Privacy & Refund Policy

 PRIVACY & REFUND POLICY

This Privacy & Refund Policy (“Policy”) explains how Vijay Porwal, operating under the trade name Infoline Equity Research, collects, uses, stores, protects and, where necessary, shares personal information of visitors, clients and prospective clients who access or use our website and research services.

This Policy also explains the cancellation and refund terms applicable to our research services.

By using our website, submitting an enquiry, registering for our services, entering into a service agreement, or providing personal information to us, you acknowledge that you have read and understood this Policy. Where applicable, we will obtain consent in the manner required under applicable data protection laws.

1. ABOUT US

Registered Name: Vijay Porwal
Trade Name: Infoline Equity Research
Type of Registration: Individual
SEBI Registration No.: INH000028158
BSE Enlistment No.: 7308

Website: www.infolineequity.com
Email: support@infolineequity.com
Phone: +91 9183581161

Office Address:
First Floor, 137 Ahilya Nagar Extn.,
Gopur Square, Indore, Madhya Pradesh, India.

Infoline Equity Research is a SEBI Registered Research Analyst and provides research and related services in accordance with applicable SEBI regulations, circulars, directions and applicable requirements of the Research Analyst Administration and Supervisory Body (RAASB), as amended from time to time.

2. SCOPE OF THIS PRIVACY POLICY

This Policy applies to personal information collected through:

• Our website;
• Enquiry and contact forms;
• Communication with prospective or existing clients;
• Research service registration and onboarding;
• Service agreements and related documentation;
• Payment and billing processes;
• Email, telephone and other business communications;
• Other lawful interactions relating to our research services.

This Policy does not apply to third-party websites, applications, payment gateways, communication platforms or other services that may be linked from our website. Users should review the privacy policies of such third parties separately.

3. INFORMATION WE MAY COLLECT

Depending on the nature of your interaction with us, we may collect information such as:

A. Contact and Identification Information

• Full name;
• Mobile number;
• Email address;
• Residential or correspondence address, where required;
• State, city and PIN code;
• Information required for client onboarding and regulatory compliance.

B. Service-Related Information

Where required for providing research services or complying with applicable laws and regulations, we may collect information relating to:

• Client category;
• Service selected;
• Subscription or service period;
• Service agreement details;
• Payment and billing information;
• Communications and requests made by the client.

C. Technical and Usage Information

When you visit our website, certain technical information may be automatically collected, such as:

• Internet Protocol (IP) address;
• Browser type and version;
• Device type;
• Operating system;
• Pages visited;
• Date and time of visit;
• Referring website or source;
• General website usage information;
• Information required for website security and performance.

We collect such information only to the extent reasonably necessary for legitimate business, security, analytical or technical purposes.

4. INFORMATION WE DO NOT ROUTINELY COLLECT

Our website does not require access to your device’s:

• Contact list;
• Camera;
• Photo library;
• Precise location;
• Microphone;

unless a specific service or feature is introduced in the future and such access is necessary and lawfully obtained with appropriate notice and consent.

We do not represent that we collect information merely because a particular technology or feature exists on a third-party platform.

5. PURPOSES FOR WHICH PERSONAL DATA IS USED

We may process personal information for the following purposes:

1. To respond to enquiries and requests;
2. To communicate with prospective and existing clients;
3. To provide research services;
4. To complete client onboarding and documentation;
5. To enter into and perform service agreements;
6. To process payments, invoices and accounting records;
7. To comply with SEBI, RAASB, tax, accounting and other applicable legal or regulatory requirements;
8. To maintain records required under applicable laws and regulations;
9. To provide service-related communications;
10. To improve website functionality, security and user experience;
11. To detect, prevent and investigate fraud, misuse or security incidents;
12. To handle complaints, disputes and legal matters;
13. To comply with lawful requests from government, regulatory or law-enforcement authorities;
14. For other purposes specifically communicated to you at the time of collection or otherwise permitted under applicable law.

We will not use personal information for purposes materially different from those disclosed to you unless such processing is permitted or required under applicable law.

6. COMMUNICATIONS

We may contact you through email, telephone, SMS, WhatsApp or other permitted communication channels for purposes including:

• Responding to enquiries;
• Client onboarding;
• Service-related information;
• Payment and billing matters;
• Important contractual or regulatory communications;
• Research-service communications where permitted;
• Customer support and complaint resolution.

Where consent is required for promotional or marketing communication, we will follow applicable consent and communication requirements.

You may request that promotional communications be stopped, subject to communications that we are legally or contractually required to send.

7. COOKIES AND SIMILAR TECHNOLOGIES

Our website may use cookies and similar technologies for purposes such as:

• Essential website functionality;
• Security;
• Website performance;
• Analytics;
• Understanding website usage;
• Improving user experience;
• Measuring marketing or campaign performance, where applicable.

Cookies may be session-based or persistent.

You may manage or disable cookies through your browser settings. However, disabling certain cookies may affect some website functionality.

Where a separate consent mechanism is required for a particular category of cookies or tracking technology, we will use such mechanism as applicable.

8. THIRD-PARTY SERVICE PROVIDERS

We may use trusted third-party service providers where reasonably necessary to operate our business and provide our services.

Such service providers may include providers of:

• Website hosting;
• Website security;
• Email and communication services;
• Payment processing;
• Accounting and billing;
• Customer support;
• Analytics;
• Electronic documentation or signing services;
• Information technology services.

Such third parties may process personal information only to the extent reasonably necessary for the services they provide to us and subject to applicable contractual, legal or regulatory requirements.

We do not sell your personal information as a business practice.

9. REGULATORY AND LEGAL DISCLOSURES

We may disclose personal information where reasonably necessary to:

• Comply with applicable law;
• Comply with SEBI or RAASB requirements;
• Respond to lawful directions, notices or requests from regulators or government authorities;
• Comply with court orders or legal proceedings;
• Prevent fraud or unlawful activity;
• Protect our legal rights and interests;
• Resolve disputes or complaints;
• Meet statutory, accounting, audit or record-keeping obligations.

Any such disclosure will be limited to what is reasonably necessary for the relevant purpose, subject to applicable law.

10. CLIENT CONFIDENTIALITY

We will maintain appropriate confidentiality of information obtained from clients in connection with our research services, subject to:

• Applicable laws and regulations;
• Regulatory or statutory requirements;
• Lawful disclosure obligations;
• Information that is already publicly available;
• Situations where disclosure is authorized by the client.

Client information will not be used for purposes unrelated to our business or regulatory obligations except where permitted by applicable law or with appropriate authorization.

11. DATA SECURITY

We take reasonable technical and organizational measures to protect personal information against unauthorized access, misuse, alteration, disclosure, loss or destruction.

However, no method of transmission over the internet or electronic storage system can be guaranteed to be completely secure.

Accordingly, while we take reasonable precautions, we cannot guarantee absolute security of information transmitted electronically.

12. DATA RETENTION

We retain personal information only for as long as reasonably necessary for the purposes for which it was collected, including:

• Providing services;
• Maintaining business and accounting records;
• Meeting SEBI and RAASB requirements;
• Complying with tax and other legal obligations;
• Resolving complaints and disputes;
• Establishing, exercising or defending legal claims.

Where applicable laws or regulatory requirements prescribe a specific retention period, the relevant information will be retained for such period.

After the applicable retention period, information will be deleted, anonymized or otherwise disposed of in accordance with applicable requirements, subject to any continuing legal or regulatory requirement.

13. YOUR DATA RIGHTS

Subject to applicable law and its effective implementation, you may have rights relating to your personal data, including the right to:

• Request information about processing of your personal data;
• Request correction of inaccurate or incomplete information;
• Request deletion of personal information where legally permissible;
• Withdraw consent where processing is based on consent;
• Raise a grievance regarding processing of your personal information.

Requests may be submitted to:

Email: support@infolineequity.com

We may need to verify your identity before processing a request.

Certain information may be retained where required by law, regulation, accounting requirements, contractual obligations or for establishing, exercising or defending legal claims.

14. WITHDRAWAL OF CONSENT

Where processing is based on your consent, you may withdraw such consent by contacting us at:

support@infolineequity.com

Withdrawal of consent will not affect the lawfulness of processing carried out before withdrawal.

Where information is necessary for providing a service, fulfilling a contractual obligation or complying with a legal or regulatory requirement, withdrawal of consent may affect our ability to continue providing the relevant service.

15. DATA TRANSFER

Where third-party service providers or technology infrastructure used by us process information outside your state or outside India, such processing will be carried out subject to applicable law and appropriate safeguards, contractual arrangements and security measures, as applicable.

16. CHILDREN’S DATA

Our research services are intended for eligible clients who satisfy applicable legal and contractual requirements.

We do not knowingly seek to collect personal information from children for the purpose of providing our research services.

If we become aware that personal information has been collected from a child in circumstances where such collection is not permitted by applicable law, we will take reasonable steps to address the situation in accordance with applicable legal requirements.

17. THIRD-PARTY LINKS

Our website may contain links to third-party websites or services.

We do not control and are not responsible for the privacy practices, security, content or policies of such third-party websites.

Users are advised to review the privacy policy of the relevant third party before providing personal information.

18. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect:

• Changes in our services;
• Changes in applicable laws or regulations;
• Changes in regulatory requirements;
• Changes in technology or data-processing practices.

The updated version will be published on this page with the revised “Last Updated” date.

Users are encouraged to review this page periodically.

REFUND & CANCELLATION POLICY

A. GENERAL PRINCIPLE

Infoline Equity Research provides research services and does not guarantee or assure any return, profit or performance from any research recommendation.

Payment of a research-service fee does not constitute a guarantee of profit or protection against market losses.

Investment in securities markets is subject to market risks.

B. SEBI FEE LIMIT

For Individual and HUF clients, the fees charged by the Research Analyst shall remain subject to the maximum fee prescribed by SEBI / RAASB from time to time.

As per the applicable SEBI framework presently in force, the current fee limit is:

₹1,51,000/- per annum per family of client for all research services of the Research Analyst.

This limit does not include applicable statutory charges.

The prescribed fee limit does not apply to a non-individual client or an accredited investor, subject to the applicable regulatory framework and contractual terms.

C. ADVANCE FEE

Where agreed with the client, fees may be collected in advance subject to the limits prescribed by SEBI / RAASB from time to time.

The applicable advance fee period shall not exceed the period permitted under the prevailing regulatory framework.

As per the current SEBI framework, the advance fee period is presently limited to one quarter.

D. CANCELLATION AND PREMATURE TERMINATION

A client may request cancellation or premature termination of the research service by contacting us at:

Email: support@infolineequity.com

Where research services are terminated before expiry of the agreed service period, the client shall be entitled to a refund of the proportionate fee relating to the unexpired period, subject to applicable SEBI / RAASB requirements and the terms of the applicable service agreement.

No breakage fee or similar charge shall be imposed contrary to the applicable regulatory requirements.

E. REFUND PROCESS

Where a refund becomes payable under the applicable terms and regulatory framework:

1. The client may submit a refund/cancellation request through our official communication channel.
2. We may verify the client’s identity and service details.
3. The refundable amount will be calculated based on the applicable fee, service period and unexpired period.
4. The refund will be processed through an appropriate permitted payment mechanism.
5. The time required for the refund may depend on the payment method, banking system and payment service provider.

Any statutory charges, taxes or amounts that are legally non-refundable shall be dealt with in accordance with applicable law.

F. REFUND IS NOT LINKED TO MARKET PERFORMANCE

Refund eligibility shall not be determined by whether a research recommendation resulted in a profit or loss.

Research services involve market risk and no assurance of returns is provided.

However, this does not restrict any refund or remedy that is otherwise available under applicable law, regulations, contractual terms or the applicable SEBI / RAASB framework.

G. PAYMENT METHODS

Clients may make payment through payment methods permitted under the applicable regulatory framework, such as:

• Online bank transfer;
• UPI;
• Cheque; or
• Other permitted electronic payment mechanisms.

Cash payment shall not be accepted for research-service fees.

Where applicable and available, clients may also use the centralized fee collection mechanism prescribed or facilitated by the recognized RAASB.

H. NO GUARANTEED RETURNS

Infoline Equity Research does not offer or provide:

• Guaranteed returns;
• Assured returns;
• Fixed returns;
• Profit guarantees;
• Schemes promising a fixed level of return; or
• Any similar arrangement prohibited under applicable securities laws.

Past performance, if displayed, should not be considered a guarantee of future results.

I. CLIENT ACKNOWLEDGEMENT BEFORE PAYMENT

Before purchasing or subscribing to any research service, clients are advised to:

• Read the relevant service description;
• Review the applicable pricing;
• Read the Terms & Conditions;
• Read the Minimum Information / Mandatory Terms and Conditions applicable to Research Analyst services;
• Read the Service Agreement;
• Read the Privacy & Refund Policy;
• Review the relevant disclosures and disclaimers;
• Understand the applicable fee and refund provisions;
• Understand that investment in securities markets is subject to market risks.

Clients should make investment decisions based on their own assessment and risk profile.

J. GRIEVANCE / PRIVACY CONTACT

For any privacy-related query, cancellation request, refund request or grievance relating to this Policy, you may contact:

Infoline Equity Research
Registered Name: Vijay Porwal
SEBI Registration No.: INH000028158
BSE Enlistment No.: 7308

Email: support@infolineequity.com
Phone: +91 9183581161

Office:
First Floor, 137 Ahilya Nagar Extn.,
Gopur Square, Indore, Madhya Pradesh, India.

For investor complaints relating to research services, clients may also refer to the Investor Charter and Complaint Board sections available on our website.

K. REGULATORY COMPLIANCE

This Policy shall be read together with our:

• Terms & Conditions;
• Service Agreement;
• Mandatory Terms and Conditions (MITC);
• Investor Charter;
• Disclaimer & Disclosures;
• Complaint Handling Mechanism; and
• Other applicable policies and disclosures published on our website.

In case of any conflict between this Policy and a mandatory provision of applicable law, SEBI regulations, circulars, directions or RAASB requirements, the applicable legal or regulatory requirement shall prevail to the extent of such conflict.

L. CONTACT DETAILS

Infoline Equity Research
Vijay Porwal
SEBI Registered Research Analyst
SEBI Registration No.: INH000028158
BSE Enlistment No.: 7308

Website: www.infolineequity.com
Email: support@infolineequity.com
Phone: +91 9183581161

Office Address:
First Floor, 137 Ahilya Nagar Extn.,
Gopur Square, Indore, Madhya Pradesh, India.

Last Updated: 30 September 2026