Privacy Policy

This Policy, pertaining to the privacy practices of Vishrav Technologies and its Group Companies collectively referred to as "Myfinportfolio" or "Company," outlines how we access, collect, use, process, and disclose information provided by you or collected by us through our mobile application Myfinportfolio and/or our website myfinportfolio.com (referred to as Myfinportfolio Platform or Platform). These activities are conducted for the purpose of delivering various services, products, and content collectively referred to as the "Services." This Policy is an integral part of the Terms of Use and other applicable terms on the Myfinportfolio Platform. It should always be read in conjunction with the Terms of Use, specific product/service terms and conditions, disclaimers, declarations and undertakings. For the purpose of this Privacy Policy, the term "User" refers to you, whether you are an individual, a guest user, a visitor, or a representative of an entity, who visits, accesses, uses, downloads, interacts with, avails Products & Services, or transacts through the Myfinportfolio Platform. Throughout this Policy, "You" or "Your" refers to the User, while "We," "Us," or "Our" refers to Myfinportfolio. This Privacy Policy is applicable to all personally identifiable information (PII), sensitive personal data or information (SPDI), and other personal data collected from you through the Myfinportfolio Platform. The Privacy Policy is governed by the provisions of applicable law in India, including the Information Technology Act 2000, the Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011 and other regulatory provisions in place. The terms "Personal Information" and "Sensitive Personal Data or Information" carry the same meaning and definition as defined under the aforementioned rules to ensure the privacy of your Personal Data. Myfinportfolio may for the purpose of rendering its services, collect personal information such as: Myfinportfolio may for the purpose of rendering its services, collect personal information such as: 1. Name, gender, residential / correspondence address, telephone number, date of birth, marital status, email address or other contact information; 2. Identification Documents, Aadhaar details, KYC Status, Signature and Photograph; 3. Financial information such as bank account or credit card or debit card or other payment instrument details; 4. Any other detail for providing services. This Policy applies to you for all the services available on the Myfinportfolio Platform. If you do not agree to this Privacy Policy or any specific clause within it, we advise you not to visit, access, or register on the Myfinportfolio Platform or avail any of Our Services. If you have already registered, we recommend you to deregister from the Myfinportfolio Platform and discontinue using Our Products/Services. Continued access or use of the Myfinportfolio Platform will be deemed as your consent to the most recently updated Privacy Policy. You must be a natural person who is at least 18 (eighteen) years of age. You must not misrepresent your identity. The right to use the Myfinportfolio Platform is personal to the User and is not transferable to any other person or entity. The Company presumes adequate and lawful parental consent in case the Personal Information is shared by a User under the age of 18 years.

1. When you voluntarily provide the personal information requested by us. 2. When you participate in KYC (Know Your Customer) and other due diligence processes for setting up an Investment Account. 3. When you avail or apply for services offered by Myfinportfolio. 4. When you interact with the Myfinportfolio platform. 5. When you voluntarily provide details through different communication channels or on the Myfinportfolio Platform. 6. When you transact through your Myfinportfolio accounts. 7. When information about you is supplied by parties authorized by you to provide it. 8. When material information is supplied to Myfinportfolio by related parties under a contractual arrangement or otherwise. 9. When personal information is obtained from service providers to verify your identity, prevent fraud, or identify products and services that may be of interest to you. 10. When you provide feedback and opinions about the current or future availability of products and services. 11. Any other mode as applicable from time to time.

We understand that it is very cumbersome for you to keep uploading your statements regularly & you may miss getting a clear view of your investments on the Myfinportfolio Platform. Hence 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 attachment from a small set of senders specifically comprising: [email protected], [email protected], [email protected], [email protected], [email protected], [email protected], [email protected], [email protected], [email protected] If the sender email ids are changed then we will notify you and also update this Privacy Policy on a best effort basis. The attachments from these senders have the details of your investments such as Folio numbers, Transaction Dates, Dividends, Subscription and Redemption Amounts, etc. The Company plans to organizes this information in your account to provide deep analytics. The benefit of opting to connect your Gmail account is that your investment information gets automatically updated every month. Given the updated information, the Platform can give you accurate analytics on your investments more seamlessly and in a frictionless manner. You can choose to de-link your Gmail account at any time by writing to us. Alternatively, you can also de-link your email by visiting Google Mail's permission settings located at: myaccount.google.com/permissions Please note we will never rent or sell your information or data to anyone. We never use or transfer the data collected via Gmail for serving ads, including retargeting, personalized, or interest-based advertising on the Myfinportfolio Platform. This act of connecting your Gmail accounts with the Company accounts comes under the "Restricted scopes" under Google API services user data policy. We urge you to also refer to the restricted scope as mentioned in the section below under Use of Information

We use your information primarily for the following purposes: 1. Responding to your inquiries or requests. 2. Maintaining and safeguarding the interests of your accounts. 3. Processing transactions that you submit or initiate. 4. Fulfilling our legal and regulatory obligations. 5. Fulfilling our audit and contractual obligations within the boundaries of the law. 6. Conducting research and analysis. 7. Developing, offering, and providing the financial products and services we offer, distribute, or refer. 8. Offering customized product offerings directly or in collaboration with group entities/vendors. 9. Informing you about the financial products and services we offer. 10. Marketing or advertising our products or services. 11. Sharing information with ultimate or partner service providers under referral, distributor, partner, or service provider arrangements. 12. Complying with legal obligations or any other act required by law. 13. Completing specific transactions or account changes as directed by you. 14. Showing you relevant advertisements. 15. Releasing information about you if you authorize us to do so or if we are compelled by law or legal process to do so, or in limited legally defined circumstances (such as fraud prevention). 16. Using your email address or other personally identifiable information to contact you or send commercial or marketing messages about our services, as well as additional updates and features about third party's products and services, with an option to subscribe or unsubscribe. 17. Any other legitimate purpose including submissions to regulatory or legal purposes which has arisen or may arise in the future. 18. We employ automated processes for accessing and analysing/processing the information provided/collected.

We uphold a strict policy of not renting or selling your personal information to any party. However, in certain circumstances, we may need to disclose your Personal Information with third parties, as explained in this section: 1. Data Transfer for User-Facing Features: We will only disclose your data to others if it is necessary to provide services or enhance user-facing features that are prominently displayed in the requesting application's user interface. Additionally, data may be transferred to comply with applicable laws, or under any regulatory obligations or under any legal obligations or in the special case, with prior intimation. 2. No transfer of Data for Advertising: We do not transfer your personal or SDPI data for serving ads, including retargeting, personalized, or interest-based advertising. 3. Limited Human Access to Data: We ensure that no humans have access to read your data, except in the following circumstances: a. When we obtain your explicit agreement for specific purposes. b. When it is required to provide the services as offered by Myfinportfolio c. When it is necessary for security reasons, such as investigating a bug or abuse. d. When it is required to comply with applicable law. e. When our use is limited to internal operations and the data, including any derivations, has been aggregated and anonymized. Our employees, agents, and contractors also adhere to the Privacy policy. We want to reassure you that we will never rent or sell your information or data to anyone. The transfer of data to others only occurs when it becomes necessary to provide or improve user-facing features, comply with the law, or in case of certain business transactions. Moreover, any data shared is either anonymized or aggregated. We will take explicit consent from you before sharing personal information with any third party, except for cases where such sharing is required as per statutory or regulatory requirement.

We neither rent nor sell your Personal Information to anyone. However, we may share your Personal Information with third parties as described in this section: • We only transfer the data to others, if necessary, to provide or improve user-facing features that are prominent in the requesting application's user interface. We may also transfer data as necessary to comply with applicable law or as part of a merger, acquisition, or sale of assets with notice to users. All other transfers or sales of the user data are prohibited • We don't use or transfer the data for serving ads, including retargeting, personalized, or interest-based advertising; and • We don't allow humans to read the data, unless: - We first obtain your affirmative agreement for specific purposes; - It is necessary for security purposes (such as investigating a bug or abuse); - It is necessary to comply with applicable law; or - Our use is limited to internal operations and the data (including derivations) have been aggregated and anonymized. These prohibitions of user of data apply to the raw data obtained from Restricted Scopes and data aggregated, anonymized, or derived from them. Our employees, agents, contractors, and successors comply with the "Google API Services: User Data Policy". • We will also be undergoing annual security assessment from a Google-designated third party and keep the same updated from time to time or as per instructions from Google and will publish the "letter of assessment" on the Company website and mobile applications. Your personal information with respect to connecting your Gmail account with Myfinportfolio Application: Compliance w.r.t. Google OAuth API Scopes (Restricted scopes) We will never rent or sell your information or data to anyone. Company ensures that it is always in compliance with the restricted scope defined under Google OAuth API policies. • Company limits use of data to provide or improve your user experience. Connecting your Gmail account with the Company is completely optional and based on your explicit consent for only specific use cases as has been described in this Privacy Policy. The benefit of this option is that you do not need to keep updating your investment information every month. Given the updated information, the application can hence give you deep and accurate analytics on your investments. You can choose to de-link your Gmail account with the application at any time and/or you can request to delete your Myfinportfolio account by writing to us (subject to regulatory compliance). Alternatively, you can remove access to Company from Google Mail's permission settings located at: myaccount.google.com/permissions. • We only transfer the data to others if necessary, to provide or improve user-facing features that are prominent in the requesting application's user interface. We may also transfer data as necessary to comply with applicable law or as part of a merger, acquisition, or sale of assets with notice to users. All other transfers or sales of the user data are prohibited. • We don't use or transfer the data for serving ads, including retargeting, personalized, or interest-based advertising and we do not allow, and we prohibit access to any of the third-party analytics providers. • We don't allow humans to read the data, unless : - We first obtain your affirmative agreement for specific messages; - It is necessary for security purposes (such as investigating a bug or abuse); - It is necessary to comply with applicable law; or - Our use is limited to internal operations and the data (including derivations) have been aggregated and anonymized. These prohibitions of user of data apply to the raw data obtained from Restricted Scopes and data aggregated, anonymized, or derived from them. Our employees, agents, contractors, and successors comply with the "Google API Services: User Data Policy". We will also be undergoing annual security assessment from a Google-designated third party and keep the same updated from time to time or as per instructions from Google and will publish the "letter of assessment" on the Company website and mobile applications. In relation to the SMS information, you provide to the Myfinportfolio application for expense and savings account balance organization, Myfinportfolio complies with the Google Play store policies and Google policies to ensure data usage is in line with improving user experience. Giving consent to access your SMS text messages is entirely optional and will be used only for specific purposes described in the Privacy Policy.

At Myfinportfolio, we have implemented various measures to safeguard your personal information. Here's how we ensure the security of your data: 1. Limited Access: We restrict access to your information to employees who require it to perform their job duties. This helps us maintain confidentiality and ensures that only authorized personnel can access your data. 2. Physical, Electronic, and Procedural Safeguards: We have implemented physical, electronic, and procedural safeguards in accordance with applicable laws, industry standards, and best practices. These measures are regularly reviewed and adjusted to stay updated with advances in technology. 3. Account Protection: To ensure the security of your account, we advise against sharing your Myfinportfolio account information, username, or password with anyone. If you come across any suspicious activity or suspect fraud, please contact us via email provided below. 4. Reviewing Account Information: Myfinportfolio provides multiple options for accessing and reviewing your account information. 5. Website Restrictions for Children: Our website and apps are not intended for individuals under 18 years of age.

• Managed within legal and regulatory frameworks. • Either disposed of or kept confidential to ensure privacy. • Collected, controlled, and stored in India. • Accessible on a need-to-know basis only and not freely available to everyone. • Transmitted or transferred in a secure manner. • Stored in a secure environment to minimize the risk of data breaches. Your personal information is not: • Sold/transferred for monetary purposes or transferred to third parties. • Collected beyond what is required by law or necessary for your intended purpose. • Held or processed more than necessary for your specific purpose. Accessibility or sharing of your personal data is as follows: • Restricted and available only on a need-to-know basis. • Shared with entities connected to the business purpose or directly/indirectly assisting Myfinportfolio in better serving the clients. • With affiliated companies within the permissible limits of the law when specifically connected to business purpose. • With service providers/partners/entities under contractual agreements to perform actions or improve services. These service providers are mostly required to maintain the same level of confidentiality as Myfinportfolio. Security measures for your personal data include: • Storing data in controlled and supervised environments. • Setting boundaries for secure data sharing. • Sharing data only with those who have a legitimate interest in accessing it.

You can request updates to your sensitive personal data or information by writing to us and providing the necessary supporting documents. Vishrav Technologies will process your request in accordance with applicable regulatory requirements, ensuring that your Sensitive Personal Data or Personal Information is updated accordingly

• We may receive information about you from parties authorized by you or for due-diligence purposes. • We may combine information collected from various sources, including online and offline, in accordance with our policy. • Non-disclosure of information to external organizations is maintained unless necessary for providing services, complying with legal requirements, or as per agreed terms and conditions. • Myfinportfolio shall not access mobile phone resources such as file and media, contact list, call logs, telephony functions, etc. while it may seek one-time access for camera, microphone, location or any other facility necessary for the purpose of on-boarding/ KYC with your prior explicit consent. • Myfinportfolio shall not collect or store biometric data. • We may also collect additional information at other times, on a voluntary basis, including but not limited to, when You provide feedback, comments, change Your content or email preferences, respond to a survey, or any communications with Us. You shall ensure that the information provided by you is up to date. The Company/its affiliates and group companies/partners/vendors/ service providers etc. may also contact You from time to time, through any mode of communication, including for requesting You to update or confirm Your personal information, in order to keep the same up to date and also to provide you with such features that We believe may benefit / interest You. • We may also use Your email address or other personally identifiable information to reach out to you or to send commercial or marketing messages about Our Services and/or such additional updates and features about third parties' products and services with an option to subscribe/unsubscribe. Please note that failure to provide information to Myfinportfolio may limit our ability to offer certain products or services to you. Other privacy-related disclosures: 1. Use of Technology: We utilize various technologies to gather information that aids us in understanding the usage of our websites and mobile applications. This includes technical and navigational details such as the date and time of your visit, duration since your last visit, viewed pages, selected links, general geographic location, search queries, and access details. These insights are utilized for purposes like identifying software compatibility issues, resolving technical or service problems, enhancing security, and analysing data to improve our website and mobile application design, functionality, and communication regarding our products and services. 2. Cookies: We employ cookies to distinguish you from other users of our online services, providing you with a more personalized and improved browsing experience. Cookies assist in enhancing site navigation, developing and offering products and services, and improving the structure, functionality, security, and content of our online services. Session cookies, which expire at the end of your online session, are also used. If you have concerns about cookies, you can configure your browser settings to reject or notify you about the placement of cookies, as well as delete cookies from your device. However, please note that blocking or deleting cookies may impact the correct functioning of certain features on our websites or mobile applications. Some customized features and enhanced authentication on our platforms require cookies to be enabled. We do not use cookies or similar data files created by other websites to view or collect data. 3. Third-Party Links and Information Sharing: Our website contains links to third-party sites or information that we believe may be of interest or importance to you. When you click on these links and leave our website, the terms of use, policies, and privacy policies of the linked website apply in addition to ours. It is your responsibility to comply with the terms of use and understand the privacy policy of the third-party site. Our websites may also allow you to share information directly with third-party websites or online services. If you choose to use these features, you may disclose information to those websites. Even if you do not use these plug-in features, third parties may collect information about you, including your IP address and viewed pages, and may set and access cookies on your device. Myfinportfolio is not responsible for the content or practices of these third-party websites and services. The collection, use, and disclosure of information through these websites and services are subject to the privacy policies of the respective third-party websites or services. 4. Analytics: Myfinportfolio engages service providers to collect the aforementioned information for analysis, auditing, research, and reporting purposes. These providers may utilize cookies and other technologies to gather information about your activity on our website or mobile application. 5. Interest-Based Advertising: We may collaborate with service providers, including social networks, to offer targeted advertising services customized based on your online activities over time. This helps to measure brand awareness and the effectiveness of our online advertising. These service providers may employ cookies and various technologies to collect information. Information collected during your use of our online services, including limited demographic information like age, may be utilized to target non-Myfinportfolio advertisements based on your general online activity. Please note that the aforementioned practices are subject to the privacy policies of Myfinportfolio and the involved third-party websites or services. Compliance with Google OAuth API Scopes: Please note that Myfinportfolio's use of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.

If you have any complaints, wish to report abuse, or have concerns regarding the use, processing, and disclosure of your information or a breach of these terms, we recommend that you promptly reach out to us in writing or via email: [email protected] Opt-out option: You have the freedom to opt-out of this permission at any time by adjusting the App's permission settings or by writing to us. You also have the option to request account deactivation. This will block your access to the Myfinportfolio Platform until a re-activation request is sent to us.

You can request to delete your Myfinportfolio account/data by writing to us and Vishrav Technologies will process the request by deleting the account /data subject to applicable regulatory provisions and/or any active service you are availing and/or any amounts are outstanding under any Products.

We are committed to ensuring the security and integrity of our systems and apply all reasonable cybersecurity safeguards as required under applicable laws, and adopt industry best practices in line with established cybersecurity standards. In the event of any data security breach, the Company will promptly identify the cause of such breach and take immediate and appropriate steps to contain it. We will act in a timely and responsible manner to mitigate any risks, comply with applicable legal and regulatory obligations, and implement preventive measures to minimize the risk of recurrence.

VISHRAV TECHNOLOGIES may share user data including the their personal data with the business Partners for offering their products and services to the clients. VISHRAV TECHNOLOGIES may share the personal data for the regulatory and operational purposes or for any other purpose in order to provide the services available on the platform. VISHRAV TECHNOLOGIES uses service providers (like telecom, payment gateways, etc.) to execute the user requests. Some of users data like user's contact details, bank details etc. may be shared with service providers for processing the user's request which service providers can store in their systems..

We will retain customer records and data in accordance with applicable laws and regulatory requirements governing all products and services offered on the Myfinportfolio platform, including but not limited to investment advisory. This includes retention requirements under the Prevention of Money Laundering Act, 2002, the SEBI (Investment Advisers) Regulations, 2013, and any other applicable laws, rules, or guidelines issued by regulatory authorities in India such as SEBI, RBI, IRDAI, PRFDA or any other competent body. In the event of any ongoing legal, regulatory, or compliance proceedings, such records will be retained for the extended duration until the proceedings reach a logical conclusion. Policy Updating: We may periodically update and/or modify this policy to incorporate necessary changes in technology, applicable law, or other factors. We reserve the right to change the terms of this policy or the Terms of Use at any time. Any changes we make will take effect immediately upon posting the new policy on our Myfinportfolio Platform. To stay informed of any changes, we recommend reviewing this policy periodically for the latest version. Continued access or use of the Sites or Services after such notice will be considered acceptance of the changes. Our commitment: As an investor, client, or prospective investor/client, you may entrust your funds and personal/financial information to our care. We understand that you expect us to act responsibly and in your best interests. When we share client or prospective client information, whether personal or otherwise, we do so under the circumstances briefly described in this policy.