KYC Requirements & Data Handling

1. Purpose

1.1 This KYC & Onboarding Policy ("Policy") describes how “Raj Rupesh Shah” ("“Raj Rupesh Shah” ", "we", "our", "us"), a SEBI-registered Research Analyst, conducts client onboarding and Know Your Customer ("KYC") verification in compliance with: SEBI (Research Analyst) Regulations, 2014; SEBI RA Master Circular as issued from time to time; Prevention of Money Laundering Act ("PMLA") and associated KYC Rules; SEBI KYC Master Circular as issued from time to time and any directions or clarifications issued by SEBI or RAASB from time to time; Internal compliance standards followed by us.

1.2 This Policy applies to all individuals and institutions subscribing to research services issued/provided by us.

2. Requirement for KYC Verification

2.1 As mandated under applicable SEBI regulations, KYC verification is compulsory for every paying clients for research services.

2.2 KYC ensures: (a) Authenticity of client identity; (b) Regulatory compliance under RA Regulations; (c) Prevention of fraudulent or unauthorized use of research services; (d) Adherence to PMLA obligations.

2.3 We retain full responsibility for all KYC steps and compliance with SEBI and PMLA obligations.

2.4 A client is activated for research subscription only after successful completion of all verification steps.

3. Information Collected for KYC

We collect and verify the following identity information, as required for RA registration and PMLA compliance:

3.1 Mandatory Identity Information

• • Full Name, Father/Spouse Name, Date of Birth and such data attributes as prescribed under the SEBI Circular(s) on KYC from time to time
• • Permanent Account Number (PAN)
• • Proof of Identity which includes [Aadhaar XML / Masked Aadhaar Data Omitted] or other officially valid document
• • Proof of Address
• • Recent Photograph
• • Signature

3.2 Additional KYC-Related Information

• • Email & mobile number used for verification
• • KYC verification status and audit logs
• • Any risk-assessment or compliance flags
• • Communication records related to KYC

4. How KYC Verification Is Conducted

4.1 We conduct mandatory KYC verification for individuals and institutions who subscribe and agreed to pay for its research services, as required under SEBI and PMLA regulations.

4.2 This website is not used to collect KYC documents or accept onboarding applications. We do not request or accept KYC submissions through this website.

4.3 KYC documents are collected only through secure verification mechanisms designated by us, which may include SEBI-compliant digital KYC partners or authorised communication channels or physically under offline mode.

4.4 Once KYC documents are submitted through such mechanisms, the verification process is completed by our authorised representative.

4.5 After successful verification, We store KYC records in its secure compliance environment as mandated by SEBI and PMLA.

5. Storage and Retention of KYC Records

5.1 All KYC documents and verification records are stored exclusively by us in secure encrypted systems.

5.2 KYC data is retained for a minimum of 5 years or such other durations from the date of termination of the client relationship, as required by: SEBI RA Regulations; PMLA; Applicable regulatory directives.

5.3 If any regulatory proceeding, audit or inquiry is ongoing, KYC documents shall be retained until formally permitted to delete.

5.4 We do not share KYC documents with any external party except: SEBI, KRA, RAASB or FIU-IND when legally required; Courts or law enforcement authorities under due process.

6. Handling and Security of KYC Information

We implement strict technical and organisational measures to protect KYC data, including:

6.1 Technical Measures

• • AES-256 encryption at rest
• • TLS encryption in transit
• • Role-based access controls
• • Multifactor authentication for access
• • Secure storage zones segregated from other datasets
• • Immutable audit logs for all access events

6.2 Organisational Measures

• • Restricted access to compliance personnel only
• • Annual KYC-related internal audits
• • Regular regulatory inspections readiness
• • Incident response framework
• • Staff training on RA Regulations & data confidentiality

7. Rights of Clients

In accordance with DPDP Act 2023 and SEBI norms applicable on KYC, clients may request: Access to personal data submitted for KYC, Correction of inaccurate information.

However, erasure requests cannot be honoured for KYC documents until the statutory retention period required by SEBI/PMLA is completed.

8. Refusal or Termination of Service

We reserve the right to: Decline onboarding if KYC is incomplete or inconsistent; Terminate relationship if fraudulent documents are detected; Suspend service upon detection of regulatory red flags.

9. Updates to the Policy

We may update this Policy based on regulatory changes or internal compliance requirements. Revised versions will be posted on our official website.