Terms & Conditions

SUKHMAL MUTUAL FUND DISTRIBUTORS PRIVATE LIMITED

TERMS & CONDITIONS

1. GENERAL INTRODUCTION

Welcome to Sukhmal Mutual Fund Distributors Private Limited ("Sukhmal," "we," "us," or "our"). These Terms and Conditions ("Terms") govern your access to and use of our mutual fund distribution services, including our website and other platforms (collectively, the "Platform"). By accessing or using the Platform, you ("User," "you," or "your") agree to comply with and be bound by these Terms. If you do not agree, please refrain from using the Platform.

We operate as a mutual fund distributor registered with the Association of Mutual Funds in India (AMFI) under ARN-279960. Our services comply with SEBI (Securities and Exchange Board of India) guidelines, AMFI regulations, and other applicable laws.

The website is owned, operated and maintained by Sukhmal, a Company incorporated under the Companies Act 2013 with CIN U66190GJ2025PTC158580, having its registered office at Office No. 815, Office Tower, Homeland City, Business Park, Piplod, Surat, Gujarat 395007.

The access has been provided to your mutual fund account, and the usage of your account is subject to your compliance with all the terms and conditions set forth herein, read along with all documents, including but not limited to application forms and undertakings, signed by you during account opening. You are advised to read this page carefully and retain it for future reference.

The objective of this document is to lay out the Terms and Conditions that would apply to the access and use of the Sukhmal platform through the website "revenumf.com" (herein after referred to as "Website").

These Terms and Conditions are published in accordance with the provisions of Rule 3 (1) of the Information Technology (Intermediaries guidelines) Rules, 2011, that require publishing the Rules and Regulations, Privacy Policy and user agreement for access or usage of the intermediary's computer resource by any person.

2. DISCLAIMER

2.1 The Client acknowledges and agrees that all investments and investment decisions are made solely based on the Client's own investment objectives and assessment of prevailing financial conditions. This includes any decisions made by the Client based on information available on the Platform. The Client understands that Sukhmal acts solely as a facilitator, providing access to financial and commodity markets, and does not seek to influence or interfere with the Client's decision-making process in any manner.

2.2 The Client agrees not to hold Sukhmal, or any of its officers, directors, partners, employees, agents, subsidiaries, affiliates, or business associates, liable for any financial losses or damages resulting from reliance on any information, opinions, advice, or other materials available on the Platform, in brochures, promotional materials, or any other literature issued by Sukhmal or its affiliates or partners.

2.3 The Client is responsible for seeking independent professional advice regarding the suitability of any investment decisions. The Client acknowledges that employees and representatives of Sukhmal are not authorised to provide such advice and agrees not to solicit or rely on any investment recommendations from Sukhmal or its personnel. Any advice inadvertently provided by an employee or representative of Sukhmal shall be considered personal in nature, and Sukhmal disclaims any liability arising from such communications.

3. ELIGIBILITY, ACCOUNT INFORMATION, AND RESPONSIBILITIES

3.1 One of the conditions for establishing a relationship with Sukhmal is that the individual must not be debarred by SEBI or any other statutory authority from dealing in the securities market. By using our Product, you represent that you are of legal age to enter into a binding contract and are not prohibited from receiving services under applicable Indian laws. You also agree to provide true, accurate, current, and complete information about yourself, whether through the Product's registration form or any other means of communication. If any information provided by you is found to be untrue, inaccurate, outdated, or incomplete—or if Sukhmal has reasonable grounds to suspect the same—we reserve the right to suspend or terminate your account and deny any current or future access to our Product or its services. You undertake to indemnify and keep Sukhmal indemnified against any loss, claim, damage, or costs (including legal and professional expenses) arising from any misrepresentation, violation, or misuse, including those specified above.

3.2 "Personal Information" refers to any details you provide during registration, in the feedback section, or through any email communication. Your information will be protected in accordance with our Privacy Policy. If you access the Product/Website, you are responsible for maintaining the confidentiality of your Login ID and Password and for restricting access to your device. You agree to accept responsibility for all activities carried out under your Login ID or Password. Sukhmal shall not be liable for any loss or damage resulting from your failure to protect your account credentials. You undertake to indemnify and keep Sukhmal indemnified against any loss, claim, damage, or costs (including legal and professional expenses) arising from your responsibility, liability, or failure to comply with security measures. You agree to notify us immediately in case of any unauthorised access to your account or any security breach. Sukhmal reserves the right to refuse service, terminate accounts, or remove or modify content at its sole discretion.

4. ACCOUNT OPENING AND REGISTRATION

4.1. Sukhmal allows all types of entities, including individuals (minors via legal guardian), NRIs, HUFs, and Corporate entities, to create an account with us. Before accessing any online investment services on the Platform, the Client must complete Sukhmal's registration process, as prescribed from time to time. Individuals or entities barred by SEBI, AMFI, or any other regulatory authorities are strictly prohibited from accessing or using the services.

4.2 To register, the Client must follow the procedure outlined on the Platform, along with any instructions communicated by Sukhmal's employees or representatives. The Client's account shall be opened only after submission of the required documentation, its verification, and at the sole discretion of Sukhmal.

4.3 Users are required to complete electronic Know Your Customer (e-KYC) verification through PAN-based authentication, with identity validation conducted via third-party APIs such as BSE Star MF. The mandatory documents for registration include PAN, Aadhaar, bank details, FATCA declarations, and proof of address, while Non-Resident Indians (NRIs) must additionally submit a canceled cheque. Users warrant that all information provided is accurate and truthful, and any fraudulent submissions may result in account suspension and potential legal action.

5. ACCOUNT SECURITY, TRANSACTIONS, AND COMPLIANCE AT SUKHMAL

5.1 At Sukhmal, security is paramount. Every Client is provided with a unique login ID and password, granting them access to our investment platform. These credentials are essential for carrying out transactions, reviewing account details, and managing investments. To further enhance security, we implement a robust two-factor authentication (2FA) system, ensuring that only the rightful account holder can access and operate their account.

5.2 All transactions on our platform are conducted through BSE Star MF, a highly secure and regulated mutual fund platform. Every transaction—whether an investment or withdrawal—is handled directly through BSE Star MF's APIs. When a Client initiates a transaction, they are redirected to the official BSE Star MF website, where they complete the process independently. Sukhmal does not process or hold any Client funds at any stage. Instead, we act as a facilitator, ensuring a smooth and secure experience for our Clients.

5.3 In compliance with SEBI regulations, we strictly adhere to the principle that all financial transactions must occur directly between the Client and the exchange. As a distributor or broker, Sukhmal is not permitted to accept funds from Clients and then transfer them to the exchange. Instead, Clients must directly transfer their investment amount from their registered bank account to the exchange, ensuring transparency and regulatory compliance.

5.4 Security also extends to the handling of sensitive personal data. Clients must provide PAN details, bank account information, and other personal identification details to complete their registration. This information is treated with the highest level of confidentiality, ensuring that it remains secure and inaccessible to unauthorised parties. Furthermore, investments cannot be processed unless payments are made directly from the Client's bank account, adding another layer of protection against fraudulent transactions.

5.5 At Sukhmal, we are committed to providing a secure, transparent, and compliant investment platform. By integrating directly with BSE Star MF and adhering strictly to SEBI guidelines, we ensure that every Client's funds and data remain protected, giving them the confidence to invest securely.

5.6 The Client acknowledges that they are solely responsible for maintaining the confidentiality and security of their login credentials, including their Client ID and password. Any and all transactions carried out using these credentials shall be deemed to have been conducted by the Client themselves, regardless of whether such transactions were authorised by the Client. Sukhmal shall bear no liability for any loss, claim, or consequence arising from unauthorised access or misuse of the Client's login credentials or two-factor authentication details.

5.7 The Client confirms that they are fully aware of the inherent risks associated with online investment platforms, including the possibility of their login credentials being compromised or misused by third parties. The Client accepts the risk of unauthorised access, including instances of hacking or manipulation, and acknowledges that such actions may result in transactions being executed on their behalf without consent.

5.8 Without prejudice to the above, the Client agrees to notify Sukhmal immediately in writing if they suspect any unauthorised activity involving their login credentials or two-factor authentication. Such notification must include complete details, including the date, nature of the unauthorised access, and any transactions carried out as a result. The Client also undertakes to inform Sukhmal promptly if they are unable to recover access to their account even after utilising the standard password reset procedures provided on the Platform.

5.9 The Client further agrees to report to Sukhmal without delay upon discovering any technical vulnerability, security loophole, or other defect in the Platform or its integrated systems, including those connected to BSE Star MF.

6. MODIFICATION AND ACCURACY OF INFORMATION

6.1 The Client hereby confirms that all information provided in relation to the modification of their account details, including but not limited to bank account information, is true, accurate, and complete to the best of their knowledge. The Client understands that any false, misleading, or incomplete information may result in adverse consequences for which the Client shall be solely liable.

6.2 The Client further undertakes to immediately notify Sukhmal of any errors, discrepancies, or changes in the information submitted. It is the Client's responsibility to ensure that all modifications are promptly and accurately communicated, and any delay or failure to report such changes may impact the processing of transactions or services linked to their investment account.

6.3 The Client also acknowledges and agrees that once approved, the requested changes shall apply across all services associated with their account on the Sukhmal platform, including investment processing, redemption, and fund settlements.

7. CLIENT ACCOUNT TERMINATION AND SUSPENSION

7.1 Sukhmal reserves the right to suspend or terminate a Client's access to the Platform, either partially or entirely, under circumstances including but not limited to violation of applicable laws, breach of these Terms and Conditions, impersonation, or submission of false or misleading information. Suspension or termination of services may also result from any activity deemed unlawful, fraudulent, or in contravention of SEBI regulations.

7.2 Once suspended or terminated, the Client's right to access or use the Platform and related services shall cease immediately. Sukhmal shall not be liable to the Client or any third party for any claims, losses, or damages arising directly or indirectly from such suspension or termination, including the inability to transact or access investment data.

7.3 Sukhmal takes identity fraud and impersonation seriously. If it is discovered that a person is operating an investment account on behalf of someone else without authorisation, this will constitute a severe breach. The matter shall be reported to SEBI, and the concerned investment account may be permanently banned. Legal proceedings may also be initiated against the offending individual.

7.4 Users may request the deletion of their Sukhmal accounts, which will result in the permanent removal of their personal information from Sukhmal's internal databases. However, transactional and financial data submitted to BSE (via BSE Star MF APIs) cannot be deleted, as BSE retains such data as per regulatory requirements, and Sukhmal has no control over its deletion.

7.5 During the KYC process, Clients are required to submit an undertaking confirming that all information provided is accurate and complete to the best of their knowledge. Sukhmal shall not be held liable for any consequences arising out of incorrect or misleading information submitted by the Client. The Client bears full responsibility for ensuring the integrity and accuracy of their data.

7.6 In the event of a grievance related to account suspension or termination, Clients may write to Sukhmal in accordance with the grievance redressal policy provided on the Platform. Sukhmal will review such requests in line with applicable regulations, and any decision to reinstate account access shall be final and binding.

8. ORDERS AND PLACEMENTS

8.1 All orders and investment instructions placed through Sukhmal's platform using the Client's registered account, including but not limited to Systematic Investment Plans (SIPs) and lump sum investments in mutual funds, shall be deemed to have been placed by the Client.

8.2 Sukhmal shall not be responsible for any incorrect orders placed by the Client. Any order entered through the Client's registered account shall be considered final and binding, and the Client assumes full responsibility for the same.

8.3 The Client acknowledges that the cut-off timings for Net Asset Value (NAV) allocation for mutual fund transactions shall be as per the regulations prescribed by the Securities and Exchange Board of India (SEBI) and as provided on the Association of Mutual Funds in India (AMFI) website (https://www.amfiindia.com/investor-corner/knowledge-center/cut-off-timings.html).

8.4 Since Sukhmal does not process or handle payments directly, all payments for mutual fund transactions are redirected to the Bombay Stock Exchange (BSE) payment gateway. Any issues related to payment processing should be directed to the BSE. However, Clients may contact Sukhmal for assistance regarding transaction status.

8.5 The Client acknowledges that transaction confirmations, including SMS and email notifications, are provided by the BSE. Sukhmal may introduce a feature in the future to send transaction confirmations independently, but at present, all confirmations are handled solely by the BSE.

8.6 The transaction status of mutual fund investments is displayed within the Sukhmal application, along with any reasons for transaction failures. If an order fails for any reason, the Client may retry the payment through the 'Make Pending Payment' section of the application.

8.7 Currently, there is no provision for modifying or canceling a mutual fund transaction once it has been placed. The Client understands that all transactions are subject to market conditions and regulatory approvals, and Sukhmal does not have control over modifications or cancellations.

8.8. If a mutual fund scheme closes for new investments after a Client has placed an order, Sukhmal shall not be held responsible for the rejection of the order, as such decisions are managed by the BSE and respective fund houses.

8.9. Sukhmal retrieves and updates the Client's mutual fund portfolio daily based on the data provided by the exchange. The platform may provide insights and analytics based on the portfolio, but these are for informational purposes only and do not constitute financial advice.

8.10 Sukhmal reserves the right to impose or modify limitations on transactions, including but not limited to exposure limits, turnover limits, or restrictions on specific mutual fund schemes, at its sole discretion. The Client agrees that such limitations may be imposed without prior notice.

8.11 Sukhmal may reject any transaction order at its sole discretion for reasons including, but not limited to, regulatory restrictions, scheme suspensions, or circuit breaker limitations imposed by the exchange. If an order is rejected, it shall be considered lapsed and shall not be reprocessed.

8.12 If, for any reason, the markets close before an order is accepted by the exchange, such orders may be rejected. Orders rejected by the exchange shall remain declined and shall not be automatically reprocessed.

8.13 Without prejudice to the above provisions, Sukhmal may, at its sole discretion, permit the execution of an order irrespective of the balance amount in the Client's account. Such amounts may subsequently be recovered by Sukhmal during settlement. The cut-off time for processing and execution of such orders shall be as prescribed by the relevant stock exchange or mutual fund transaction platform and may vary based on the type of scheme or regulatory guidelines.

8.14 Pending orders shall be handled as per exchange rules and regulations at the end of each investment day. The Client acknowledges that the execution and settlement of mutual fund transactions are subject to market risks and regulatory constraints, and Sukhmal shall not be liable for any resultant losses.

9. TRANSACTION EXECUTION, CONFIRMATION, AND SYSTEM RISKS

9.1 The Client acknowledges that all mutual fund transactions initiated through Sukhmal's platform will be forwarded to the respective Asset Management Companies (AMCs) for execution. Orders are subject to AMC cut-off times, and those placed after the deadline will be processed on the next business day.

9.2 Upon successful execution, Sukhmal will send a transaction confirmation via email and/or SMS detailing the scheme, NAV, and allocated units. The Client must review the confirmation immediately and report any discrepancies within 24 hours.

9.3 Clients must report any transaction errors, unit allocation discrepancies, or NAV miscalculations within one business day. Sukhmal will verify such claims but holds the right to accept or reject corrections based on AMC policies.

9.4 The Client understands that transaction delays may occur due to AMC processing times, network/server outages, or high transaction volumes. Sukhmal shall not be liable for delays beyond its control.

9.5 Orders may be rejected if there are insufficient funds in the Client's bank account, investment limits are exceeded as per AMC or SEBI guidelines, or due to regulatory non-compliance. Rejected orders will not be automatically reprocessed.

9.6 Sukhmal relies on third-party integrations, including AMCs, banks, and payment gateways. In case of platform downtime or technical failures, transactions may be delayed or unsuccessful. Clients should manually verify their investment status.

9.7 All transaction updates will be sent to the registered email ID and mobile number. Clients must ensure their contact details remain updated, as Sukhmal shall not be responsible for communication failures due to outdated information.

9.8 All mutual fund transactions will be executed in accordance with SEBI, AMFI, and AMC regulations. Clients agree to abide by these policies while using the platform.

10. MARGIN REQUIREMENTS

10.1 Sukhmal does not require Clients to maintain any form of margin, funds, or assets with the Company. At no point shall Sukhmal request or accept custody of Client funds or assets, either directly or indirectly. All transactions are processed directly between the Client and the exchange through the official BSE Star MF platform, as per SEBI regulations.

10.2 Clients are solely responsible for initiating investments directly from their own registered bank accounts. Sukhmal neither facilitates nor interferes in such fund transfers and does not act as an intermediary in holding or managing Client money.

10.3 The Client may be required to maintain a portion of the margin in cash for liquidity purposes and must comply with any such requests made by Sukhmal.

10.4 The Client is responsible for continuously monitoring the market value of margin assets. If a decline in value results in a shortfall, the Client must immediately replenish the required margin, with or without notification from Sukhmal.

10.5 The Client must adhere to margin and investment exposure limits set by Sukhmal, regulatory authorities, or fund houses. Sukhmal reserves the right to revise margin requirements at its discretion.

10.6 In periods of market volatility, redemptions or transactions may be temporarily restricted due to regulatory or operational constraints. Sukhmal shall not be liable for any resulting losses due to such restrictions.

10.7 The Client acknowledges that margin assets may be pledged or assigned to banks, custodians, or clearing corporations to meet financial obligations. The Client authorises Sukhmal to take necessary actions for such arrangements.

10.8 Any reference to asset liquidation includes the redemption or transfer of mutual fund units held as margin. Sukhmal retains sole discretion in determining which assets to redeem in case of default or non-compliance.

11. FEES, CHARGES, AND REVENUE MODEL

11.1 Sukhmal operates on a commission-based revenue model, earning commissions from Asset Management Companies (AMCs) for facilitating investments. The Client shall not be charged any direct subscription fees, transaction costs, or service charges for using Sukhmal's platform. The platform remains entirely free for users, with no hidden charges or mandatory payments.

11.2 Sukhmal does not levy any fees on investments, withdrawals, or transactions made through its platform. However, regulatory charges such as exit loads, transaction fees, or penalties imposed by SEBI, AMCs, or stock exchanges may apply based on the specific mutual fund or investment product. These charges are determined by regulatory bodies and fund houses, and Sukhmal has no control over them.

11.3 There are no platform fees, service charges, or hidden costs associated with using Sukhmal for investing in mutual funds. The Client can access all available services without incurring any charges from Sukhmal. The platform does not engage in any direct billing or subscription-based services for users.

11.4 Sukhmal does not charge Clients for any premium features, including but not limited to portfolio tracking, investment analysis, financial insights, or advisory services. The platform remains committed to offering a cost-free experience for investors, with its only source of income being commissions from AMCs.

11.5 Sukhmal may send promotional emails for the purpose of providing information regarding a particular information not limited to mutual fund, IPO, new share which doesn't in any case indicate the preference of Sukhmal regarding any purchase of the share or fund. The information provided is just for educational purpose and is provided free of cost to the clients.

11.5 Sukhmal does not impose penalties on Clients for missed SIP (Systematic Investment Plan) payments or premature withdrawals. However, SEBI or the respective AMCs may apply penalties or restrictions based on the terms of the fund. The Client acknowledges that these charges are not under Sukhmal's control and must be reviewed before making investment decisions.

11.6 In the event of a failed transaction, refunds shall be processed directly by BSE or the respective clearing entity. Sukhmal does not handle refunds directly, and the timeline for processing refunds shall depend on the exchange's policies. The Client agrees to refer to the exchange or AMC for further details on refund procedures.

11.7 The Client may cancel an investment and request a refund based on the applicable terms of the mutual fund. If there is no lock-in period, the Client may withdraw funds at any time, subject to any exit load or penalties imposed by the AMC. However, if the fund has a lock-in period (such as ELSS or tax-saving schemes), withdrawal requests shall be rejected by BSE, and the Client must wait until the lock-in period ends.

11.8 Exit loads, AMC fees, or other regulatory charges applicable to specific mutual funds shall be displayed on the fund's description page. Sukhmal provides this information for transparency; however, the platform does not guarantee its accuracy. The Client is advised to verify details from the official SEBI website or consult a financial advisor before making any investment. Sukhmal shall not be held liable for any discrepancies in fund-related charges.

11.9 Sukhmal Fin Consultancy Private Limited, acting as a registered Mutual Fund Distributor, may suggest mutual fund schemes suitable to the client's investment goals and risk profile. Such suggestions are incidental to distribution services and do not constitute investment advice under SEBI (Investment Advisers) Regulations, 2013. The Company does not charge any advisory fee and is not registered as an Investment Adviser with SEBI.

11.10 As mandated by SEBI, Sukhmal shall provide full commission disclosures on its website, ensuring transparency regarding earnings received from AMCs. The Client acknowledges and agrees that these disclosures shall be publicly accessible and updated as per regulatory requirements.

12. REPRESENTATIONS AND WARRANTIES

12.1 The Client affirms that they are legally competent to enter into and be bound by these Terms, meet all eligibility requirements, including the legal age of 18 years, and are not restricted by any law from using Sukhmal's platform or services. Their participation does not violate any existing agreements or legal obligations. They also confirm that all personal and financial information provided to Sukhmal is accurate, complete, and up to date, including regulatory details such as PAN and SEBI registration, where applicable.

12.2 All investments made through Sukhmal, including funds used for transactions, belong solely to the Client and are free from legal disputes, encumbrances, or third-party claims. The Client acknowledges the risks involved in investing through the platform and understands that Sukhmal does not guarantee investment returns or the accuracy of third-party market data. They accept full responsibility for any investment decisions and transactions executed through their account and shall not hold Sukhmal liable for any technical interruptions, platform errors, or regulatory actions affecting services. It is the Client's sole responsibility to maintain the confidentiality of their account credentials, including passwords and authentication details, and to prevent unauthorised access. Any orders or transactions placed through the Client's account shall be deemed to have been executed by them or an authorised representative, and they accept full liability for such transactions.

12.3 Sukhmal affirms that it operates in full compliance with applicable laws, regulations, and SEBI guidelines for providing investment services through its platform. Reasonable measures shall be taken to ensure secure access, data protection, and transparency in its services, subject to regulatory requirements and prevailing market risks.

13. INTELLECTUAL PROPERTY RIGHTS

13.1 All intellectual property associated with the Platform, including but not limited to its software, underlying processes, techniques, trademarks, logos, designs, images, content, and any proprietary information, is the exclusive property of Sukhmal or is lawfully licensed to Sukhmal. The Client acknowledges that no rights, ownership, or licenses in any intellectual property are granted—whether expressly or impliedly—through the use of the Platform.

13.2 The Client shall not copy, modify, decompile, reverse engineer, or attempt to extract any source code or proprietary information from the Platform. Further, the Client shall not use, distribute, or replicate Sukhmal's branding, logos, marketing materials, or any other intellectual property for any purpose without prior written consent. Any attempt to remove copyright notices or use automated tools such as spiders, crawlers, or bots to access, extract, or replicate any content from the Platform is strictly prohibited. Any unauthorised use, reproduction, or infringement of Sukhmal's intellectual property in connection with any other service, product, or offering shall be considered a violation of applicable intellectual property laws and may be subject to legal action.

14. PERMITTED USE AND RESTRICTIONS

14.1 Subject to compliance with these Terms, Sukhmal grants the Client a non-exclusive, limited right to access and use the Platform. The Client agrees to use the Platform solely for lawful purposes as permitted by these Terms and in compliance with all applicable laws, regulations, and industry standards.

14.2 The Client shall not copy, reproduce, modify, publish, transmit, sell, distribute, display, or exploit any content, material, services, or information available on or through the Platform. However, the Client may download and use the Platform for personal, internal, and non-commercial purposes. The Client agrees not to engage in any activity that may disrupt, impair, or adversely affect the functionality of the Platform or interfere with other users' rights, access, or use of the Platform. Further, the Client shall not remove any copyright, proprietary notices, or legal disclaimers contained in any content available on the Platform.

14.3 The Client explicitly agrees not to:

• Engage in defamatory, abusive, harassing, or unlawful conduct against any individual or entity.
• Publish, distribute, or transmit any offensive, obscene, infringing, or illegal content.
• Copy, republish, or redistribute any Platform content without obtaining prior authorisation from Sukhmal.
• Conduct unauthorised surveys, contests, or marketing schemes.
• Upload or distribute software or files containing malware, viruses, or any harmful programs that could damage the Platform.
• Attempt unauthorised access to the Platform, its networks, servers, or any related systems.
• Probe, scan, or test the security of the Platform or breach any authentication measures.
• Collect, store, or misuse data of other users.
• Use automated tools such as bots or scrapers to access, extract, or interfere with the Platform.
• Use the Platform for unlawful activities or any purpose that infringes upon Sukhmal's or any third party's rights.
• Misrepresent or misuse Sukhmal's registration details, certificates, or credentials in any manner that could mislead the public or third parties into conducting business under Sukhmal's name.

Any violation of these terms may result in suspension or termination of the Client's access to the Platform, in addition to legal action as per applicable laws.

15. INDEMNITIES

15.1 The Client acknowledges that the use of internet-based investments requires robust authentication technologies and stringent security measures. The Client agrees to indemnify and hold Sukhmal, along with its affiliates, partners, directors, employees, and agents, harmless against any losses incurred by Sukhmal, its clients, or any third parties due to: (a) Any claims or actions initiated by a third party arising from the improper use of the Client's user ID, password, or two-factor authentication (2FA) credentials; (b) Any failures or delays in processing debits from the Client's bank account for fund transfers, including those related to mutual fund transactions; and (c) Any delays in order execution caused by banking issues or technical disruptions at Sukhmal's end, leading to variations in the Net Asset Value (NAV) at which mutual fund transactions are executed.

15.2 In the event of the Client's death, insolvency, liquidation, or any incapacity preventing them from fulfilling their obligations regarding securities transactions placed through the Platform, Sukhmal reserves the right to close out such transactions on the Client's behalf. The Client or their legal representatives shall bear any resulting losses or liabilities and shall also be entitled to any surplus gains arising therefrom. The Client further agrees to indemnify Sukhmal for any shortfalls that may result from such close-out actions.

15.3 By using the Platform, the Client expressly agrees to indemnify and hold Sukhmal, its affiliates, partners, directors, employees, and agents harmless from any losses or damages arising from: (a) The Client's violation of any applicable laws, regulations, or rules governing their transactions on the Platform; (b) Any breach by the Client of the provisions outlined in these Terms; and (c) Any act, negligence, misconduct, or fraudulent activity committed by the Client. This clause ensures that the Client remains accountable for their actions and safeguards Sukhmal against any financial or legal repercussions.

16. INVESTOR GRIEVANCE REDRESSAL MECHANISM

16.1 At Sukhmal, we prioritise investor satisfaction and are committed to addressing client grievances in accordance with the rules, regulations, and circulars issued by SEBI, Exchanges, and Depositories from time to time.

16.2 Our dedicated Investor Grievance team ensures that all complaints are efficiently monitored and resolved in compliance with regulatory requirements and our internal code of conduct. The grievance redressal process is overseen by the Compliance Officer, who directly reports to senior management and the Board of Directors, ensuring appropriate escalation in case of long-pending or critical issues.

16.3 Investors can submit their grievances via email at [email protected], which is prominently displayed on our website and other client communications. All complaints received—whether in writing, via email, or verbal communication—are centrally recorded, tracked, and addressed with appropriate resolutions. Our team also conducts periodic reviews to analyse complaint patterns and implement necessary improvements to prevent recurring issues.

16.4 Additionally, branch visits and audits are conducted to gather investor feedback and enhance service standards. We continuously refine our processes to enhance investor experience and maintain transparency, ensuring prompt and effective resolution of all concerns.

17. INVESTMENT ADVICE

17.1 The Client acknowledges that none of the services offered by Sukhmal shall be construed as investment advice. In the event that the Client receives any information, recommendations, or guidance from any employee or representative of Sukhmal, such communication shall be strictly in the personal capacity of the respective individual. Any investment decisions made by the Client based on such information shall be at their sole discretion, risk, and cost. Sukhmal shall bear no liability for any transactions executed by the Client in reliance on such recommendations or advice.

17.2 Furthermore, Sukhmal, along with its directors, officers, partners, employees, agents, and affiliates, shall not be held responsible for any investment decisions or transactions undertaken by the Client.

18. FORCE MAJEURE

18.1 Sukhmal shall not be held liable for any delays, disruptions, or failures in the performance of its obligations due to circumstances beyond its reasonable control. Such circumstances may include, but are not limited to, market or exchange rulings, suspension of investment, natural disasters such as fires, floods, earthquakes, cyclones, or tsunamis, civil unrest, riots, wars, strikes, pandemics, health emergencies, terrorist activities, system failures, internet disruptions, or any regulatory actions imposed by the government.

19. SEVERABILITY

19.1 If any provision of these Terms is found to be invalid, illegal, or unenforceable under any applicable law or regulation, the remaining provisions shall continue to be in full force and effect, unaffected by such invalidity, illegality, or unenforceability.

20. SECURITY, DATA PROTECTION & USER PRIVACY

20.1 Sukhmal is committed to ensuring the highest standards of security, data protection, and user privacy. The following measures and policies are in place to safeguard user data and comply with applicable legal requirements:

• Encryption & Cybersecurity Measures: All APIs are secured with HTTPS and require user authentication tokens. Data is encrypted using AES 256 CBC to prevent unauthorised access.
• Data Storage Location: While not all customer data is stored on Sukhmal's servers, the servers are located in India, in compliance with Indian data protection laws.
• Account Deletion & Data Erasure: Users have the ability to delete their accounts and erase their personal data upon request.
• Third-Party Data Sharing: Sukhmal does not share user data with third parties except where necessary, such as KYC and investment data shared by BSE. However, analytics services from Google and Meta are used to track app performance.
• Data Breach Handling & Notification: In the event of a data breach, Sukhmal ensures that any stored data remains encrypted and secure. Users will be promptly notified via email and updates on the website.
• Storage of Sensitive Financial Data: While bank account details and UPI IDs may be temporarily stored to assist with KYC verification, they are not retained in the database once the process is complete.
• Compliance with IT Act, 2000 & Digital Personal Data Protection Act: Sukhmal strictly adheres to all applicable laws and regulations concerning data protection and privacy.
• Mobile App Permissions: To enhance user experience and functionality, the mobile application may require the following permissions: Location Access (for analytics purposes); Camera & File Access (to upload necessary documents); Notifications (to send personalised and important alerts); Device Identifiers (to recognise users and their devices for security purposes).

21. MISCELLANEOUS

21.1 Sukhmal does not guarantee that its services will be uninterrupted or free from errors. All services are provided on an "as is" and "as available" basis, without any warranties, whether express or implied, including but not limited to warranties of merchantability or fitness for a particular purpose.

21.2 The Client acknowledges that online investments and investment services involve various complexities, including potential hardware failures, software issues, communication breakdowns, and unforeseen technical disruptions. These factors may lead to the temporary unavailability of services without prior notice. Sukhmal and its affiliates shall not be held liable for any interruptions, delays, or malfunctions affecting the platform's availability.

21.3 Sukhmal shall not be held responsible for any losses, damages, or liabilities arising from disruptions in its services. The Client agrees not to make any claims against Sukhmal or its affiliates due to the nonavailability or suspension of the platform's services. If there is any inconsistency between these Terms, the Privacy Policy, any service-specific policies, and agreements entered into between Sukhmal and the Client, the following order of precedence shall apply: (i) the agreement between Sukhmal and the Client, (ii) product- or service-specific terms and policies, (iii) the Privacy Policy, and (iv) these Terms.

21.4 To the fullest extent permitted by law, Sukhmal and its affiliates shall not be liable for any indirect, special, incidental, consequential, or punitive damages—including but not limited to loss of business, revenue, profits, or goodwill—arising from the Client's use or inability to use the platform.

22. GOVERNING LAW, JURISDICTION, AND DISPUTE RESOLUTION

22.1 These Terms, along with the use of Sukhmal's platform, shall be governed by and interpreted in accordance with the laws of India.

22.2 In the event of any dispute or disagreement between the Client and Sukhmal regarding the validity, interpretation, performance, termination, or alleged breach of these Terms ("Dispute"), both parties shall make a sincere effort to resolve the matter amicably within 30 days from the date the dispute arises.

22.3 If the parties are unable to reach an amicable resolution within the stipulated timeframe, the Client shall provide written notice to Sukhmal and refer the dispute for resolution through arbitration. The arbitration shall be conducted by a sole arbitrator mutually appointed by both parties. If the parties fail to mutually agree upon an arbitrator, the arbitrator shall be appointed in accordance with the rules of a recognised arbitration institution. The arbitration proceedings shall be conducted in English and follow the applicable arbitration laws of India. The venue and seat of arbitration shall be Surat, Gujarat. The arbitral award shall be final and binding on both parties.

22.4 For any matters that require judicial intervention, the courts in Surat, Gujarat, shall have exclusive jurisdiction over any disputes arising from these Terms or the use of Sukhmal's platform.

23. NOTICE

23.1 Any official communication, notice, or correspondence under these Terms will be considered validly delivered if sent to the recipient's last known email address, residential address, or registered business location. These communications may be sent through various methods, including: Hand delivery; Registered or regular post; Certified postal service; Email or fax; Affixing the notice at the recipient's last known business or residential address; Phone calls, voicemails, or verbal communication on the last known contact number.

23.2 If a notice sent by Sukhmal is returned as undelivered, unclaimed, or refused, it will still be considered properly served, provided it was sent using one of the prescribed methods.

23.3 Any information, notifications, or updates sent by Sukhmal to clients via their registered email IDs or phone numbers are intended solely for their personal use. Clients are strictly advised against sharing, forwarding, or distributing such communications to unauthorised parties.

24. AMENDMENTS TO THE TERMS

24.1 Sukhmal reserves the right to modify, update, or amend these Terms at its sole discretion. Any changes will be communicated through appropriate channels, including notifications on the platform or via email. Continued use of Sukhmal's services after such notification shall be deemed as the Client's acceptance of the revised Terms.

25. CONTACT INFORMATION

25.1 For any questions or concerns regarding these Terms, please feel free to reach out to us at [email protected]. Our team will be happy to assist you.