Disclosure - RIA

The information provided in this Disclosure Document is prepared in accordance with SEBI (Investment Advisers) Regulations, 2013. Its purpose is to present relevant details about the Investment Advisory Services to help prospective and existing clients make informed decisions before engaging with the Investment Adviser.

For this document, the Investment Adviser is "Cusp Money Advisors Pvt Ltd," registered with SEBI under the SEBI (Investment Advisers) Regulations, 2013, with Registration No. INA000020004 dated March 24, 2025. The company's registered office is located at 401, Gala Hub, Near Basant Bahar Club, Bopal Road, Bopal, Ahmedabad - 380058.

A. About Cusp Money Advisors Private Limited ("Cusp")

Company Overview
Cusp offers investment advisory services with a client-centric approach. By understanding each client's return expectations, risk appetite, and financial objectives, Cusp tailors an asset allocation strategy best suited for the individual. Periodic portfolio reviews and course-corrections are carried out as necessary to stay aligned with clients' goals.

Advisory Terms & Conditions
Cusp offers investment advice under a mutually agreed fee structure, for a specified duration. These terms may evolve, and all services are rendered at the client’s risk, as detailed in the executed agreement between the client and Cusp.

Disciplinary Record
No regulatory or disciplinary action has been taken against Cusp or its representatives as Investment Advisers.

Compliance Audit
As FY 2024-25 marks the inaugural year for Cusp, the annual compliance audit required under Regulation 19(3) of SEBI (Investment Advisers) Regulations, 2013 will be conducted and completed within the stipulated timeline.

Affiliations
Cusp does not have any affiliations or registrations with other intermediaries.

B. Remuneration/Compensation Disclosure for Distribution Services

Cusp does not enter into distribution or execution arrangements for the securities it advises on. However, affiliate companies may receive commissions or referral fees for such products. Indicative commissions of such affiliates are disclosed on the company’s website.

C. Referral Arrangements for Brokers or Intermediaries

Cusp does not refer or promote any stockbroker or intermediary, nor does it have any compensation-sharing arrangement for such referrals.

D. Personal Investments by Cusp

Cusp is not a SEBI-registered broker and does not currently engage in proprietary trading. Investments in financial securities may be made in the future.

E. Conflict of Interest

Cusp is an independent legal entity focused solely on investment advisory. It does not participate in other activities like stock broking, portfolio management, research, or mutual fund distribution that might compromise its objectivity.

F. Product-Related Disclosures

Clients are encouraged to carefully review the features, historical performance, and associated disclaimers of any product before investing. Information may be made available directly by Cusp or accessible via regulatory portals like www.sebi.gov.in, www.nseindia.com, or www.bseindia.com.

G. Disclaimer & Risk Warnings in Marketing Materials

Cusp ensures that its advisers explicitly highlight all relevant warnings and disclaimers included in promotional or informational materials for investment products.

H. Standard Risk Factors Acknowledged by Cusp

1. Investment in equities, derivatives, and mutual funds involves market risk and does not guarantee returns.
2. Past performance does not indicate future outcomes.
3. Portfolio NAVs may fluctuate with market movements.
4. Returns may be impacted by government policy changes, interest rates, and trading environment.
5. Risks include but are not limited to economic shifts, illiquidity, poor corporate performance, geopolitical risks, and natural calamities.
6. Product names do not guarantee performance.
7. Debt instruments are subject to credit, liquidity, and interest rate risks.
8. Reinvestment risks may affect income earned from maturing securities.
9. Unlisted investments carry higher liquidity risks.
10. Securities lending exposes portfolios to counterparty and collateral risks.
11. Derivatives trading introduces leverage and valuation risks.
12. Mispricing and correlation errors can arise in derivative products.
13. NAVs may be impacted by settlement delays.
14. Higher-yield, lower-rated instruments may increase portfolio risk, subject to the advisory agreement.

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General Risks

Clients should ensure that they have reviewed all product-related documents and risk factors before proceeding. Cusp maintains full confidentiality of client information unless legally obligated to disclose. Advisory recommendations are based on data provided by the client and interactions with Cusp's investment advisers.

Investor Charter - RIA

Vision

Invest with knowledge & safety.

Mission

Every investor should be able to invest in right investment products based on their needs, manage and monitor them to meet their goals, access reports and enjoy financial wellness.

Details of business transacted by the Investment Advisor with respect to the investors.

• To enter into an agreement with the client providing all details including fee details, aspect of Conflict of interest disclosure and maintaining confidentiality of information.
• To do a proper and unbiased risk – profiling and suitability assessment of the client.
• To obtain registration with Know Your Client Registration Agency (KRA) and Central Know Your Customer Registry (CKYC).
• To conduct audit annually.
• To disclose the status of complaints in its website.
• To disclose the name, proprietor name, type of registration, registration number, validity, complete address with telephone numbers and associated SEBI regional/local Office details in its website.
• To employ only qualified and certified employees.
• To deal with clients only from official number
• To maintain records of interactions, with all clients including prospective clients (prior to onboarding), where any conversation related to advice has taken place.

Details of services provided to investors (No Indicative Timelines)

• Onboarding of Clients
• Sharing of agreement copy
• Completing KYC of clients
• Disclosure to Clients
  
  • To provide full disclosure about its business, affiliations, compensation in the agreement.
  • To not access client’s accounts or holdings for offering advice.
  • To disclose the risk profile to the client.
  • To provide investment advice to the client based on the risk-profiling of the clients and suitability of the client.

Details of grievance redressal mechanism and how to access it

• In case of any grievance / complaint, an investor should approach the concerned Investment Adviser and shall ensure that the grievance is resolved within 30 days.
• If the investor’s complaint is not redressed satisfactorily, one may lodge a complaint with SEBI on SEBI’s 'SCORES' portal which is a centralized web based complaints redressal system. SEBI takes up the complaints registered via SCORES with the concerned intermediary for timely redressal. SCORES facilitates tracking the status of the complaint.
• With regard to physical complaints, investors may send their complaints to: Office of Investor Assistance and Education, Securities and Exchange Board of India, SEBI Bhavan, Plot No. C4-A, ‘G’ Block, Bandra-Kurla Complex, Bandra (E), Mumbai - 400 051.

Expectations from the investors (Responsibilities of investors)

Do’s

• Always deal with SEBI registered Investment Advisers.
• Ensure that the Investment Adviser has a valid registration certificate.
• Check for SEBI registration number. Please refer to the list of all SEBI registered Investment Advisers which is available on SEBI website in the following link:  https://www.sebi.gov.in/sebiweb/other/OtherAction.do?doRecognisedFpi=yes&intmId=13
• Pay only advisory fees to your Investment Adviser. Make payments of advisory fees through banking channels only and maintain duly signed receipts mentioning the details of your payments.
• Always ask for your risk profiling before accepting investment advice. Insist that Investment Adviser provides advisory strictly on the basis of your risk profiling and take into account available investment alternatives.
• Ask all relevant questions and clear your doubts with your Investment Adviser before acting on advice.
• Assess the risk–return profile of the investment as well as the liquidity and safety aspects before making investments.
• Insist on getting the terms and conditions in writing duly signed and stamped. Read these terms and conditions carefully particularly regarding advisory fees, advisory plans, category of recommendations etc. before dealing with any Investment Adviser.
• Be vigilant in your transactions.
• Approach the appropriate authorities for redressal of your doubts / grievances.
• Inform SEBI about Investment Advisers offering assured or guaranteed returns.

Don’ts

• Don’t fall for stock tips offered under the pretext of investment advice.
• Do not provide funds for investment to the Investment Adviser.
• Don’t fall for the promise of indicative or exorbitant or assured returns by the Investment Advisers. Don’t let greed overcome rational investment decisions.
• Don’t fall prey to luring advertisements or market rumors.
• Avoid doing transactions only on the basis of phone calls or messages from any Investment adviser or its representatives.
• Don’t take decisions just because of repeated messages and calls by Investment Advisers.
• Do not fall prey to limited period discount or other incentive, gifts, etc. offered by Investment advisers
• Don’t rush into making investments that do not match your risk taking appetite and investment goals.
• Do not share login credential and password of your trading and demat accounts with the Investment Adviser.

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Investor Complaints - RIA

Client’s queries / complaints may arise due to lack of understanding or a deficiency of service experienced by clients. Deficiency of service may include lack of explanation, clarifications, understanding which escalates into shortfalls in the expected delivery standards, either due to inadequacy of facilities available or through the attitude of staff towards client.

• Clients can seek clarification to their query and are further entitled to make a complaint in writing, orally or telephonically. An email may be sent to the Client Servicing Team on compliance@cusp.money. 
• A letter may also be written with their query/complaint and posted at the below mentioned address: Cusp Money, 401, Gala Hub, Near Basant Bahar Club, Bopal Road, Bopal, Ahmedabad
• Clients can write to the Compliance Officer at compliance@cusp.money if the Investor does not receive a response within 10 business days of writing to the Client Servicing Team. The client can expect a reply within 10 business days of approaching the Compliance Officer.
• In case you are not satisfied with our response you can lodge your grievance with SEBI at https://scores.sebi.gov.in/ or you may also write to any of the offices of SEBI. SCORES may be accessed thorough SCORES mobile application as well, same can be downloaded from below link:https://play.google.com/store/apps/details?id=com.sebi&hl=en_IN

• ODR Portal could be accessed, if unsatisfied with the response. Your attention is drawn to the SEBI circular no. SEBI/HO/OIAE/OIAE_IAD-1/P/CIR/2023/131 dated July 31, 2023, on “Online Resolution of Disputes in the Indian Securities Market”. A common Online Dispute Resolution Portal (“ODR Portal”) which harnesses conciliation and online arbitration for resolution of disputes arising in the Indian Securities Market has been established. ODR Portal can be accessed via the following link - https://smartodr.in/

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Trend of monthly disposal of complaints

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*Inclusive of complaints of previous months resolved in the current month.

#Inclusive of complaints pending as on the last day of the month.

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March Month Complaints

‍*Inclusive of complaints of previous months resolved in the current month.

#Inclusive of complaints pending as on the last day of the month.

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Trend of annual disposal of complaints

*Inclusive of complaints of previous years resolved in the current year.

#Inclusive of complaints pending as on the last day of the year.

Privacy Policy

Effective Date: 14th May, 2024
Last Updated: 14th May, 2024

1. Introduction

Cusp Money Advisors Private Limited (referred to herein as "the Company," "Cusp Money," "We," "Our," or "Us") operate the Cusp Money website located at https://www.cusp.money and the Cusp Money mobile application available on App Store and Google Play Store (collectively referred to as the "Platform").

We are committed to protecting the privacy and security of your personal information ("Personal Data") and respecting your privacy. This Privacy Policy ("Policy") describes how we collect, use, process, and disclose your Personal Data in connection with your access to and use of the Platform and the personal finance management and wealth advisory services ("Services") offered through it.

By accessing, browsing, or using our Platform or Services, you acknowledge that you have read, understood, and agree to the processing of your Personal Data in accordance with the terms of this Privacy Policy and our Terms of Service.

2. Policy Review, Updates, and Applicability

This Privacy Policy applies to all users of the Platform and Services ("Customer," "You," or "Your"). It covers Personal Data, which includes any information or documents that relate to a natural person and can, either directly or indirectly in combination with other information, identify that person.

We may amend this Privacy Policy from time to time by posting a revised version on our Platform. The revised version will be effective as of the published effective date. We will provide you with prior notice of material changes where required by applicable law. Your continued use of the Platform or Services after the effective date of the revised Privacy Policy constitutes your acceptance of the changes.

3. Information We Collect

In order to provide you with the Services and improve your experience, we collect the following types of information, which may include Personal Data, in compliance with applicable law:

A. Information You Provide Directly to Us:

• Registration and Account Information: When you create an account, we collect personal details such as your name, email address, phone number, date of birth, gender, marital status, nationality, and other identifying information.
• Identity and KYC Information: To comply with regulatory requirements for financial services and investment advisory, we may collect information necessary for Know Your Customer (KYC) and identity verification purposes. This may include:
  
  • Permanent Account Number (PAN)
  • Aadhaar number (where permissible and necessary, often partially masked)
  • Father's name, Mother's name.
• Financial Information: We collect information related to your financial situation and activities to provide PFM and advisory services. This includes:
  
  • Bank account details (account number, name, IFSC code).
  • Bank statements and transaction details.
  • Investment details (e.g., folio numbers, scheme names, investment dates, values, statements from depositories, RTAs, brokers).
• Contacts and Nominee Details: You may provide details of your contacts or nominees as required for certain financial products or services.
• Communications and Support: When you communicate with us, such as through customer support chats, calls, or emails, we collect the content of these communications and any information you provide. We may monitor or record customer support interactions for quality, training, or record-keeping purposes.
• Survey Responses: Information you provide when participating in surveys about the Services.

B. Information We Collect Through Your Use of the Platform:

• Usage Data: We collect information about how you access and use the Platform and Services, including the types of Services you use, features you interact with, actions you take (e.g., viewing pages, clicking buttons, entering data), the time, frequency, and duration of your activities.
• Transaction Data: Details of any transactions you initiate or that occur through the Platform, including payment methods, amounts, and related financial data.
• Device Information: We collect information from the device you use to access the Platform, including IP address, unique device identifiers, device type, operating system and version, mobile network information, browser type, and software information.
• Log Data: Server logs collect standard information when you access the Platform, including IP address, access times, hardware and software information, and the page or feature you requested.

C. Information We Collect from Third Parties:

With your explicit consent and where necessary for the provision of Services, we may collect information about you from third parties:

• KYC Registries: We may fetch your KYC details from regulated KYC registries (e.g., CKYC, CVL) for identity verification and compliance purposes.

4. How We Use Your Information

We use the information we collect, including Personal Data, for the following purposes:

• To Provide and Manage the Services: Operate, maintain, and provide you with the features and functionalities of the Platform and Services, including PFM tools, financial tracking, investment advisory, mutual fund transaction processing, and customer support.
• Account Management and Verification: Create, maintain, and update your account, verify your identity (including during onboarding, KYC, and password resets), and manage your relationship with us.
• Personalization: Customize your experience on the Platform by providing personalized content, services, and recommendations based on your financial profile and usage patterns.
• Analytics and Improvement: Analyze usage trends, monitor and measure the performance of the Platform and Services, conduct research, troubleshoot issues, and develop and improve our products and offerings.
• Security and Fraud Prevention: Detect, prevent, and investigate fraud, unauthorized access, security incidents, and other potentially prohibited or illegal activities. Protect the security and integrity of our Platform and your data.
• Communication: Communicate with you regarding your account, transactions, Service updates, security alerts, technical notices, and administrative messages. Respond to your inquiries and provide customer support.
• Compliance and Legal Obligations: Comply with applicable laws, regulations, legal processes, and government requests (e.g., AML/CFT requirements, tax regulations, reporting obligations). Enforce our Terms of Service and other policies.
• Enabling Specific Service Features: Facilitate activities necessary for specific features, such as linking bank accounts, initiating investments, or providing specific advisory based on your data.

5. How We Share Your Information

We do not sell or rent your Personal Data to third parties for their marketing purposes. We may share your information with third parties under the following circumstances:

• With Your Consent: We may share your information with third parties when you provide explicit consent for us to do so.
• Service Providers: We share information with trusted third-party vendors, such as identity verification, KYC checks, payment processing. These service providers are contractually bound to protect your information and use it only for the purposes for which it was disclosed.
• Legal and Regulatory Requirements: We may disclose your information if required to do so by law, regulation, or legal process (e.g., in response to a subpoena, court order, or government request), or if we believe such disclosure is necessary to:
  
  • Comply with legal obligations.
  • Prevent physical harm or financial loss.
  • Report suspected illegal activity.
  • Investigate violations of our Terms of Service or other policies.
  • Protect our rights, property, or safety, or the rights, property, or safety of others.
• Business Transfers: In the event of a merger, acquisition, reorganization, sale of assets, or bankruptcy, your information may be transferred as part of that transaction. We will notify you before your Personal Data is transferred and becomes subject to a different privacy policy.

We take reasonable steps to ensure that any third parties with whom we share your Personal Data are bound by privacy and security obligations consistent with this Privacy Policy and applicable law.

6. Cookies and Tracking Technologies

We use cookies, pixel tags, web beacons, and similar technologies to collect information about your usage of the Platform. These technologies help us to:

• Recognize you when you return to the Platform.
• Remember your preferences and settings.
• Analyze how you use the Platform to improve its functionality and your experience.
• Measure the effectiveness of our marketing and promotional efforts.
• Administer the Platform and ensure its security.

"Cookies" are small text files placed on your device. You can manage your cookie preferences through your browser settings. However, blocking certain types of cookies may impact your ability to use certain features of the Platform.

By using the Platform, you consent to our use of cookies and similar technologies as described in this Privacy Policy.

7. Data Security

We implement reasonable physical, technical, and administrative security measures designed to protect your Personal Data from unauthorized access, use, disclosure, alteration, and destruction. These measures include:

• Encryption of sensitive data (such as financial information) during transmission and at rest.
• Access controls and authorization procedures to restrict access to your Personal Data to only those employees and service providers who need it to perform their job duties.
• Regular security assessments and testing.
• Physical safeguards at facilities where data is stored.

While we strive to use commercially acceptable means to protect your Personal Data, no method of transmission over the Internet or electronic storage is 100% secure. Therefore, we cannot guarantee its absolute security.

You are responsible for maintaining the confidentiality of your account credentials (username, password) and for any activity that occurs under your account. Do not share your password with anyone. We are not responsible for the security of information that you transmit over networks that we do not control.

We shall not be held responsible for any loss, damage, or misuse of your Personal Data if such loss, damage, or misuse is attributable to a Force Majeure Event (an event beyond our reasonable control, including but not limited to hacking, data breaches, strikes, natural disasters, acts of government, etc.).

8. Data Retention

We retain your Personal Data for as long as necessary to provide the Services you have requested, to comply with our legal and regulatory obligations, resolve disputes, and enforce our agreements.

Financial data and KYC information are subject to specific retention periods mandated by applicable laws and regulations e.g., under SEBI regulations for investment advisors and RBI for financial information users of account aggregatory ecosystem.

Upon your request to delete your account, we will delete your Personal Data from our active databases, subject to our legal and regulatory retention requirements. Please note that some information may remain in our archives or backups for a limited period.

We may retain and use aggregated and anonymized information (which cannot identify you personally) for research, analytics, and business purposes indefinitely.

9. Your Rights

Depending on your location and applicable laws, you may have certain rights regarding your Personal Data, including:

• Access: The right to request a copy of the Personal Data we hold about you.
• Correction: The right to request that we correct any inaccurate or incomplete Personal Data.
• Deletion: The right to request that we delete your Personal Data, subject to certain exceptions (e.g., legal obligations to retain data).
• Withdraw Consent: Where we process your data based on your consent, you have the right to withdraw that consent at any time. This will not affect the lawfulness of processing based on consent before its withdrawal.

To exercise these rights, please contact us using the details provided in the "Contact Us" or "Grievance Officer" section below. We may need to verify your identity before processing your request.

Please note that deleting your account or requesting the deletion of certain data may impact your ability to use some or all of the Services.

10. Third-Party Links

Our Platform may contain links to websites or services operated by third parties. This Privacy Policy does not apply to third-party websites or services. We are not responsible for the privacy practices, content, or data collection practices of any third-party websites or services. We encourage you to review the privacy policies of those third parties before providing any information to them.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. The "Last Updated" date at the top of this Policy indicates when it was last revised. Any changes will be effective when we post the revised Privacy Policy on the Platform. If we make material changes, we will notify you as required by law. We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your information. Your continued use of the Platform or Services after the changes become effective constitutes your acceptance of the revised Privacy Policy.

12. Governing Law and Dispute Resolution

This Privacy Policy shall be governed by and construed in accordance with the laws of the Republic of India, without regard to its conflict of laws principles. Any dispute arising out of or relating to this Privacy Policy shall be subject to the exclusive jurisdiction of the courts located in Ahmedabad, India.

13. Grievance Officer

In accordance with the provisions of the Information Technology Act, 2000 and the rules made thereunder, the name and contact details of the Grievance Officer are provided below. You may contact the Grievance Officer to address any concerns or grievances you may have regarding the processing of your Personal Data or this Privacy Policy.

Name: Hardik Thakkar
Designation: Grievance Officer
Email: compliance@cusp.money
Time: Mon - Fri, 10 AM - 7 PM IST

We will endeavor to resolve your grievances within a reasonable timeframe as prescribed by applicable law.

14. Contact Us

If you have any questions, comments, or concerns about this Privacy Policy or our data practices, please contact us at:

Email: compliance@cusp.money