Agreement, privacy and disclosures.

1.Important client acknowledgement

By accepting this Agreement, the Client confirms that:

1. I/We have read and understood the terms and conditions of the Investment Advisory Services provided by Visor, including the applicable fee structure and the mechanism for charging and payment of fees.
2. Based on my/our written request, I/we have been given an opportunity to ask questions and interact with persons associated with investment advice.
3. I/We understand that investment advice involves market risks and that Visor does not guarantee returns, profits, preservation of capital, accuracy of forecasts or any particular investment outcome.
4. I/We understand that Visor provides advisory services only and does not take custody or control of my/our funds or securities.
5. I/We understand that Visor will not execute or carry out any purchase or sale transaction on my/our behalf without my/our specific and positive consent for that transaction.
6. I/We understand that Visor will never ask for my/our bank, trading or demat passwords, PINs or OTPs.
7. I/We understand that I/we remain responsible for the final decision to accept, reject or defer any recommendation.

Visor declaration

Visor declares that:

• no Investment Advisory Services will be provided and no advisory fee will be charged before this Agreement is validly accepted by the Client;
• Visor will not manage Client funds or securities;
• Visor will only receive amounts necessary for payment of agreed advisory fees; and
• Visor will not represent or imply that any investment advice is assured, guaranteed, minimum-return, target-return, risk-free or capable of generating returns with any level of assurance.

2.Regulatory details

3.Appointment and nature of relationship

The Client appoints WealthOS Technologies Private Limited, operating under the brand name Visor, to provide Investment Advisory Services in accordance with this Agreement and Applicable Law.

Visor shall act in a fiduciary capacity towards the Client and shall provide advice based on the Client’s objectives, financial circumstances, risk profile, risk capacity, investment horizon and other relevant information.

The Client remains free to accept, reject or defer any recommendation.

4.Scope of advisory services

Visor may provide investment advice and financial planning relating to:

• securities and investment products within the regulatory scope of SEBI;
• portfolio construction and asset allocation;
• investments and retirement planning;
• financial goals;
• cash-flow and financial-position analysis;
• portfolio review;
• risk assessment;
• suitability assessment;
• investment research and analysis;
• tax-aware investment considerations; and
• other investment advisory services permitted under Applicable Law.

Visor may advise across the full range of securities and investment products permitted to a SEBI-registered Investment Adviser, subject to the Client’s circumstances, suitability and Applicable Law.

Visor is an advisory-only service. At present, Visor does not provide distribution, brokerage, custody, discretionary portfolio management or transaction-execution services.

5.Services relating to products outside SEBI’s purview

Visor may also provide financial planning or advisory information relating to products or services outside SEBI’s regulatory jurisdiction, where legally permitted.

Such products may include, where applicable, insurance, deposits, loans, real estate, gold, tax-related financial considerations and other products or services outside SEBI’s jurisdiction.

The Client acknowledges that:

1. SEBI regulates investment advice relating to securities within its jurisdiction.
2. Products and services outside SEBI’s jurisdiction, and Visor’s advisory services specifically relating to them, are outside SEBI’s regulatory purview.
3. The Client will not have recourse to SEBI for grievances relating specifically to such products or services, or to Visor’s advisory services in respect of them.
4. Such services remain subject to all other applicable laws and regulatory requirements.

The Client’s acknowledgement of this clause is recorded separately in Schedule C.

6.Risk profiling and suitability

Visor shall conduct risk profiling and suitability assessment before providing Investment Advisory Services, and thereafter on an ongoing basis as required by Applicable Law.

The Client’s assessed risk profile shall be communicated to the Client and advice shall be provided in accordance with it. The risk profile is recorded in Schedule B.

The Client shall provide accurate and reasonably complete financial information and shall inform Visor of material changes in circumstances, objectives, liabilities, income, investment horizon or risk tolerance.

If sufficient information is unavailable to assess suitability, Visor may decline to provide the relevant advice.

7.Investment objectives and guidelines

The specific investment objectives, financial plan, model, strategy, risk profile, investment horizon and any Client-specific restrictions shall be documented separately for the Client.

Visor shall recommend investments consistent with the Client’s assessed circumstances and suitability.

Where direct plans or other non-commission-based alternatives are available and applicable, Visor shall recommend direct plans in accordance with Applicable Law.

The Client understands that investment advice is based on information and circumstances prevailing at the time it is given and may become unsuitable when circumstances change.

8.Risk factors

Investments are subject to market and other risks, including market volatility, liquidity risk, credit or default risk, interest-rate risk, inflation risk, concentration risk, issuer risk, regulatory risk, taxation risk, operational risk and risks specific to individual investments.

The value of investments may rise or fall and the Client may lose part or all of the invested capital.

Past performance is not indicative of future performance.

Any projections, illustrations, scenarios or estimates are based on assumptions and are not guarantees of future results.

9.No guarantee

Visor does not guarantee:

• returns;
• profits;
• preservation of capital;
• achievement of financial goals;
• investment performance;
• accuracy of forecasts; or
• achievement of any target return.

No communication from Visor shall be interpreted as representing an investment as risk-free or as providing an assurance of returns.

10.Client responsibilities

The Client shall:

• provide accurate and current information;
• provide information reasonably required for KYC, risk profiling and suitability;
• disclose relevant investments, assets and liabilities;
• notify Visor of material changes in circumstances;
• review recommendations and the associated risks;
• make the final investment decision;
• independently obtain tax, legal or other professional advice where appropriate; and
• maintain accurate contact details with Visor.

Visor may rely on information provided by the Client and authorised third-party sources, subject to reasonable verification and Applicable Law.

11.Visor’s responsibilities

Visor shall:

• comply with Applicable Law;
• act in a fiduciary capacity;
• undertake risk profiling and suitability assessment;
• maintain required records;
• maintain appropriate compliance and audit processes;
• provide appropriate investment analysis and recommendations;
• communicate relevant risks;
• maintain confidentiality of Client information;
• disclose material conflicts of interest;
• maintain appropriate grievance-redressal mechanisms; and
• comply with the applicable Code of Conduct.

Visor shall maintain appropriate records of Client-wise KYC, risk assessment, analysis, suitability, dated investment advice and its rationale, fees, communications and other records required by Applicable Law.

12.Advisory-only relationship

Visor provides advice; the Client makes the investment decision.

Visor does not:

• hold Client funds or securities;
• operate the Client’s bank, trading or demat account;
• execute transactions;
• provide discretionary portfolio management;
• provide distribution services; or
• require a power of attorney for implementation of advice.

Any future change to the nature of Visor’s services shall be subject to Applicable Law, appropriate disclosures and amendment of this Agreement where required.

13.Specific client consent

Visor shall obtain the Client’s required consent before undertaking any action relating to Securities or investment products advised by Visor.

Visor cannot execute or carry out any purchase or sale transaction on behalf of the Client without the Client’s specific and positive consent for every such transaction.

The Client is advised not to permit any person claiming to represent Visor to execute any trade without the Client’s explicit consent.

14.No power of attorney or credentials

Visor shall not seek a power of attorney or other authorisation allowing it to independently implement investment advice.

Visor shall never request:

• bank passwords;
• trading passwords;
• demat passwords;
• OTPs;
• UPI PINs;
• transaction PINs; or
• similar confidential credentials.

The Client shall never share such information with Visor or anyone claiming to represent Visor.

15.Conflicts of interest

Visor shall operate independently and at arm’s length from its related parties and shall disclose material conflicts of interest as and when they arise.

Visor shall not derive any direct or indirect benefit from the Client’s Securities or investment products except as expressly permitted and disclosed under Applicable Law.

Visor shall not recommend investments merely to generate transactions, fees or commercial benefit.

Visor shall seek to place the Client’s interests ahead of commercial considerations in providing Investment Advisory Services.

16.Distribution

Visor currently operates as an advisory-only business and does not provide distribution services for Securities or investment products.

Accordingly, the Client’s relationship with Visor is an investment advisory relationship and not a distribution relationship.

If Visor or any group entity commences distribution activities in the future, the applicable client-level segregation and other regulatory requirements shall be complied with before such services are offered to advisory clients.

17.Fees and billing

Visor shall charge the Client a fixed advisory fee, subject to the applicable regulatory limits and the specific fee agreed with the Client.

The fee, billing frequency, service period, advance-payment terms, taxes and payment method applicable to the Client are set out in the Fee Schedule (Schedule A, Part 2).

The Client shall receive an appropriate invoice, receipt or other evidence of payment.

Fees shall be collected only through traceable payment methods permitted under Applicable Law. Cash payments shall not be accepted.

Where available, the Client may also use the Centralised Fee Collection Mechanism for Investment Advisers (CeFCoM).

Applicable GST and statutory charges are payable in addition to the advisory fee, where applicable.

18.Fee limits and refunds

For Individual and HUF Clients to whom the regulatory fee limits apply, the advisory fee shall not exceed the maximum amount prescribed by SEBI/IAASB from time to time. The limits in force are recorded in Schedule A, Part 3.

These limits:

• apply to investment advice relating to securities under SEBI’s purview;
• exclude applicable statutory charges; and
• do not apply in the same manner to non-individual clients or accredited investors where exempted under Applicable Law.

Visor may charge fees in advance only with the Client’s agreement and within the period permitted by SEBI.

Where an advance-paid advisory arrangement is terminated prematurely, the Client shall be entitled to a proportionate refund for the unexpired period, subject to the applicable regulatory framework. Any permissible breakage fee shall not exceed the amount permitted by SEBI.

19.Technology and AI

Visor may use technology, automated systems, analytical tools and artificial intelligence as part of its advisory and service processes.

Technology may assist with activities such as financial analysis, research, data organisation, insights, monitoring and communication.

The use of technology does not change Visor’s regulatory or fiduciary responsibilities. Visor remains responsible for Investment Advisory Services provided to the Client in accordance with Applicable Law. The Client’s acknowledgement is recorded in Schedule D.

20.Client data and privacy

Visor may collect and process information reasonably necessary to provide the Services, including financial, investment, KYC, risk-profile and related information.

Client information shall be handled in accordance with Applicable Law and Visor’s Privacy Policy (see Schedule E).

Visor may use authorised third-party technology and infrastructure providers where necessary to provide the Services, subject to applicable confidentiality, security, regulatory and data-protection requirements.

Visor shall not knowingly sell Client financial information for unrelated advertising or commercial purposes.

21.Records and confidentiality

Visor shall maintain Client records and advisory records for the periods and in the manner required by Applicable Law.

Such records may include KYC information, risk assessments, suitability assessments, investment analysis, advice and rationale, fees, communications, consents and other regulatory records.

Visor shall maintain confidentiality of Client information except where disclosure is:

• authorised by the Client;
• necessary to provide the Services;
• made to authorised service providers;
• required by law, regulation, court or governmental authority; or
• otherwise permitted by Applicable Law.

22.Taxes

The Client shall be responsible for taxes and statutory charges arising from the Client’s investments.

Visor may provide tax-aware investment considerations where permitted but does not provide tax filing, legal or accounting services unless separately agreed and legally permitted.

Visor’s advisory fees shall be subject to applicable GST and other statutory charges.

23.Term and termination

This Agreement shall commence upon valid acceptance by the Parties and shall continue until terminated.

Either Party may terminate this Agreement by giving written notice for the period stated in Schedule A, Part 3, unless a shorter period is permitted or required by Applicable Law.

Visor may suspend or terminate the Services immediately where required by law, regulatory direction, fraud, unlawful conduct, material misrepresentation, security risk or other circumstances permitting such action under Applicable Law.

If Visor’s SEBI registration is suspended or cancelled, the Client shall have the rights and options available under Applicable Law.

Upon termination:

• outstanding fees shall be settled;
• applicable refunds shall be processed;
• ongoing advisory services shall cease;
• outstanding matters shall be addressed as required;
• Visor shall provide reasonable transition assistance where required by Applicable Law; and
• regulatory records shall be retained for the required period.

24.Death or disability of Client

If the Client dies or becomes legally incapacitated, Visor may suspend advisory services until the appropriate nominee, legal representative, successor or authorised person is identified in accordance with Applicable Law.

Visor shall deal with such person in accordance with Applicable Law and shall settle applicable fees, refunds and outstanding matters appropriately.

25.Liability

Visor shall not be liable for losses arising solely from fluctuations in asset values, market conditions, or the performance, non-performance or underperformance of Securities, funds or other investments.

Visor shall not be liable for losses arising solely from a Client’s decision to reject, delay, modify or independently implement advice.

Visor shall not be liable to the extent that a loss results from materially inaccurate, incomplete or outdated information supplied by the Client.

Nothing in this Agreement shall exclude or limit liability that cannot lawfully be excluded, including liability arising from fraud, wilful misconduct or other non-excludable liability.

Except to the extent prohibited by Applicable Law, Visor’s aggregate liability arising from or relating to the Services shall be limited to the cap stated in Schedule A, Part 3.

Nothing in this Agreement shall restrict any statutory, regulatory or other non-waivable right available to the Client.

26.Force majeure

Visor shall not be liable for delays, interruptions or errors caused by circumstances beyond its reasonable control, including natural disasters, war, civil disturbance, government or regulatory action, fire, flood, power failure, telecommunications failure, widespread cyber incidents, third-party infrastructure failures or other comparable events.

Visor shall take reasonable steps to minimise disruption and restore Services as soon as reasonably practicable.

27.Grievance redressal

The Client should first raise any grievance with Visor, using the details of the Grievance Officer in clause 2 or on the Grievance redressal section of this page.

Visor shall address grievances within the timelines prescribed by Applicable Law.

If the Client is dissatisfied with Visor’s resolution, the Client may lodge a complaint through SEBI’s SCORES platform.

If the Client remains dissatisfied, the Client may consider the applicable Online Dispute Resolution mechanism through the Smart ODR platform.

28.Dispute resolution and arbitration

The Parties shall first attempt to resolve disputes through Visor’s grievance-redressal process.

Nothing in this Agreement prevents the Client from exercising rights available under Applicable Law or approaching SEBI, SCORES, IAASB or the applicable ODR mechanism.

Subject to such regulatory mechanisms, disputes arising out of or relating to this Agreement shall be governed by the laws of India.

Where arbitration is applicable, the dispute shall be referred to arbitration in accordance with the Arbitration and Conciliation Act, 1996, as amended, and the applicable regulatory framework. The seat, venue and jurisdiction are stated in Schedule A, Part 3, subject to Applicable Law.

Nothing in this clause limits the Client’s statutory and regulatory rights or any mandatory jurisdiction prescribed by law.

29.Amendments

This Agreement may be amended by mutual written or electronic consent of the Parties.

Where an amendment is required because of a change in Applicable Law or regulatory requirement, Visor may make the required amendment and notify the Client in accordance with Applicable Law.

Material commercial changes, including changes to fees or material changes to the scope of Services, shall be communicated and implemented in accordance with Applicable Law and shall require Client consent where required.

30.Representations and covenants

Visor represents that it shall maintain the registrations, approvals, qualifications, certifications, personnel and regulatory arrangements required to provide the Services.

Visor shall comply with the applicable SEBI regulations, circulars, directions and Code of Conduct throughout the term of the advisory relationship.

The Client represents that the information provided to Visor is accurate to the best of the Client’s knowledge and that the Client has the authority to enter into this Agreement.

31.Regulatory disclosure

The Client acknowledges that:

• SEBI registration, IAASB enlistment and applicable NISM certification do not guarantee the performance of Visor or assure returns;
• investment advice is subject to market risks;
• the Client must maintain current contact details with Visor; and
• Visor shall never request trading-account, demat-account or bank-account login credentials or OTPs.

32.Investor Charter

The applicable SEBI Investor Charter for Investment Advisers shall be provided or made available to the Client as required by Applicable Law (see Schedule F).

The Investor Charter is complementary to this Agreement and does not reduce any rights available to the Client under Applicable Law.

33.Standardised SEBI MITC

The Most Important Terms and Conditions (MITC) prescribed by SEBI for Investment Advisers, as applicable on the date of execution of this Agreement, form an integral and binding part of this Agreement as Schedule G.

The MITC shall be reproduced in the then-current standardised form prescribed by SEBI/IAASB and shall not be modified in a manner that dilutes any regulatory requirement.

In the event of any inconsistency between this Agreement and the mandatory MITC or Applicable Law, the mandatory regulatory requirement shall prevail.

34.SEBI MITC: Client confirmation

By accepting this Agreement, the Client confirms that the Client has been informed of and understands the following mandatory principles:

1. Visor accepts only advisory fees and does not accept or hold Client funds or Securities on the Client’s behalf.
2. Visor does not guarantee returns, accuracy or risk-free investments.
3. Guaranteed, assured or fixed-return schemes prohibited by law shall not be offered.
4. SEBI regulates investment advice relating to Securities within its jurisdiction; services relating to products outside SEBI’s jurisdiction require the disclosures and Client undertaking described in this Agreement.
5. Visor cannot execute or carry out a purchase or sale transaction without the Client’s specific and positive consent for every transaction.
6. Applicable advisory fees are subject to SEBI/IAASB fee limits where those limits apply.
7. Advance fees, refunds and permissible breakage fees are subject to the applicable SEBI framework.
8. Fees shall be paid through traceable permitted modes and shall not be paid in cash.
9. The Client is required to provide relevant financial information necessary for advisory services.
10. Visor shall conduct risk profiling and suitability analysis before providing services and thereafter as required, and shall communicate the assessed risk profile to the Client.
11. Applicable conflict-of-interest and advisory/distribution segregation requirements shall be followed, and direct/non-commission-based plans shall be advised wherever available and applicable.
12. Complaints may be raised first with Visor, followed by SEBI SCORES and, where applicable, Online Dispute Resolution.
13. SEBI registration, IAASB enlistment and NISM certification do not guarantee Visor’s performance or assure returns.
14. The Client must keep contact details, including email and mobile number, updated.
15. Visor shall never ask for the Client’s Trading Account, Demat Account or Bank Account login credentials or OTPs.

35.SEBI MITC: Trade-consent requirement

This Agreement is for Investment Advisory Services provided by Visor. Visor cannot execute or carry out any trade, including any purchase or sale transaction, on behalf of the Client without the Client’s specific and positive consent for every trade.

The Client is advised not to permit Visor or any person claiming to represent Visor to execute any trade on the Client’s behalf without explicit consent.

36.Severability

If any provision of this Agreement is held invalid, unlawful or unenforceable by a competent authority, the remaining provisions shall continue to remain effective to the extent permitted by law.

37.Miscellaneous

Each Party shall execute such further documents and take such further actions as may reasonably be required to give effect to this Agreement.

This Agreement, together with Schedules A to G, the Client’s declarations, and the execution page, constitutes the agreement between the Parties concerning the Investment Advisory Services.

If any provision conflicts with a mandatory requirement of Applicable Law, the mandatory requirement shall prevail.

Schedule A.Client details and commercial terms

Everything that is specific to you, or that can change, is kept here. It is completed for each client.

Schedule B.Client risk profile

Schedule C.Products outside SEBI’s purview: declaration

Schedule D.Technology and AI disclosure

Schedule E.Privacy Policy

Schedule F.Investor Charter

Schedule G.SEBI standardised MITC

Execution

1. Who we are

Visor is a financial advisory and financial planning platform operated by WealthOS Technologies Private Limited (“Visor”, “we”, “us” or “our”).

Privacy contact: Sainath S, Principal Officer

Grievance contact: Sainath S, Principal Officer (compliance@visorwealth.in)

Where applicable, Visor acts as the entity responsible for determining how and why your personal data is processed.

We handle personal information in line with applicable Indian law, including the Digital Personal Data Protection Act, 2023 and the rules made under it, as they come into force.

2. Our approach to your data

We follow a few principles in everything we do with your information:

• Your data belongs to you.
• We collect information only when there is a clear reason for us to use it.
• We collect only what is reasonably necessary for that purpose.
• We explain why we need information before or when we collect it.
• We do not use your financial information for unrelated purposes without an appropriate legal basis or your consent, where consent is required.
• You remain in control of your information and can exercise the rights available to you under applicable law.
• We do not sell your personal information.
• We do not share your personal financial information with third parties for their own marketing purposes without your appropriate consent.
• We use appropriate technical and organisational measures to protect the information entrusted to us.

3. What information do we collect?

The information we collect depends on how you interact with Visor.

Information you provide directly

This may include:

• Name
• Mobile number
• Email address
• Age or date of birth
• PAN and other identification information where required
• KYC information
• Financial goals and priorities
• Income and employment information
• Expenses and cash-flow information
• Savings and investments
• Loans and liabilities
• Insurance information
• Risk-profile information
• Information you provide in conversations with us
• Information you provide when you contact us or request support

We will only ask for information that is relevant to the service or purpose for which it is being collected.

Financial information

Where you choose to connect financial accounts or information sources, we may receive information such as:

• Bank account information
• Account balances
• Transactions
• Investments and securities
• Mutual fund holdings
• Insurance information
• Loans and liabilities
• Other financial information made available through the relevant connection

Where financial information is obtained through an Account Aggregator or another regulated consent-based mechanism, the applicable consent framework will apply.

Information collected automatically

When you use our website or services, certain technical information may be collected automatically, such as:

• IP address
• Device and browser information
• Operating system
• Website or app activity
• Pages viewed and interactions
• Approximate location derived from technical information, where applicable
• Diagnostic and security information

We use this information primarily to operate, secure and improve our services.

Our services are intended for adults. We do not knowingly collect personal information from anyone under 18 without the verifiable consent of a parent or lawful guardian, as required by law. If you believe a child’s information has been shared with us, please contact us and we will act on it.

4. Why do we collect your information?

We collect and use information only for clear and legitimate purposes, including to:

Provide financial advice and planning

We use relevant information to understand your financial situation, goals, priorities and risk profile and to provide financial analysis, planning and recommendations.

Personalise your experience

We may use information to make our services, communication and recommendations more relevant to you.

Monitor and review your financial plan

Where you have engaged Visor for ongoing advice, we may use your information to help review your circumstances and identify where your financial plan may need to change.

Provide and improve our services

We use information to operate, maintain, troubleshoot and improve our products and services.

Communicate with you

We may use your contact information to:

• Respond to your questions and requests
• Provide information about your engagement
• Send important service communications
• Share updates relating to your account or services
• Communicate with you where you have asked us to do so

Security and fraud prevention

We may process information to protect our customers, systems and services, detect suspicious activity, prevent fraud and maintain security.

Legal and regulatory requirements

We may process and retain information where required to comply with applicable laws, regulations, regulatory requirements, court orders, audits, investigations or other lawful obligations.

Business operations

We may use information for accounting, billing, record-keeping, internal controls, dispute resolution and other activities necessary to operate our business.

5. We collect only what is useful

We do not believe in collecting information simply because it might be useful someday.

Before asking for information, we consider whether it is genuinely needed to:

• Understand your financial situation
• Provide better financial analysis
• Give you appropriate advice
• Operate the service you have requested
• Keep the service secure
• Meet a legal or regulatory requirement

If information is not needed for one of these purposes, we aim not to collect it.

6. How we use your financial information

Financial information is central to the services Visor provides, so we treat it with particular care.

We may use your financial information to understand your current position, analyse your cash flows, savings, investments, loans and other financial commitments, assess your risk profile, understand your goals and develop financial recommendations.

We may also use information you provide over time to review whether your financial plan continues to make sense as your circumstances change.

We will not use your financial information for unrelated purposes simply because we have access to it.

7. How Visor uses AI

Visor uses artificial intelligence to support parts of our services. AI may be used to help analyse information, identify patterns, organise information, support financial analysis, improve personalisation, assist advisors and make parts of the service faster and more useful.

AI does not replace the responsibility Visor has for the services we provide.

AI systems used by Visor operate within processes, controls and review mechanisms established by Visor. Where AI plays a material role in an interaction or service, we will aim to provide appropriate information about its use.

We do not treat AI as a reason to collect information that we otherwise would not need.

Where third-party AI or technology providers are used to process personal information, we will assess and manage those providers in accordance with our security, privacy and contractual requirements.

8. How we share your information

We do not sell your personal information.

We may share information where it is necessary to provide the service, operate our business, comply with law, protect our users or where you have provided appropriate consent.

This may include sharing information with:

Service providers

We may use trusted third-party providers for services such as:

• Cloud infrastructure
• Data storage
• Analytics
• Communication
• Customer support
• Identity verification
• KYC
• Security
• Payments
• Technology infrastructure
• AI and other software services

These providers may process information on our behalf and are expected to use it only for the purposes for which we engage them and in accordance with applicable contractual and legal requirements.

Financial information providers

Where you choose to connect a financial account through an Account Aggregator or another consent-based mechanism, information may be exchanged through the applicable regulated framework and your consent.

Regulators, authorities and legal processes

We may disclose information where required or permitted by law, regulation, court order, regulatory direction or lawful government request.

Security and fraud prevention

We may disclose information where reasonably necessary to detect, prevent or investigate fraud, security incidents, unlawful activity or threats to our users or systems.

Business transactions

If Visor is involved in a merger, acquisition, restructuring, financing, sale of assets or similar transaction, personal information may be transferred as part of that transaction, subject to applicable law and appropriate protections.

We will not share your financial information with another organisation for its own marketing or unrelated commercial use without your appropriate consent.

9. Your consent and control

Where consent is the basis for processing your personal information, we will seek consent in a clear and understandable manner.

You should not have to agree to unrelated uses of your information simply to use a service that does not require them.

Where applicable, you may withdraw consent. Withdrawal of consent will not affect the lawfulness of processing that took place before withdrawal.

After withdrawal, we will stop or restrict processing based on that consent within a reasonable period, unless we are required or permitted to continue processing the information under applicable law.

10. Your rights

Subject to applicable law, you may have rights including the ability to:

• Know what personal information we process and why
• Request access to your personal information
• Request correction of inaccurate or incomplete information
• Request deletion of personal information where permitted
• Withdraw consent where consent is the basis for processing
• Request information about how your information is being used
• Request information about the sharing of your information, where applicable
• Raise a grievance about our handling of your personal information
• Nominate another individual to exercise applicable rights on your behalf, where provided for under applicable law

Some requests may be subject to legal, regulatory or contractual limitations. For example, we may need to retain certain information to comply with legal or regulatory obligations, maintain required records, resolve disputes or establish or defend legal claims.

To exercise your rights, contact us at:

compliance@visorwealth.in

We may need to verify your identity before acting on a request. This is to protect your information from unauthorised access.

11. Data retention

We keep personal information only for as long as it is reasonably necessary for the purpose for which it was collected, or for as long as required by applicable law, regulation, contractual obligations, dispute resolution or legitimate record-keeping requirements.

For example, where Visor is subject to regulatory requirements applicable to investment advisers, certain client, advice, risk-profile and interaction records may need to be retained for prescribed periods.

When information is no longer required, we will delete it, anonymise it or securely dispose of it in accordance with our retention practices and applicable law.

12. How we protect your information

We use reasonable and appropriate technical and organisational measures designed to protect your information against:

• Unauthorised access
• Unauthorised use
• Loss
• Misuse
• Alteration
• Disclosure
• Destruction

These measures may include access controls, authentication, encryption where appropriate, logging, monitoring, secure infrastructure, employee controls and other security practices appropriate to the nature of the information.

Access to financial information is limited to people and systems that need it for an authorised purpose.

No digital service can guarantee absolute security. If we become aware of a security incident affecting your personal information, we will take steps to contain and address it, and will notify affected individuals and the relevant authorities as required by applicable law.

13. Cookies and tracking technologies

Visor may use cookies, pixels, SDKs and similar technologies to operate and secure our website and services, understand how they are used, remember preferences and improve our services.

These technologies may include:

Necessary technologies

These help our website and services function properly and may not be optional where they are required for the service.

Analytics technologies

These help us understand how people use our website and where we can improve it.

Preference technologies

These help remember choices you make.

Marketing technologies

Where used, these may help us understand the effectiveness of marketing or show more relevant communications.

Where applicable, we will provide controls that allow you to manage non-essential cookies or tracking technologies.

We do not use tracking technologies to collect financial information simply for advertising purposes.

14. Marketing communications

We may occasionally send you information about Visor, our services, educational content, events or other relevant updates.

Where required, we will obtain the appropriate consent before sending marketing communications.

You can opt out of marketing communications at any time by using the unsubscribe mechanism provided in the communication or by contacting us.

Opting out of marketing will not stop important service-related communications that are necessary for an existing engagement.

15. Communications from Visor

Some communications are necessary for us to provide our services. These may include:

• Account and security notifications
• Service updates
• Appointment or engagement information
• Payment information
• Important changes to our services
• Information relating to your financial plan or advisory relationship

You may not be able to opt out of these communications while using the relevant service.

We will not use necessary service communications as a way to send unrelated marketing.

16. Third-party links and services

Our website or services may contain links to third-party websites, applications or services.

Those services are governed by their own privacy policies and terms. Visor is not responsible for the privacy practices of third parties that operate independently from us.

Where we integrate a third-party service into the Visor experience, we will seek to provide appropriate information about the role that service plays and the information it may process.

17. Storage and Processing of Personal Data

Visor aims to keep your personal information primarily within India and, wherever possible, processes and stores it in India, subject to applicable law and regulatory requirements.

Some of the technology and service providers we use may process information outside India. Where that happens, it will be only where permitted under applicable Indian law and regulatory requirements, and we will require appropriate safeguards.

Where third-party service providers are used to support our services, we will require them to meet appropriate privacy and security requirements and will ensure that their handling of your information is consistent with our obligations.

18. Complaints and Grievance Redressal

If you have a concern about how Visor has collected, used, stored or otherwise handled your personal information, we encourage you to contact us first.

You can raise a privacy-related request or grievance using the contact details provided at the beginning of this Privacy Policy.

We will acknowledge your concern within 72 hours and resolve it within 15 days, or sooner where applicable law requires.

You may also exercise any rights or pursue any remedies available to you under applicable law.

19. Changes to this Privacy Policy

As Visor grows, our services, technology and legal or regulatory obligations may change. We may therefore update this Privacy Policy from time to time.

If we make material changes, we will take reasonable steps to bring them to your attention through our website, application, email or another appropriate channel, where required.

The latest version of this Privacy Policy will always be available on our website, along with the date on which it was last updated.

Where a change requires your consent under applicable law, we will seek your consent before continuing the relevant processing.

20. Questions, Requests and Contact

If you have a question about this Privacy Policy, want to understand how your information is being used, or wish to exercise your rights, please contact us using the privacy contact details provided at the beginning of this Privacy Policy.

We encourage you to reach out whenever you are unsure about how your information is being handled. We will endeavour to provide a clear explanation and assist you with your request.