Clearsharp Advisory Services - Privacy Policy
PRIVACY POLICY FOR RIA SERVICES
Last updated : 31 March 2026
Clearsharp Technology Pvt. Ltd (“Company” “our” or “we” or “us”) is a registered investment adviser authorized by the Securities Exchange Board of India, bearing registration number INA000020439. It is a company incorporated under the Companies Act 1956 having its registered office at X - 58, II Floor, Loha Mandi, Naraina New Delhi West Delhi DL 110028 IN and its Corporate Office at Ground Floor, 2A, AMR Tech Park, Bangalore -560068 CIN: U72200DL2011PTC218497.
This Privacy Policy (the “Policy”) describes how the Company (as defined hereinafter) collects, uses, processes, stores, and discloses the information of the User (hereinafter “you”, “your”, or “User”) when you avail the Services on (www.blackbycleartax.in) (the “Platform”).
The Services on the Platform are provided by the Company. Defmacro Software Private Limited (“Cleartax”), a company incorporated under the Companies Act, 2013 having its registered office at Cabin No. 206, Ofis Square Tower, Sushant Lok, Phase-I, Triangle, DLF QE Gurgaon, DLF QE, Haryana, India – 1220028, provides the Platform to the Company. Cleartax operates exclusively as a technology facilitator, enabling users to access the Services through the Platform and Cleartax’s involvement is strictly limited to the provision and maintenance of the Platform technology, and Cleartax does not participate in the delivery of the Services themselves. For abundant clarity, Cleartax has no involvement in, control over, or responsibility for the Services offered to the Users, through the Platform.
By accessing or using the Platform, you agree to the terms of this Policy. If you do not agree with these terms, please do not use the Platform. The Policy extends to the following information: (a) information you provide us, or the information otherwise collected by us through availing of our Services; (b) information collected while you use the Services; (c) information collected from any other source; or (d) information generated while availing the Services. We aim for full transparency on how we gather, use, and share your information.
This Policy (read with the Terms of Use (hereinafter the “Terms”)) constitute a binding and legally enforceable contract between Company and User. Capitalised terms not defined herein, shall have the meaning set out in the Terms.
1. Processing Personal Data
We process your personal data (“Personal Data”) based on the following principles:
1.1. We process your Personal Data only for a lawful purpose for which you have given your consent.
1.2. We take reasonable steps to ensure that the Personal Data we process is accurate, complete, and up-to-date. We rely on the information you provide us, and therefore the accuracy of our records is dependent on the completeness and correctness of your inputs.
1.3. We retain your Personal Data only for as long as is necessary to fulfill the purpose set out in this Policy, or as may be required to be retained under applicable laws.
1.4. We implement reasonable security safeguards to protect your Personal Data from unauthorized access, processing, or loss or data breach.
2. Information we collect
2.1. Personal Data you provide to us:
2.1.1. Identity Data: Name, date of birth, gender, marital status, nationality, PAN card details, Aadhaar card details, signature, photographs and other KYC (Know Your Customer) documents.
2.1.2. Contact Data: Mobile number, email address, postal address.
2.1.3. Financial Data: Bank account details, investment details (e.g., mutual fund holdings, stock portfolios), income details, expense details, credit scores, transaction history, details of financial goals.
2.1.4. Communication Data: Records of your correspondence and communications with us (e.g., through email, in-app chat, customer support calls).
2.2. Information We Collect Automatically:
2.2.1. Device Information: IP address, device type, operating system, unique device identifiers (e.g., IMEI number), mobile network information.
2.2.2. Usage Data: Details of how you use the Platform, including access times, features used, pages viewed, app crashes, and other statistical information.
2.2.3. Location Data: Approximate location derived from your IP address or, with your explicit consent, precise location data from your mobile device.
2.3. Information from Third Parties
In addition to the Personal Data you provide directly, we may also collect and process your information from the following third-party sources. We do this with your specific and informed consent to provide our services and meet our regulatory obligations.
2.3.1. Credit Bureaus: We may obtain your credit score and credit history from credit bureaus to assess your financial health and risk profile.
2.3.2. Account Aggregators: With your explicit consent, we will access your digital financial data—such as bank account details, transaction history, and investments—from various financial institutions via a regulated Account Aggregator. This helps us get a comprehensive view of your financial position to offer tailored advisory services.
2.3.3. Publicly Available Sources: We may use information from publicly accessible databases to perform due diligence and verify your identity as required by law.
3. How We Use Your Information
We do not sell or share your personal or financial information to anyone. However, notwithstanding anything contained in this Policy, you expressly acknowledge, consent and agree to the following terms on information use and further authorize us to access and use your information in the manner set out below:
3.1. To Provide and Manage Services:
3.1.1. To create and manage your account.
3.1.2. To provide financial planning services, including personalized recommendations, portfolio tracking, and goal setting.
3.1.3. To process your transactions and facilitate financial operations within the Platform.
3.1.4. To verify your identity.
3.1.5. To communicate with you regarding your account, the Services, and updates.
3.2. To Improve and Personalize the Platform:
3.2.1. To understand your financial behavior and preferences.
3.2.2. To customize your experience and offer tailored financial products and services.
3.2.3. To analyze app usage and performance, troubleshoot issues, and enhance functionality.
3.3. Security and Fraud Prevention:
3.3.1. To detect and prevent fraudulent activities, unauthorized access, and other illegal activities.
3.3.2. To ensure the security and integrity of our systems and data.
3.4. Legitimate Use:
We may share your information with the following parties, only on a need-to-know basis and for legitimate purposes:
3.4.1. Regulators and Authorities: SEBI, the Reserve Bank of India (RBI), and other government and law enforcement agencies, when required by law or a court order.
3.4.2. Service Providers: Third-party service providers who assist us in our business operations, such as payment processors, KYC agencies, data storage providers, and auditors. These service providers are contractually obligated to maintain the confidentiality of your information.
3.4.3. Affiliated Entities: Our affiliated entities, if any, for business purposes, provided they adhere to this Policy.
3.4.4. Legal & Professional Advisors: Our legal counsel, accountants, and other professional advisors.
3.4.5. To comply with applicable laws.
3.4.6. To establish, exercise, or defend legal claims.
3.5. Marketing and Promotions (with your consent where required):
3.5.1. To send you promotional offers, newsletters, and information about our products and services that may be of interest to you.
3.5.2. To deliver personalized advertisements.
3.5.3. We do not transfer your Personal Data for serving ads, including retargeting or personalized advertising.
3.6. Limited Human Access: No humans have access to read your data except when we obtain explicit agreement, for security reasons (investigating bugs/abuse), or to comply with applicable law.
4. Cookie Policy
4.1. Like many websites, we use cookies, flash cookies, web beacons or similar technologies. “Cookies” are small text files that are stored on your computer or other device when you visit certain online pages that record your preferences and actions. We use cookies for a variety of purposes, including remembering you and your preferences, tracking your use of the Platform, and facilitating your use of Platform. Most web browsers automatically accept cookies, but, if you prefer, you can usually modify your browser setting to decline cookies. However, please note that refusing a cookie may limit your access and/or use of the Platform and Services.
5. Links to Other Sites
5.1. Our Services may provide links to other websites and third-party platforms (“Third-Party Platforms”). Such Third-Party Platforms may collect information about you. We are not responsible for the privacy practices or the content of those linked websites and Third-Party Platforms. We recommend you review the privacy policies of such Third-Party Platforms.
6. Gmail Integration (Optional)
6.1. You can choose to provide explicit consent to connect your Gmail account with the Company account (using Google’s OAuth authentication method), so that the Platform can “read only” the attachments from a small set of specifically authorized senders. The benefit of opting to connect your Gmail account is that your investment information gets automatically updated every month, allowing the Platform to provide accurate analytics on your investments seamlessly. We will never rent or sell your information or data to anyone, nor will we use or transfer data collected via Gmail for serving ads, including retargeting, personalized, or interest-based advertising. You can choose to de-link your Gmail account at any time by writing to adithya.v@clearsharp.in.
7. Data Retention by Us
7.1. We will retain your information only for as long as is necessary for the purposes set out in this Policy. We will retain and use your information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws, including Prevention of Money Laundering Act, 2002 and SEBI (Investment Advisers) Regulations, 2013), to resolve disputes, and enforce our legal agreements and policies.
7.2. The retention period may vary depending on the type of data and the purpose of processing. We encourage you to review the information and inform about any discrepancies and information found to be inaccurate shall be corrected or amended. Please reach out to us at adithya.v@clearsharp.in in case you would like to review the information collected by us.
7.3. You shall at all times, take adequate necessary precautions, at your end, to preserve the integrity and security of your data which shall include and not be limited to your personal information. All information disclosed by you shall be deemed to be disclosed willingly and without any coercion.
8. Information Security
8.1. We are committed to protecting your Personal Data from loss, misuse, or unauthorized access. We have implemented robust electronic and procedural safeguards, including using secure servers, access controls, data encryption, and regular security audits. We use both internal and external resources to review and enhance our security procedures.
8.2. In the event of a personal data breach, we will take all necessary steps to contain and mitigate the breach in accordance with applicable Indian data protection laws.
8.3. While we strive to protect your data, no method of transmission over the internet or electronic storage is 100% secure. Therefore, we cannot guarantee absolute security. We shall not be liable for any loss or damage incurred due to a security breach that is beyond our reasonable control or due to a breach of your own credentials.
8.4. You are solely responsible for ensuring that you maintain back-up copies of all information you submit to us, as we do not provide or store back-up copies.
9. Changes to this Policy
9.1. Please note that this Policy may change from time to time. The “Last Updated” date at the top of the Policy indicates when the most recent modifications were made to the Policy.
9.2. We reserve the right to modify or amend the terms of our Policy from time to time. We will endeavor to post any changes to this Policy on our webpage and, if the changes are significant, to provide a more prominent notice.
9.3. While we will make reasonable efforts to keep you posted on any updates to this Policy, to make sure that you are aware of any changes, we recommend that you review this Policy periodically. In the event we modify this Policy, your continued use of the Platform will signify your acceptance of the modified Policy, and will be adequate proof that you have expressly agreed to the terms of this Policy which shall apply from the date of your first use of the Platform.
10. Withdrawal of Consent by You
10.1. You may choose to withdraw your consent provided hereunder at any point in time. Such withdrawal of consent must be sent in writing to adithya.v@clearsharp.in. In case you later withdraw your consent, we request you not to access the Platform and/or use the Services and also reserve the right to not provide you any Services through the Platform.
11. Governing Law
11.1. This Policy shall be governed by and construed and enforced in accordance with the laws of India.
11.2. Any controversies, conflicts, disputes, or differences arising out of this Policy shall be resolved by arbitration seated at New Delhi in accordance with the Arbitration and Conciliation Act, 1996 by a sole arbitrator appointed by Company. The language of the arbitration shall be English. The decision of the arbitrator shall be final and binding on all the Parties hereto.
11.3. Subject to above, the courts at New Delhi, India shall have exclusive jurisdiction over all issues arising out of this Policy or the use of the Platform or the Services.
12. Contact Us
If there are any questions or grievances regarding this Policy or the safety of your information, you may contact us at the address given below.
Grievance Officer
Name: Adithya V
Address: Ground Floor, 2A, AMR Tech Park, Bangalore -560068
Email: adithya.v@clearsharp.in
Contact No: 9538192952