Privacy Policy

Compoundexpress Private Limited, having its registered office at the 121/22, Floor-11, Plot-221/222, Mafatlal Centre, Vidhan Bhavan Marg, Nariman Point, Mumbai, Maharashtra, India, 400021(hereinafter referred to as " compoundexpress", "we", "us", or "our") provides certain software applications or online digital portals ("Platform”) whereby, through the Platform, a Financial Intermediary will be able to access and utilize its features and services, including but not limited to managing and tracking the generated leads of Investors (as defined hereinafter), and selling the financial products, such as mutual funds or other financial instruments, as recognized under the applicable laws of India, displayed by the Financial Intermediary and the Investors will be able to access and utilize its features including but not limited to onboarding, reporting, transacting and servicing etc. (hereinafter referred to as the “Services”).

This privacy policy and disclaimer, as amended from time to time (“Privacy Policy & Disclaimer”) forms part and parcel of the respective Terms and Conditions of the respective User and is included therein by this reference. The capitalized terms which have been used herein but are not specifically defined shall have the same meaning as attributed to such term in the Terms. In the event of any inconsistency between the Terms and this Privacy Policy & Disclaimer, the Privacy Policy & Disclaimer will supersede solely in respect of the content contained herein and not in respect of any other clause, term or provision contained in the Terms.

By accessing, registering or transacting through the Platform, you (hereinafter referred to as “You”, “Your”, “User”, “Financial Intermediary” or “Investor” as applicable) acknowledge and expressly provide your free, informed and unequivocal consent to Our receipt, collection, storage, use and disclosure of the Information (as defined hereunder) in accordance with the terms of this Privacy Policy & Disclaimer.

As We update, improve and expand the Platform, this Privacy Policy & Disclaimer may change at Our sole discretion without notice, so please refer back to it periodically as You will be deemed to be governed by the terms of such modified Privacy Policy & Disclaimer, as it comes into effect from time to time.

Type of Information Collected

To access/utilise the Platform, the Users are required to provide certain personal, non-personal financial, non-financial and other information, as indicated below as per their engagement with the Platform (such information and correspondences hereinafter collectively referred to as “the Information”):

1. In order for you to access certain Services (as defined in the respective Terms), We may require You to provide us with certain information that personally identifies You ("Personal Information"). Personal Information includes but is not limited to the following categories of information: (i) password; (ii) financial information such as Bank account or credit card or debit card or other payment instrument details ; (iii)sexual orientation; (iv) medical records and history; (v) Biometric information; (vi) any detail relating to the above clauses as provided to body corporate for providing service; (vii) Registered Email ID; (viii) Phone Number; (ix) Permanent Account Number (PAN); (x) Unique Identification (UI) Number; (xi) ARN Number (AMFI Registration Number); (xii) Residential Address; (xiii) Financial Data; (xiv) Investment Data; and (xv) any of the information received under above clauses by body corporate for processing, stored or processed under lawful contract or otherwise, including the above details as may be subsequently updated by you on the Platform. Furthermore, such data may be provided directly by You or may be obtained from third parties, including but not limited to asset management companies, registrars and transfer agents, distributors, financial intermediaries, service providers, or any other entities that are authorized under applicable laws and regulations to share such information with us.

2. Please note that the above list is not an exhaustive list and is only an illustrative list and is without prejudice to Our right to seek further Personal Information, as may be required for the provision of the Services to You.

3. Any Personal Information provided by You will not be considered as sensitive if it is freely available and/or accessible in the public domain. Further, any comments, messages, blogs, scribbles etc. posted/uploaded/conveyed/communicated by You on the public or comments sections of the Platform becomes published content and is not considered personally identifiable information subject to this Privacy Policy & Disclaimer. We will not be responsible for the accuracy or filtration of any of the content posted on Our Platform by any User, however, We will be entitled to remove any content posted by any User on Our Platform which We, in Our sole discretion, consider offensive, discriminatory, racist, defamatory or inappropriate in nature.

4. Non-Personal Information

When You visit the Platform, We may collect certain non-personal information such as Your internet protocol address, operating system, browser type, and internet service provider. This type of information does not identify You personally.

5. Automatic Information

To improve the responsiveness of the Platform for You, We may use "cookies" (including traffic log cookies), or similar electronic tools to collect information to understand the User's individual interests. These server logs may include information such as Your web request, Internet Protocol address, browser type, browser language, the date and time of Your request and one or more cookies that may uniquely identify Your browser. We use cookies primarily for user authentication but may also use them to improve the quality of Our Service by storing user preferences and tracking user trends.

6. Mobile

When You use the Platform through Your mobile, We may receive information about Your location and Your mobile device, including a unique identifier number for Your device. We may use this information to provide You with suggestions in respect of Services if required.

7. User communications

When You send emails or other communications to Us, We may retain those communications in order to process Your inquiries, respond to Your requests and improve Our Services.

8. Information on behalf of Children

If You are a parent or legal guardian of a minor child, You may, in compliance with the Terms, access the Platform or avail the Services on behalf of such minor child. You also expressly undertake that You have the authority to share such information on behalf of Your child. Any information that You provide while using the Platform or Service on behalf of Your minor child will be treated as Personal Information unless otherwise provided herein.

9. In case You choose to decline to submit any Information, We may not be able to provide You access to the Platform/Services or certain aspects of the Platform/Services. We will not be liable and/or responsible for the denial of providing access to the Platform to You on account of inadequacy of Information provided by You.

10. When You register, integrate or onboard with the Platform, We may contact You from time to time about updation of Information to provide You such features that We believe may benefit/interest You.

11. Data Usage and Sharing of Information

A. We may process the Information You provide in any one or more of the following manner:

a. To process and fulfil Your request for Services or to process and fulfil Your purpose of engagement with the Platform;

b. For providing Services, We may disclose Your Personal Information to Service professionals and/or other registered Vendors (as applicable).

c. The Company shall be entitled to process the Information in accordance with the Company Policy & Disclaimer and as permitted by the applicable law;

d. To troubleshot issues, improve Our Platform, Services and offerings;

e. To enforce Our Terms and resolve disputes;

f. To contact You;

g. To avoid fraud and other prohibited or illegal activities;

h. To protect the security or integrity of the Platform, Our business, Services and other users;

i. To customise Our communication with You and the marketing material We share with You;

j. To publish any testimonials or reviews that You may have provided on the Platform;

k. We may disclose Information, in good faith, wherein the access, use, preservation or disclosure of such information is reasonably necessary to (i) satisfy any applicable law, regulation, legal process or enforceable governmental request, (ii) enforce applicable Terms, including investigation of potential violations thereof, (iii) detect, prevent, or otherwise address fraud, security or technical issues, or (iv) protect against imminent harm to the rights, property or safety of the Company, its users or the public as required or permitted by law;

l. Additionally, in the event of a audit, reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of Our business, assets or stock (including in connection with any bankruptcy or similar proceedings), We may share/transfer/assign the Information We have collected to the relevant third party.

B. You expressly consent to us sharing Your data, strictly on a need-to-know basis, with relevant parties necessary for providing Services through the Platform. Such parties may include but are not limited to (i) Your registered distributors, advisors, or intermediaries for servicing support, executing transactions, and offering suitable financial products; (ii) asset management companies, registrars, transfer agents, and other financial institutions for transaction processing, record maintenance, and portfolio servicing; (iii) service providers, technology partners, hosting providers, data processors, and IT infrastructure partners engaged to support the operation, maintenance, and enhancement of the Platform, subject to confidentiality and security obligations; and (iv) regulatory, governmental, or judicial authorities where disclosure is required under applicable law, regulation, or directive.

C. Data Access from Registrar and Transfer Agents (RTAs)

With the explicit consent and authorization of the Financial Intermediary, Compoundexpress may access and retrieve data from Registrar and Transfer Agents (RTAs), including Computer Age Management Services Limited (CAMS) and KFin Technologies Limited (KFintech), through secure and consent-based mechanisms or integrations such as platform login or mailback processes. Such access is solely for the purpose of enabling investment servicing, data synchronization, and information display within the Platform. All data so accessed shall be handled strictly in accordance with applicable data protection laws, this Privacy Policy, and the Terms and Conditions.

D. Security, Processing, and Retention of RTA-Sourced Data

Any data accessed or retrieved from Registrar and Transfer Agents (“RTAs”) shall be processed strictly for the limited purposes of enabling transaction processing, portfolio servicing, data synchronisation, and display of investment information within the Platform. Compoundexpress shall implement appropriate technical and organisational measures, consistent with industry standards and Applicable Laws, to protect the security, confidentiality, and integrity of such data. These measures include secure transmission practices, controlled and permission-based access, auditability of access, and periodic internal security assessments.
RTA-sourced data shall be retained and processed by compoundexpress in accordance with its internal data-retention and data-purging policies, subject always to Applicable Laws and legitimate business requirements. You may withdraw consent for continued access to your investment data by requesting the relevant RTA to remove or disable your data from mailback files or any equivalent data-sharing mechanism authorised by such RTA. Upon withdrawal of such consent, further processing, retention, or deletion of your data shall be carried out by compoundexpress in accordance with its internal policies and Applicable Laws.

E. Use of Data for Investment Servicing and Product Offerings:

You hereby consent to Financial Intermediary(s) accessing and using Your investment, transaction, and personal data for the purpose of servicing Your existing investments, including portfolio monitoring, record-keeping, and providing transaction-related support. Additionally, subject to applicable laws and regulations, such Financial Intermediary(s) may use such data to inform You about, and offer, other financial products or services that may be relevant or suitable to Your needs.

12. User Responsibilities

a. As a User of the Platform, You agree to:

i. Provide accurate and updated information while registering or interacting with the Platform.

ii. Maintain the confidentiality of your login credentials and not share them with others.

iii. Notify Us immediately of any unauthorized access or suspected breach of security.

iv. Use the Platform only for lawful purposses and in compliance with applicable laws and this Privacy Policy & Disclaimer.

13. Data Retention

We shall be entitled to retain Your Information for Our records for a period of 8(eight) years after the deletion of Your account on the Platform or after termination or expiry of your engagement with the Platform and such Information shall be used by Us only in consonance with this Privacy Policy & Disclaimer, including for the purpose of compliance with legal obligations, resolving of disputes and enforcing agreements executed between us.

14. Accessing and Updating your Information

As a registered User of the Platform, You can update or modify the Personal Information you have included in your profile by logging in and accessing Your Account. Please note that your username, which is your registered email address or mobile number, cannot be changed through the profile section. Though You may delete Your account, You acknowledge that it may be impossible to remove your account without some residual information being retained by the Platform.

14A. User Access Management and Delegation of Permissions

a. Role-Based Access Configuration: The Platform provides functionality to enable the authorized person who creates the primary account on compoundexpress (“Main Users”) to delegate limited access rights to employees, agents, or other authorized personnel (“Authorized Users”) through a feature titled “User Access Management”.

b. Permission Assignment: The Main User may configure specific roles (such as Relationship Manager, Support Staff, or Administrative Assistant) and assign module-specific permissions (including but not limited to access to Transactions, CRM, Reports, and Portfolio Data). The Platform records the permission configuration and assignment history.

c. Onboarding of Authorized Users: Each Authorized User must be invited by the Main User through the Platform and is required to independently register using a separate login credential. Activation of access for any Authorized User shall be subject to the Authorized User's acceptance of the Platform’s Terms and Conditions.

d. Consent and Accountability: By initiating access, the Main User acknowledges full responsibility for the actions of their Authorized Users and agrees to ensure compliance with all applicable data privacy and security obligations. The Main User represents that such access is lawfully authorized and that no personal or investor data shall be misused or unlawfully disclosed.

e. Revocation and Control: The Main User may suspend or revoke access to any Authorized User at any time. The Platform may also revoke or suspend access in the event of suspected misuse or breach of these Terms.

f. Data Usage by Authorized Users: Authorized Users shall only access and use such data as is necessary to perform their role as defined by the Main User. The Platform provides technical restrictions to limit access based on permissions; however, it remains the Main User’s obligation to ensure that Authorized Users are suitably trained and monitored.

g. Confidentiality and Data Safeguards: Main Users shall ensure that Authorized Users undertake appropriate confidentiality obligations and are made aware of the importance of safeguarding investor data. Any access to investor folios, KYC information, transaction reports, or sensitive personal data (as defined under applicable law) must be treated as confidential and used solely for the authorized business purposes of the Main User.

h. Indemnity: The Main User agrees to indemnify and hold harmless the Platform, its affiliates, directors, and employees from and against any claims, losses, damages, penalties, or legal proceedings arising out of: (a) Any breach of applicable data privacy laws by the Authorized User; (b) Unauthorized access, data leakage, or misuse of investor data by the Authorized User; (c) Failure of the Main User to revoke access of any ex-employee, terminated personnel, or agent who no longer has authority to operate on the Main User’s behalf.

i. Audit Rights and Enforcement: The Platform reserves the right to conduct usage audits, access logs, and activity trails of Authorized Users to ensure security compliance. In the event of suspected breach or misconduct, the Platform may: (a) Temporarily suspend access of any Authorized User or Main User account; (b) Issue notice requiring explanation or evidence of due diligence; (c) Escalate the matter to regulators or authorities where mandated by law.

j. Access Logs and Retention: All activities performed by Authorized Users shall be logged by the Platform, including timestamps, IP addresses, modules accessed, and actions performed (view/download/edit). These logs shall be retained for a reasonable period (typically up to 7 years or as required under applicable law) for audit, dispute resolution, or regulatory reporting purposes.

k. Termination of Access: Upon termination or deletion of the Main User’s account, access of all associated Authorized Users shall be automatically revoked. The Main User may independently deactivate or restrict access of any Authorized User at any time during the account lifecycle. Deletion requests of Authorized User accounts shall be subject to applicable regulatory and audit constraints.

l. Modifications: The Platform reserves the right to modify the access framework, permission modules, or any provisions of this para based on operational updates, legal requirements, or platform enhancements. Continued use of the Platform by the Main User or any Authorized User following such modifications shall constitute deemed acceptance.

m. No Third-Party Rights: Nothing in this para shall be construed as granting rights to any Authorized User directly against the Platform. All rights and liabilities lie between the Platform and the Main User, who remains solely responsible for managing its internal relationships.

15. Security and Confidentiality

We use reasonable security measures to protect Information from unauthorized access, maintain data accuracy and help ensure the appropriate use/disclosure of Information. We host the Platform in a secure server environment that uses firewalls and other advanced technology to prevent interference or access from outside intruders. These measures include encryption, restricted access, role-based data handling, and periodic reviews of security systems. Despite such measures, you acknowledge that no electronic storage or transmission can be guaranteed to be fully secure, and We renounce any liability for events beyond Our reasonable control.

You are responsible for maintaining the security and confidentiality of Your Account, user IDs and passwords, Your integration or implementation while accessing the Platform as a User. You acknowledge that neither the Company nor any of its representatives shall be liable to You under any circumstances for any direct, indirect, punitive, incidental, special or consequential damages that result from or arise out of, or a breach or compromise of registration of Your Account on the Platform and/or Your ability or inability to use such Account and/or Your integration or implementation or engagement with the Platform.

We have engaged with payment aggregators for any payments made on the Platform. The processing of payments will be subject to the terms, conditions and privacy policies of the Payment Processors in addition to the Terms and any stored card data can be moved at Our sole discretion between the databases of third party providers or Us . You acknowledge that neither the Company nor any of its representatives shall be liable to You under any circumstances for any direct, indirect, punitive, incidental, special or consequential damages that result from or arise out of Your use of the Payment Processors, Your payment through the Payment Aggregators or Your ability or inability to complete the payment.

compoundexpress maintains the confidentiality of all personal data relating to Investors and Financial Intermediaries and implements appropriate technical and organisational measures to protect such data against unauthorised access, disclosure, alteration, or misuse.

Personal data may be processed or disclosed only to the extent necessary for:

• (a) providing services through the Platform, including data access from Registrar and Transfer Agents (RTAs) pursuant to valid consent;
• (b) complying with Applicable Laws, regulatory requirements, or lawful requests; or
• (c) fulfilling contractual obligations with Financial Intermediaries.

Confidentiality obligations apply equally to data accessed through electronic consent mechanisms, assisted processes, or RTA mailback mechanisms, and such data is handled in accordance with compoundexpress’s internal data-retention and security policies and Applicable Laws, including the Digital Personal Data Protection Act, 2023

16. Advertising

We do not use third-party service providers to display advertisements on Our behalf, either on the Platform or elsewhere. However, We may engage third-party service providers for analytics or other support services that help Us improve Our Platform and Services. These providers may collect anonymized data through standard technologies such as pixel tags or cookies for the sole purpose of enhancing user experience and Platform performance.

17. Links to Third Party Sites

The Platform may include links to third party applications/Platforms (“Third Party Sites”). Such Third Party Sites are governed by their respective privacy policies, which are beyond Our control. Once You leave Our Platform, use of any information You provide is governed by the privacy policy of the operator of the Third Party Site You are visiting. That policy may differ from Ours. If You can't find the privacy policy of any of these Third Party Sites, You should contact the relevant Third Party Site directly for more information.

We do not provide any Personal Information or personally identifiable information to third party websites/advertisers/ad-servers without Your consent.

18. Logo Usage Disclaimer

The logos of various Asset Management Companies (AMCs) displayed on the Platform are used solely for representation purposes, to indicate the financial products offered by such companies and are showcased on the Platform for reference only. compoundexpress does not claim any ownership, affiliation, or endorsement by the respective AMCs unless expressly stated.

compoundexpress does not hold any copyright or trademark rights over the logos or brand assets of such AMCs. All trademarks, logos, and brand names are the property of their respective owners. While such trademarks may be displayed on the Platform, in the event of discontinuation of such products, compoundexpress will make reasonable efforts to remove the associated logos in a timely manner.

The logos presented on the Platform may differ slightly from the official or most recent versions used by the respective AMCs. compoundexpress makes no warranties regarding the accuracy or currency of such representations and disclaims any consequent responsibilities.

19. Your Consent

By using the Platform and/ or by providing Your Information, You consent to the collection and use of such Information in accordance with this Privacy Policy & Disclaimer, including but not limited to Your consent for sharing Your Information as per this Privacy Policy & Disclaimer. You specifically agree and consent to us collecting, storing, processing, transferring and sharing Information (including Personal Information) related to You with third parties, Service Professionals or to registered Vendors/Users for the purposes as set out in this Privacy Policy & Disclaimer. You may withdraw your consent for the collection, storage, processing, or sharing of your data (except where such use or disclosure is mandated under law or regulation) by notifying us in writing or through the prescribed digital process available on the Platform. You acknowledge that withdrawal of consent may restrict or prevent us and/or your distributor(s)/Financial Intermediary(s) from providing accurate reports, services to you, processing future transactions, or administering your investments effectively.

20. Limitation of Liability

To the fullest extent permissible under applicable law, We shall not be liable for any direct, indirect, incidental, special or consequential damages, or for loss of profits or revenue, whether incurred directly or indirectly, or any loss of data, use, goodwill, or other intangible losses resulting from:

a. Your access to or use of or inability to access or use the Platform;

b. Any conduct or content of any third party on the Platform;

c. Any unauthorized access, use or alteration of Your transmissions or content;

d. Any bugs, viruses, or other harmful code that may be transmitted to or through thePlatform.

21. Disclaimer of Warranties

The Platform, its features, and Services are provided on an “as is” and “as available” basis without any warranties of any kind, express or implied. We expressly disclaim all warranties, whether express, implied, statutory or otherwise, including without limitation warranties of merchantability, fitness for a particular purpose, title and non-infringement. We do not warrant that the Platform will be uninterrupted, timely, secure, or error-free.

22. Google Calendar

The AI Assistant is designed with built-in, pre-defined questions and is restricted to responding only to a limited set of topics such as client-related queries, regulatory circulars, and investment-related information. It functions independently and does not access or interact with any external APIs, including those offered by Google. Further, it does not possess general query capabilities and does not transmit or retrieve any data from external APIs, services, or third-party platforms, including Google services.

AI Assistant is used only for limited internal functions as described above and does not integrate with, or make use of, the Google Workspace API, Google Photos API, or any other unrelated Google services.

CE’s application seeks access solely to the Google Calendar API, and such access is limited to facilitating calendar-based functionalities for its users (such as viewing, scheduling, and managing calendar events).

23. Grievance Officer

Any complaints, abuse or concerns with regards to content and or comment or breach of this Privacy Policy & Disclaimer shall be immediately informed to the designated Grievance Officer as mentioned below via in writing or through email:

Name: Vinny Sial

Designation: Customer Service

Email Address: [email protected]

Postal Address: Compoundexpress Private Limited
Mafatlal Centre, 11th floor, Nariman Point,, Mumbai, Mumbai City, Maharashtra, India, 400021

Working Hours: Monday to Friday, [9.30 am to 6.30 pm], excluding public holidays.

Response Time: We will acknowledge the complaint within 24 hours and endeavor to resolve it within 15 (fifteen) business days from the date of receipt.

This document was last updated on [18/12/2025]