Investment Advisory
for HNIs & Institutions

A. Vision and Mission Statements for investors

• Vision: Invest with knowledge & safety.
• Mission: Every investor should be able to invest in right investment products based on their needs, manage and monitor them to meet their goals, access reports and enjoy financial wellness.

B. Details of business transacted by the Investment Adviser with respect to the investors

• To enter into an agreement with the client providing all details including fee details, aspects of Conflict of interest disclosure and maintaining confidentiality of information.
• To do a proper and unbiased risk – profiling and suitability assessment of the client.
• To conduct audit annually.
• To disclose the status of complaints on its website.
• To disclose the name, proprietor name, type of registration, registration number, validity, complete address with telephone numbers and associated SEBI Office details (i.e. Head office/ regional/ local Office) on its website.
• To employ only qualified and certified employees.
• To deal with clients only from official number
• To maintain records of interactions, with all clients including prospective clients (prior to onboarding), where any conversation related to advice has taken place.
• To ensure that all advertisements are in adherence to the provisions of the Advertisement Code for Investment Advisers
• Not to discriminate in terms of services provided, among clients opting for same/similar products/services offered by investment adviser.

C. Details of services provided to investors (No Indicative Timelines)

• Onboarding of Clients
  • Sharing of agreement copy
  • Completing KYC of clients
• Disclosure to Clients
  • To provide full disclosure about its business, affiliations, compensation in the agreement.
  • To not access client’s accounts or holdings for offering advice.
  • To disclose the risk profile to the client.
  • To disclose any conflict of interest of the investment advisory activities with any other activities of the investment adviser.
  • To disclose the extent of use of Artificial Intelligence tools in providing investment advisory services.
• To provide investment advice to the client based on the risk-profiling of the clients and suitability of the client.
• To treat all advisory clients with honesty and integrity.
• To make adequate disclosure to the investor of all material facts such as risks, obligations, costs, etc. relating to the products or securities advised by the adviser.
• To provide clear guidance and adequate caution notice to clients when providing investment advice for dealing in complex and high-risk financial products/services.
• To ensure confidentiality of information shared by clients unless such information is required to be provided in furtherance of discharging legal obligations or a client has provided specific consent to share such information.
• To disclose the timelines for the various services provided by the investment adviser to clients and ensure adherence to the said timelines.

D. Details of grievance redressal mechanism and how to access it

• Investor can lodge complaint/grievance against Investment Adviser in the following ways:
  
  Mode of filing the complaint with investment adviser
  
  In case of any grievance / complaint, an investor may approach the concerned Investment Adviser who shall strive to redress the grievance immediately, but not later than 21 days of the receipt of the grievance.
  
  Mode of filing the complaint on SCORES or with Investment Adviser Administration and Supervisory Body (IAASB)
  
  
  • SCORES 2.0 (a web based centralized grievance redressal system of SEBI for facilitating effective grievance redressal in time-bound manner) (https://scores.sebi.gov.in)
    
    Two level review for complaint/grievance against investment adviser:
    
    
    • First review done by designated body (IAASB)
    • Second review done by SEBI
  • Email to designated email ID of IAASB
• If the Investor is not satisfied with the resolution provided by the Market Participants, then the Investor has the option to file the complaint/ grievance on SMARTODR platform for its resolution through online conciliation or arbitration.
• With regard to physical complaints, investors may send their complaints to:
  
  Office of Investor Assistance and Education,
  Securities and Exchange Board of India,
  SEBI Bhavan, Plot No. C4-A, ‘G’ Block,
  Bandra-Kurla Complex, Bandra (E),
  Mumbai - 400 051

E. Rights of investors

• Right to Privacy and Confidentiality
• Right to Transparent Practices
• Right to fair and Equitable Treatment
• Right to Adequate Information
• Right to Initial and Continuing Disclosure
  - Right to receive information about all the statutory and regulatory disclosures.
• Right to Fair & True Advertisement
• Right to Awareness about Service Parameters and Turnaround Times
• Right to be informed of the timelines for each service
• Right to be Heard and Satisfactory Grievance Redressal
• Right to have timely redressal
• Right to Suitability of the Financial Products
• Right to Exit from Financial product or service in accordance with the terms of agreement with the investment adviser
• Right to receive clear guidance and caution notice when dealing in Complex and High-Risk Financial Products and Services
• Additional Rights to vulnerable consumers
  - Right to get access to services in a suitable manner even if differently abled
• Right to provide feedback on the financial products and services used
• Right against coercive, unfair, and one-sided clauses in financial agreements

F. Expectations from the investors (Responsibilities of investors)

• Do’s
  • Always deal with SEBI registered Investment Advisers.
  • Ensure that the Investment Adviser has a valid registration certificate.
  • Check for SEBI registration number.
    Please refer to the list of all SEBI registered Investment Advisers which is available on SEBI website in the following link:
    https://www.sebi.gov.in/sebiweb/other/OtherAction.do?doRecognisedFpi=yes&in tmId=13)
  • Pay only advisory fees to your Investment Adviser. Make payments of advisory fees through banking channels only and maintain duly signed receipts mentioning the details of your payments.
  • You may make payment of advisory fees through Centralised Fee Collection Mechanism (CeFCoM) of IAASB if investment adviser has opted for the mechanism.
  • Always ask for your risk profiling before accepting investment advice. Insist that Investment Adviser provides advisory strictly on the basis of your risk profiling and take into account available investment alternatives.
  • Ask all relevant questions and clear your doubts with your Investment Adviser before acting on advice.
  • Assess the risk–return profile of the investment as well as the liquidity and safety aspects before making investments.
  • Insist on getting the terms and conditions in writing duly signed and stamped. Read these terms and conditions carefully particularly regarding advisory fees, advisory plans, category of recommendations etc. before dealing with any Investment Adviser.
  • Be vigilant in your transactions.
  • Approach the appropriate authorities for redressal of your doubts / grievances.
  • Inform SEBI about Investment Advisers offering assured or guaranteed returns.
  • Always be aware that you have the right to exit the service of an Investment Adviser
  • Always be aware that you have the right to seek clarifications and clear guidance on advice
  • Always be aware that you have the right to provide feedback to the Investment Adviser in respect of services received.
  • Always be aware that you will not be bound by any clause, prescribed by the investment adviser, which is contravening any regulatory provisions.
• Don’ts
  • Don’t fall for stock tips offered under the pretext of investment advice.
  • Do not provide funds for investment to the Investment Adviser.
  • Don’t fall for the promise of indicative or exorbitant or assured returns by the Investment Advisers. Don’t let greed overcome rational investment decisions.
  • Don’t fall prey to luring advertisements or market rumors.
  • Avoid doing transactions only on the basis of phone calls or messages from any Investment adviser or its representatives.
  • Don’t take decisions just because of repeated messages and calls by Investment Advisers.
  • Do not fall prey to limited period discount or other incentive, gifts, etc. offered by Investment advisers.
  • Don’t rush into making investments that do not match your risk taking appetite and investment goals.
  • Do not share login credential and password of your trading, demat or bank accounts with the Investment Adviser.

This privacy policy (“Privacy Policy”) has been drafted and published in accordance with the Information Technology Act, 2000 and the Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011.

Appreciate Investment Advisory Private Limited ("Company") is concerned about the privacy of the users (hereinafter referred to as “You”, “Your” or “User”) of its website located at www.appreciateadvisory.com(“Website”). This Privacy Policy describes the Company’s policies and procedures for collection, use, storage, processing, disclosure and protection of any information, including, but not limited to, business or personal information provided by You while using the Website.

This policy constitutes a legal agreement between You, as the user of the website, and the Company, as the owner of the Website. You must be a natural person who is at least 18 (eighteen) years of age. If You are less than 18 (eighteen) years of age, please read through this Privacy Policy with Your parent or legal guardian, and in such a case this Privacy Policy shall be deemed to be a contract between the Company and Your legal guardian or parent and to the extent permissible under Applicable Laws, enforceable against You.

By availing the Services, visiting or accessing the Website and voluntarily providing the Company with information (personal and/ or non- personal), You are consenting to the Company’s use of it in accordance with this Privacy Policy. This Privacy Policy does not apply to third-party websites/ applications that are connected via links to the Website. If You do not agree with the terms and conditions of this Privacy Policy, please do not proceed further to use and access this Website.

Your use of the Website will be governed by this Privacy Policy as applicable to the Website together with all policies, notices, guidelines, disclaimers that are published and shared with You from time to time which are incorporated herein by way of reference including but not limited to Terms and Conditions and such other terms as may be applicable to You in Your capacity as a user of the Website. This Privacy Policy shall be enforceable against You in the same manner as any other written agreement.

The Company may update this Privacy Policy from time to time. You must periodically review the Privacy Policy for the latest information on the Company’s privacy practices.

Definitions and Interpretations

“Applicable Law” means all laws, ordinance, statutes, rules, orders, decrees, injunctions, licenses, permits, approvals, authorizations, consents, waivers, privileges, agreements and regulations of any governmental authority/court of law having jurisdiction over the relevant matter including any interpretations thereof, in effect.

“Cookies” means small files that reside on Your computer or other mobile device's hard drive and generally contain an anonymous unique identifier and are accessible only by the website/ application that placed them there and not any other sites.

“Force Majeure Event” means any event that is beyond the Company’s reasonable control and shall include, without limitation, sabotage, fire, flood, explosion, acts of God, civil commotion, strikes or industrial action of any kind, riots, insurrection, war, acts of government, computer hacking, unauthorised access to computer, computer system or computer network, computer crashes, breach of security and encryption (provided beyond the Company’s reasonable control),power or electricity failure or unavailability of adequate power or electricity.

“Services” means and includes provision of investment advice, and facilitation of investments on Company’s Website, as well as all ancillary activities performed to support the provision of investment advice and the facilitation of investments on the Website.

“Terms and Conditions” means the terms and conditions available on the Website.

“User Account” means the personal online account created by User to gain access and use the Website.

Purpose

The purpose of this Privacy Policy is to ensure that the Your information provided by You is used, processed, disclosed and stored in accordance with the Applicable Laws. The information stored in such manner shall be protected by the Company in accordance with the terms and conditions set out in this Privacy Policy. Company’s Privacy Policy explains:

• What information is collected and why such information is collected;
• How such information is used; and
• How such information can be accessed and updated.

Please read the following Privacy Policy to learn about the Company’s information gathering and dissemination practices

Information the Company Collects

During Your use of the Website and with respect to the Company’s Services availed by you, the Company may collect and process such information from You, including but not limited to the information mentioned below:

• Personal Information: This includes the information that can be used to uniquely identify or contact You (“Personal Information”). While you create the User Account on the Website and avail the Company’s Services through the Website, the Company may collect a variety of Personal Information, including but not limited to, Your name, postal address, phone number, email address, contact preferences, etc.

  You are required to ensure that Your contact information and preferences are accurate, complete and up to date by logging into the User Account. The Company shall also provide You with the opportunity to request correction of data relating to Your Personal Information if the same is inaccurate or delete the data. Further, the Company may decline to process requests which the Company finds to be contrary to the terms laid down under this Privacy Policy, the Terms and Conditions or any Applicable Laws, or which require disproportionate technical effort, jeopardize the privacy of others or are extremely impractical.

  In the event You make payments on the Website via a payment gateway to complete any transaction on the Website, the Company may collect and store Your credit, debit card and other financial information in accordance with Applicable Law. You acknowledge that the payment gateway may be provided by a third party service provider, in which case applicable terms and use and privacy policy of such service provider shall be applicable.

  The Personal Information is collected from You in a voluntary fashion when You provide your credentials on the Website. You may choose to not provide such Personal Information to the Company.

• Non-Personal Information: Non-personal information is any information that does not reveal Your specific identity, such as, browser information, information collected through, pixel tags and other technologies, demographic information, etc., (“Non-Personal Information”). As is true with most websites and applications, the Company’s Website gathers some information automatically when You visit the Website and stores it in log files. When You use the Website, the Company may collect certain information about Your computer to facilitate, evaluate and verify Your use of the Website. For example, the Company may store environmental variables, such as browser type, operating system, speed of the central processing unit (CPU), referring or exit web pages, click patterns and the internet protocol (IP) address of Your computer. This information is generally collected in aggregate form, without identifying any user individually.

The Website may use also temporary Cookies to help you access some of the special functions within the database driven areas of the Website. Once you leave the Website, these Cookies expire.

We, or third parties authorised by the Company, may use the information provided by You in the following ways, viz:

To create User Account and to support You with any services related to Your User Account;

• To Provide You the Services through the Website;
• To update you upon the development and news with respect to Services or any other products or related services of the Company;
• To collect any monies owed by You to the Company;
• Conduct research and analysis to detect, prevent, mitigate and investigate fraudulent or illegal activities;
• Analyze how the Website is used, diagnose service or technical problems, maintain security;
• To help You efficiently access the Website and avail the Services;
• Monitor aggregate metrics such as total number of users, traffic, and demographic patterns;
• To notify You regarding your User Account, to troubleshoot problems with Your User Account, to resolve a dispute, to confirm Your identity in order to ensure that You are eligible to use the Website;
• For advertising and marketing communications. The Company may also share Non-Personal Information with third parties such as, the Company’s advertisers, sponsors, investors, business partners;
• To carry out the Company’s obligations and to process transactions arising from any contracts entered into between You and the Company;
• To notify You about changes on the Website;
• Notify You, if possible, in the event The Company becomes aware of any breach of the security of Your information and take appropriate action to the best of the Company’s ability to remedy such a breach;
• To enable the Company to comply with legal and regulatory obligations;
• To act on your behalf as a power of attorney holder, where you authorize us to do so;
• To carry out operation of bank accounts (including but not limited to managing remittances) exclusively associated with the making investments supported by the Company, where you authorize us to do so;

The Company will use and retain Your information for such periods as necessary to comply with the Company’s legal obligations, resolve disputes, and enforce the Company’s agreements.

Information Security

• The Company uses reasonable safeguards to protect and preserve the integrity and security of Your information against unauthorized access, loss, theft, unauthorised, reproduction, use or amendment, disclosure or destruction of information the Company holds. The Company encrypts its Services using secure server software, which is the industry standard and among the best software available today for secure transactions. The Company uses reasonable security practices and procedures and use secure servers as mandated under Applicable Laws for the protection of Your information. The Company reviews its information collection, storage and processing practices, including physical security measures to guard against unauthorized access to systems.
• The Company limits the disclosure of Personal Information to its employees, independent contractors including vendors, affiliates, consultants, business associates, service providers and distributors of the Services, on a “need-to-know” basis, and only if the disclosure will enable that entity to provide the Company with business, professional, or technical support or fulfil Your request. However, the Company is not responsible for any breach of security or for any actions of any third parties that receive Your Personal Information. The Company shall not be liable for any loss or injury caused to You as a result of You providing Your Personal Information to third party (including any third party websites) even if links to such third party websites are provided on the Website.
• As a registered user with a User Account, You are responsible for keeping Your password confidential. By submitting Your information on the Website, You agree to the handling of Your information by the Company in a manner as stated under this Privacy Policy. The Company will take such steps as it considers reasonably necessary to ensure that Your information is treated securely and in accordance with the Privacy Policy.
• By using the Website, You accept the inherent security implications of data transmission over the internet and the world wide web cannot always be guaranteed as completely secure. Therefore, Your use of the Website will be at Your own risk.
• Notwithstanding anything contained in this Privacy Policy or elsewhere, the Company shall not be held responsible for any loss, damage or misuse of Your Personal Information, if such loss, damage or misuse is attributable to a Force Majeure Event.
• You agree and acknowledge that the Company shall retain all information provided by You until such time as is required by the Applicable Law or until it is required for the Company’s internal use, whichever is later.

Information the Company Shares

• The Company may disclose any information provided by You on the Website as may be deemed to be necessary or appropriate: (a) under Applicable Law, including laws outside Your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside Your country of residence; (d) to enforce Terms and Conditions; (e) to protect the Company’s operations or those of any of its affiliates; (f) to protect the Company’s rights, privacy, safety or property, and/or that of its affiliates, You or others; and (g) to allow the Company to pursue available remedies or limit the damages that the Company may sustain.
• The Company may share Personal Information with other corporate entities and affiliates to help detect and prevent identity theft, fraud and other potentially illegal acts and to prevent abuse of the Website or Services. The Company may disclose Personal Information to the Company’s third party providers including but not limited to those who provide products or services such as contact information verification, payment processing, Website hosting, data analysis, infrastructure provision, IT services, auditing services and other similar services. In such an event, the third parties’ use of Your information will be bound, among other things, by confidentiality obligation and the Privacy Policy. The Company may store information in locations outside the direct control of the Company (for instance, on servers or databases co-located with hosting providers).
• The Company may be involved in the transaction of a merger, acquisition, sale of assets, business re-organization, bankruptcy etc. During such a process, it may sell, transfer or otherwise share some or all of its assets which may include Your information. However, in such an event of sale or transfer, the Company shall reasonably ensure that Your information collected and stored by the Company is stored and used by the transferee in a manner that is consistent with this Privacy Policy. Any such third party to whom the Company transfers or sells shall have the right to continue to use the information that You provide to the Company or collected by the Company immediately prior to such transfer or sale. On completion of the sale or transfer, the Privacy Policy of the third party shall apply with respect to Your information. To stay updated about such business transactions, please read this Policy from time to time.
• The Company assumes no liability for any disclosure of information due to errors in transmission, unauthorised third party access or other acts of third parties, or acts or omissions beyond the Company’s reasonable control and You agree that You will not hold the Company responsible for any breach of security unless such breach has been caused as a direct result of the Company’s gross negligence or wilful default. The Company may also collect Personal Information and information about your transactions with the Company and those You engage in with the Company’s affiliates, unaffiliated third parties, banking verification services and information from consumer reporting agencies. The Company may further collect information about You from third-party data sources, such as brokers, banks and government databases. The Company may combine data the Company collects about You from third-party data sources with data the Company collects from You and may use and share such data as described in this Privacy Policy.

Change in Privacy Policy

The Company may update this Privacy Policy at any time, with or without advance notice. In the event there are significant changes in the way the Company treats Your Personal Information, Company will display a notice on the Website or send You an email, as provided for above. Unless stated otherwise, this Privacy Policy applies to all information that Company has about You and Your User Account. Notwithstanding the above, Company shall not be required to notify You of any changes made to the Privacy Policy. If You use the Website after notice of changes have been sent to You or published on the Website, You hereby provides Your consent to the changed practices.

Choice/Opt-Out

• Company provides all its Users with the opportunity to opt-out of receiving non-essential communications from the Company or on behalf of the Company’s partners after setting up a User Account.
• If You want to remove Your contact information from the Company’s lists and newsletters, please write to the Company at unsubscribe@ppreciate.com with “unsubscribe” as the subject.

Severability

The Company has taken every effort to ensure that this Privacy Policy adheres with the Applicable Laws. The invalidity or unenforceability of any part of this Policy shall not prejudice or affect the validity or enforceability of the remainder of this Privacy Policy. This Privacy Policy does not apply to any information other than the information collected by the Company through the Website. This Privacy Policy shall be inapplicable to any unsolicited information You provide the Company through this Website or through any other means. This includes, but is not limited to, information posted in any public areas of the Website. All unsolicited information shall be deemed to be non-confidential and the Company shall be free to use and/ or disclose such unsolicited information without any limitations.

Waiver

Any rights or remedies under this Privacy Policies may be waived only in writing. Delay in exercising or non-exercise of any such right or remedy does not constitute a waiver of that right or remedy, or any other right or remedy.

Governing law and Jurisdiction

This Privacy Policy is governed by and construed in accordance with the laws of India. Any dispute arising out of or in connection with the use of the Website or this Privacy Policy shall be subject to the exclusive jurisdiction of the courts in Mumbai, India.

Questions and Grievances

Your grievances, questions or feedback regarding this Privacy Policy should be directed to the Company’s grievance officer mentioned below:

• Name: Shlok Srivastav
• Email Id: concerns@appreciateadvisor.com
• Address: Floor-2, 0-14, Mahalaxmi Industrial Estate, Dainik Shivneri Marg, Worli, Mumbai City, Maharashtra, 400018

Objectives

Objectives of this Grievance Redressal Policy are to: 

• Treat all Customers fairly and consistently and conduct operations in accordance with prevailing regulatory and statutory requirements; and
• Make Appreciate’s redressal channels effective and meaningful by putting in place a structured system to ensure that customer complaints are redressed seamlessly and well within the committed time frame.

Methods of grievance submission

Methods of grievance submission by customers and stakeholders:

Escalation matrix:

Appreciate’s defined customer grievance redressal escalation matrix is described below:

Grievance topics and associated methods

SEBI Contact details:

If not satisfied with the response you receive you can lodge your grievance with SEBi at http://scores.gov.in or you may also write to any of the offices of SEBI. For any queries, feedback or assistance, please contact the SEBI Office on Toll Free Helpline at 1800 22 7575 / 1800 266 7575. Alternatively investors may also use the Online Dispute Resolution (ODR) mechanism to lodge complaints against the intermediary if they are not satisfied by the above resolution process. The ODR Portal can be accessed at www.smartodr.in

Maintenance of records:

Appreciate will maintain comprehensive records of all customer complaints, including details of the nature of the complaint, actions taken for resolution, and timelines. A centralized system (CRM) has been implemented to track the progress of complaints from lodgment to resolution.

Review and oversight:

• Board Approval: The Board has reviewed, approved and adopted this document as Grievance Redressal Policy.
• Periodicity of Review:
  • This Grievance Redressal Policy will be reviewed by the management either annually or whenever there’s any amendment in the policy based on the issue of any government circular relevant to customer grievances, data privacy and other related issues.
  • The Compliance Officer will review this policy periodically.
• Amendments:
  • Any amendments to this Grievance Redressal Policy will be reviewed and approved by the Board.
  • Provisions of this Grievance Redressal Policy are subject to amendments in accordance with Applicable Laws (including rules, regulations, notifications) on the subject as may be issued, from time to time. In case any provisions of this Grievance Redressal Policy are inconsistent with Applicable Laws (including any subsequent amendment(s), clarification(s), circular(s), etc.) then such provisions of Applicable Laws shall prevail over the provisions hereunder and this Grievance Redressal Policy shall be deemed to have been amended to such extent.

• Investments in securities market are subject to market risks. Read all the related documents carefully before investing.
• Registration granted by SEBI, membership of BASL and certification from NISM in no way guarantee performance of the intermediary or provide any assurance of returns to investors

Data for the month ending - June 2025

Number of complaints received during month against the IA due to impersonation by some other entity:

Note: In case of any complaints received against the IA due to impersonation of the IA by some other entity, the IA may adjust the number of such complaints from the total number of received/resolved complaints while preparing the above table. Further, IA must close such impersonation related complaints after following the due process as specified by SEBI/ IAASB.

* Inclusive of complaints of previous months resolved in the current month.
# Inclusive of complaints pending as on the last day of the month
^ Average Resolution time is the sum total of time taken to resolve each complaint in days, in the current month divided by total number of complaints resolved in the current month.

Trend of monthly disposal of complaints

* Inclusive of complaints of previous years resolved in the current year.
# Inclusive of complaints pending as on the last day of the year