCA Guidelines on Cyber Security and Cyber Resilience for Regulated Entities in IFSCs dated March 10, 2025, we maintain a cyber security and cyber resilience framework that is proportionate to the scale, nature, and complexity of our operations. This framework includes reasonable technical, administrative, and physical safeguards designed to protect personal information from unauthorized access, disclosure, alteration, or destruction, including access controls, encryption in transit, secure hosting, vendor due diligence, and incident response procedures.
However, no method of transmission over the Internet or electronic storage is completely secure. We cannot guarantee absolute security, and you acknowledge that you provide information to us at your own risk.
11. Your Rights
Subject to applicable law, including the DPDPA, you may have the following rights with respect to your personal information:
- Right to Access: To obtain confirmation of whether we process your personal data and to access such data.
- Right to Correction and Erasure: To request correction of inaccurate or incomplete personal data, and to request erasure where the personal data is no longer necessary for the purpose for which it was collected, subject to the mandatory retention periods set out in Section 9 above.
- Right to Withdraw Consent: To withdraw your consent at any time where processing is based on consent. Withdrawal will not affect the lawfulness of processing carried out prior to withdrawal, nor our ability to retain information required by law.
- Right to Grievance Redressal: To register a complaint with our Compliance Officer / Grievance Officer and, if unresolved, to escalate the matter under the IFSCA Complaint Handling and Grievance Redressal framework (see Section 13 below).
- Right to Nominate: To nominate any other individual to exercise these rights in the event of your death or incapacity, in accordance with the DPDPA.
To exercise any of these rights, please contact us at info@equisights.com. We may need to verify your identity before responding. Certain rights may be limited where retention is required by IFSCA, SEBI, the IFSCA (AML/CFT/KYC) Guidelines, 2022, or other applicable law.
12. Notice for U.S. and International Users
If you are accessing the Website or Services from the United States or another jurisdiction outside India, you acknowledge that your information may be transferred to and processed in India and other countries. Where applicable U.S. state privacy laws grant you rights with respect to your personal information — such as rights to access, delete, or opt out of certain uses — you may exercise those rights by contacting us at info@equisights.com.
We do not engage in the “sale” or “sharing” of personal information as those terms are defined under U.S. state privacy laws such as the California Consumer Privacy Act.
13. Grievance Redressal and Complaint Handling
Equisights has established a complaint handling and grievance redressal mechanism in accordance with Regulation 18 of the CMI Regulations, Chapter IX of the IFSCA Master Circular for Research Entities, and the IFSCA circular titled “Complaint Handling and Grievance Redressal by Regulated Entities in the IFSC” dated December 2, 2024 (as extended).
Complaints relating to data privacy, the Services, or any other aspect of our operations should first be addressed to our Compliance Officer (appointed under Chapter IV of the IFSCA Master Circular for Research Entities) at the following contact:
- Email: info@equisights.com
- Address: GIFT SEZ, GIFT City, Gandhinagar, Gujarat-382050, India
If your complaint is not resolved to your satisfaction within the timelines prescribed under the applicable IFSCA grievance redressal framework, you may escalate the matter to IFSCA in accordance with the procedure specified by the Authority. Details of escalation and timelines are available on the IFSCA website at https://www.ifsca.gov.in.
14. Third-Party Links
The Website may contain links to third-party websites, products, or services. We are not responsible for the privacy practices of third parties, and we encourage you to review their privacy policies before providing any personal information.
15. Changes to this Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, legal or regulatory requirements (including changes to the CMI Regulations or IFSCA circulars), or for other operational reasons. The updated version will be posted on this page. Your continued use of the Website or Services after such update constitutes acceptance of the revised Policy.
16. Contact Us
If you have any questions or concerns about this Privacy Policy or our data practices, please contact us at:
Equisights Research IFSC LLP
GIFT SEZ, GIFT City, Gandhinagar, Gujarat-382050, India
Email: info@equisights.com
IFSCA Registration No.: CMI2025RA0918
