Refund, Cancellation & Termination Policy

1. NATURE AND ROLE OF THE PLATFORM

Simple RA Solutions Private Limited operates www.simplyra.com as a technology and digital platform that enables independent SEBI-registered Research Analysts (“Research Analyst” or “RA”) to onboard and manage clients, offer their research services, manage subscriptions and facilitate the delivery of research-related services through the Platform.

Simple RA Solutions Private Limited is not itself providing investment research, investment advice, securities recommendations, portfolio management services or any other regulated securities-market service merely by making the Platform available.

The research reports, research recommendations, analysis, trading calls, subscriptions and other research services made available through the Platform are provided by the respective Research Analyst.

The concerned Research Analyst remains solely responsible for the research service offered to the client and for complying with all applicable provisions of the Securities and Exchange Board of India Act, 1992, the SEBI (Research Analysts) Regulations, 2014, applicable SEBI circulars, directions, guidelines and other applicable laws and regulatory requirements.

2. CONTRACTUAL RELATIONSHIP

Where a client purchases a research service through the Platform, the research service is provided by the respective Research Analyst.

The applicable service terms, including the scope of service, fees, service period, renewal, cancellation, termination and refund provisions, shall be disclosed to and agreed with the client in accordance with applicable regulatory requirements.

The Research Analyst shall remain responsible for its contractual and regulatory obligations towards the client.

The use of the Platform does not create an investment advisory, research or other regulated-service relationship between the client and Simple RA Solutions Private Limited.

3. CANCELLATION BY THE CLIENT

A client may request cancellation or termination of a research service in accordance with the terms applicable to that particular service and the relevant Research Analyst.

Where applicable SEBI regulations or the agreed terms provide for a refund upon premature termination of a research service, such refund shall be processed in accordance with the applicable regulatory requirements and contractual terms.

Cancellation of a subscription shall ordinarily prevent future renewal or billing, subject to the applicable service terms.

Cancellation shall not, by itself, entitle a client to a refund of fees already earned or attributable to research services already provided, except where a refund is required under applicable law, SEBI requirements or the applicable terms of service.

4. REFUNDS FOR RESEARCH SERVICES

Refunds relating to a research service shall be governed by:

• 1. the terms and conditions applicable to that research service;
• 2. the terms agreed between the client and the relevant Research Analyst; and
• 3. applicable SEBI regulations, circulars, directions and other applicable laws.

For applicable individual and HUF clients who are not accredited investors, where a research service is prematurely terminated and a refund is required under applicable SEBI requirements, the relevant Research Analyst shall refund the proportionate amount of fees attributable to the unexpired period of the service, in accordance with applicable regulatory requirements.

No breakage fee shall be charged where such charge is prohibited by applicable SEBI requirements.

Simple RA Solutions Private Limited does not independently determine a client's entitlement to a refund arising from the research service, its performance, content or termination.

Where technically and operationally applicable, Simple RA Solutions may facilitate the processing of a refund determined to be payable by the relevant Research Analyst. Such facilitation shall not make Simple RA Solutions the provider of the underlying research service or transfer the Research Analyst’s regulatory or contractual obligations to Simple RA Solutions.

5. ADVANCE FEES

Where advance payment for research services is permitted under applicable SEBI requirements and agreed with the client, the relevant Research Analyst shall comply with the applicable limits, conditions and refund requirements prescribed by SEBI from time to time.

Nothing on the Platform shall be construed as permitting a Research Analyst to charge or retain fees contrary to applicable SEBI requirements.

6. PLATFORM-RELATED PAYMENT ISSUES

Simple RA Solutions may consider refunds or payment reversals where a transaction has been:

• duplicated;
• incorrectly processed due to a demonstrable technical error attributable to the Platform;
• charged despite a confirmed failure of the transaction; or
• otherwise incorrectly processed due to an error attributable to the Platform or its payment-processing arrangements.

Any such request shall be subject to verification of the relevant transaction and applicable payment-processing procedures.

This provision does not apply to disputes concerning the quality, performance, accuracy, suitability or outcome of a research service provided by a Research Analyst.

7. NO REFUND FOR INVESTMENT LOSSES OR PERFORMANCE

A client shall not be entitled to a refund merely because:

• an investment or security has declined in value;
• a research recommendation did not generate the expected return;
• a research recommendation resulted in a loss;
• a target price was not achieved;
• market conditions changed; or
• the client is dissatisfied with the performance or outcome of an investment decision.

Investment in securities is subject to market risks. There is no assurance or guarantee that the objectives of any research service or recommendation will be achieved.

Simple RA Solutions Private Limited does not guarantee, represent or warrant any investment return, market outcome or performance of any research service made available through the Platform.

8. REFUND AND CANCELLATION REQUESTS

For platform-related payment issues, transaction issues, cancellation requests or refund-related queries, customers may contact:

Customers should provide the following information when submitting a request:

• Full name;
• Registered email address and/or mobile number;
• Transaction or order ID;
• Date and amount of transaction;
• Name of the relevant Research Analyst;
• Relevant subscription/service; and
• Reason for the cancellation or refund request.

Where a request relates to the underlying research service, Simple RA Solutions may facilitate communication with or forward the request to the relevant Research Analyst.

The relevant Research Analyst shall remain responsible for determining and fulfilling any refund or termination obligation arising from its research service, subject to applicable law and regulatory requirements.

9. RESEARCH ANALYST'S REGULATORY RESPONSIBILITY

Each Research Analyst using the Platform is independently responsible for compliance with all laws and regulatory requirements applicable to its activities, including, as applicable:

• SEBI registration requirements;
• SEBI (Research Analysts) Regulations, 2014;
• applicable SEBI circulars and directions;
• disclosure requirements;
• fee-related requirements;
• client agreements and applicable terms and conditions;
• Most Important Terms and Conditions (“MITC”);
• conflict-of-interest requirements;
• grievance redressal requirements; and
• applicable refund and termination requirements.

The availability or use of the Platform does not transfer, reduce, waive or otherwise modify any such responsibility of the Research Analyst.

10. NO WAIVER OF STATUTORY OR REGULATORY RIGHTS

Nothing in this Policy shall be construed as excluding, restricting, waiving or limiting any right or remedy available to a client under applicable law, SEBI regulations, circulars, directions or other binding regulatory requirements.

In the event of any conflict between this Policy and a mandatory provision of applicable law or regulatory requirement, the mandatory legal or regulatory provision shall prevail.

11. GRIEVANCE REDRESSAL

For grievances relating specifically to the Platform, payment processing, technical issues or other services provided by Simple RA Solutions Private Limited, customers may contact:

Where a grievance concerns the research service, recommendation, research report or other regulated service provided by a Research Analyst, the grievance may be directed to the concerned Research Analyst in accordance with the grievance-redressal mechanism disclosed by that Research Analyst.

Simple RA Solutions may facilitate communication between the client and the relevant Research Analyst where appropriate.

12. CHANGES TO THIS POLICY

Simple RA Solutions Private Limited reserves the right to amend or update this Policy from time to time to reflect changes in the Platform, applicable laws, SEBI regulations, circulars, directions or business practices.

The updated version shall be published on www.simplyra.com and shall become effective from the date specified therein, unless otherwise required by applicable law.

13. GOVERNING LAW

This Policy shall be governed by and construed in accordance with the laws of India.

Subject to applicable statutory and regulatory remedies, disputes concerning the Platform or services provided directly by Simple RA Solutions Private Limited shall be subject to the jurisdiction of the competent courts and authorities having jurisdiction over the Company's registered office, as may be applicable.