PRIVACY POLICY

1. INTRODUCTION

QuantifyPlus (“Platform”) is operated by Arista Capitals (Proprietorship) (“Company”, “We”, “Us”, “Our”).

This Privacy Policy explains how we collect, use, process, store, and protect your personal data in compliance with applicable Indian laws, including:

• The Information Technology Act, 2000
• IT (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011
• The Digital Personal Data Protection Act, 2023

By using our Platform, you consent to the practices described in this Policy.

2. DATA WE COLLECT

We may collect the following categories of personal data:

A. Account Information

• Full name
• Email address
• Mobile number
• Address (if provided)
• PAN (if voluntarily provided for invoicing or compliance purposes)

B. Technical Information

• IP address
• Device type
• Browser type
• Operating system
• Usage logs
• Session activity

C. Broker Integration Data

• API Key
• Secret Key
• TOTP (if required for automation)
• Trading account ID
• Order and position data
• Margin information

We do NOT collect or store broker login passwords.

D. Payment Information

Payments are processed through third-party payment gateways. We do not store credit/debit card details.

3. PURPOSE OF DATA COLLECTION

Your personal data is processed for:

• Account creation and authentication
• Providing algorithmic trading software services
• Enabling API integration with brokers
• Processing payments
• Sending service-related communication
• Customer support
• Improving platform functionality
• Legal and regulatory compliance

We do NOT sell personal data.

4. LEGAL BASIS FOR PROCESSING (DPDP ACT)

We process personal data based on:

• Your explicit consent
• Performance of a contract (service subscription)
• Compliance with legal obligations
• Legitimate business purposes

You may withdraw consent at any time, subject to contractual and legal limitations.

5. DATA STORAGE & SECURITY

We implement reasonable security practices including:

• Encryption of API credentials
• Secure servers
• Access control mechanisms
• Firewall protection
• Limited internal access to sensitive data

However, no digital system is 100% secure. Users acknowledge inherent cybersecurity risks.

6. DATA RETENTION

We retain personal data:

• As long as your account is active
• As required for legal or regulatory purposes
• For dispute resolution and audit purposes

Upon account deletion, data may be retained for statutory compliance where required.

7. DATA SHARING & DISCLOSURE

We may share data only in the following cases:

• With payment gateway providers
• With broker APIs (for order execution)
• With cloud hosting providers
• When required by law or court order
• To comply with government or regulatory requests

We do NOT sell, rent, or trade your personal data.

8. USER RIGHTS (UNDER DPDP ACT, 2023)

You have the right to:

• Access your personal data
• Correct inaccurate data
• Request deletion of data
• Withdraw consent
• Nominate another individual to exercise rights in case of incapacity

Requests may be made by contacting us at: quantifyplus.team@gmail.com

We will respond within reasonable timelines as required by law.

9. COOKIES & TRACKING TECHNOLOGIES

We may use cookies and analytics tools for:

• Session management
• Performance monitoring
• Improving user experience

Users may disable cookies via browser settings, though some features may not function properly.

10. CHILDREN’S PRIVACY

QuantifyPlus is not intended for individuals under 18 years of age.

We do not knowingly collect personal data from minors.

11. CROSS-BORDER DATA TRANSFER

If data is stored on servers located outside India, we ensure:

• Adequate safeguards
• Compliance with applicable Indian data protection laws

12. THIRD-PARTY LINKS

Our Platform may contain links to broker websites or third-party services. We are not responsible for their privacy practices.

Users are encouraged to review third-party privacy policies.

13. GRIEVANCE OFFICER

In compliance with Indian IT laws, the Grievance Officer details are:

Name: Aditya Goswami
Email: quantifyplus.team@gmail.com
Address: 146/ Neelkanth Villa Bungalows, Near DPS School, Bopal, Ahmedabad – 380058, Gujarat, India
Phone: +91 8128830103

Grievances shall be acknowledged within 24 hours and resolved within 15 days or as required by applicable law.

14. DATA BREACH POLICY

In case of a data breach:

• We will take immediate corrective action
• Affected users will be notified where legally required
• Authorities will be informed if mandated by law

15. LIMITATION OF LIABILITY

The Company shall not be liable for:

• Unauthorized access caused by user negligence
• Broker-side security failures
• Third-party cyberattacks beyond reasonable safeguards

16. CHANGES TO THIS POLICY

We reserve the right to modify this Privacy Policy at any time.

Changes will be posted on this page with updated Effective Date.

Continued use of the Platform constitutes acceptance of the revised Policy.

17. GOVERNING LAW

This Privacy Policy shall be governed by the laws of India.

Jurisdiction: Courts located in Ahmedabad, Gujarat, India shall have exclusive jurisdiction.

REFUND POLICY

1. GENERAL POLICY

QuantifyPlus provides access to digital software products, algorithmic trading tools, automation systems, and custom technology solutions.

Due to the nature of digital services and immediate access to proprietary software, all payments made are generally non-refundable unless explicitly stated in this policy.

By subscribing to our services, you acknowledge and agree to this Refund Policy.

2. NON-REFUNDABLE SERVICES

The following payments are strictly non-refundable:

• Subscription fees (monthly / quarterly / annual)
• Strategy access fees
• Custom software development charges
• API integration charges
• Setup fees
• Renewal fees
• Upgrade or migration fees

Refunds will NOT be provided for:

• Trading losses
• Strategy underperformance
• Market volatility
• Technical misunderstanding by the user
• Partial usage of subscription
• Change of mind after activation
• Failure to achieve expected returns
• Regulatory or broker-side restrictions
• Account suspension due to user violation

3. DIGITAL ACCESS CLAUSE

Once:

• Login credentials are issued, or
• Strategy access is granted, or
• Software is delivered or deployed,

the service is considered rendered, and no refund shall be processed.

4. DUPLICATE PAYMENT REFUND

Refunds may be issued only in the following limited case:

• Duplicate payment made due to technical error.

Conditions:

• User must notify within 48 hours of payment.
• Refund will be processed after verification.
• Processing time: 7–10 business days.
• Payment gateway charges (if any) may be deducted.

5. SERVICE FAILURE EXCEPTION

Refund may be considered (at sole discretion of the Company) only if:

• The platform remains non-functional for more than 7 consecutive business days due to internal technical fault, and
• The issue is not caused by broker, exchange, API provider, internet failure, force majeure, or user-side configuration.

Refund, if approved, shall be limited to the unused proportion of subscription fees.

6. NO REFUND FOR MARKET OR PERFORMANCE REASONS

QuantifyPlus is a technology platform only.

Arista Capitals:

• Does NOT guarantee profits
• Does NOT assure capital protection
• Does NOT provide investment advice
• Does NOT manage portfolios

Therefore, no refund will be issued due to:

• Market losses
• Strategy drawdowns
• Slippage
• Execution delays
• Black swan events
• API malfunction from broker side

7. CUSTOM DEVELOPMENT PROJECTS

For custom algorithm or software development:

• 50% advance payment is non-refundable.
• Once development begins, no refund will be issued.
• If project is canceled by client midway, paid amount is forfeited.
• Deliverables already completed will be chargeable.

8. CHARGEBACK & PAYMENT DISPUTE POLICY

Unauthorized chargebacks or payment disputes without prior communication may result in:

• Immediate suspension of services
• Permanent account termination
• Legal recovery proceedings if applicable

Users are encouraged to contact support before initiating disputes.

9. FORCE MAJEURE

No refund shall be issued for interruptions caused by:

• Exchange outages
• Broker API issues
• Government restrictions
• Regulatory changes
• Natural disasters
• Cyber-attacks
• Internet service disruptions
• Power failures

10. POLICY MODIFICATION

Arista Capitals (Proprietorship) reserves the right to modify this Refund Policy at any time.

Continued use of QuantifyPlus after updates constitutes acceptance of the revised policy.

11. CONTACT INFORMATION

For refund-related queries, contact:

QuantifyPlus Support
Operated by Arista Capitals (Proprietorship)
Email: quantifyplus.team@gmail.com
Phone: +91 8128830103

CLIENT API AUTHORIZATION & LIABILITY WAIVER

1. PURPOSE

This Client API Authorization & Liability Waiver (“Agreement”) governs the integration of the Client’s broker/trading account with the QuantifyPlus platform via API connectivity.

By proceeding with API connection, the Client acknowledges and agrees to the terms below.

2. NATURE OF SERVICE

QuantifyPlus is a technology platform that enables automated trade execution based on algorithmic strategies selected and configured by the Client.

Arista Capitals (Proprietorship):

• Is NOT registered with Securities and Exchange Board of India (SEBI)
• Is NOT a Research Analyst (RA)
• Is NOT an Investment Adviser (IA)
• Is NOT a Portfolio Management Service (PMS) provider
• Does NOT provide stock recommendations
• Does NOT manage client funds
• Does NOT execute discretionary trades

The platform merely transmits trade instructions generated by software logic chosen by the Client.

3. CLIENT AUTHORIZATION

The Client voluntarily authorizes QuantifyPlus to:

• Connect to their broker account using API credentials
• Transmit algorithm-generated trade instructions to the broker
• Access account-level data necessary for automation (positions, orders, margins, etc.)

The Client confirms:

• API Key, Secret Key, TOTP, or authentication credentials are entered manually by the Client.
• Credentials are provided voluntarily.
• The Client has full authority over the trading account.
• The broker account belongs to the Client.

4. NO DISCRETIONARY CONTROL

The Client acknowledges:

• All strategies are selected by the Client.
• All parameters are configured by the Client.
• The Company does not override, modify, or take discretionary decisions.
• Trades are system-triggered based solely on predefined algorithmic conditions.

5. RISK ACKNOWLEDGMENT

The Client understands and accepts that:

• Market volatility may result in significant losses.
• API delays may cause slippage.
• Exchange outages may prevent order execution.
• Broker-side issues may affect trades.
• Internet or server downtime may disrupt automation.
• Algorithmic malfunction may result in unintended trades.
• Stop-loss orders may fail in gap-up/gap-down markets.

The Client agrees that all trading is undertaken at their sole risk.

6. LIABILITY WAIVER

To the maximum extent permitted by Indian law, the Client agrees that:

Arista Capitals and QuantifyPlus shall NOT be liable for:

• Trading losses
• Capital loss (partial or complete)
• Missed trades
• Incorrect execution due to broker/exchange/API failure
• Margin penalties
• Regulatory changes
• Technical malfunction beyond reasonable control
• Data latency or pricing discrepancies

Total liability, if any, shall not exceed the subscription fee paid for the current billing period.

7. DATA & SECURITY

• API credentials may be stored in encrypted format.
• The Company implements reasonable cybersecurity safeguards.
• No system is completely immune to breach.
• The Client remains responsible for safeguarding broker credentials.

8. NO PROFIT GUARANTEE

The Client acknowledges that:

• No returns are guaranteed.
• No capital protection is assured.
• Past performance does not indicate future results.
• The Company does not engage in profit-sharing.

9. INDEMNIFICATION

The Client agrees to indemnify and hold harmless Arista Capitals from:

• Regulatory actions
• Broker disputes
• Financial claims
• Legal proceedings arising from Client trading activity
• Third-party claims related to use of API

10. REVOCATION OF AUTHORIZATION

The Client may disconnect API access at any time by:

• Revoking API credentials at broker level, or
• Removing API keys from the QuantifyPlus platform.

Upon revocation, the Company shall not be responsible for any open trades or pending orders.

11. GOVERNING LAW

This Agreement shall be governed by the laws of India.

Jurisdiction: Courts located in Ahmedabad, Gujarat, India shall have exclusive jurisdiction.

REGULATORY CLARIFICATION & NON-INTERMEDIARY DECLARATION

For QuantifyPlus – Operated by Arista Capitals (Proprietorship)

1. PURE TECHNOLOGY SERVICE PROVIDER

QuantifyPlus, operated by Arista Capitals (Proprietorship), is strictly a technology development and software licensing company.

The Company provides:

• Algorithmic trading software infrastructure
• Automation tools
• Strategy execution engines
• API-based technical integration systems

The Company does not provide financial services.

2. NO SEBI REGULATED ACTIVITY

The Company expressly declares that it:

• Is NOT registered with the Securities and Exchange Board of India (SEBI).
• Is NOT acting as a Research Analyst under SEBI (Research Analyst) Regulations.
• Is NOT acting as an Investment Adviser under SEBI (Investment Advisers) Regulations.
• Is NOT providing Portfolio Management Services (PMS).
• Is NOT acting as a stock broker, sub-broker, intermediary, or distributor.

The Company does not undertake any activity requiring SEBI registration.

3. NO INVESTMENT ADVICE OR RECOMMENDATION

The Company:

• Does NOT provide stock recommendations.
• Does NOT suggest buying or selling securities.
• Does NOT provide personalized or non-personalized investment advice.
• Does NOT prepare research reports.
• Does NOT assess suitability of investments for users.

All strategies made available on the platform are:

• Mathematical or rule-based software logic
• Fully disclosed at code/logic level
• User-activated at the sole discretion of the Client

The User independently evaluates and chooses any strategy without reliance on the Company.

4. NO DISCRETIONARY CONTROL

The Company:

• Does NOT exercise discretion over client accounts.
• Does NOT select securities on behalf of clients.
• Does NOT determine capital allocation.
• Does NOT manage portfolios.
• Does NOT access broker accounts beyond API permission voluntarily granted by the Client.

All trade instructions are system-generated based strictly on parameters configured by the Client.

5. NO CUSTODY OF FUNDS

At no time does the Company:

• Hold client funds
• Receive trading capital
• Operate pooled accounts
• Collect margin money
• Accept deposits for investment purposes

All funds remain exclusively with the Client’s chosen broker.

6. USER SELF-DIRECTED TRADING DECLARATION

The Client acknowledges that:

• All trading decisions are self-directed.
• Strategy deployment is voluntary.
• The Company does not influence investment decisions.
• The Company does not assure or project returns.
• The Client is solely responsible for compliance with applicable securities laws.

7. TECHNOLOGY INFRASTRUCTURE ROLE ONLY

QuantifyPlus operates similarly to:

• Charting platforms
• Trading terminals
• API middleware systems
• Technical automation software providers

The Platform merely provides technical infrastructure for order transmission and automation.

8. NO SOLICITATION

The Company does not:

• Solicit investments
• Promote guaranteed returns
• Advertise assured performance
• Engage in profit-sharing arrangements
• Offer risk-free trading systems

Any marketing content shall not be construed as investment solicitation.

9. REGULATORY SEVERABILITY

If any regulatory authority interprets any service in a manner inconsistent with this declaration, the relevant provision shall be interpreted strictly as a technology service only, and not as a regulated financial activity.

10. CLIENT ACKNOWLEDGMENT

By using QuantifyPlus, the Client confirms that:

• They understand the Company is not a SEBI-regulated intermediary.
• They are not relying on the Company for investment advice.
• They accept full responsibility for all trading decisions.
• They waive any claim alleging advisory or portfolio management services.