Privacy Policy — MultibaggerShares MMB

Announcements
1

Forum operator: Multibagger Securities Research & Advisory Pvt. Ltd. (CIN: U93090DL2017PTC313815)
SEBI Registered Investment Adviser: Registration No. INA100007736 (valid 29.05.2017 – Perpetual)
Registered office: 410, Pearl Best Heights-1, Netaji Subhash Palace, New Delhi-110034, INDIA

Important — please read: Multibagger Securities Research & Advisory Pvt. Ltd. is a SEBI Registered Investment Adviser. However, this discussion forum is NOT the SEBI IA advisory service. Personalised, suitability-assessed investment advice is delivered only through our paid subscription on www.multibaggershares.com, pursuant to SEBI (Investment Advisers) Regulations, 2013. Posts on this forum — including any posts by the Operator or its staff — are for community discussion and education only. They do not constitute investment advice to any forum user and are not backed by individual risk-profiling, KYC, or the client-advisor relationship required by SEBI IA Regulations. If you are looking for investment advice, subscribe at https://multibaggershares.com/ or consult any SEBI-registered Investment Adviser or Research Analyst.

Effective date: 2026-04-16
Version: 1.1
Data Fiduciary: Multibagger Securities Research & Advisory Pvt. Ltd. (CIN: U93090DL2017PTC313815)

This Privacy Policy describes how Multibagger Securities Research & Advisory Pvt. Ltd. (“we”, “us”, “Data Fiduciary”) collects, uses, discloses, and protects personal data of Users of the MultibaggerShares MMB forum, in accordance with the Digital Personal Data Protection Act, 2023 (“DPDP Act”), the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, and — for Users who are also IA Service clients — the SEBI (Investment Advisers) Regulations, 2013.

2.1 Data Fiduciary

2.2 Separation between Forum and IA Service

The Forum is operated separately from our SEBI IA Service. Data collected when you use the Forum is processed only for operating the Forum and is not merged with IA Service client data unless you have separately subscribed to the IA Service and given consent in the IA onboarding process.

2.3 Personal Data We Collect

When you register, we collect:

  • Email address (required, used for login, notifications, and account recovery)
  • Username (required, publicly displayed)
  • Password (hashed; we never store or see plain-text passwords)
  • Optional profile fields you choose to provide (display name, location, bio, profile picture, website)

When you use the Forum we automatically collect:

  • IP address and approximate location derived from it
  • Browser and device information (user agent, screen size, operating system)
  • Usage data (pages visited, posts read, time on site, interaction events)
  • Cookies and similar technologies (session, preferences, analytics)

When you post, all content you submit is public and visible to any Forum visitor. Do not include information you are not comfortable making public.

2.4 Purposes of Processing

We process your personal data for the following purposes, on the legal grounds indicated (Sections 6 and 7 of the DPDP Act):

  • Providing and operating the Forum (consent + legitimate use)
  • Authenticating your account and preventing unauthorised access (legitimate use)
  • Sending transactional emails (verification, password reset, notifications) (consent)
  • Complying with legal obligations, including SEBI record-retention requirements where applicable (statutory compliance)
  • Detecting and preventing fraud, spam, and abuse (legitimate use, public interest)
  • Analytics and product improvement in aggregated form (consent)
  • Enforcing these Terms (legitimate use)

2.5 Sharing of Personal Data

We do not sell your personal data. We share personal data only with:

  • Discourse Inc. (our forum hosting provider) under contractual obligations of confidentiality and DPDP Act-compliant data processing
  • Email delivery providers solely to transmit transactional emails to you
  • Analytics providers (if enabled) in aggregated, pseudonymised form
  • Law-enforcement, SEBI, or other regulatory authorities pursuant to a valid legal order
  • A successor entity in the event of a merger, acquisition, or sale of assets

2.6 Cross-Border Transfer

The Forum is hosted by Discourse Inc., with data centres in Singapore and/or the United States. By using the Forum, you consent to transfer of your personal data outside India for hosting purposes. Discourse Inc. provides DPDP Act and GDPR-equivalent protections.

2.7 Retention

We retain your personal data for as long as your account is active. If you close your account, we retain minimal records (email, username, IP) for 90 days to permit reactivation, and thereafter delete or anonymise. Public posts may remain visible after account closure, with the author shown as “anonymous”, unless you separately request deletion of those posts.

Certain data may be retained longer if required by law — for example, moderation logs for 3 years to evidence compliance, and IA-related records for 5 years per SEBI IA Regulations where applicable.

2.8 Your Rights as a Data Principal

Under the DPDP Act you have the right to:

  • Access the personal data we hold about you
  • Request correction or updating of inaccurate personal data
  • Request erasure of your personal data
  • Withdraw your consent to processing at any time
  • Nominate another individual to exercise these rights in the event of your death or incapacity
  • Lodge a complaint with the Data Protection Board of India

To exercise any of these rights, email ankit@multibaggershares.com with the subject line “DPDP Rights Request”. We will respond within 30 days.

2.9 Security

We implement reasonable security practices and procedures in accordance with ISO 27001-equivalent standards: encryption of passwords (bcrypt), TLS for all connections, regular backups, access controls, and security patches. However, no system is impervious to attack and you acknowledge that transmission of data over the internet carries inherent risk.

2.10 Cookies

We use cookies for session management, preferences, and limited analytics. You may disable cookies in your browser, but some Forum features (login) will not work. Cookie categories:

  • Strictly necessary: authentication, CSRF protection (cannot be disabled)
  • Preferences: theme, language, notification settings
  • Analytics: aggregated, anonymised usage statistics (may be disabled in account settings)

2.11 Children

The Forum is intended for users aged 18 and above. We do not knowingly collect personal data from children. If we become aware that a child has created an account, we will terminate the account and delete associated data.

2.12 Changes to This Policy

We may update this Privacy Policy periodically. The “Effective date” at the top of this document will reflect the most recent revision. Material changes will be notified via an announcement thread and, where required by law, by email.

2.13 Contact — Data Fiduciary

Multibagger Securities Research & Advisory Pvt. Ltd.
410, Pearl Best Heights-1, Netaji Subhash Palace, New Delhi-110034, INDIA
011-41634643
ankit@multibaggershares.com (privacy & grievances) | info@multibaggershares.com (general)