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This website www.primeinvestor.in (“Website”) is owned and operated by PrimeInvestor Financial Research Pvt. Ltd. (“RA”), a SEBI-registered Research Analyst with Registration No. INH200008653.

Through the Website, the RA allows clients to access research recommendations, research reports, and model portfolios, along with tools, personal finance products, and articles, on the payment of a subscription fee (“Research Services”). The terms ‘RA’ or ‘us’ or ‘we’ refer to PrimeInvestor Financial Research Pvt Ltd (SEBI RA Registration No INH200008653) who are the owners of this Website and offering the Research Services. The term ‘you’ and ‘client’ refers to the subscriber of the Services on the Website. The RA provides the Research Services subject to the notices, terms, and conditions set forth in these Terms. By accepting these Terms when you subscribe to the Research Services, you provide your consent to abide by these Terms.

Most Important Terms and Conditions (MITC)

[Forming part of the Terms and Conditions for providing research services]

1. These terms and conditions, and consent thereon are for the research services provided by the Research Analyst (RA) and RA cannot execute/carry out any trade (purchase/sell transaction) on behalf of the client. Thus, the clients are advised not to permit RA to execute any trade on their behalf.
2. The fee charged by RA to the client will be subject to the maximum amount prescribed by SEBI/ Research Analyst Administration and Supervisory Body (RAASB) from time to time (applicable only for Individual and HUF Clients).
   Note:
   • SEBI's current cap on fee is Rs 1,51,000/- per annum per family of client for all research services of the RA.
   • The fee limit does not include statutory charges.
   • The fee limits do not apply to a non-individual client / accredited investor.
3. RA may charge fees in advance if agreed by the client. Such advance shall not exceed the period stipulated by SEBI; presently it is one quarter. In case of pre-mature termination of the RA services by either the client or the RA, the client shall be entitled to seek refund of proportionate fees only for the unexpired period.
4. Fees to RA 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 RAASB).
5. The RA is required to abide by the applicable regulations/ circulars/ directions specified by SEBI and RAASB from time to time in relation to disclosure and mitigation of any actual or potential conflict of interest. The RA will endeavor to promptly inform the client of any conflict of interest that may affect the services being rendered to the client.
6. 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 RA.
7. The RA cannot guarantee returns, profits, accuracy, or risk-free investments from the use of the RA's research services. All opinions, projections, estimates of the RA are based on the analysis of available data under certain assumptions as of the date of preparation/publication of research report.
8. Any investment made based on recommendations in research reports are subject to market risks, and recommendations do not provide any assurance of returns. There is no recourse to claim any losses incurred on the investments made based on the recommendations in the research report. Any reliance placed on the research report provided by the RA shall be as per the client's own judgement and assessment of the conclusions contained in the research report.
9. The SEBI registration, Enlistment with RAASB, and NISM certification do not guarantee the performance of the RA or assure any returns to the client.
10. For any grievances,
    • Step 1: the client should first contact the RA using the details on its website or following contact details:
      Customer care: [email protected]
      Grievance officer: [email protected], ATTN: Srikanth Meenakshi
      Compliance officer: [email protected], ATTN.: Bhavana Acharya
      Principal officer: [email protected], ATTN.: Vidya Bala
    • Step 2: If the resolution is unsatisfactory, the client can also lodge grievances through SEBI's SCORES platform at www.scores.sebi.gov.in
    • Step 3: The client may also consider the Online Dispute Resolution (ODR) through the Smart ODR portal at https://smartodr.in
11. Clients are required to keep contact details, including email id and mobile number/s updated with the RA at all times.
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By browsing, viewing, using the Website and subscribing to the Research Services provided therein you consent to and agree to comply with these Terms and Conditions of subscription (“Terms”).

The RA reserves the right to change or modify the Website, the contents thereof and these Terms at any time. All modifications to these Terms & Conditions will be posted on the Website and will become effective immediately upon such posting. Changes once made will be communicated to the client. Continued use of the Website shall be construed as acceptance of the revisions to the Terms by conduct.

The following terms and conditions include but are not limited to minimum mandatory terms and conditions to clients as stipulated by SEBI.

1. Availing the research services

By accepting delivery of the research service, the client confirms that he/she has elected to subscribe to the research service of the RA at his/her sole discretion. The RA confirms that Research Services shall be rendered in accordance with the applicable provisions of the SEBI RA Regulations.

2. Obligations on RA

The RA shall be bound by the SEBI Act and all the applicable rules and regulations of SEBI, including the RA Regulations and relevant notifications of Government, as may be in force, from time to time.

3. Client Information and KYC

The client shall furnish all such details in full as may be required by the RA in its standard form with supporting details, if required, as may be made mandatory by Research Analyst Administration and Supervisory Body(RAASB)/SEBI from time to time. RA shall collect, store, upload and check KYC records of the clients with KYC Registration Agency (KRA) as specified by SEBI from time to time.

4. Standard Terms of Service

The consent of client shall be taken on the following understanding:

“I / We have read and understood the terms and conditions applicable to a research analyst as defined under regulation 2(1)(u) of the SEBI (Research Analyst) Regulations, 2014, including the fee structure.

I/We are subscribing to the research services for our own benefits and consumption, and any reliance placed on the research report provided by research analyst shall be as per our own judgement and assessment of the conclusions contained in the research report.

I/We understand that –

1. Any investment made based on the recommendations in the research report are subject to market risk.
2. Recommendations in the research report do not provide any assurance of returns.
3. There is no recourse to claim any losses incurred on the investments made based on the recommendations in the research report.”

The declaration of the RA is as follows:

1. We are duly registered with SEBI as an RA pursuant to the SEBI (Research Analysts) Regulations, 2014 and our registration details are: registration no SEBI INH200008653, with registration date 19th August, 2021
2. We have the registration and qualifications required to render the services contemplated under the RA Regulations, and the same are valid and subsisting;
3. Research analyst services provided by us do not conflict with or violate any provision of law, rule or regulation, contract, or other instrument to which it is a party or to which any of its property is or may be subject;
4. The maximum fee that may be charged by the RA is ₹1.51 lakhs per annum per family of client. Our current fee structure, the term and duration of our subscription for our Research Services, can be viewed on our website here: https://primeinvestor.in/prime-pricing
5. The recommendations provided by us as part of the Research Services do not provide any assurance of returns.

5. Consideration and mode of payment

The client shall duly pay to the RA the agreed fees for the services that RA renders to the client and statutory charges, as applicable. Such fees and statutory charges shall be payable through the specified manner and mode(s)/ mechanism(s).

The payment of fees shall be through a mode that shows traceability of funds. Such modes include but are not limited to credit cards/debit cards/ UPI/ net banking or any other mode specified by SEBI from time to time. However, the fees shall not be in cash.

6. Risk factors

1. Investments are subject to market risk. Investing or trading in financial products involves risk. Past performance of the recommendation is not an indication of future returns. Past performance of the RA is not an indicator of future performance. Past performance of the security is not an indication of future returns.
2. There are no assurances or guarantees that the objectives of any investment in financial products will be achieved.
3. The names of financial products mentioned herein do not in any manner indicate their prospects or returns. The performance in the equity may be adversely affected by the performance of individual companies, changes in the market place and industry specific and macro-economic factors.
4. The performance of the investments/ products recommended by the RA are subject to a wide range of risks, including but not limited to: performance of the respective companies, changes in equity and debt market conditions, micro and macro factors and forces affecting equity and debt markets, general levels of interest rates and interest rate risk, credit risk, liquidity risk, reinvestment risk, economic slowdown, volatility & illiquidity of the stocks, risks associated with trading volumes, liquidity and settlement systems in equity and debt markets and/or such other circumstance beyond the control of the RA or any of its Associates.
5. Other risk factors include that may affect the performance of the investments/ products recommended by the RA include but are not limited to economic policies, changes of Government and its policies, acts of God, acts of war, civil disturbance, sovereign action and /or such other acts/ circumstance beyond the control of the RA or any of its Associates.
6. The recommendations provided by the RA as part of its Research Services may not be suitable to all categories of investors.
7. The client should read all scheme and security related documents carefully before investing.
8. Returns and performance figures mentioned in the research report represent past performance and should not be constituted to be future returns or guaranteed returns.

7. Conflict of interest

The RA shall adhere to the applicable regulations/ circulars/directions specified by SEBI from time to time in relation to disclosure and mitigation of any actual or potential conflict of interest. Registration granted by SEBI and certification from NISM in no way guarantee performance of the intermediary or provide any assurance of returns to investors. Investment in securities market are subject to market risks. Read all the related documents carefully before investing.

General disclosures: PrimeInvestor Financial Research Pvt Ltd (with brand name PrimeInvestor) is an independent research entity offering research services on personal finance products to customers. We are a SEBI registered Research Analyst (Registration: INH200008653). PrimeInvestor Financial Research Pvt. Ltd., its employees, directors or agents, do not have any material adverse disciplinary history as on the date of publication of this report.

Restrictions on trading: To ensure no conflict of interest, the RA declares as follows:

1. Personal trading activities of the individuals employed as research analysts shall be monitored, recorded and subject to a formal approval by the directors or compliance officer of PrimeInvestor Financial Research Private Limited.
2. Research analysts employed by PrimeInvestor Financial Research Private Limited or their associates or relatives shall not:
   • Deal/ trade in stocks recommended/ tracked by the research analyst within 30 days before and five days after the publication of a research report;
   • Deal/ trade in securities that the research analyst reviews in a manner contrary to the given recommendation;
   • Purchase or receive securities of the issuer before the issuer's initial public offering, if the issuer is principally engaged in the same types of business as companies that the research analyst follows or recommends.

Disclosures with respect to Research and Recommendations Services:

1. The RA or its directors or any of its officer/employee does not trade in securities which are subject matter of recommendation.
2. The RA, or any of its officers, directors, employees, or subsidiaries have not received any compensation/ benefits whether monetary or in kind, from the AMC, company, government, bank or any other product manufacturer or third party, whose products are the subject of its Research Services or investment information.
3. The Research Analysts who have prepared the research reports that form part of the Research Services (“Research Analyst”) certify that all of the views expressed in the research report accurately reflect their views about the subject company or subject security.
4. The RA or directors or employees or Research Analyst certify that no part of their compensation was, is, or will be directly or indirectly related to the specific recommendation(s) or view(s) in this report.
5. The Research Analyst has not served as director, officer or employee in the subject company, AMC or insurance company of the mutual fund or insurance policy that is the subject of this report, or company whose bonds, NCDs, fixed deposits or other savings products that is the subject of this report.
6. The Research Analyst or their relatives do not have any known direct or indirect material conflict of interest including long/short positions in the subject company.
7. The Research Analyst may hold investments in the stocks, mutual fund schemes, bonds, fixed deposits, insurance policies, or other products that are the subject of the recommendations provided as part of the Research Services. The Research Analyst certifies that they will not act in a manner contrary to their views on these securities except in the event of significant news or event or change in personal financial circumstances and without formal approval from the directors of PrimeInvestor Financial Research Pvt. Ltd. or the compliance officer.
8. There are no actual or potential conflicts of interest arising from any connection to or association with any issuer of products/ securities, including any material information or facts that might compromise its objectivity or independence in the carrying on of the Research Services. Such conflict of interest shall be disclosed to the client as and when they arise.
9. The RA or its directors or its employee or its associates have not managed or co-managed the public offering of any company. The RA or its directors or its employee or its associates have not received any compensation for investment banking or merchant banking of brokerage services from the subject company. The RA or its directors or its employee or its associates have not received any compensation for products or services other than above from the subject company. The RA or its directors or its employee or its associates have not received any compensation or other benefits from the Subject Company or 3rd party in connection with the research report/ recommendation.
10. The subject company of its research recommendations was not a client of the RA or its directors or its employee or its associates during twelve months preceding the date of recommendation services provided.
11. The RA or its directors or its employee or its associates has not served as an officer, director or employee of the subject company. Research Analysts has not been engaged in market making activity of the subject company.

PrimeInvestor Financial Research Pvt. Ltd., its Associates, the Research Analysts or their relatives holds ownership of 1% or more, in respect of the said issuer company(ies)? – NO

8. Termination of service and refund of fees:

The RA may terminate or suspend rendering of Research Services to the client in the following circumstances:

1. On account of suspension/cancellation of registration of RA by SEBI. In case of suspension of certificate of registration of the RA for more than 60 (sixty) days or cancellation of the RA registration, RA shall refund the fees, on a pro rata basis for the period from the effective date of cancellation/ suspension to end of the client’s subscription period.
2. The RA voluntarily chooses to terminate its Research Service. In the event of such termination of the Research Service, the RA shall refund the fees, on a pro rata basis for the period from the date of such termination of research service to end of the client’s subscription period.

9. Grievance redressal and dispute resolution:

Any grievance related to:

1. nonreceipt of research report, or
2. missing pages or inability to download the entire report, or
3. any other deficiency in the research services provided by RA

shall be escalated promptly by the client to the person/employee designated by RA, in this behalf as under:

Name: Bhavana Acharya
Designation: Director & Compliance Officer, PrimeInvestor Financial Research Pvt Ltd
Email: [email protected]

The RA shall be responsible to resolve grievances within 7 (seven) business working days or such timelines as may be specified by SEBI under the RA Regulations.

RA shall redress grievances of the client in a timely and transparent manner. Any dispute between the RA and his client may be resolved through arbitration or through any other modes or mechanism as specified by SEBI from time to time.

If the client is not satisfied with the response of the RA, he/she can lodge his/her grievances with SEBI at scores.sebi.gov.in. Alternatively, the client may also write to any of the offices of SEBI. For any queries, feedback or assistance, please contact SEBI Office on Toll Free Helpline at 1800 22 7575 / 1800 266 7575

Details on grievances are available on the Website as follows: https://primeinvestor.in/ra-grievance/

10. Additional clauses:

Scope of the Research Service: The Research Services will be limited to providing independent research recommendation and shall not be involved in any advisory or portfolio allocation services. The Research Services are not meant to be tailor-made or customized solutions that specifically apply to each client based on his/her risk profile.

The RA never guarantees the returns on the recommendation provided. Investor shall take note that investment/trading in stocks/Index or other securities is always subject to market risk. Past performance is never a guarantee of same future results. The RA shall not be responsible for any loss to the Investors.

This service is not directed for access or use by anyone in a country, especially the USA, Canada or the European Union countries, where such use or access is unlawful or which may subject PrimeInvestor Financial Research Pvt Ltd or its affiliates to any registration or licensing requirement.

The Research Service, including recommendations, research reports, updates, and other information will be accessible through the RA’s website https://primeinvestor.in only. Such recommendations and updates will not be provided over phone calls.

Fees: Our current fee structure, the term and duration of our subscription for our Research Service, can be viewed on our website: https://primeinvestor.in/prime-pricing. Eligibility for any discounts is ascertained at the time the client subscribes. Any such discount and its tenure shall be at the discretion of the RA.

Subscription and access to content services fall under the purview of Goods and Services Tax (GST) as per the current indirect taxation policy, Government of India. Unless otherwise indicated, prices stated on our website are exclusive of applicable GST, any applicable value added tax (VAT) or other sales taxes. We are a business-to-consumer (B2C) service provider and we do not commit to provide any input tax credit on GST charged on subscription to our Research Service.

We may change the Subscription Fees and charges then in effect, or add new fees or charges which will take effect at the end of the client’s subscription period, by giving notice in advance and an opportunity to cancel renewal of the subscription.

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Unless the client notifies us before the end of his/her subscription period, or the client cancels the auto-renewal mandate within the period specified by law, that the client does not wish to renew his/her subscription, the client’s subscription will renew for the period defined by the client’s subscription plan. We will charge the subscription using the same payment method that you previously used.

Although the client may notify to us his/her intention to his/her subscription, such notice will only take effect at the end of his/her then current subscription period, and he/she will not receive a refund other than as set out under Clause 8 in these Terms.

The client may notify us of his/her wish to cancel his/her subscription by sending an email to [email protected]. The client must provide at least 5 business days advance notice for this to be implemented.

Refunds: There can be no cancellation and refund of subscription fee paid once the subscription is active, other than as stated in Clause 8 of these Terms. If the client is entitled to a refund as specified under Clause 8 of these Terms, the RA will credit that refund to the card or other payment method used by the client to submit payment, unless it has expired - in which case the RA will contact the client to proceed with the refund. If we do issue a refund or credit due to circumstances outside the obligations specified under Clause 8, we are under no obligation to issue the same or a similar refund in the future.

General disclaimers: The recommendations made herein in the Research Services are expression of views and/or opinions and should not be deemed or construed to be advice for the purpose of purchase or sale of any security, nor a solicitation or offering on any investment/ trading opportunity on behalf of the company, AMC, insurance company, or issuer of security referred to herein.

The content and research reports generated by the RA does not constitute or is not intended to constitute an offer to buy or sell, or a solicitation to an offer to buy or sell financial products, units or securities.

The information/ opinion/ views mentioned in research reports or by the RA are not meant to serve as a professional guide to the client or recipients of this Report. The research report, recommendation, or any other content published by the RA do not assure or guarantee any minimum or fixed returns to the client or recipients of the reports/ recommendations/ content.

Use of this information is at the client’s own risk. The client must make his/ her own investment decisions based on his/her specific investment objective and financial position and using such independent advisors as he/she believes necessary. The services rendered by the RA are on a best-effort basis. All information in the content or research report of the RA is provided on an as is basis. Information is believed to be reliable but the RA does not warrant its completeness or accuracy and expressly disclaim all warranties and conditions of any kind, whether express or implied.

While due care has been taken to ensure that the disclosures, information, and opinions given are fair and reasonable, PrimeInvestor Financial Research Pvt Ltd and/or none of its officers, directors, partners, employees, agents, subsidiaries, affiliates or business associates shall be liable for any direct, indirect, special, incidental, consequential, punitive or exemplary damages, including lost profits arising in any way whatsoever from the information/ opinions/ views contained in the research report and recommendations that form part of the Research Service, and/or mails, social media or notifications issued by PrimeInvestor Financial Research Pvt Ltd or any other agency appointed/authorised by PrimeInvestor Financial Research Pvt Ltd. Returns and performance figures mentioned in the research report represent past performance and should not be constituted to be future returns or guaranteed returns.

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The purpose of these disclosures is to provide essential information about the Research Services in a manner to assist and enable the prospective client/client in making an informed decision for engaging in Research Services before onboarding.

History, present business and background: PrimeInvestor Financial Research Private Limited is registered with SEBI as Research Analyst with registration no. INH200008653. The Research Analyst got its registration on August 19, 2021 and is engaged in offering research and recommendation services.

Disciplinary history: There are no pending material litigations or legal proceedings against the Research Analyst. As on date, no penalties / directions have been issued by SEBI under the SEBI Act or Regulations made thereunder against the Research Analyst relating to Research Analyst services.

Details of the RA's associates: No associates.

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Without the prior written consent of the RA, modification of the materials, use of the materials on any other web site or networked computer environment or use of the materials for any purpose other than personal, non-commercial use is a violation of the copyrights, trademarks and other proprietary rights, and is prohibited. Any use for which the client receives any remuneration, whether in money or otherwise, is a commercial use for the purposes of these Terms.

The client may occasionally distribute a copy of a research report, or a portion of the same, from the Website in non-electronic form to a few individuals without charge, provided the client includes all copyright and other proprietary rights notices in the same form in which the notices appear, original source attribution, and the phrase “Used with permission from PrimeInvestor Financial Research Pvt. Ltd.”

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We reserve the right to cease to provide the client with the Research Services or access to the Website, or terminate your subscription, with immediate effect and without notice and liability, for violating these Terms, applicable law, rules or regulations and reserves the right to remove Prohibited Content which is in violation of these Terms, or is otherwise abusive, illegal or disruptive. The determination of whether any content constitutes Prohibited Content, violates these Terms, or is otherwise abusive illegal or disruptive, is subject to the sole determination of the Firm.

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• This Website and/or Research Services will be constantly available, or available at all;
• The information on this Website or provided through the Research Services is complete, true, accurate or not misleading; or
• The quality of any products, services, information, or other material that you obtain through the Website or Services will meet your expectations.

The RA, to the fullest extent permitted by law, disclaims all warranties, whether express or implied, including the warranty of merchantability, fitness for particular purpose and non-infringement. The RA makes no warranties about the accuracy, reliability, completeness, or timeliness of the Website, Research Services, Content, Contributed Content, Services, software, text, graphics and links.

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1. Represents, warrants and covenants that no materials of any kind provided by him/her will:
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2. Hereby agree to indemnify, defend and hold harmless the RA and all of the RA’s officers, directors, owners, agents, customers/clients, information providers, affiliates, licensors and licensees (collectively, the “Indemnified Parties”) from and against any and all liability and costs, including, without limitation, reasonable advocate’s fees, incurred by the Indemnified Parties in connection with any claim arising out of any breach by the client of these Terms or the foregoing representations, warranties and covenants. The client shall cooperate as fully as reasonably required in the defence of any such claim. The RA reserves the right, at its own expense, to assume the exclusive defence and control of any matter subject to indemnification by the client.

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In accordance with the Information Technology Act 2000, the name and the details of the Grievance Officer at PrimeInvestor is provided below:

Mr. Srikanth Meenakshi
PrimeInvestor Financial Research Pvt. Ltd., Registered office: 659, 4th Avenue, D-Sector, Anna Nagar Western Extension, Chennai 600 101.
Email: [email protected]

11. Mandatory notice:

Clients shall be requested to go through Do’s and Don’ts while dealing with RA as specified in SEBI master circular no. SEBI/HO/MIRSD-POD-1/P/CIR/2024/49 dated May 21, 2024 or as may be specified by SEBI from time to time.

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SEBI has operationalized a centralized fee collection mechanism for IA and RA. Under this mechanism, clients shall pay fees to IAs/RAs through a designated platform/portal administered by a recognized Administration and Supervision body. This is an optional mechanism for the registered entities. At this time, PrimeInvestor has opted out of this fee collection mechanism. Therefore, all subscription payments for the Research Services will be through the modes as specified in Clause 5 of these Terms.