Terms & Conditions

1. Definitions

In these Terms & Conditions, the following definitions apply:

• "Platform" means the TrudyINV Enterprise Portal accessible at portfolioanalysis.in and all associated pages, features, APIs, tools, and services, including both Free and Pro tiers.
• "Company", "we", "us", "our" means TrudyINV Services LLP, LLPIN: ACJ-9359, 10th Floor, West Wing, Raheja Towers, MG Road, Ashok Nagar, Bangalore, Karnataka 560001.
• "User", "you", "your" means any individual or entity who accesses, registers, or uses the Platform.
• "Free Plan" means the no-cost tier of the Platform offering manual portfolio entry, gap analysis, goal planning, and PDF report generation.
• "Pro Plan" means the paid subscription tier offering Account Aggregator integration, live portfolio tracking, goal achievement tracking, and additional features as described in Section 4.
• "Subscription" means a recurring billing arrangement for the Pro Plan, processed through Razorpay.
• "AA" means an RBI-licensed Account Aggregator, specifically Setu (Pine Labs Private Limited), acting as a data intermediary under the RBI Master Directions on Account Aggregators.
• "FIP" means a Financial Information Provider — a SEBI/RBI/IRDAI-regulated entity holding your financial data, such as CAMS, KFintech, CDSL, NSDL, or a bank.
• "Consent" means your explicit, revocable, time-limited approval for the AA to fetch specific financial data from specific FIPs and share it with TrudyINV for portfolio analysis purposes.
• "Financial Data" means any data fetched via the AA framework including mutual fund holdings, equity holdings, bank deposits, insurance policies, and NPS holdings.
• "Outputs" means any analysis, projection, allocation model, future value estimate, probability score, report, commentary, or result generated by the Platform.
• "SEBI" means the Securities and Exchange Board of India.
• "AMFI" means the Association of Mutual Funds in India.
• "RIA" means a SEBI-registered Investment Adviser under the SEBI (Investment Advisers) Regulations, 2013.
• "DPDP Act" means the Digital Personal Data Protection Act, 2023.

2. Acceptance of Terms

By creating an account, logging in, subscribing to a Pro plan, or connecting financial accounts via AA, you confirm that you have read, understood, and agree to be bound by these Terms and our Disclaimer & Privacy Policy. If you are accessing the Platform on behalf of an organisation, you represent that you have authority to bind that entity to these Terms.

3. Eligibility

• You must be at least 18 years of age or the legal age of majority in your jurisdiction.
• You must have the legal capacity to enter into binding contracts under Indian law.
• You must not be barred from using financial services under any applicable law, regulation, or court order.
• For Pro Plan subscriptions, you must hold a valid Indian payment method (UPI, card, or net banking) and provide accurate billing information.
• For AA integration, you must be the account holder or an authorised representative of the financial accounts you connect, and the mobile number used must be registered with those accounts.

4. Nature of the Platform — Free & Pro

The Platform operates on a freemium model. All users access the Free Plan by default. The Pro Plan is an optional paid upgrade.

Free Plan features include manual portfolio entry, portfolio gap analysis, goal planning, future value calculations, Monte Carlo simulation, PDF report generation, and investor persona profiling.

Pro Plan features additionally include:

• Connection of financial accounts via the RBI-regulated Account Aggregator framework (Setu)
• Automatic population of portfolio data from linked accounts
• Monthly automatic refresh of holdings from linked accounts
• Goal achievement tracking with visual progress indicators
• Email notification when a financial goal is achieved
• Portfolio value trend charts based on historical snapshots
• All Free Plan features

The Platform is a self-service financial analysis and planning tool. It does not constitute personalised investment advice, portfolio management, or any other regulated financial service. TrudyINV Services LLP is not a SEBI-registered Investment Adviser (RIA) and does not provide regulated advisory services through this Platform.

5. User Account & Registration

• You must provide accurate, current, and complete information during registration.
• You are solely responsible for maintaining the confidentiality of your login credentials.
• You are responsible for all activity occurring under your account.
• Notify us immediately at uday@trudy.in of any suspected unauthorised access.
• Each account is for individual use only. Sharing credentials with third parties is prohibited.
• The Company reserves the right to suspend or terminate accounts that violate these Terms.

6. Pro Subscription — Terms & Billing Pro

6.1 Subscription Plans

Pro subscriptions are available on two billing cycles:

• Pro Monthly: ₹299 per month (plus applicable GST at 18% = ₹352.82 per month)
• Pro Annual: ₹2,499 per year (plus applicable GST at 18% = ₹2,948.82 per year)

Prices are displayed exclusive of GST on the upgrade page. Total amount charged includes GST at the prevailing rate. The Company reserves the right to revise pricing with 30 days' advance notice.

6.2 Payment Processing

All payments are processed by Razorpay (Razorpay Software Private Limited), a PCI DSS Level 1 certified payment gateway. By subscribing, you authorise Razorpay to charge your chosen payment method on a recurring basis per your selected billing cycle. TrudyINV Services LLP does not store your card details. All payment data is handled exclusively by Razorpay in accordance with their Privacy Policy and applicable RBI regulations.

6.3 Automatic Renewal

Subscriptions automatically renew at the end of each billing period unless cancelled. Renewal charges are applied to your registered payment method. You will receive an email confirmation of each successful charge at your registered email address.

6.4 Cancellation Policy

You may cancel your subscription at any time via My Account → Cancel Subscription, or by contacting us at uday@trudy.in. Upon cancellation, your Pro access continues until the end of the current paid billing period. No refund is provided for the unused portion of a current billing period. Cancellation takes effect at the start of the next billing cycle.

6.5 Refund Policy

Subscription fees are non-refundable except in the following circumstances: (a) double charge due to a technical error, (b) subscription activated but Pro features were completely unavailable for more than 72 consecutive hours due to a platform issue, or (c) as required by applicable consumer protection law. Refund requests must be submitted within 7 days of the charge to uday@trudy.in with the Razorpay payment ID. Approved refunds are processed within 5–7 business days to the original payment method.

6.6 Failed Payments

If a renewal payment fails, Razorpay will retry the charge as per their standard retry policy. If payment continues to fail, your subscription will be suspended and Pro features will become inaccessible. Your data is retained and Pro access is restored immediately upon successful payment.

6.7 GST & Tax Invoices

TrudyINV Services LLP is registered under GST (GSTN: 29AAWFT9808M1ZW). A GST-compliant tax invoice will be issued for each successful subscription payment and sent to your registered email address. If you are a GST-registered business, provide your GSTIN at uday@trudy.in to have it included on your invoices for input tax credit purposes.

6.8 Subscription Suspension by Company

The Company reserves the right to suspend or terminate a Pro subscription without refund if the subscriber is found to be in breach of these Terms, engaging in fraudulent activity, or misusing the Platform in a manner that may harm other users or the Company.

7. Account Aggregator Integration Pro

7.1 The AA Framework

The Account Aggregator (AA) framework is an RBI-regulated data-sharing infrastructure. TrudyINV uses Setu (Pine Labs Private Limited), an RBI-licensed AA, as its technology partner to facilitate secure, consent-based sharing of your financial data for portfolio analysis purposes. TrudyINV acts as a Financial Information User (FIU) in this framework.

7.2 Explicit Consent Requirement

Before any financial data is fetched, you will be required to provide explicit, informed consent via the Setu consent interface. Your consent specifies:

• Exactly which financial accounts and data types are shared (e.g. mutual funds, demat holdings, bank deposits)
• The time period for which data is fetched
• The duration for which TrudyINV may hold your data
• The frequency of data refresh
• The purpose: portfolio gap analysis and financial planning

TrudyINV will not fetch any financial data without your explicit consent as captured through the Setu consent interface. Each consent is recorded with a unique consent ID.

7.3 Read-Only Access

TrudyINV's access to your financial data via AA is strictly read-only. We cannot and will not initiate any financial transaction, place any order, or perform any action on your linked accounts. The AA framework is architecturally designed to prevent transactional access.

7.4 Your Right to Revoke Consent

You may revoke your AA consent at any time via My Account → Revoke AA Access, or directly through the Setu AA mobile application. Upon revocation, TrudyINV immediately ceases to receive data from your linked accounts. Previously fetched data already stored in TrudyINV's systems is not automatically deleted upon revocation but may be requested for deletion under Section 17.3.

7.5 Data Accuracy from AA

Financial data fetched via AA is sourced directly from your financial institutions (FIPs). TrudyINV does not modify, manipulate, or guarantee the accuracy or completeness of data received from FIPs. Any errors, omissions, or outdated values in your holdings data are the responsibility of the respective FIP. TrudyINV is not liable for portfolio analysis outputs that are based on inaccurate or incomplete data received from FIPs.

7.6 Mobile Number

To initiate AA consent, you must provide the mobile number registered with your financial accounts (e.g. the mobile linked to your demat account, bank, or mutual fund folios). This mobile number is used solely for AA consent authentication and is not used for any marketing purpose. It is stored in encrypted form in our database.

7.7 Third-Party Terms

Your use of the AA integration is also subject to Setu's Terms of Use and Privacy Policy (available at setu.co). The FIPs you connect may have their own terms governing data sharing. TrudyINV is not responsible for the terms, privacy practices, or availability of Setu or any FIP.

7.8 Data Refresh

Pro subscribers receive one automatic refresh of AA-linked holdings per month, subject to your active consent remaining valid. You may also trigger a manual refresh at any time from the Portfolio Entry page. Each refresh creates a new data session and updates your portfolio table upon your confirmation.

8. Permitted Use

You are granted a limited, non-exclusive, non-transferable, revocable licence to use the Platform solely for personal, non-commercial financial planning and educational purposes. Permitted uses include:

• Entering investment data or connecting AA accounts to generate portfolio gap analysis for personal review.
• Using goal planning tools to explore financial scenarios.
• Generating and downloading PDF reports for personal reference.
• Sharing your reports with your own financial adviser for professional review.
• Pro users: connecting financial accounts with explicit consent for personal portfolio analysis.

9. Prohibited Activities

• Using the Platform or its Outputs for any commercial purpose without prior written consent.
• Distributing, republishing, selling, or sublicensing any part of the Platform or its Outputs.
• Attempting to reverse-engineer, decompile, or extract any algorithm or source code.
• Entering false or fabricated data to generate misleading Outputs.
• Using the Platform to provide investment recommendations to third parties without holding appropriate SEBI registration.
• Attempting to gain unauthorised access to another user's account or financial data.
• Using automated tools, bots, or scripts to access the Platform.
• Transmitting malicious code, viruses, or harmful data.
• Sharing your Pro subscription credentials to allow access by persons other than yourself.
• Attempting to manipulate or circumvent the AA consent mechanism.
• Violating any applicable law, including the DPDP Act, IT Act, or SEBI regulations.

10. Investment Risk Disclosure

11. No Investment Advice

Nothing on the Platform constitutes personalised investment advice as defined under the SEBI (Investment Advisers) Regulations, 2013, a solicitation to buy or sell any security, or a recommendation of any specific financial product. This applies equally to Free Plan features and Pro Plan features including AA-populated portfolio data, goal tracking results, and portfolio commentary. TrudyINV Services LLP is not a SEBI-registered Investment Adviser. Users are strongly encouraged to consult a qualified SEBI-registered Investment Adviser for personalised investment decisions.

12. Accuracy of Outputs

All Outputs are dependent on the accuracy of data entered by the user or fetched from FIPs via AA. The Company makes no warranty regarding accuracy, completeness, or fitness for any purpose of Platform Outputs. The Company reserves the right to modify or discontinue any feature, model, or calculation methodology at any time without notice.

For Pro users: while AA data is sourced directly from regulated FIPs, TrudyINV does not verify FIP data for accuracy. Portfolio analysis generated from AA data carries the same illustrative nature as manually-entered data.

13. Limitation of Liability

To the maximum extent permitted by applicable Indian law, TrudyINV Services LLP and its directors, partners, employees, and affiliates shall not be liable for any loss or damage including:

• Financial loss arising from any investment decision made on the basis of Platform Outputs.
• Loss arising from inaccurate data received from FIPs via AA.
• Loss arising from failure, interruption, or unavailability of Setu or Razorpay services.
• Subscription charges incurred before a cancellation request was processed.
• Loss of profits, data, or goodwill of any kind.
• Unauthorised access to your account or financial data.

In any event, the Company's total aggregate liability shall not exceed the subscription fees paid by you in the three months preceding the claim, or ₹500, whichever is higher.

14. Indemnification

You agree to indemnify and hold harmless TrudyINV Services LLP and its directors, partners, and employees from any claims, liabilities, damages, losses, costs, and expenses arising from: your use or misuse of the Platform; any breach of these Terms; any investment decision based on Platform Outputs; any false or inaccurate data you enter or that you cause to be fetched via AA; or any violation of applicable law.

15. Intellectual Property

All intellectual property rights in the Platform — including software, algorithms, allocation models, databases, trademarks, and content — are the exclusive property of TrudyINV Services LLP and are protected under the Indian Copyright Act, 1957, and the Trade Marks Act, 1999. You are granted no rights in or to the Platform's intellectual property except the limited licence in Section 8. PDF reports generated for personal use may be downloaded and retained by the user for personal reference only and may not be redistributed commercially.

16. Third-Party Services

The Platform integrates with the following third-party services. Use of these services is governed by their respective terms:

• Razorpay (razorpay.com) — Payment processing for Pro subscriptions. Your payment data is governed by Razorpay's Privacy Policy. TrudyINV does not store card details.
• Setu / Pine Labs Private Limited (setu.co) — Account Aggregator gateway for AA integration (Pro). Your consent data is governed by Setu's Privacy Policy and RBI's AA Master Directions.
• Amazon Web Services (AWS) — Cloud hosting and database services. Data is stored on AWS servers.
• Brevo (formerly Sendinblue) — Transactional email delivery for verification, notifications, and receipts.
• AMFI (amfiindia.com) — Mutual fund NAV data for portfolio value calculations (publicly available data).

TrudyINV is not responsible for the availability, accuracy, privacy practices, or terms of any third-party service. Links to third-party websites, including SEBI SCORES (scores.sebi.gov.in), are provided for convenience only.

17. Privacy, Data & Security

17.1 Data Collected

• Name, email address, and password (hashed) — collected at registration
• Investor profile data (life stage, risk profile, wealth segment) — entered by user
• Portfolio data — entered manually or fetched via AA (Pro)
• Goal data — entered by user
• Financial holdings data — fetched from FIPs via AA (Pro, with explicit consent)
• Mobile number — collected for AA consent only (Pro)
• Payment information — processed by Razorpay; TrudyINV stores only subscription status and plan type

17.2 Purpose of Data Processing

All data is processed solely to provide the Platform's features as requested by the user. We do not sell, rent, or share your personal or financial data with any third party for commercial purposes. Financial data fetched via AA is used exclusively for portfolio analysis and goal tracking within the Platform.

17.3 Your Rights Under DPDP Act

Under the Digital Personal Data Protection Act, 2023, you have the right to: access your personal data; correct inaccurate data; request erasure of your data; withdraw consent for processing (including AA consent); and file a grievance. To exercise any of these rights, email uday@trudy.in with the subject "Data Rights Request". We will respond within 30 days.

17.4 Security Measures

• All data in transit is encrypted via HTTPS/TLS 1.3
• Database hosted on AWS RDS with encryption at rest (AES-256)
• Financial data received via AA is additionally encrypted with AES-256-GCM before storage
• Passwords are hashed using bcrypt (cost factor 12)
• JWT tokens expire after 8 hours
• All API endpoints require authenticated access
• Pro features additionally require active subscription verification on every API call

17.5 Data Retention

Your account data is retained for as long as your account remains active. AA-fetched financial data is retained for up to 6 months per consent period. Upon account deletion, all personal and financial data is permanently deleted within 30 days. Subscription payment records are retained for 7 years as required by Indian accounting and GST regulations.

17.6 Data Deletion Request

To request deletion of your account and all associated data, email uday@trudy.in with the subject "Data Deletion Request". This will result in permanent deletion of your account, portfolio data, goal data, AA-fetched holdings, and profile information. Subscription history is retained per Section 17.5. Account deletion does not automatically cancel an active Pro subscription — please cancel your subscription separately before requesting deletion.

18. Regulatory Disclosures

19. Grievance Redressal

20. Termination

The Company may suspend or terminate your access at any time for breach of these Terms, fraudulent activity, or as required by law. You may close your account at any time by emailing uday@trudy.in. Active Pro subscriptions must be cancelled separately. Upon termination, your right to use the Platform ceases immediately. Sections 10, 11, 13, 14, 15, and 22 survive termination.

21. Amendments

The Company reserves the right to modify these Terms at any time. Material changes — including changes to Pro pricing, subscription terms, or AA data handling — will be communicated by email to registered users at least 14 days before taking effect. Continued use of the Platform after the effective date of any change constitutes acceptance of the revised Terms. If you do not agree to revised Terms, you must cancel your subscription and discontinue use of the Platform.

22. Governing Law & Dispute Resolution

These Terms are governed by the laws of the Republic of India. Disputes shall first be attempted to be resolved through good-faith negotiation within 30 days of written notice. Unresolved disputes shall be referred to arbitration under the Arbitration and Conciliation Act, 1996, seated in Bangalore, Karnataka, conducted in English. Either party may seek urgent equitable relief from courts of competent jurisdiction in Bangalore.

23. Entire Agreement

These Terms, together with the Disclaimer & Privacy Policy, constitute the entire agreement between you and TrudyINV Services LLP with respect to the Platform. If any provision is found invalid or unenforceable, the remaining provisions continue in full force. No waiver of any right or provision shall constitute a continuing waiver.

24. Contact Information