PRIVACY POLICY

Version: 1.0

Effective date: 25 October 2026

INTRODUCTION

This Privacy Policy (“Privacy Policy”) describes how ADORN GLOBAL PRIVATE LIMITED, a company incorporated under the provisions of the Companies Act, 2013, having its registered office at 101, Aaradhya Swastik, Plot No. 373, 6th Rd, Near Sandu Garden, Chembur East, Mumbai, Maharashtra, 400071 (“Finopoli”, “Company”, “we”, “our” or “us”), collects, receives, stores, uses, discloses, transfers and otherwise processes your Personal Data (as defined below) when you access or use our website located at www.finopoli.com or our mobile application named BUILD (collectively, the “Platform”), create an account, communicate with us, or otherwise interact with us.

This Privacy Policy forms an integral part of the Terms of Use governing the Platform. At or before the time of collecting your Personal Data, the Company shall provide you with a notice specifying the Personal Data proposed to be collected, the purposes for which such Personal Data will be processed, the manner in which you may exercise your rights under Applicable Law including the details that will be required for you to exercise such rights in so far as the Platform is concerned. At the time of creating an account on the Platform, you will be required to provide your express consent to the collection and processing of your Personal Data by selecting the designated checkbox acknowledging this Privacy Policy as well as any other terms and conditions.

If you do not consent to this Privacy Policy, you should not create an account on or use the Platform.

DEFINITIONS

For the purposes of this Privacy Policy, unless the context otherwise requires:

“Applicable Law” means all applicable laws, rules, regulations, notifications and governmental requirements relating to privacy, data protection and cybersecurity, including the Digital Personal Data Protection Act, 2023 and the rules framed thereunder, as amended from time to time.

“Personal Data” means any data about an individual who is identifiable by or in relation to such data and shall have the meaning assigned to it under the Digital Personal Data Protection Act, 2023 and the rules created thereunder.

SCOPE OF THIS PRIVACY POLICY

This Privacy Policy applies to all visitors, users, registered users, and other individuals who access or use the Platform or otherwise provide Personal Data to the Company.

This Privacy Policy governs the processing of Personal Data collected through:

your use of the Platform;
creation and operation of a user account;
enquiries submitted through contact forms;
communications with the Company;
interactions with customer support;
cookies and similar technologies; and
any other lawful interactions between you and the Company.

AGE ELIGIBILITY

The Platform is intended solely for individuals who are 18 (eighteen) years of age or older and any use or access by anyone under the age of 18 (eighteen) years is prohibited. By creating an account or using the Platform, you represent and warrant that you are at least 18 (eighteen) years of age.

The Company does not knowingly collect or process Personal Data of individuals under the age of 18 (eighteen). If the Company becomes aware that it has inadvertently collected Personal Data from an individual under the age of 18 (eighteen), it will take appropriate steps to delete such Personal Data in accordance with Applicable Law.

Where applicable, the consent obtained from you for the collection and processing of your Personal Data shall be obtained by the Company on behalf of itself and its group companies for the purposes solely specified in this Privacy Policy. Such consent shall apply to the processing of your Personal Data by the Company and its relevant group companies in accordance with this Privacy Policy and Applicable Law.

For the avoidance of doubt, such consent shall not constitute consent or authorisation for the sharing or disclosure of your identifiable Personal Data with any group company engaged in providing investment advisory as regulated by Securities and Exchange Board of India.

INFORMATION WE COLLECT

We collect Personal Data only to the extent necessary to operate, provide, maintain and improve the Platform and our educational services. Depending on your interaction with the Platform, we may collect the following categories of information:

1. Information You Provide

When you access or use the Platform, we may collect the following Personal Data that you voluntarily provide to us, depending on the type of account you create:

your full name;
your email address;
a password created by you for your account.

You are responsible for ensuring that all Personal Data provided by you is accurate, complete and up to date.

2. Information Generated Through Your Use of the Platform

We may also collect information generated through your use of the Platform, including:

your learning progress;
quiz and assessment results;
course completion status;
your interactions with educational content;
your learning engagement and behavioural consistency, response to market movements and action discipline on the Platform; and
usage and engagement information relating to your use of the Platform.

3. Technical and Device Information

We may collect certain technical information through cookies, analytics and similar technologies, including;

your IP address;
browser type and version; and
device information.

We use Google Analytics as an analytics processor for the analysis of such information.

HOW WE USE YOUR PERSONAL DATA

We process your Personal Data only for lawful purposes, in a fair, transparent and reasonable manner, and only to the extent necessary for the purposes described in this Privacy Policy or as otherwise permitted or required under Applicable Law.

Depending on how you interact with the Platform, we may use your Personal Data for the following purposes:

to create, administer and maintain your user account, where applicable;
to provide you with access to the Platform and its features;
to deliver educational content, administer courses and assessments, monitor your learning progress and course completion, analyse your interaction with the Platform, and personalise and improve your learning experience and our educational services;
to compute and maintain discipline score based on your learning engagement, behavioural consistency, response to market movements and action discipline, solely for the purpose of personalising your learning experience and measuring your progress on the Platform. The methodology used to generate such discipline score is proprietary to the Company;
to use automated and AI-assisted processing to personalise your learning experience, generate discipline score, and provide educational support through the Platform. Such processing is used solely as a learning tool and is not used to make any legally or financially significant decision about you without human involvement;
to respond to your enquiries, requests or feedback and communicate with you regarding your use of the Platform;
to operate, maintain, troubleshoot, secure and improve the Platform, including analysing usage trends and enhancing user experience;
to detect, prevent, investigate and address fraud, unauthorised access, security incidents, misuse of the Platform or violations of the Terms of Use;
to comply with Applicable Law, regulatory requirements, judicial or governmental requests, and to enforce our legal rights and obligations; and
to establish, exercise or defend legal claims, resolve disputes, and obtain professional or legal advice where necessary.

We will not use your Personal Data for any purpose that is incompatible with the purposes set out in this Privacy Policy unless we obtain your consent or are otherwise permitted or required to do so under Applicable Law.

WITHDRAWAL

Your consent to the collection and processing of your Personal Data shall be obtained at the time of creating your account on the Platform in the manner described in this Privacy Policy.

You may withdraw your consent at any time by visiting the Manage Privacy page at https://www.finopoli.com/manage-privacy, also reachable in the Build app via Settings then Privacy, or by contacting the Company’s Grievance Officer at the contact details provided in this Privacy Policy. Withdrawal of consent shall not affect the lawfulness of processing undertaken by the Company prior to such withdrawal.

COOKIES AND OTHER TRACKING TECHNOLOGIES

We use cookies and similar tracking technologies on our Platform to enable core functionality, improve performance, and analyse usage.

Cookies are small text files stored on your device that help us recognise your browser or device and remember certain information, including preferences and login-related data, where applicable.

You may manage your cookie preferences, including withdrawing or modifying your consent to non-essential cookies, by visiting our Cookie Preference Centre at https://www.finopoli.com/cookie-preferences. You may also manage or disable cookies through your browser settings. However, if you disable or delete cookies, some features of the Platform may not function properly, and you may be required to re-enter your login credentials.

For more information on the cookies we use and your choices, please refer to our Cookie Policy.

1. Access to Personal Data

Access to Personal Data is restricted to employees, contractors, and authorised personnel of the Company who require such access on a need-to-know basis for the purpose of providing, operating, maintaining, developing, or improving the Platform and its services.

All such personnel are bound by confidentiality obligations and are permitted to access Personal Data only to the extent necessary for their respective functions.

2. General Principle of Non-Disclosure

The Company does not sell or rent Personal Data.

We do not share Personal Data with third parties except in accordance with this Privacy Policy, including where required for service delivery, legal compliance, or with your consent.

3. Service Providers and Partners

We may share Personal Data with trusted third-party service providers engaged by Company to perform functions on our behalf, including cloud hosting, analytics, communications and other technology support services.

Such service providers process Personal Data strictly in accordance with our instructions and are subject to applicable confidentiality and data protection obligations and are not permitted to use or disclose the information for their own independent purposes. The Company ensures that appropriate contractual arrangements are in place with such service providers before any Personal Data is shared with them.

4. Discipline Score

The Company shall not disclose or make available any individual or identifiable discipline score generated through your use of the Platform to any third party, advertiser, financial institution or partner for such third party's own purposes.

The Company may use aggregated or anonymised insights that do not identify any individual for research, product improvement or institutional reporting.

5. Legal and Regulatory Disclosures

We may disclose Personal Data where necessary to:

comply with Applicable Law, regulation, legal process, or court order;
enforce our rights, terms, or policies;
investigate, prevent, or address fraud, security incidents, or other illegal or harmful activities; or
protect the rights, property, or safety of Company, its users, or the public.

6. Business Transfers

In the event of a merger, acquisition, restructuring, reorganisation, or sale of assets, Personal Data may be transferred to the relevant third party as part of such transaction, subject to appropriate safeguards and continued protection of Personal Data.

7. Cross Border Transfer

The Company may transfer the Personal Data outside the territory of India for the purposes set out in this Privacy Policy. Any such transfer shall be subject to such requirements or restrictions as may be specified by the Central Government from time to time under Applicable Law.

USER RIGHTS

Subject to Applicable Law, you may have certain rights in relation to your Personal Data processed by the Company:

to obtain information regarding your Personal Data processed by the Company;
to request the correction, completion, updating or erasure of your Personal Data;
to request information regarding the broad factors considered in generating any discipline score relating to you and to request correction of inaccurate Personal Data used in generating such information, provided that the proprietary methodology used by the Company shall not be disclosed.
where the processing of your Personal Data is based on your consent, to withdraw such consent at any time through the mechanism made available on the Platform or by contacting the Company’s Grievance Officer, without affecting the lawfulness of processing carried out prior to such withdrawal;
to raise a grievance regarding the processing of your Personal Data by contacting the Company's Grievance Officer in accordance with this Privacy Policy; and
to nominate any other individual who shall, in the event of your death or incapacity, exercise your rights under the Digital Personal Data Protection Act, 2023 in the manner prescribed under Applicable Law.

GRIEVANCE REDRESSAL:

If you have any grievance or complaint regarding the collection, use, processing, disclosure or handling of your Personal Data, or wish to exercise your rights under Applicable Law, you may contact the Grievance Officer at:

Grievance Officer: Krunal Nilesh Sheth

Email: grievance@finopoli.com

Address: 101, Aaradhya Swastik, Plot No. 373, 6th Rd, Near Sandu Garden, Chembur East, Mumbai, Maharashtra, 400071.

The Company shall acknowledge your grievance promptly and endeavour to resolve it as expeditiously as possible, and in any event within 90 (ninety) days from the date of its receipt.

If you are not satisfied with the resolution of your grievance, or if your grievance remains unresolved within the aforesaid period, you may seek such remedies as are available under the Digital Personal Data Protection Act, 2023, including approaching the Data Protection Board of India, in accordance with Applicable Law.

RETENTION OF PERSONAL DATA

Your Personal Data is retained by the Company only for as long as your account remains active, and thereafter for a period of 12 (twelve) months following account closure, or for such longer period as may be required to comply with applicable legal, regulatory, contractual, or statutory obligations. Where Personal Data is no longer required for such purposes, it will either be securely deleted, anonymised, or retained in an archived form only to the extent required under Applicable Law.

Any individual or identifiable discipline score associated with a user account shall be retained only for the same period as the associated Personal Data. Upon closure or deletion of the user’s account, such discipline score shall, subject to applicable legal, regulatory, or contractual retention requirements, be securely deleted or anonymised in accordance with this Privacy Policy.

CONFIDENTIALITY AND SECURITY

The security and confidentiality of your Personal Data is important to the Company. We implement appropriate technical, organisational, administrative safeguards to protect Personal Data against unauthorised access, loss, misuse, alteration, or disclosure. Such safeguards include, where appropriate, encryption, obfuscation, masking, access controls, maintenance of logs, and other reasonable security measures in accordance with Applicable Law.

The Company periodically reviews and updates its security practices to ensure the continued protection of Personal Data. While the Company endeavours to protect Personal Data using appropriate safeguards, no method of transmission over the internet or electronic storage is completely secure, and accordingly, the Company cannot guarantee absolute security.

PERSONAL DATA BREACH

In the event of a Personal Data breach affecting your Personal Data, the Company will:

take appropriate steps to contain, investigate and mitigate the effects of the Personal Data breach;
notify you of the Personal Data breach in accordance with Applicable Law;
notify the Data Protection Board of India, including by making the initial notification upon becoming aware of the Personal Data breach and submitting the prescribed detailed report within 72 (seventy-two) hours or such extended period as may be permitted under Applicable Law; and
take appropriate remedial measures to prevent the recurrence of such Personal Data breach.

CHANGES TO THIS PRIVACY POLICY

The Company reserves the right to update, change or modify this Privacy Policy at any time. Where any changes to this Privacy Policy are material, the Company will notify you on the Platform for a reasonable period of time following such update or by sending an email to the email address associated with your user account. The updated Privacy Policy shall specify the revised version number and effective date.

You are encouraged to review this Privacy Policy periodically to remain informed of any updates.

GOVERNING LAW

The governing law and dispute resolution applicable to this Privacy Policy shall be as set out in the Terms of Use governing the Platform.

HOW YOU MAY CONTACT US:

If you have any questions regarding this Privacy Policy or the processing of your Personal Data, or wish to contact the Company in relation to your Personal Data, you may contact us at:

ADORN GLOBAL PRIVATE LIMITED