Alphaniti Fintech Private Ltd is a financial technology company. It is engaged in providing technology services, products and offering under its Technology Services Division. www.alphaniti.com is the platform developed and maintained by the Technology Services Division. It also has a separate Investment Advisory unit under Alphaniti Investment Advisory Division (“AIA”) bearing Sebi registration no INA000009481.

Brainstormerz Research and Data Analytics Private Limited is a 100 pc subsidiary of Alphaniti Fintech Private Ltd and is a Sebi registered Research Analyst company bearing Sebi registration number INH000009719.

User Consent and Agreement

By submitting Personal Information through our Site or Services, you agree to the terms of this Privacy Policy, and you expressly give your voluntary consent to the collection, use and disclosure of the Personal Information in accordance with this Privacy Policy.

Scope of services offered

The platform offers a complete Do-It-Yourself (‘DIY”) experience to individual users. All investment themes/opportunities listed on the platform have been availed from SEBI-registered entities and the platform is simply responsible for displaying the investment themes/opportunities and provide a seamless digital execution experience to the users of the platform.

The platform is not responsible for verifying the accuracy of any data presented on the platform by the SEBI registered entities and users should do their own due diligence before any investment decision.

Rules for Use of the Site and/or Services

While using the Site or Services, you shall be subject to the restrictions set out below and under law, and AFPL reserves the right to take any action as may be deemed necessary in the event of any breach or failure to adhere to any such restrictions:

• You agree not to attempt to reverse-engineer, disseminate, copy, exploit, or represent yourself as an agent or reseller of the Site and the Services, or any part thereof;
• You agree not to misrepresent yourself as or impersonate any other person, or otherwise cause harm to any person, or host, display, upload, modify, publish, transmit, store, update or share any information that
• belongs to another person,
• infringes any intellectual property rights,
• deceives or misleads the addressee about the origin of the message or knowingly and intentionally communicates any information which is patently false or misleading in nature but may reasonably be perceived as a fact,
• threatens the unity, integrity, defence, security or sovereignty of India, friendly relations with foreign States, or public order, or causes incitement to the commission of any cognisable offence or prevents investigation of any offence or is insulting other nation, or,
• is patently false and untrue, and is written or published in any form, with the intent to mislead or harass a person, entity or agency for financial gain or to cause any injury to any person.
• You agree not to upload or transmit any vulgar, obscene, abusive, defamatory, libellous, invasive, or unlawful content, including content which is harmful to children, objectionable or results in a breach of privacy of any other person;
• You agree not to use or abuse the Site or Services for or in relation to any illegal or unlawful purposes including fraud, embezzlement, money laundering, etc.;
• You agree not to carry out or facilitate any actions which result in a detrimental effect on the Site or the Services or any related computer resource, including DDoS attacks, data security breaches, or otherwise any disruption to the servers, hardware, or network of any other person or the Site or the Services;
• You agree that AFPL shall be the sole and exclusive owner of the intellectual property and any proprietary information made available or accessible through the Site or the Services;
• You agree not to violate any applicable laws, whether or not intended by you;
• You represent and warrant that you possess the legal right and ability to enter into these terms and to use the Site and the Services in accordance with these terms.

Risk Factors

The value of the investments made by the subscribed user and the expected returns may be affected generally by factors affecting financial and securities markets, such as price and volume, volatility in interest rates, currency exchange rates, changes in regulatory and administrative policies of the Government or any other appropriate authority (including tax laws) or other political, economic, and other developments as detailed below:

• Companies Risk: The performance of the model investment themes will depend upon the business performance of the companies included in that investment theme and their prospects. AIA focuses on studying business and sustainability with a focus on studying the balance sheet will help the AIA in mitigating these sector or company risks.
• Valuation Risk: AIA will assess the valuations for the stocks included in the investment themes from varied valuation parameters in order to establish whether the valuations are reasonable while creating the model investment themes and reassess the same from time to time.
• Market Risk: AIA endeavours to create an investment theme using bottom-up fundamental research rather than trying to time the markets. However, in order to mitigate Market Risk, the AIA will monitor and analyse the market and economic circumstances from time to time that may affect the performance of these investment themes.
• Liquidity Risk: While investing in equities, liquidity constraints are potential near-term risks while investing and disinvesting. The AIA endeavours to mitigate these risks by investing and creating an investment theme with a medium to long-term time horizon.
• Service Provider Risk - AIA is reliant upon the performance of third-party service providers for their functions. Weak control over technology used in the third-party arrangement may result in threats to the security and the integrity of systems and resources, which can have a materially detrimental impact on the operations of the AIA. These issues could result in unauthorized transactions or the inability to transact business as expected. AIA endeavours to mitigate these risks by entering into the arrangement with regulated entities and/or incorporating an indemnity clause in the agreement entered with service providers.
• Other Risks: Certain investment themes offered by AIA may be suitable for clients with an “Aggressive”/ “High Risk” risk profile which carries a risk of substantial or permanent capital loss. AIA does not offer any assured/guaranteed returns. Investments in securities are subject to market risk. Please read the Key Information and Disclosure Document carefully before investing.
• Neither the Company nor any of its holding company, associate concerns or affiliates or their respective directors, employees, or representatives shall be liable for any direct, indirect, special, incidental, consequential, punitive, or exemplary damages, including lost profits arising in any way from the information contained in this material.
• Any sort of graphical representations, recommendations, feedback, and reviews, provided on the platform, are in no way, either a guarantee for the performance of the investment theme or an assessment of the investment theme, or the investment theme’s underlying securities’ creditworthiness. The Company does not furnish any guarantees, warranties, or representations, express or implied, on any investment theme offered through the platform. The Company accepts no liability for any damages or losses however caused, in connection with investments made through the platform.
• The Company does not provide any promise or assurance of favourable view for a particular industry or sector or business group in any manner. The investor is requested to take into consideration all the risk factors including their financial condition, suitability to risk-return profile, and take professional advice before investing. The analysis for various investment themes or reports created by the AIA certify that all information/ material therein accurately reflect his or her personal views about the subject company or companies and its or their securities, and no part of his or her compensation was, is, or will be, directly or indirectly related to the AIA in various investment theme or reports created by the AIA. No part of this material may be duplicated in any form and/ or redistributed without the prior written consent of the AIA.
• The information contained on this platform should not be reproduced or redistributed or passed on directly or indirectly as advice on behalf of the platform or AIA or in any form to any other person or published, copied, in whole or in part, for any purpose.

Information you provided to us

• If you provide us feedback or contact us via e-mail on customercare@alphaniti.com, we will collect your name and e-mail address, as well as any other content included in the e-mail, in order to send you a reply.
• When you participate in one of our surveys, we may collect additional information.
• We may collect Personal Information from you, such as your first and last name, phone, e-mail address, age etc. when you apply for creating/opening an account with one of our partners - brokers, advisors etc.
• We may also collect Personal Information on the Site or through the Services when we make clear that we are collecting it and you voluntarily provide the same, for example when you submit an application for employment.
• You must ensure to recheck the information or data being provided to us. In case if any of the data/information is found to be inaccurate or incorrect, the same shall be informed to us for immediate amendment. We shall not be responsible for the authenticity of any information including personal information submitted to us.

Information collected via technology

• To make our Site and Application more useful to you, our servers (which may be hosted by a third-party service provider) collect information from you, including your browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), and domain name.
• We may use third party service providers to help us analyse certain online activities. For example, these service providers may help us analyse visitor activity on the Site. We may permit these service providers to use cookies and other AFPL to perform these services for us.

Use of Personal Information

In general, any personal Information that you may submit to us regarding yourself or your company, may be used either to respond to requests that you make, or to aid us in serving you better. We may use such Personal Information in the following ways:

• To identify you as a user in our system;
• To provide improved administration of our Site and Services;
• To provide the Services you request;
• To improve the quality of experience when you interact with our Site and Services;
• To send you e-mail notifications;
• To send newsletters, surveys, offers, and other promotional materials related to our Services and for other marketing purposes.
• Protect our services and our users.
• Market and customer analysis, market research and statistics.
• To prevent and detect fraud or abuse of our services as well as to prevent, detect and investigate any potential unlawful or prohibited activities.

Your demographic information and PAN will be utilised for and shared with various SEBI registered entities for various regulatory purposes (KYC, AML etc) as required by applicable SEBI regulations. Your financial information (such as value of holdings, annual income etc) will also be utilised and shared with the said SEBI registered entities for the aforesaid purposes and tracking purposes.

Disclosure to third parties

We may be required from time to time to disclose any personal information collected by us to governmental or judicial bodies or agencies or our regulators based on their requirement to comply with the applicable laws including cyber laws. We may share your information including personal information to third parties to carry out technical, logistical and other functions on our behalf. (e.g., Sending emails or newsletters to users).

Creation of anonymous information

We may create Anonymous Information records from Personal Information by excluding information (such as the name and email). We use this Anonymous Information to analyse request and usage patterns so that we may enhance the content of our Services and improve Site navigation. AFPL reserves the right to use Anonymous Information for any purpose and disclose Anonymous Information to third parties at its sole discretion.

Third party websites

When you click on a link to any other website or location, you will leave our Site and go to another site and another entity may collect Personal Information or Anonymous Information from you. We have no control over, do not review, and cannot be held responsible for, these outside websites or their content. Please be aware that the terms of this Privacy Policy do not apply to these outside websites or content, or to any collection of information after you click on links to such outside websites.

Cookies

"Cookies" are pieces of information that a browser can record after visiting a web site. We may use cookies for technical purposes such as to enable better navigation through our site, or to store user preferences for interacting with the site. If you turn off the option to have cookies stored on your browser, it will affect your experience on alphaniti.com

Security of your information

AFPL is committed to protecting the security and privacy of your Personal Information. We endeavour to have suitable technical, operational and physical security controls and measures to protect information collected by us that are commensurate with the nature of our business at all times. We use a variety of industry-standard security AFPL and procedures to help protect your Personal Information from unauthorized access, use, or disclosure, and periodically review the same. In the event of any breach of our security control measures resulting in unauthorised access to your information, we will endeavour to inform you of the extent of such breach, subject to applicable law and cooperation with the relevant authorities. Further, despite our efforts to protect your information, if unauthorized persons breach security control measures and illegally use such sensitive/personal data or information, AFPL, its affiliates and directors shall not be held responsible/liable.

Retention of information/data

It may be noted that we may retain the data as may be provided to us till such time as may be provided under the law and as required to efficiently provide service to our users.

Amendments/ Modifications

This Privacy Policy available on our website is current and valid. However, AFPL reserves the right to amend/modify any of the sections of this policy at any time and the general public are requested to keep themselves updated for changes by reading the same from time to time.

Contact Information

Alphaniti welcomes your grievances, comments or questions regarding the term of this Privacy Policy, the Site, or the Services. Please e-mail us at customercare@alphaniti.com or contact our grievance officer at the following address:

Alphaniti Fintech Private Limited, 401 & 402, Airawat Building, Plot No. 12B, S. No. 6/1/7, Baner, Pune 411045.

Definitions

• Anonymous Information - Anonymous information means information that does not directly or indirectly identify, and cannot reasonably be used to identify, an individual guest / user.
• Internet Protocol (IP) - Internet Protocol (IP) is the principal set (or communications protocol) of digital message formats and rules for exchanging messages between computers across a single network or a series of interconnected networks, using the Internet Protocol Suite (often referred to as TCP/IP). Messages are exchanged as datagrams, also known as data packets or just packets.
• Personal Information - Personal Information means any information that relates to a natural person, which, either directly or indirectly, in combination with any other information available, is capable of identifying such person.