Legal

Privacy Policy

Last updated: 10 August 2026

1. Introduction & Scope

This Privacy Policy (“Policy”) describes the manner in which we collect, receive, hold, store, use, process, disclose, transfer, retain, protect and dispose of the personal data of visitors to the Website, prospective clients and clients. It applies to personal data collected through the Website and through electronic communications, during the client on-boarding and risk-profiling process, and in the course of providing investment advisory services.

This Policy must be read together with our Website Terms of Use, the Investment Advisory Agreement executed between us and our clients, and any consent or disclosure notices provided to you. We are committed to processing personal information in accordance with the provisions of the Information Technology Act, 2000, the Digital Personal Data Protection Act, 2023, applicable rules, regulations and other laws governing privacy and data protection, as amended from time to time.

By accessing or using the Website, or by sharing your personal data with us, you acknowledge that you have read, understood and consented to the collection, use and disclosure of your personal data in accordance with this Policy. If you do not agree with this Policy, please do not access the Website or avail of our services.

2. Information We Collect

Depending upon your interaction with us, we may collect the following categories of personal data, including, without limitation:

2.1 Identity and contact information. Name, date of birth, gender, photograph, signature, Permanent Account Number (PAN), Aadhaar number, residential and correspondence address, e-mail address and telephone number(s).

2.2 KYC and regulatory information. KYC records and identifiers, KYC Registration Agency (KRA) / Central KYC Records Registry (CKYCRR) data, FATCA/CRS declarations, tax residency status, politically-exposed-person (PEP) status, nominee details, and any document or information required under KYC, AML/CFT or other regulatory norms.

2.3 Financial information. Information necessary to undertake risk profiling and suitability assessment as mandated by SEBI, including your income, net worth, assets and liabilities, existing investments and insurance, investment objectives, investment horizon, liquidity needs, risk appetite, risk tolerance and risk capacity, and your responses to our risk-profiling questionnaire.

2.4 Communications and interaction records. Records of our interactions with you (including with prospective clients prior to on-boarding) where any conversation relating to advice has taken place, such as e-mails, written correspondence, and records of telephonic or video meetings.

2.5 Technical and usage information. When you access the Website, we may automatically collect technical information such as your Internet Protocol (IP) address, browser type and version, device and operating-system information, referring/exit pages, date and time of access, and clickstream data, including through cookies and similar technologies, to enable basic functionality, remember your preferences, measure and improve performance.

3. How We Collect Your Information

Depending upon your interaction with us, we may collect your information in the following ways:

• Directly from you, when you enter into an Investment Advisory Agreement, or otherwise communicate with us;
• From KYC Registration Agencies (KRAs) and the Central KYC Records Registry (CKYCRR), and from other SEBI-registered intermediaries, in accordance with applicable law;
• Automatically, through cookies and similar technologies, when you browse the Website; and
• From authorised third-party service providers engaged by us for KYC, technology, payment or compliance purposes, subject to applicable law.

4. Purpose of Collection and Use of Information

We process your personal data only for lawful purposes connected with our function as a SEBI-registered Investment Adviser and for purposes for which you have given consent or which are otherwise permitted under applicable law. These purposes include, without limitation:

• undertaking client identification and verification (KYC) and complying with AML/CFT obligations;
• carrying out risk profiling and suitability assessment, and providing investment advice that is appropriate to your risk profile;
• entering into and performing the Investment Advisory Agreement, and collecting advisory fees through permitted banking channels;
• maintaining records of advice and client interactions;
• complying with our legal and regulatory obligations, including reporting to SEBI, the IAASB, stock exchanges, the Financial Intelligence Unit – India (FIU-IND) and other authorities;
• responding to and redressing your grievances and queries;
• such other purposes as are reasonably connected with the above and as may be permitted by law or to which you have consented.

5. Consent, Withdrawal, and Other Rights

Where processing is based on consent, we will, at or before the time of collecting your personal data, provide you with a notice describing the personal data sought, the purposes for which it is to be processed, and the manner in which you may exercise your rights, including:

• Right to access information processed by us;
• Right to request correction or updating of inaccurate or incomplete information;
• Right to request deletion or erasure of personal data, subject to applicable legal and regulatory retention requirements;
• Right to withdraw consent for processing where consent is the basis for such processing;
• Right to seek grievance redressal regarding the processing of your personal data; and
• Any other rights available under applicable laws.

You may withdraw your consent at any time by writing to us at anushrisshukla@gmail.com. Upon withdrawal, we will cease processing your personal data for the relevant purpose within a reasonable time, unless such processing is required or authorised under applicable law. The withdrawal of consent will not affect the lawfulness of processing carried out prior to such withdrawal.

6. Disclosure and Sharing of Information

We maintain the confidentiality of your data and do not sell, rent or trade it. We may disclose your personal data only in the following circumstances:

• To regulatory authorities including regulators, statutory authorities, governmental agencies, courts, law enforcement authorities or other competent bodies where required by applicable law or legal process.
• To service providers including our technology service providers, cloud service providers, payment partners, KYC agencies, auditors, consultants and other service providers who assist us in providing the Services. Such entities shall be contractually obligated to maintain appropriate confidentiality and security standards.
• To any other person or entity with your explicit consent or where otherwise permitted by applicable law.

7. Data Storage and Retention

We currently store all data on servers located within India. We retain your personal data and records only for so long as is necessary for the purposes for which it was collected, or as required under applicable law. Where any litigation, investigation, audit or regulatory proceeding is pending or anticipated, we may retain the relevant data for a longer period. Upon expiry of the applicable retention period, we will securely delete, destroy or anonymise your personal data.

8. Changes to This Policy

We may amend this Policy from time to time to reflect changes in law, regulation, technology or our practices. The revised Policy will be posted on the Website with an updated “Last Updated” date and will take effect upon posting. We encourage you to review this Policy periodically. Your continued use of the Website or our services after any amendment constitutes your acceptance of the amended Policy.

9. Grievance Redressal

If you have any questions or concerns regarding this Policy or our processing of your data, you may contact us at anushrisshukla@gmail.com. If you are not satisfied with our response in relation to the processing of your personal data, you may make a complaint to the Data Protection Board of India in the manner prescribed under the DPDP Act.

10. Governing Law and Jurisdiction

This Policy shall be governed by and construed in accordance with the laws of India. Subject to the grievance-redressal and dispute-resolution mechanisms prescribed by SEBI, the courts and tribunals at Raipur, Chhattisgarh shall have jurisdiction in respect of any matter arising out of or in connection with this Policy.