LevUp – Privacy Policy 

1. About this Privacy Policy

This Privacy Policy (“Policy”) applies to:

• LevUp and its group entities / affiliates from time to time (collectively, “LevUp”, “we”, “our”, “us”), and
• All individuals (“Users”, “you”, “your”) who access or use:
  • the LevUp mobile application,
  • our website (including www.levup.in),
  • any tools, features or services we provide (together, the “Platform” or “Services”), or
  • whose information is otherwise collected by us.

LevUp is a AMFI registered Mutual Fund Distributor as well as APMI registered PMS distributor (herein after referred to as (“ARN/APRN holder” or “Distributor”) and does not operate as a Research Analyst or Investment Adviser or Portfolio Manager or Portfolio Management Services (PMS) provider. AMFI registered Mutual Fund Distributor number is ARN-272609 ; and APMI registered PMS distributor number is APRN00166For the latest SEBI registration number, please visit our website: www.levup.in

For the purposes of this Policy, “Personal Information” means any information that can identify you directly or indirectly, alone or together with other information. Information that is publicly available is not treated as Personal Information under this Policy.

This Policy is published in compliance with:

• The Information Technology Act, 2000; and
• The Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 (including Rule 4).

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2. User Consent and Acknowledgement

By:

• accessing or using the Platform or Services,
• sharing your information with us, or
• authorising data access (for example MF Central),

you explicitly and voluntarily consent to the collection, use, storage, sharing and processing of your information in accordance with this Policy.

You also consent to:

• transfer and storage of your Personal Information on LevUp’s servers and systems, and
• sharing with authorised third parties as described in this Policy.

This Policy is to be read together with our Terms of Use and other product-specific terms, and is incorporated by reference into them.

While we follow reasonable and industry-standard security practices, no system is completely secure and we cannot guarantee absolute security of data transmitted over the internet.

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3. What Information We Collect

We collect information in the following ways:

A. Information You Voluntarily Provide

When you interact with us, you may provide:

• Name, mobile number, email address
• City, state, pin code and other contact details
• Date of birth, PAN (if/when needed for KYC or regulatory checks)
• Risk profile inputs (e.g., horizon, comfort with volatility, goals)
• Your portfolio related information entered manually or by uploading excel sheet or pdf files
• Any information shared via support channels, feedback forms, emails, in-app chat or calls

If you apply or onboard for SEBI RA-driven services, we may also collect additional information as required by law or product design (e.g., income band, occupation category, goal preferences).

We may also record and retain audio, chat or written communications for:

• service improvement,
• dispute resolution, and
• regulatory compliance (where applicable).

B. Portfolio & Financial Data (via Consented Sources)

To provide portfolio analytics and research, LevUp may access portfolio data from regulated systems and providers, only with your explicit consent. This can include:

1. Mutual Fund Data (MF Central / RTAs / other registrars)

From MF Central or similar infrastructure, we may receive:

• Folio details, scheme information
• Transaction history (purchases, redemptions, switches, SIPs)
• Units, NAV, cost value, market value
• Asset type, tax status, last transaction date, KYC status
• Any other information as provided by the data provider

This enables us to:

• Ascertain your MF portfolio,
• calculate cost, returns, and holding patterns, and
• generate analytics and research views on your MF investments.

2. Equity & Other Securities Data (via Account Aggregators / Brokers/CAS files)

From RBI-regulated Account Aggregators (AA) or broker partners (as applicable), we may receive:

• Demat / equity holdings summary (ISIN, quantity, last traded price, current value)
• Transaction data for equities / ETFs / other securities
• Basic account attributes (e.g., masked account number, broker name, account type)

This enables us to:

• Ascertain your equity portfolio,
• analyse allocation, diversification, risk and performance, and
• generate analytics, research-driven insights and comparisons.

We do not receive or store your broker login credentials, bank login credentials or trading passwords.

C. Platform Usage Data

When you visit or use the Platform, we may automatically collect:

• Pages viewed, buttons clicked, features used
• Time spent, navigation patterns, and session data
• IP address, device type, OS, browser type, app version
• Device identifiers, crash logs and diagnostic information
• Referral information (e.g., which campaign or link brought you in)

This helps us:

• understand how users engage with the product,
• improve UX, stability, and performance, and
• measure effectiveness of features and content.

D. Cookies and Similar Technologies

We may use:

• Cookies (small text files on your browser/device)
• SDKs / pixels / tags in the app or website

to:

• keep you logged in,
• remember preferences,
• provide a personalised experience, and
• run analytics and A/B tests.

You may choose to disable cookies in your browser, but some parts of the Platform may not work properly as a result.

E. Information from Third Parties

We may receive information about you from:

• MF Central / RTAs / AMCs
• SEBI-registered intermediaries we integrate with
• Marketing or referral partners (subject to their privacy policies)

All such information is used in accordance with this Policy and applicable law.

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4. How We Use Your Personal Information

We use your Personal Information for the following purposes:

A. To Provide and Improve Our Services

• Understand your portfolio
• Generate analytics, research, insights and comparisons
• Show summaries like allocation, diversification, risk patterns, performance bands
• Run simulations (e.g., “You vs Strategy”, “You vs Market”)
• Insights, nudges and educational content

B. Onboarding, Support and Communication

• Create and maintain your LevUp account
• Respond to queries, feedback and support tickets
• Send important service, security or legal updates
• Share insights, product features, and relevant updates

You may opt out of promotional communications, but we may still send service-related messages (e.g., security alerts, key feature changes).

C. Compliance, Security and Risk Management

• Verify identity where required by regulation
• Detect, prevent or investigate fraud, abuse or suspicious activity
• Comply with SEBI, RBI and other regulatory requirements
• Respond to lawful requests from regulators, law enforcement or courts
• Maintain logs for security and audit purposes

D. Analytics, Research and Product Improvement

We may use anonymised or aggregated data:

• to understand behaviour patterns,
• improve algorithms and scoring,
• test new features, and
• optimise performance and reliability.

Such anonymised data does not identify you personally.

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5. Web Analytics and Third-Party Tools

We may use third-party tools (for example: analytics, crash reporting, engagement tools) to understand how users interact with the Platform and to improve our Services.

These tools may collect:

• pages/screens visited,
• clicks, scrolls, taps,
• session duration,
• device and technical information.

All such partners are required (by contract) to follow appropriate data protection and security standards and to process data only for permitted purposes.

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6. Payment Details and Processing

If you pay LevUp for any RA/research-related services:

• Payment may be processed via PCI-DSS compliant third-party payment gateways.
• You may be required to provide card/bank details directly to such gateways.
• LevUp does not store your full payment instrument details on its own servers.

Payment processors use your data strictly to complete transactions and are not permitted to use it for other purposes.

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7. Third-Party Websites and Links

The Platform may contain links to third-party websites, apps, or services. When you visit these:

• Their own privacy policies and terms apply.
• LevUp is not responsible for their practices, content, or data handling.

We recommend reviewing the privacy policy of any such third-party service before sharing information.

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8. Personal Information of Minors

The Platform is not intended for individuals under 18 years of age.

We do not knowingly collect Personal Information of minors, except where:

• such information is provided by a parent / legal guardian, and
• required for regulatory or product reasons (e.g., nominee details).

By providing information of a minor, you confirm that you are authorised to do so and consent to its processing as per this Policy.

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9. Data Retention

We retain your Personal Information for as long as necessary:

• to provide the Services,
• to satisfy legal, regulatory or audit requirements,
• to resolve disputes, and
• to enforce our agreements.

Once the purpose is fulfilled and retention is no longer required by law, we will delete, anonymise or securely store your data in accordance with applicable regulations.

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10. Data Security

We use reasonable and industry-standard technical and organisational measures to protect your information, including:

• encryption in transit (e.g., HTTPS) and at rest (where applicable),
• access controls and role-based permissions,
• logging and monitoring for unusual activity,
• periodic security reviews and updates.

However, no method of transmission or storage is 100% secure. Risks such as hacking, phishing, malware, third-party vulnerabilities, or force-majeure events may still occur. LevUp shall not be liable for breaches or losses arising from circumstances beyond our reasonable control.

If you suspect any un-authorised use of your account, you should:

• change your credentials immediately, and
• contact us at [support@levup.in].

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11. Data Transmission

Data between your device and our servers is transmitted over secure protocols (e.g., HTTPS).

To keep your data safe, you should:

• not share OTPs, passwords or device-level authentication with others,
• avoid using LevUp on compromised/jailbroken devices,
• log out or secure access on shared devices.

LevUp is not responsible for losses arising due to your negligence or intentional sharing of credentials.

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12. Disclosure of Your Information

We do not sell or rent your Personal Information.

We may share your information:

1. Within LevUp group entities – for internal operations, product enhancement, and compliance.
2. With regulated partners – such as:
   • Account Aggregators,
   • payment gateways,
   • SEBI-registered intermediaries,
   • cloud infrastructure providers.
3. To comply with law – with regulators, law enforcement, tax authorities or courts, where required.
4. In a business transaction – if LevUp undergoes a merger, acquisition, restructuring or sale, subject to applicable law.

All such sharing is done under appropriate confidentiality and data protection obligations.

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13. Your Rights and Control Over Your Information

Subject to applicable law, you may:

• Access / Review your Personal Information available on the Platform
• Request correction of inaccurate or incomplete data
• Withdraw consent for specific data processing (where applicable)
• Request deletion of your Personal Information (subject to legal retention requirements)

You can write to us at: [privacy@levup.in] or [support@levup.in].
Please note: deletion or withdrawal of consent may affect your ability to use some or all features of the Platform.

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14. Disclaimer on User Information

LevUp is not responsible for verifying the completeness or accuracy of information that you provide or authorise.

Any misrepresentation, inaccuracies, or omissions in the information you submit are your responsibility, including any resulting legal, financial or tax implications.

Our research and analytics are based on:

• the data we receive,
• public / third-party information, and

They may be incomplete, delayed or incorrect, and can lead to outcomes including full loss of invested capital. Nothing on the Platform should be construed as a guarantee of performance.

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15. Grievance Officer & Contact Details

For any questions, concerns, or complaints regarding this Policy or your Personal Information, you may contact our designated Grievance Officer:

Grievance Officer: : Parag Kasliwal
Email: grievance@levup.in
Address: 107, Bhaveshwar Arcade Annexe, LBS Marg, Opposite Shreyas/Rajhans Cinema, Ghatkopar West, Mumbai-86

Any Personal Information shared as part of a grievance may be retained as necessary to address the issue and comply with legal obligations.

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16. Governing Law and Jurisdiction

This Policy is governed by the laws of India.

Any disputes arising out of or in connection with this Policy shall be subject to the exclusive jurisdiction of the courts at Mumbai, India.

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17. Updates to this Policy

We may update this Policy from time to time to reflect:

• changes in law,
• changes in our practices, or
• new features / services.

The “Last Updated” date at the top will indicate the latest version.
Your continued use of the Platform after any update constitutes your acceptance of the revised Policy.

If you do not agree with the updated Policy, you should stop using the Platform and write to us requesting deactivation / data handling as per Section 13.