Effective Date: 27 November 2025 Growthvine Capital (“Growthvine”, “we”, “our”, or “us”) Growthvine Capital is committed to protecting your personal information and respecting your privacy. By accessing or using any of our services including our website, mobile application, platform, or by voluntarily providing your information , you consent to the practices described in this Privacy Policy. This Privacy Policy explains:

• The information we collect
• Why we collect it
• How we use and share your information
• Your rights and choices
• How we protect and retain your data
• When this policy applies
• How you can contact us

If you have any questions, please write to support@growthvine.in.

1. Scope of This Privacy Policy

This Policy applies to all personal information collected by Growthvine when:

• You visit our website or mobile application
• You create an account
• You use our wealth management, advisory, or investment services
• You communicate with us or submit documents

This Policy does not apply to:

• Third-party websites, apps, or services we do not own or control
• Individuals or organisations not managed by Growthvine Capital

2. Information We Collect

We collect information in the following categories:

A. Information You Provide Directly

When you register, complete your profile, or use our services, you may provide:

• Full Name (as per PAN/Aadhaar)
• Email Address
• Mobile Number
• Date & Place of Birth
• Residential Address
• PAN
• Aadhaar (where legally permitted)
• Bank account details & cancelled cheque
• Nominee information (Name, DOB, Relationship, Allocation %)
• Occupation, income range, and tax status
• Investment preferences, goals, and risk profile
• Documents submitted for KYC/CKYC verification

Purpose: Account creation, identity verification, KYC compliance, regulatory requirements, and providing investment-related services.

B. Information Collected Automatically

When you use our website/app, we automatically collect:

• Device details (model, OS, version)
• IP address
• Browser type, plugins
• Pages visited, time spent, and referring URLs
• App usage analytics, interaction data
• Crash logs and performance data
• Cookies, local storage, and tracking identifiers

Purpose: Security, analytics, optimisation, troubleshooting, and improving the user experience.

C. Information from Third Parties

We may receive information from:

• KYC agencies (e.g., CKYC)
• Registrars & Transfer Agents (RTAs)
• Payment gateways
• Analytics and cloud service providers
• Mutual fund companies & market data sources

Purpose: Completing KYC, enabling transactions, compliance, data validation, and service delivery.

3. Why We Collect Your Information

We use your information to:

• Create and maintain your Growthvine Capital account
• Complete mandatory KYC/AML verification
• Enable investments, purchases, redemptions and transactions
• Provide portfolio insights, dashboards, and reports
• Offer personalised recommendations and investment insights
• Send alerts, confirmations, statements, and regulatory communications
• Respond to support queries and requests
• Enhance platform performance, security, and functionality
• Comply with SEBI, RBI, FIU, AMFI and other regulatory obligations

We do NOT sell your personal information to any third party.

4. Cookies & Tracking Technologies

We use cookies and similar technologies to:

• Recognise returning users
• Maintain login sessions
• Analyse usage patterns
• Improve content, navigation, and performance

You may disable cookies in your browser settings; however, some features may not function correctly. External websites linked from our platform may have their own cookie policies.

5. How We Share Your Information

We share information strictly on a need-to-know basis and only with authorised partners.

A. Regulated & Authorised Service Providers

Your information may be shared with:

• Registrars & Transfer Agents (RTAs) – CAMS, KFintech
• Asset Management Companies (AMCs)
• Payment gateways
• KYC/verification agencies
• Technology providers (cloud hosting, databases, analytics, servers)

All partners follow contractual confidentiality and security obligations.

B. Legal & Regulatory Disclosures

We may share information if required by:

• SEBI, RBI, FIU, AMFI
• Government authorities or enforcement agencies
• Courts, tribunals, or legal processes
• Compliance audits or regulatory reporting

C. Business Transfers

In the event of a merger, acquisition, restructuring, or asset transfer, customer data may be transferred under strict privacy safeguards.

6. How We Protect Your Data

We implement industry-standard security practices. During Transmission:

• HTTPS encryption
• Secure API authentication
• Tokenization
• AES-level encryption for sensitive fields

During Storage:

• Passwords hashed and salted
• Data stored in secure AWS infrastructure
• Access governed by AWS IAM and VPC isolation
• Role-based access control for authorised personnel
• Continuous monitoring, logs, and automatic session timeouts

While we use strong protections, no electronic transmission is 100% secure.

7. Your Rights & Choices

You may exercise the following rights:

• Access & Update: View or edit your personal information
• Correction: Request changes to inaccurate data
• Data Portability: Request a readable copy of your personal data
• Account Closure: Request deletion/closure (subject to regulatory retention rules)
• Opt-Out: Opt-out of marketing or promotional communications

To exercise these rights, contact: support@growthvine.in

8. International Data Transfer

If you access our services from outside India, your data may be transferred to and stored in India.By using our platform, you consent to this transfer.

9. Data Retention

We retain your information:

• As long as your account is active
• As required by SEBI, AMFI, FIU, RBI and the Indian IT Act
• For audit, compliance, and dispute-resolution purposes

Certain historical or regulatory data may remain archived even after you delete or modify your account.

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. If changes are material, we will notify you via:

• Email, and/or
• Notices on our website/app

Continued use of our services constitutes acceptance of the updated Policy.

11. Contact Us

For questions, concerns, or rights requests, please contact: Growthvine Capital Email: support@growthvine.in Address: IA Spaces, UG Floor, MGF Metropolis Mall, MG Road, Gurgaon, Haryana – 122002