A. Vision and Mission Statements for investors

• Vision Invest with knowledge & safety

• Mission

• To enter into an agreement with the client providing all details including fee details, aspect 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 obtain registration with Know Your Client Registration Agency (KRA) and Central Know Your Customer Registry (CKYC).
• To conduct audit annually.
• To disclose the status of complaints in its website.
• To disclose the name, proprietor name, type of registration, registration number, validity, complete address with telephone numbers and associated SEBI regional/local Office details in 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.

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

• 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 provide investment advice to the client based on the risk-profiling of the clients and suitability of the client.

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

• In case of any grievance / complaint, an investor should approach the concerned Investment Adviser and shall ensure that the grievance is resolved within 30 days.
• If the investor's complaintis not redressed satisfactorily, one may lodge a complaint with SEBI on SEBI's 'SCORES' portal which is a centralized web-based complaints redressalsystem. SEBI takes up the complaints registered via SCORES with the concerned intermediary for timely redressal. SCORES facilitates trackingthe status of thecomplaint.
• 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. 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.
• 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.
• 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 assuredor guaranteed returns.

Don't

• 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.
• 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 and demat accounts with the Investment Adviser.

F. Governing Law and Jurisdiction

In case of any dispute, either judicial or quasi-judicial the same will be subject to the exclusive jurisdiction of the courts in Mumbai. These terms shall be construed in accordance with the laws prevalent in India and are subject to SEBI guidelines, circulars, press releases or notifications that may be issued by SEBI from time to time or the Government of India, to regulate the activities of RIAs (Registered Investment Advisors).

Annexure 2

Most Important Terms and Conditions (MITC)

1. The Investment Adviser (IA) shall only accept payments towards its fees for Investment Advisory Services and is not permitted to accept funds or securities in its account on the Client’s behalf.
2. The IA does not guarantee returns, accuracy, or risk-free investments. All advice is subject to market risks, and there is no assurance of any returns or profits.
3. Any assured/guaranteed/fixed returns schemes or any other schemes of similar nature are prohibited by law. No scheme of this nature shall be offered to the Client by the IA.
4. Investment advice, only related to securities shall fall under the purview of SEBI. In case of any services offered by IA related to products/services not under the purview of SEBI, IA shall make disclosure to the Client and take appropriate declaration and undertaking from the Client that such products/services and the services of IA in respect of such products/services do not come under regulatory purview of SEBI and that no recourse is available to the Client with SEBI for grievances related to such products/services or services of IA in respect of such products/services.
5. This agreement is for the investment advisory services provided by the IA and IA cannot execute/carry out any trade (purchase/sell transaction) on behalf of the Client without his/her/its specific and positive consent on every trade. Thus, the Client is advised not to permit IA to execute any trade on his/her/its behalf without explicit consent.

6. The fee charged by IA to the Client will be subject to the maximum of amount prescribed by SEBI/Investment Adviser Administration and Supervisory Body (IAASB) from time to time (applicable only for Individual and HUF Clients).

   Note:

   1. The current fee limit under Fixed Fee mode is Rs 1,51,000/- per annum per family of the Client. Under Assets under Advice (AUA) mode, maximum fee limit is 2.5 per cent of AUA per annum per family of client.
   2. The IA may change the fee mode at any time with the Client’s consent; however, the maximum fee limit in such cases shall be higher of fee limit under the fixed fee mode or 2.5 per cent of AUA per annum per family of Client.
   3. The fee limits do not include statutory charges.
   4. The fee limits apply only for investment advice related to securities under purview of SEBI.
   5. The fee limits do not apply to a non-individual client / accredited investor.

7. IA may charge fees in advance if agreed by the Client. Such advance shall not exceed the period stipulated by SEBI; presently it is maximum one year. In case of pre-mature termination of the IA services by the Client or the IA, the Client shall be entitled to seek refund of proportionate fees only for unexpired period. However, IA is entitled to retain a maximum breakage fee of not greater than one- quarter fee.
8. Fees to IA may be paid by the Client through any of the specified modes like cheque, online bank transfer, UPI, etc. Cash payment is not allowed. Optionally the Client can make payments through Centralized Fee Collection Mechanism (CeFCoM), managed by BSE Limited (i.e. currently recognized IAASB).
9. The IA is expected to know the Client’s financial details for providing services. Hence, the Client is required to share the financial information (e.g. income, existing investments, liabilities, etc.) with the IA.
10. The IA is required to carry out the client’s risk profiling and suitability analysis before providing services and thereafter on an ongoing basis. The services provided will be in line with the assessed risk profile. IA shall also communicate the assessed risk profile to the client.
11. As part of conflict of interest management, the client or the client’s family members will not be provided any distribution services by IA or any of its group entity/ family members. IA shall, wherever available, advice direct plans (non- commission based) of products only. The IA shall endeavor to promptly inform the client of any conflict of interest that may affect the services being rendered to the client.
12. For any grievances,

    Step 1: The Client should first contact the IA using the details on his website or following contact details:

    Contact Person: Ajay Pruthi

    Email id: support@plnr.in

    Mobile no: 8860000332

    Address:

    Shop No. 2, 1st Floor, Tulip Plaza, Plot No. 114, Sector 13, Kharghar
    Navi Mumbai-410210

    Step 2: If the resolution provided by IA is unsatisfactory, the client can lodge grievances through SEBI’s SCORES platform at www.scores.sebi.gov.in.

    Step 3: If the Client remains dissatisfied with the outcome of the SCORES complaint, the client may consider the Online Dispute Resolution (ODR) through the Smart ODR portal at smartodr.in.

13. The SEBI registration, enlistment with IAASB, and NISM certification do not guarantee the performance of IA or assure returns to the client.
14. The Client is required to keep contact details, including email id and mobile number/s updated with the IA at all times.
15. The IA shall never ask for the Client’s login credentials and OTPs for the Client’s Trading Account, Demat Account and Bank Account. Never share such information with anyone including IA.

Annexure 3

Disclosure about Usage of Artificial Intelligence Tools

I do not use any artificial intelligence tools as on date for providing investment advice and shall disclose to you if I use artificial intelligence tools for providing investment advice in the future.

Annexure 4

Grievance Redressal for Products/Services not under the purview of SEBI (for your information and informed consent)

We may advise (or may have advised) investments/products or offer services that do not come under the purview of SEBI. Please note that you shall have no recourse available with SEBI for any grievance related to such investments/products/services.

Your grievances related to financial products or services outside SEBI purview shall be overseen by the relevant regulator of those products. Such products/services include, but are not limited to, insurance products (IRDA), pension products (PFRDA), and bank fixed deposits and gold bonds (RBI).

Additionally, products such as overseas ETFs trading on foreign exchanges are not regulated by any financial regulator in India. No grievance redressal shall be available for such product with any financial regulator in India including SEBI.

You declare and undertake that you understand that you shall have no recourse available with SEBI for grievances related to investments, products, or services that do not fall under SEBI's purview.

OBJECTIVE

The security of your personal information is our priority. We receive and store both personal and non-personal information about you when you visit and/or use our website, www.plnr.in. We protect this information by maintaining physical, electronic, and procedural safeguards that meet applicable laws. We train our employees in the proper handling of personal information. This Privacy Policy lays down the norms that govern the use, disclosure, and sharing of information about the registered users of Plnr “Plnr”, “Plnr.in” and “www.plnr.in” are properties owned by Ajay Pruthi (“PLNR”).

COLLECTION OF INFORMATION

We collect the following Personal and Non-Personal Information when you use Plnr.
a. Personal Information for the purpose of this privacy policy includes:
i. YYour name, contact number, and e-mail that is collected for signing up on Plnr.
ii. Information provided by you, for using the services provided by us, such as your mobile number, e-mail, password, date of birth, residential address, gender, marital status, and Permanent Account Number (PAN).
iii. You may be required to provide certain additional information depending on the services that you wish to use, at your discretion.
iv. We may also retrieve information from centralized Know Your Customer (KYC) databases such as CVL KRA, NDML KRA, CERSAI (CKYC) etc. such as your KYC status and, father’s name, occupation, identity, and address proof documents.
v. For use of some services, we may be required to perform a Know Your Customer registration check and register/update your KYC if not already registered/updated. In such cases, we will require you to provide your KYC information as detailed in (i–iv) above, upload documentary evidence of your identity, address, and financial details, and record a live video interaction through the device in use that clearly shows your face to establish liveliness and verify that it’s you who is accessing our application.
vi. When you interact with our customer support systems including but not limited to chatbots, email, and live interaction with an agent either over chat or on call, we may record these interactions.

b. Non-Personal Information

i. When you visit our website, we collect and store information to enable us to provide an online experience that matches your device. The information collected includes the type and address of the device you use, the browser and its version, the operating system and its version you are using, and the website from which you came to the Plnr website.
ii. When you access our website through a mobile device, we collect information including your location, IP address, the make, model, and the unique identifier of the device in use, the browser and its version, the operating system installed on the device, and its version.
iii. When you browse our site or receive an e-mail from us, we and the companies we work with, use cookies and/or pixel tags to collect information and store your online preferences. Cookies are widely used and most browsers are set up to accept them automatically. If you would prefer, you can choose to not accept cookies by disabling the same through browser settings.
iv. Cookies and pixel tags help us improve your online experience. This comprises, inter alia, your response to any of our e-mails, the time and duration of your visit to our site, and the pages you viewed while on our site.
v. We may also supplement the information we collect with information we receive from other companies. For example, we may use marketing segments developed by us or other companies to customize certain services to your local area and provide relevant Plnr offers tailored to you. Any information provided to us by you or collected by us about you shall be deemed to have been disclosed willingly by you, without any coercion by our officers, agents or affiliates. While we make efforts to validate the information provided by you, we do not/shall not undertake any liability and do not/shall not make any representations as to the genuineness, validity, completeness, or correctness of the information provided by you.

3. STORAGE OF YOUR INFORMATION

Information collected is stored on our servers, log files, and/or storage systems owned by us or by third parties specifically providing such storage services.

4. USE OF INFORMATION

We use the personal information and non-personal information provided by you for
a. We use personal information and non-personal information provided by you for:
i. Facilitating various services provided by us, the availing of each of which are at your discretion, including - To enable us to complete your registration with us and/or with them.
ii. Checking/Updating/Registering your KYC in centralized KYC databases such NDML KRA, and CERSAI (CKYC).
iii. Resolving your queries, and concerns and providing you with support in case of any issues during the use of our services and of those provided by our partners.
iv. Informing you about any offers relating to services including sharing marketing material with you.
v. Streamlining and customizing your experience while accessing our services through the mobile browser or our website.
vi. Informing you over email or on a call about the progress of any issues with, if any, pertaining to the transactions initiated by you and the resolution thereof or relating to the services availed by you.
vii. To prepare analysis, reports, and tools for your use such as first cut calculation, financial plan, etc.
b. We use the non-personal information provided by you and aggregated information for:
i. To improve your experience while using our website, and mobile website.
ii. For troubleshooting and identifying any bugs, operational issues, process bottlenecks, and errors in the application and for analysing usage and activity trends and
iii. To prepare analysis, reports, and tools for your use.
iv. To monitor, identify, resolve, and prevent any security incidents, frauds, criminal activities, prohibited activities, non-compliance
v. For research, design, and development of the services offered by us.
vi. We may use aggregated information that does not identify you individually for better product design, research, and for developing customized marketing offers either by us or any affiliated or unaffiliated third-party consultants or service providers.

5. SHARING OF YOUR INFORMATION

a. When we use third parties to provide services, we require them to protect the confidentiality of personal information about you that they receive from us. The information is disclosed on a need-to-know basis.
b. We may use third-party service providers to enable us in providing some services to you such as sending e-mail messages to you and tracking them on our behalf, collecting a fee for our services, and providing technical support that can contact you regarding an issue with any feature or functionality on our website.
c. Information will be shared with select third parties such as entities registered under applicable laws with the Securities Exchange Board of India, the Reserve Bank of India, Central Registry of Securitisation Asset Reconstruction and Security Interest of India (CERSAI), KYC registration agencies (KRA), payment gateway providers.
d. Information will be shared with select third parties such as entities registered under applicable laws with the Securities Exchange Board of India, the Reserve Bank of India, Central Registry of Securitisation Asset Reconstruction and Security Interest of India (CERSAI), KYC registration agencies (KRA), payment gateway providers.
e. We also use third-party services such as Google tag manager, Google Analytics, etc that may collect information used to identify you.
f. We will not share with, or make available, your personal information to any third party without your authorisation, except if we are specifically directed or mandated to do so under any applicable law, legal proceeding, or directive by any administrative, judicial, quasi-judicial, statutory or regulatory body or any authority or agency of the Government.

6. SECURITY OF YOUR INFORMATION

a. Registering for a service on our website requires the creation of a Login ID and Password by you to ensure the privacy and security of the information you provide. Your Login ID and Password are the primary means to access our services and website, and hence as a security feature, our website requires the creation of a password that meets certain complex requirements. We recommend and require that you keep your Login ID and Password confidential. Further, we recommend that you change your password periodically. We shall not be responsible for any unauthorized access to your account if you share your Login ID and Password with anyone or as a consequence of a violation of this Privacy Policy or the Website’s Terms of Use.
b. Every time you log in to our website, we use, inter alia, the authentication and encryption protocols along with session time outs, and firewalls to protect your account from unauthorised access. Your password information is not accessible to anyone including us and can only be changed/updated by you using a two-factor authentication process.
c. We may offer the use of social logins or identity providers such as Google etc. to enable you to conveniently create an account and register yourselves on our website. By enabling the use of these credentials, we offer you the convenience of not having to create and remember a fresh user ID and password. Such service, its availability, and the privacy of your login information are governed by the terms and conditions of the respective service providers. Whilst we do take adequate measures to safeguard your information, we do not take responsibility of your information in case of a security breach at these service providers or in case you share your login information with anyone, or in case your social media account was to get hacked. We require you to maintain adequate confidentiality of your social login information and use this facility after due consideration and with appropriate caution
d. When you provide us with your personal information either while setting up an account with us or later, it is kept maintained by the division that is responsible for your account management. You can view and/or update/edit this information by logging on to your account through our website. As we add more services or wish to inform you of some additional benefits that we offer either directly or in partnership with any third party, we may use the information we have collected to offer you customized recommendations as well as marketing communications through any medium including e-mail, SMS, etc. You will have the option to opt out of such communications at any time.

7. CONSENT AND CHANGES TO THE PRIVACY POLICY

When you create a login ID and password or sign in to Plnr, you are providing your consent to this Privacy Policy.
Withdrawal of consent: Personal information collected will not be used for any purposes other than as mentioned herein. You may withdraw your consent for the use of personal information at any time by deactivating your account. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your personal data conducted in reliance on lawful processing grounds other than consent. In the event you choose to withdraw your consent for collecting and processing your personal data, we will be unable to provide you with our products and services.
Changes to the Privacy Policy: We reserve the right to unconditionally modify, change or update this Privacy Policy in part or its entirety at any point at our discretion without assigning any reason whatsoever. An update of this Privacy Policy shall be adequate notification of these changes, if any. We will publish the date of the last update made to this Privacy Policy right at the beginning of this document/web page. Further, the most updated Privacy Policy and the date of the last update of this Privacy Policy shall be available on https://plnr.in/privacy-policy on the web.

8. GRIEVANCE REDRESSAL

You may reach out to us for any queries with respect to this Privacy Policy through our Help section or by writing to support@plnr.in. We comply with the requirements of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011. For the purposes of this Act, we have designated Ajay Pruthi as the Grievance Officer. The Grievance Officer may be reached by writing to support@plnr.in.

Thank you for selecting the Investment Advisory Services offered by PLNR INVESTMENT ADVISORS (SEBI Registered Investment Adviser – INA 000018966) through their website (hereinafter referred to as " PLNR ") via its website www.plnr.in.

This document is an electronic record, being generated by a computer system and it does not require any physical or digital signature. This document is published in accordance with Information Technology guidelines for intermediaries and contains the rules and regulations for accessing and using PLNR.

Please carefully examine these Terms and Conditions. By continuing, and accepting through electronic means (such as clicking "I Agree"), either by accessing the website using your login credentials or utilizing the Services, you are consenting to these Terms and Conditions. Access to and use of the Services may only be granted upon acceptance of these terms and conditions.

1. Services Offered: Our website offers financial advice and guidance services to clients who are seeking to achieve their financial goals. Our services are fee- only, which means that we do not receive any commissions or other forms of compensation from third-party companies or financial products.

2. Client Agreement: In order to use our services, you must first sign our client agreement, complete your KYC and fill in the risk profile questionnaire. This agreement outlines the scope of our services, our fees, and our responsibilities to you as a client.

3. Confidentiality: We understand the importance of keeping your financial information confidential. We will not disclose your personal or financial information to any third parties unless required by law or with your written permission or as mentioned in the privacy policy. Whilst we do take adequate measures to safeguard your information, we do not take responsibility of your information in case of a security breach at these service providers or in case you share your login information with anyone or in case your social media account was to get hacked. We require you to maintain adequate confidentiality of your social login information and use this facility after due consideration and with appropriate caution.

4. Investment Advice: Our website may contain general information about investment strategies, but this information should not be considered personalized investment advice. Before making any investment decisions, you should consult with a licensed financial advisor.

5. No Guarantee of Results: While we strive to provide our clients with the best possible financial advice and guidance, we cannot guarantee that our recommendations will result in any specific investment outcomes or financial results. We will not be responsible for any losses or damages that may result from your investment decisions.

6. Limitations of Liability: We will not be liable for any damages arising from the use of our website or our services, including but not limited to direct, indirect, incidental, or consequential damages. You acknowledge that our liability is limited to the fees paid by you for our services.

7. Termination: We reserve the right to terminate our services to any client at any time, for any reason. We will provide you with written notice of termination, and any fees paid for services not yet rendered will be refunded to you.

8. Changes to Terms and Conditions: We may update these terms and conditions at any time, without prior notice. Your continued use of our website and services after any such changes will constitute your acceptance of the revised terms and conditions.

9. Intellectual Property: Our website and all of its content, including but not limited to text, graphics, logos, and images, are the property of our company and are protected by copyright and other intellectual property laws. You may not use or reproduce any content from our website without our written permission.

10. Governing Law: In case of any dispute, either judicial or quasi-judicial same will be subject to the exclusive jurisdiction of the courts in Mumbai. These terms shall be construed in accordance with the laws prevalent in India and are subject to SEBI guidelines, circulars, press releases, or notifications that may be issued by SEBI from time to time or the Government of India, to regulate the activities of RIAs (Registered Investment Advisors).

Thank you for choosing our fee-only financial advisor website. We look forward to helping you achieve your financial goals.