Terms and Conditions

1. Acceptance of Terms

These Terms and Conditions (“Terms”) govern your access to and use of the Fynro mobile applications and website (together, the “Platform”), operated by Fynro Advisory Services Private Limited (“Fynro”, “we”, “our”, “us”).

By creating an account or using the Platform, you agree to be bound by these Terms and by our Privacy Policy. If you do not agree, please do not use the Platform.

2. Eligibility

You must be at least 18 years of age, a resident of India, and legally capable of entering into a binding contract under the Indian Contract Act, 1872. The Platform is not intended for use by minors.

3. Scope of Services

3.1 What Fynro provides

Fynro provides financial planning tools and non-discretionary investment advisory services, including:

• Financial goal setting, net-worth tracking and cashflow projection
• Mutual fund investment guidance and portfolio tracking
• Insurance and tax planning inputs
• Scheduled consultations with qualified human financial advisers
• Advisory plans and consultation credits purchased on our website

3.2 What Fynro does not do

Fynro does not:

• execute any purchase or sale transaction on your behalf;
• hold, manage or custody your funds or securities;
• operate your bank or demat account;
• accept any Power of Attorney or execution authority;
• offer, promote or represent any assured, guaranteed, fixed, minimum or risk-free return.

All investment decisions are taken solely by you.

3.3 No cryptocurrency or exchange services

Fynro does not offer, operate, facilitate, or provide access to any cryptocurrency, virtual digital asset, or token exchange service, whether centralised or decentralised. The Platform does not enable the purchase, sale, trade, conversion, custody or transfer of any cryptocurrency or virtual digital asset, and Fynro does not issue any token, coin or digital currency.

References within the Platform to a “Wallet”, to “Coins”, or to “exchanges” refer respectively to an Indian Rupee savings-goal visualisation tool, a non-monetary in-app rewards feature carrying no cash value and no redemption value, and to recognised Indian stock exchanges (NSE and BSE). None of these relates to cryptocurrency or to any virtual digital asset.

All amounts displayed and collected on the Platform are in Indian Rupees.

4. Account Registration and Security

4.1 You agree to provide true, accurate, current and complete information during registration and to keep it updated, including your email address and mobile number.

4.2 You are responsible for maintaining the confidentiality of your login credentials and for all activity under your account.

4.3 Fynro will never ask you for your trading, demat or bank account passwords or OTPs. You must never share such information with anyone, including with persons claiming to represent Fynro.

4.4 Notify us immediately at supportit@fynro.in of any unauthorised use of your account.

5. Fees and Payments

5.1 Advisory plans, subscriptions and consultation credits are purchased on the Fynro website. Payment is collected in Indian Rupees by our payment processor through traceable banking channels such as UPI, net banking, debit card, credit card or bank transfer.

5.2 In accordance with SEBI requirements, fees are accepted only through traceable banking channels. Cash payments are not accepted. You may alternatively pay through the Centralized Fee Collection Mechanism (CeFCoM) operated by BSE Limited.

5.3 Advisory fees are subject to the maximum limits prescribed by SEBI from time to time for individual and Hindu Undivided Family clients, and to the fee model, billing periodicity and advance payment terms set out in your Investment Advisory Agreement.

5.4 Where a plan runs for a fixed term, it continues until the end of that term. You may terminate at any time on the notice set out in the Investment Advisory Agreement. On early termination, proportionate fees for the unexpired period are refunded, less any breakage fee permitted by SEBI.

5.5 Applicable taxes are charged as indicated at the point of purchase.

5.6 Fynro accepts payments only towards its own advisory fees and does not accept or hold any funds or securities of a client in its own account or on a client’s behalf.

6. AI-Assisted Features

6.1 Two features of the Fynro app are assisted by artificial intelligence supplied by a third-party provider identified in our Privacy Policy: transaction categorisation and plain-language narration of your financial plan.

6.2 AI-assisted output is informational and supportive in nature. It does not constitute investment advice, a recommendation, an offer, or a solicitation to buy or sell any security. All investment advice is provided by Fynro Advisory Services Private Limited in its capacity as a SEBI-registered Investment Adviser (INA000021942), under a separate Investment Advisory Agreement, and remains subject to human review.

6.3 All financial calculations, projections, scores and plan figures within the Platform are produced by Fynro’s own deterministic computation systems. Artificial intelligence is not used to compute any financial value; in the narration feature it is used only to describe figures that have already been calculated.

6.4 Your information is transmitted to the AI service provider only after you have given explicit consent in the app, and only to the extent described in Section 4 of the Privacy Policy. You may withdraw that consent at any time from Profile → Privacy → AI & Data. The AI-assisted features will then be disabled, and all other functionality of the Platform will remain fully available to you.

6.5 AI-generated content may occasionally be incomplete, mis-categorised or inaccurate. You should not act on it without verifying it against your financial plan or raising it with your adviser. To the extent permitted by law, Fynro is not liable for any loss arising from reliance on AI-generated content that has not been confirmed by a qualified adviser.

6.6 You agree not to submit to any AI-assisted feature the personal data of another individual, or any credential, password or one-time passcode.

7. Your Information and Privacy

7.1 Our collection and use of your information is governed by our Privacy Policy, which forms part of these Terms.

7.2 You consent to the processing of your personal and financial data in accordance with the Privacy Policy and the Digital Personal Data Protection Act, 2023.

7.3 Where a feature requires a specific consent — including Account Aggregator access and AI-assisted features — that consent is sought separately and may be withdrawn at any time.

8. Your Obligations

You agree that:

• all information you provide, including income, investments, liabilities and risk profile inputs, is true, complete and accurate;
• you will promptly inform us of any material change in your financial situation or investment objectives;
• investment decisions are taken independently by you;
• you will not use the Platform for any unlawful purpose, including money laundering or the financing of any prohibited activity.

9. Prohibited Use

You may not:

• reverse engineer, decompile, scrape, or attempt to extract the source code or models underlying the Platform;
• use automated systems to access the Platform other than as expressly permitted;
• resell, sublicense or commercially exploit any content, report or plan generated by the Platform;
• upload malicious code, or attempt to gain unauthorised access to any part of the Platform;
• impersonate any person or misrepresent your affiliation with any entity.

10. Intellectual Property

All content, software, design, reports, methodologies, scoring models and materials on the Platform are the property of Fynro or its licensors and are protected under applicable intellectual property laws. Your financial plan is provided for your personal use. Nothing in these Terms transfers any intellectual property right to you.

11. Third-Party Services

The Platform integrates with third-party providers, including Account Aggregators, payment processors, e-Sign and KYC providers, and the AI service provider identified in the Privacy Policy. Those services operate under their own terms and privacy policies. Fynro is not responsible for the acts or omissions of a third-party provider beyond the contractual obligations we impose on them.

12. Disclaimers and Risk

12.1 Investments in securities are subject to market risks, including volatility, liquidity, credit and regulatory risk. Past performance is not indicative of future results.

12.2 Fynro provides no assurance or guarantee of returns, income or capital protection.

12.3 Projections, growth assumptions and goal-success probabilities shown in the Platform are illustrative estimates based on stated assumptions and the information you supply. They are not predictions and actual outcomes will differ.

12.4 Registration with SEBI, enlistment with IAASB, or NISM certification does not guarantee the performance of Fynro or assure any returns.

12.5 The Platform is provided on an “as is” and “as available” basis. We do not warrant uninterrupted or error-free operation.

13. Limitation of Liability

To the maximum extent permitted by law, Fynro shall not be liable for:

• losses arising from market fluctuations or the under-performance of any security;
• any indirect, incidental, consequential or punitive loss;
• loss arising from your reliance on AI-generated content not confirmed by a qualified adviser;
• loss arising from inaccurate or incomplete information supplied by you;
• interruption, delay or failure caused by events beyond our reasonable control.

Where liability cannot be excluded, our aggregate liability is limited to the fees paid by you to Fynro in the twelve months preceding the claim.

14. Indemnity

You agree to indemnify and hold harmless Fynro, its directors, officers and employees against any claim, loss, liability or expense arising from your breach of these Terms, your misuse of the Platform, or your violation of applicable law.

15. Suspension and Termination

15.1 You may stop using the Platform and request account closure at any time.

15.2 We may suspend or terminate your access where you breach these Terms, where required by a regulator or by law, or where we reasonably suspect fraud or misuse.

15.3 Termination of the advisory relationship is governed by the Investment Advisory Agreement, including its 30-day notice requirement and pro-rata refund terms.

15.4 Sections relating to intellectual property, limitation of liability, indemnity and governing law survive termination.

16. Grievance Redressal

16.1 For any complaint, query, dispute or grievance relating to the Platform, to your personal data, or to the investment advisory services, you may contact the Compliance Officer of the Investment Adviser:

16.2 Fynro maintains an appropriate grievance redressal mechanism and shall endeavour to acknowledge, address and resolve grievances within the timelines prescribed under applicable SEBI regulations, circulars and guidelines, and under the Digital Personal Data Protection Act, 2023.

16.3 You may communicate grievances through email, written communication, the Platform, customer support channels, or such other modes as may be notified from time to time.

16.4 If you are not satisfied with the resolution provided, or if the grievance remains unresolved within the prescribed timelines, you may escalate through the following regulatory and dispute resolution mechanisms, as applicable:

• the SEBI Complaints Redress System (“SCORES”) — https://www.scores.sebi.gov.in/
• the Investment Adviser Administration and Supervisory Body (“IAASB”), or such other Administration and Supervisory Body recognised by SEBI
• the SMART Online Dispute Resolution (“SMART ODR”) platform — https://smartodr.in/
• arbitration, conciliation, mediation, or other dispute resolution mechanisms available under applicable laws and regulatory frameworks

16.5 You acknowledge that grievances, disputes and complaints may be subject to the processes, procedures, timelines and jurisdiction prescribed by SEBI, recognised stock exchanges, Administration and Supervisory Bodies, ODR institutions, or other competent authorities from time to time.

16.6 Nothing contained herein restricts your right to seek any remedy available under applicable laws or regulatory frameworks.

17. Changes to these Terms

We may amend these Terms from time to time. The revised version will be posted on the Platform with a new version number and effective date. Material changes will be notified to you in the app or by email. Continued use after a change takes effect constitutes acceptance.

18. Force Majeure

Fynro shall not be liable for any delay, interruption or failure in performance arising from events beyond its reasonable control, including acts of God, national emergencies, war, civil unrest, strikes, fire, flood, natural calamities, failure of electronic or communication systems, failure of power supply, or system breakdowns not attributable to Fynro.

19. Severability

If any provision of these Terms is held invalid, illegal or unenforceable, that provision shall be severed and the remaining provisions shall continue in full force and effect.

20. Governing Law and Jurisdiction

These Terms are governed by the laws of India. Courts at Kancheepuram, Tamil Nadu, India shall have exclusive jurisdiction, subject to any SEBI-recognised dispute resolution mechanism that applies.

21. Contact

Annexure — Clause to add to the Elite Client Investment Advisory Agreement

Insert under “Confidentiality & Data Protection” in Section B of the Elite Client Investment Advisory Agreement:

Version 2.0 · Effective 24 July 2026