Client Agreement / Terms of Use
Welcome to www.sptulsian.com. This website, including the mobile app SPTulsian.com (the "Site") is operated by Sptulsian.com Investment Adviser, division of SPT Investment Advisory Services Private Limited (hereinafter referred to as "We" / "Us" / "Our"), a SEBI Registered Investment Adviser (INA000000326), to service Members and Viewers. The term "Member or Members" means and includes all registered users of the Site who have paid due consideration for the use of the Site and its services. The term "You" / "User" / "Users" / "Viewer" / "Viewers" means and includes all those persons who gain access to the Site and includes all Members (as defined hereinabove).
By using our Site, you agree to comply with and be bound by the following terms of use. Please review the following terms carefully. If you do not agree to these terms, you should not review information or use services of this Site.
You agree to the terms and conditions outlined in this Terms of Use Agreement ("Agreement") with respect to our Site. This Agreement constitutes the entire and only agreement between us and you, and supersedes all prior or contemporaneous agreements, representations, warranties and understandings with respect to the Site, the content, services provided by or through the Site, and the subject matter of this Agreement. However, we reserve our rights to carry out the periodical changes, to our site, which we deem fit and required for the benefits and larger interests of our members.
The content, text, layout, organization, graphics, design, video, compilation, digital conversion and other matters related to the Site are protected under applicable copyrights, trademarks and other proprietary (including but not limited to intellectual property) rights. The copying, redistribution, use or publication by you of any such matters or any part of the Site, except as allowed by Point 4 below, is strictly prohibited. You do not acquire ownership rights to any content, document, information or other materials viewed through the Site. The posting of information on the Site does not constitute a waiver of any right in such information. Option to read articles on site in multiple languages is by an automated tool and hence may be prone to conversion errors (all articles written in English only).
All the Site items are our trademarks or registered trademarks or property. All rights reserved.
The viewing, printing or downloading of any content, text, information, opinion, material, graphic, form or document from the Site grants you only a limited, non-exclusive license for use, solely by you (individual), for your own personal use and not for re-publication, distribution, assignment, sub-license, sale, preparation of derivative works or other use or commercial purpose. Since membership is for individual's personal use, it cannot be taken by a corporate or shared by people. No part of any content, form or document may be reproduced in any form or incorporated into any information retrieval system, electronic or physical, other than for your personal use (but not for resale or redistribution). Any violation intentionally or unintentionally will result in account termination without refund for any subscription fees already paid.
We reserve the unqualified and unlimited right to amend, modify, alter, edit, delete, suspend or discontinue, temporarily or permanently, the Site or any portion thereof and/or the information, statistics, services, and/or materials contained and provided on the Site or any part thereof, with or without prior notice. Members and Viewers understand and agree we shall not be liable in any manner whatsoever to them or to any third party for any such amendment, modification, alteration, editing, deletion, suspension or discontinuance of the Site. Any such modification would be carried out at our discretion and not entail Members for a refund of the subscription fees paid by them previously.
You agree to indemnify, defend and hold us and our partners, attorneys, staff and affiliates (collectively, "Affiliated Parties") harmless from any liability, loss, claim and expense, including reasonable attorney's fees, related to your violation of this Agreement or use of the Site.
Your right to use the Site is not transferable. Any password or right given to you to obtain information, content, document or messages (via any channel such as SMS, Email, Mobile App, Browser Notifications, Whatsapp, Telegram and other) is not transferable. Any violation in the same will be considered as a breach of Agreement and liable to immediate account termination without any refund of the active subscription.
The information contained and provided on this Site is of a general nature and it is not our intention to provide any professional advice, solicitation or offer to sell, recommend or purchase securities to Members and/or Viewers of the Site.
All information, statements, opinions, statistics, services and materials contained, provided and posted on the Site are contained, provided and posted on an "as-is," "as available," basis and all warranties, express or implied, are disclaimed. You must exercise due caution and must verify any and all information sought to be relied upon and/or seek independent professional advice before entering into any commercial or business relationship or transaction with any person or entity, and /or any other party or make any investment or enter into any financial obligation based solely on any information, statement or opinion which is contained, provided, posted or expressed on the Site.
The Site contains information, statements, opinions, statistics, and materials that have been obtained from sources believed to be reliable and an effort has been made to provide accurate information. However, We make no guarantees whatsoever regarding the timeliness, completeness, accuracy, adequacy, fullness, functionality or reliability of the information, statements, opinions, and materials contained, provided and posted on any section of the Site.
We or representative of the company or associated parties may have interest / holdings in some of the calls given on the website. This disclosure applies to all sections of the website unless mentioned otherwise explicitly. Calls given in the various sections are given based on fundamentals and/or technical and/or recent new flows and/or trends, as observed in the market and in the stock.
The information and services may contain bugs, errors, problems or other limitations. We and our affiliated parties have no liability whatsoever for your use of any information or service. In particular, but not as a limitation thereof, we and our affiliated parties are not liable for any indirect, special, incidental or consequential damages (including damages for loss of business, loss of profits, litigation, or the like), whether based on breach of contract, breach of warranty, tort (including negligence) or otherwise, even if advised of the possibility of such damages. This Site and the information would not be provided without such limitations. No advice or information, whether oral or written, obtained by you from us through the Site shall create any warranty, representation or guarantee not expressly stated in this Agreement.
All responsibility or liability for any damages caused by viruses contained within the electronic file containing the content, form or document is disclaimed. We will not be liable to you for any incidental, special or consequential damages of any kind that may result from use of or inability to use our Site.
The Member or Viewer of the Site undertakes to indemnify us and our partners for any loss suffered on account of use or misuse of content or services sold on the Site.
You understand and agree that any action taken or decision made based on the information, statements and/or opinions contained, provided, posted, made or expressed on the Site will be taken or made by you at your own risk without any recourse whatsoever to us. The information, statements, opinions and materials contained on the Site are for private use only and not intended for use in any commercial activity or purpose.
Equity investments are risky in nature, where substantial portion of investments may get eroded, including loss of capital. Hence, same should be made within the risk tolerance and financial capacity of the member.
Derivative (Future & Option) instruments are very high risk instrument in nature, where losses are not only restricted to the capital/margin and may exceed much beyond the capital/margin amount. Hence, trades must be entered into and executed within the risk tolerance and financial capacity of the member. We advise to refrain from this type of trading and even if they do so, the same is at high risk, cost and consequences of the members.
It is also advised not to take position or to exit from your investment and trading positions, which exceed your risk appetite, financial tolerance and comfort level, as and when it happens.
We reserve the right, and you authorize us, to the use and assignment of all information regarding Site uses by you and all information provided by you in any manner consistent with our Privacy Policy.
We allow access to or advertise third-party merchant sites ("Merchants") from which you may purchase certain goods or services. You understand that we do not operate or control the products or services offered by Merchants. Merchants are responsible for all aspects of order processing, fulfilment, billing and customer service. We are not a party to the transactions entered into between you and Merchants. You agree that use of such Merchants is at your sole risk and is without warranties of any kind by us, expressed, implied or otherwise including warranties of title, fitness for purpose, merchantability or non-infringement. Under no circumstances, are we liable for any damages arising from the transactions between you and merchants or for any information appearing on merchant sites or any other site linked to our Site.
All rules, policies (including privacy policies) and operating procedures of Merchants will apply to you while on such sites. We are not responsible for information provided by you to Merchants. We and the Merchants are independent contractors and neither party has authority to make any representations or commitments on behalf of the other.
Our Privacy Policy, as it may change from time to time, is a part of this Agreement.
You represent and warrant that if you are purchasing something or some service from us or from Merchants that (i) any credit information you supply is true and complete, (ii) charges incurred by you will be honoured by your credit card company / bank, and (iii) you will pay the charges incurred by you at the posted prices, including any applicable taxes. For your own safety you may be asked to complete additional verifications such as 'Verified by Visa' or '3D Secure' to verify your identity. Additionally, there is no money back policy in case you do not find the Site useful or are dissatisfied with our service. We strictly follow a no-refund policy. Once an order is placed and processed, it cannot be cancelled. All orders are final and any dispute or cancellation will be resolved at our sole discretion. Since we provide a B2C service as stated in Point 4, no GST input credit will be available for GST paid as applicable for all B2C services. You will receive invoice with our PAN and GST number but will NOT have your GST number to avail of input credit. You cannot use our services for commercial usage (kindly contact us on info@sptulsian.com for additional information on commercial or business usage of our services).
The Site contains links to other websites. We are not responsible for the content, accuracy or opinions express in such websites, and such websites are not investigated, monitored or checked for accuracy or completeness by us. Inclusion of any linked website on our Site does not imply approval or endorsement of the linked website by us. If you decide to leave our Site and access these third-party websites, you do so at your own risk.
The Site contains information, media clippings and press releases about us, our organization and employees. While this information was believed to be accurate as of the date prepared, we disclaim any duty or obligation to update this information, media clippings or any press releases. Information about companies other than ours contained in the media clippings, press release or otherwise, should not be relied upon as being provided or endorsed by us.
Subscription charges changes will always be made on prospective basis. Subscription charges provide Members access to Member Zone of the Site while other columns can be viewed for free. The price in effect when we receive your order will be the price that is charged for subscription. Upgrade offers and special promotions are subject to change. We are not responsible for typographic errors. The subscription charges applicable are as per the FAQs page and are pre payable for all orders. We reserve the right to amend our fees from time to time and fees applicable at time of making payment will apply. The validity of the advisory services is as per the chosen plan and client can renew the services prior to expiry to avoid interruption in services. The terms applicable at time of renewal will apply for the said renewal payment and services.
As per SEBI regulations, we charge fees under the Fixed fees mode where the maximum fees that may be charged cannot exceed Rs. 1.25 lakhs per annum per client. We do not offer services under the Asset Under Advice (AUA) mode. We do not accept payment in cash. There is no trial offer for our services. Additionally, there is no money back policy in case you do not find the Site useful or are dissatisfied with our service. We strictly follow a no-refund policy. Once an order is placed and processed, it cannot be cancelled. All orders are final and any dispute or cancellation will be resolved at our sole discretion. We also reserve our right to disallow anyone from becoming a member on the site to maintain site decorum or any other reason as deemed fit by us. In case the membership is disapproved, the payment will be refunded to the customer.
Each subscription plan comes with a pre specified query quota (exact number for each plan is available on Step 2 of Registration where you pick your subscription plan). You can use this quota for posting queries in Stock Query section within the duration of your subscription. You can also purchase additional Stock Query Posting quota and get as many queries you need to post. Recharged queries are valid for the duration of the order, just like the queries that came with the original order.
Answering, refraining from answering or deleting any question or comment posted in the Stock Query column of the Site is at the sole discretion of our Editor and CEO and cannot be challenged. We shall not be held responsible for this. We may, at our sole discretion, impose a limit on the number of queries a user may post as we deem fit. This may be in the form of hourly, daily, monthly or subscription period based limit for the number of queries a user may post. Any query that is deleted, for whatever reason, will still consume limit from the query quota alloted. No Stock Query posting is allowed on Saturdays and Sundays and Market Holidays, and rule may be updated from time to time. Since Stock Query is only attended to by Mr. S P Tulsian, if Mr. S P Tulsian is not available (eg. due to ill health or personal commitment or is travelling or any other commitment) then Stock Query posting will be disabled for that duration as well. Based on the feedback we get for queries of a particular Member, his Stock Query limit may be adjusted appropriately, for example, if someone is spoiling decorum on the site and other Members express the same by voting on his/her queries, then limit for Stock Query posting may be reduced or terminated, as deemed fit by us, at our sole discretion. We may update rules to allow or restrict transfer of queries between members. There will be a processing charge for the same, if permitted, which will be based on the number of queries being transferred. Subscription charges or any part of it will not be adjusted towards change or reduction of Stock Query quota alloted to the Member.
Additional, the recharged queries are added to your current order and hence will lapse with the expiry of the current order. So recharge accordingly. The recharge page will show you when your current order is expiring so can plan accordingly. No carry forward of query quota is permitted to subsequent orders and no refund shall be issued for unused queries which lapse when order expires.
Change to the username, once provided at the time of registration, is not allowed. Multiple login with the same username and password is also not allowed on the Site. We may impose restriction on an Account if it is found that the account is being used from more than normal number of devices a typical Member would use. In extreme cases, account may be terminated without any refund for violation of this is single personal use rule. We may reward users for referral of new members to our website (who have never registered or been a member before). Any such points earned will be redeemable on future renewals or payments on the website. There is no cash value for the points accumulated. The terms of usage of the points will be as mentioned in each of the sections of the site and may be updated from time to time, at our sole discretion.
The subscription is for the use by the registered individual only and the service is a pure advisory service only. Hence we do not seek any rights of Power of Attorney from our clients in any form whatsoever. We do not manage your shares or securities or funds in any manner whatsoever so in the case of death or disability of the client, the willful owner of the assets may refer to the subscription for decision making as an intermin measure. Further, there is no assets held with us which requires transfer or nomination of any kind whatsoever.
All information is updated on the website only and alerts are additional benefits given to Members. Alerts may be sent in various forms and we may impose limits on the number of channels or combination of channels that Member can subscribe to for alerts. In either case, we do not hold responsibility for timely delivery of any alerts but do best efforts to deliver them as soon as possible. If you do not receive any of the alerts for our recommendations or columns for any reason, we will not be held liable or accountable for any monetary or non-monetary loss suffered by you. Any delay in the receipt of the alerts is also not our responsibility. Alerts may be changed or cancelled without notice and subscription should not be considered as right of alerts. Subscription only entails user access to site and does not guarantee any alerts in any form. Subscription charges or any part of it will not be adjusted towards non-receipt or delay in receipt of the alerts. We may impose additional charges for per SMS sent to members and members will need to have a SMS credit balance in account to get SMS. SMS balance will be valid for current subscription only. If member, renews account before older expires expires, SMS credit balance will be carried forward. Once an account expires, SMS balance will lapse and member will need to recharge the SMS credit account if member reactivates account later, to receive SMS. Our SMS alerts are subject to guidelines of Telecom Regulatory Authority of India (TRAI) and Department of Telecom (DoT) as well as to the terms and conditions of third-party merchants, services of whom we avail of. By signing up for SMS alerts, you agree to allow us to send you SMS alerts, even if your number is registered in the Do Not Disturb (DND) registry.
We do not commit, guarantee, assure or promise any returns based on our recommendations. You act solely based on your individual risk-bearing ability and your perception of the equities market.
This Agreement shall be treated as though it were executed and performed in Mumbai, India, and shall be governed by and construed in accordance with the local laws (without regard to conflict of law principles). Any cause of action by you with respect to the Site (and/or any information or services related thereto) must be instituted within one (1) week after the cause of action arose or be forever waived and barred. All actions shall be subject to the limitations set forth in Points 8 and 10 above. The language in this Agreement shall be interpreted as to its fair meaning and not strictly for or against either party. All legal proceedings arising out of or in connection with this Agreement shall be subject to Mumbai jurisdiction only. You expressly submit to the exclusive jurisdiction of said courts.
Should any part of this Agreement be held invalid or unenforceable, that portion shall be construed consistent with applicable law and the remaining portions shall remain in full force and effect. To the extent that anything in or associated with the Site is in conflict or inconsistent with this Agreement, this Agreement shall take precedence. Our failure to enforce any provision of this Agreement shall not be deemed a waiver of such provision nor of the right to enforce such provision.
We reserves the right to add, alter, modify, withdraw , replace, wholly or in part, any of the contents and/or columns and/or sections by any other contents and/or columns and/or sections, whether similar or not, or withdraw it altogether without any prior notice. In case of dispute with any party, our decision will be binding and final. This agreement may be amended by mutual consent of the parties. We may chose modifications without consent to comply with any regulatory updates / changes / compliances as applicable from time to time.
Statutory Disclosures
1. SPT Investment Advisory Services Private Limited, having its registered office at 6/40, Tardeo AC Market, Tardeo, Mumbai – 400 034, is a SEBI Registered Investment Advisor (SEBI Registration Number: INA000000326), owns and operates www.sptulsian.com. We have been operating this website since 2007 and got SEBI registration in 2013, when the Investment Advisor regulations were first introduced by SEBI. We provide purely listed stocks advisory services only, to our clients, through this website only, by charging Subscription/Membership Fees, as our Professional charges and do not offer any execution or distribution services, of any nature whatsoever to our clients. Clients are required to handle their funds on their own, with their respective stock brokers and they themselves are responsible for executing the trades at their own end. We do not have any affiliation with any other intermediaries and we do not advise any broker to our clients for executing their trades as well.
Disciplinary History: SEBI has not imposed any penalties against the company or its directors for any economic offence and / or for violation of any securities laws, either in respect to advisory services being offered by us, or any other matter related to capital market, as on date.
As per SEBI Circular dated 13 Dec 2021, below is the summary of the complaints received against the Investment Advisor during the previous month -
| Number of Complaints | ||||
| At the beginning of the month | Received during the month | Resolved during the month | Pending at the end of the month | Reasons for Pendency |
| 0 | 0 | 0 | 0 | - |
To view all complaints data, please click here.
2. In case of queries or complaint, you can a) Contact our customer support team from the Contact Us for a quick resolution. b) Write to the Compliance Officer from the Contact Us page. c) File a complaint to the company from the Contact Us page if not satisfied with the reply of the team and/or the Compliance Officer. d) File complaints on SCORES – Easy & quick. Steps for the same are - Register on SCORES portal. Mandatory details for filing complaints on SCORES are Name, PAN, Address, Mobile Number, Email ID. Benefits: Effective communication and Speedy redressal of the grievances. In case client is not satisfied with the SCORES reply / resolution, they can escalate the matter to Smart ODR portal as well.
3. SPT Investment Advisory Services Private Limited does not receive any consideration by way of remuneration or compensation or in any other form whatsoever, received or receivable by it or any of its associates or subsidiaries, as we are not providing any distribution or execution services, or as professional fees, in respect of the stocks or securities for which the investment advice is provided to the client.
4. SPT Investment Advisory Services Private Limited, does not recommend the services of a stock broker or other intermediary to their clients and hence are not in receipt of any consideration by way of remuneration or compensation or in any other form whatsoever. The respective client has to avail the services of such intermediary of their own.
5. SPT Investment Advisory Services Private Limited discloses to the client, of its holding or position, as also of its Associates and Directors, if any, in the financial products or securities which are subject matter of our advice.
6. SPT Investment Advisory Services Private Limited discloses that there are no actual or potential conflicts of interest arising from any connection to or association with any issuer of products/securities, including any material information or facts that might compromise our objectivity or independence in carrying out investment advisory services. SPT Investment Advisory Services Private Limited shall disclosure future conflicts, whenever the same shall arise.
7. SPT Investment Advisory Services Private Limited are providing required facts / reasoning for stocks recommended in the requisite section of the website.
8. SPT Investment Advisory Services Private Limited would like to state that equity investment in stock market in general, is a risky investment where significant capital erosion is possible. For leveraged positions, such as F&O, losses may even exceed initial capital. Hence, act in equities as per your risk appetite only.
9. We maintain all records of clients digitally as per applicable SEBI, PMLA and other applicable regulations and the same is saved in records for atleast 5-10 years as applicable under different regulations.
10. We undertake to abide by the Code of Conduct as specified in the Third Schedule of the SEBI Investment Advisers Regulations, 2013.
11. Audit Reports
| Sr. No. | Financial Year | Compliance Audit Status | Remarks, If any |
| 1 | FY 2020-21 | Conducted | NIL Remarks |
| 2 | FY 2021-22 | Conducted | NIL Remarks |
| 3 | FY 2022-23 | Conducted | NIL Remarks |
| 4 | FY 2023-24 | Conducted | NIL Remarks |