Company, Compliance and Policies

About FinKasturi Nivesh, our regulatory disclosures and our policies, all on one page. Use the contents list to jump to a section.

Company

About Us

About Company

FinKasturi Nivesh Pvt. Ltd.

Four colleagues in business attire reviewing documents together at a table

FinKasturi Nivesh Private Limited is a SEBI Registered Investment Advisor (SEBI Registration No. INA000014128) based in Mumbai. We offer Investment Advisory services to individual and institutional clients. We work closely with investors to maximize yield within the defined investment objective.

With deep experience in the capital market and capabilities to deal with a range of asset classes, we aspire to build an ecosystem of Trust, Integrity, Transparency and Sustainable success while complying with all regulatory requirements to create a unique and enjoyable experience for our clients.

Call Us Now: +91 77109 16346

Our Team

Management Team

  • Portrait of Dr. Nirakar Pradhan

    Dr. Nirakar Pradhan

    Founder - Director – CFA, FRM, CFP

    LinkedIn profile of Dr. Nirakar Pradhan (opens in new tab)

    More about Dr. Nirakar Pradhan

    30+ years of experience in financial sector encompassing Banks, Insurance, Treasury, Investment & Portfolio Management

    Successfully accomplished role in enterprises like

    • Generali Group, Paris (Head of Investment Control)
    • SBI, Frankfurt (Head of Investment)
    • Future Generali India (Chief Investment Officer)
    • SBI, DHFI, Mumbai (Group Head - Treasury)

    Qualifications

    • Chartered Financial Analyst (CFA) from CFA Institute, USA.
    • Financial Risk Management (FRM) from GARP, USA.
    • PhD in Business Administration from Utkal University, India.
    • Certified Financial Planner (CFP) from FPSB, USA
  • Portrait of Ashwin Albert Dsouza

    Ashwin Albert Dsouza

    Director & CEO

    LinkedIn profile of Ashwin Albert Dsouza (opens in new tab)

    More about Ashwin Albert Dsouza

    20+ years of experience in Information Technology & Financial sector

    Successfully accomplished various Technology & Enterprise Architecture roles

    18 years with Infosys Limited

    Qualifications

    • National Institute Of Securities Markets, PGP (Securities Markets) - Portfolio Management
    • National Institute Of Securities Markets, PGP (Securities Markets) - Investment Advisory
    • Mumbai University, B.Engg (Mechanical)
  • Portrait of Nivel Monteiro

    Nivel Monteiro

    Vice President (Operations)

    LinkedIn profile of Nivel Monteiro (opens in new tab)

    More about Nivel Monteiro

    Nivel Monteiro, Vice President (Operations) at FinKasturi Nivesh Pvt Ltd, is a Finance & Accounting professional.

    Previous roles

    • Bombay Oxygen Corporation Ltd.
    • RNS Associates, Accounts and Tax Executive
    • American Eye & Retina Center in various roles in Accounts, Audit etc.
    • At FinKasturi, he is responsible for key verticals like Finance, Accounts and Operations

    Qualifications

    • Dublin Business School, Master in Business Administration
    • St. Aloysius (Deemed to be University), BBM
  • Portrait of Jatin Makwana

    Jatin Makwana

    Associate Vice President

    LinkedIn profile of Jatin Makwana (opens in new tab)

  • Portrait of Dipayan Sahu

    Dipayan Sahu

    Associate Vice President

    LinkedIn profile of Dipayan Sahu (opens in new tab)

Finkasturi

Our Core

We provide wealth management services to Individual and Corporate Investors for wealth maximization.

  • Wealth Preservation & Creation

    As a process-driven organization, we believe in creating wealth for our clients during optimistic market scenarios while minimizing erosion of portfolio value during market downturn.

  • Trust & Integrity

    Trust and Integrity act as two pillars for us as we uphold transparency in our business practice to establish a long-term partnership with the client.

  • Following a Prudent Operational Practice

    As we work towards achieving high standards in our service and client satisfaction, we strive to bring prudent advice for the client to achieve their financial goals.

Research Based Advisory Solutions. Investment Advisory Backed with Holistic Research By Experts.

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Services

Our services

  • Financial Planning

    A structured plan for your income, goals and risks, built around your own situation. It can cover:

    • Income and expense planning
    • Investment planning
    • Insurance planning
    • Tax planning
    • Loan or debt planning
    • Retirement planning
    • Salary optimization
    • Regular income planning
  • Estate Planning

    Planning how your assets are managed and passed on, so that your family has clarity. It can cover:

    • Creation of a will or trust
    • Beneficiary designation
    • Asset distribution
    • Centralizing all data related to your financial affairs
  • Investments

    Investment advice matched to your goals and risk profile, across products such as:

    • Mutual funds
    • Exchange traded funds (ETFs)
    • Bonds
    • Other investment products
  • Stock Portfolio: Kasturi Equity Opportunities Portfolio (KEOP)

    Our stock portfolio service, also called KEOP, the Kasturi Equity Opportunities Portfolio. Investments in securities markets are subject to market risks, and returns are not assured.

Our Process

Advisory Process

Our in-house process-driven method works to provide a prudent solution to the client within the risk parameters while following all regulatory and compliance requirements.

Colleagues discussing a plan on a whiteboard in a bright office
  1. Plan & Suitability Analysis
  2. Risk profiling, Objective Setting & Investment Policy
  3. Asset Allocation
  4. Select the appropriate investment opportunity
  5. Reporting & Review

Disclaimer

  • Investment in securities market are subject to market risks. Read all the related documents carefully before investing.
  • Registration granted by SEBI, membership of BSE (in case of IAs) and certification from NISM in no way guarantee performance of the intermediary or provide any assurance of returns to investors.

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Contact Us

Smiling adviser on a phone call at a desk with a laptop

Send us a message!

Reach out to our team of experts using this form. Fields marked required must be completed.

Type of message (required)

When you choose Send message, WhatsApp opens with your details already written, ready to send to us. You can then also email the same message. Nothing is sent until you press send in WhatsApp or in your email app.

Address

Working Hours

Mon to Fri : 10 am to 05 pm IST

Get Directions (opens in new tab)

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FAQs

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Media

FinKasturi in the news.

Media coverage reflects the views of the publication and interviewees. References to past returns are not an indication of future performance. Investments in securities market are subject to market risks.

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Social Media

FinKasturi Nivesh Private Limited is a SEBI Registered Investment Advisor (SEBI Registration No. INA000014128) based in Mumbai. Follow us on:

Address:

302, Sunset Heights, Kanjurbhatwadi, Prabhadevi, Mumbai, 400030

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Compliance

Complaint Status

Data for the month ending - October 2026

Complaint data for the month ending October 2026
Sr. No.Received FromPending Last MonthReceivedResolvedTotal PendingPending > 3MAverage Resolution (Days)
1Direct000000
2SEBI (Scores)000000
3Others000000

Trend of Monthly Disposal of Complaints

Trend of monthly disposal of complaints
Sr. No.MonthCarried Forward from Previous MonthReceivedResolvedPending
1Sep 30, 20260000
2Aug 31, 20260000
3Jul 31, 20260000
4Jun 30, 20260000
5May 31, 20260000
6Apr 30, 20260000
7Mar 31, 20260000
8Feb 28, 20260000
9Jan 31, 20260000
10Dec 31, 20250000
11Nov 30, 20250000
12Oct 31, 20250000

Trend of Annual Disposal of Complaints

Trend of annual disposal of complaints
Sr. No.YearCarried Forward from Previous YearReceivedResolvedPending
120260000
220250000
320240000
420230000
520220000
620210000

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Grievance Redressal

1. Investor Complaint & Grievance Mechanism

Mode of filing the complaint with Investment Adviser

In case of any grievance or complaint, an investor may approach the Investment Adviser who shall strive to redress the grievance immediately, but not later than 21 days from receipt. Log your complaint by using our contact form.

Details of designation

Grievance contact details
Details of designationContact Person NameAddressMobileEmailWorking hours
Customer CareNivel Monteiro#4-71/7, Adam Kudru, Permannur, Mangalore – 575017 Karnataka7666985008Nivel.Monteiro@finkasturi.com10:00 AM to 5:00 PM
Head of Customer Care, Principal OfficerNirakar Pradhan302, Sunset Heights, Hatiskar Marg, Prabhadevi, Mumbai-4000309833999267Nirakar@finkasturi.com10:00 AM to 5:00 PM
Compliance Officer, CEOAshwin Albert Dsouza1001 Proximus Apartments, Ashoknagar Road, Urwa Stores, Mangalore 5750069632165857Ashwin.dsouza@finkasturi.com10:00 AM to 5:00 PM

Mode of filing the complaint on SCORES or with Investment Adviser Administration and Supervisory Body (IAASB)

i. SCORES 2.0 – A web-based centralized grievance redressal system of SEBI for facilitating effective grievance redressal in a time-bound manner. Visit: SCORES (opens in new tab).

Two-level review process for complaints against an Investment Adviser:

  1. First review by the designated body (IAASB)
  2. Second review by SEBI

ii. Email – Investors may also email their grievance to the designated email ID of IAASB.

2. Filing Complaints on SMARTODR Platform

If the Investor is not satisfied with the resolution provided by the Market Participants, they may file the complaint or grievance on the SMARTODR platform (opens in new tab) for resolution through online conciliation or arbitration. Refer ODR Master Circular (opens in new tab).

3. Filing Physical Complaints

Office of Investor Assistance and Education, Securities and Exchange Board of India, SEBI Bhavan, Plot No. C4-A, ā€˜G’ Block, Bandra-Kurla Complex, Bandra (E), Mumbai - 400 051.

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Disclosures

Mandatory disclosure by SEBI

“Investments in securities market are subject to market risks. Read all the related documents carefully before investing.”

“Registration granted by SEBI, membership of BSE and certification from NISM in no way guarantee performance of the intermediary or provide any assurance of returns to investors.”

“We cannot promise or guarantee of assured risk-free return to the investors. We cannot imply any assured returns or minimum returns or target return or percentage accuracy or service provision till achievement of target returns or any other nomenclature that gives the impression to the client that the investment advice/recommendation of research report is risk-free and/or not susceptible to market risks and/or that it can generate returns with any level of assurance.”

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Investor Charter

FinKasturi Nivesh Private Limited · CIN: U65999MH2018PTC317677

Download the tagged PDF version (PDF, 4 pages)

A. Vision and Mission Statements for investors

  • 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.

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

  • To enter into an agreement with the client providing all details including fee details, aspects 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 conduct audit annually.
  • To disclose the status of complaints on its website.
  • To disclose the name, proprietor name, type of registration, registration number, validity, complete address with telephone numbers and associated SEBI Office details (i.e. Head office/ regional/ local Office) on 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.
  • To ensure that all advertisements are in adherence to the provisions of the Advertisement Code for Investment Advisers.
  • Not to discriminate in terms of services provided, among clients opting for same/similar products/services offered by investment adviser.

C. 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 disclose any conflict of interest of the investment advisory activities with any other activities of the investment adviser.
  • To disclose the extent of use of Artificial Intelligence tools in providing investment advisory services.

Advice and conduct

  • To provide investment advice to the client based on the risk-profiling of the clients and suitability of the client.
  • To treat all advisory clients with honesty and integrity.
  • To make adequate disclosure to the investor of all material facts such as risks, obligations, costs, etc. relating to the products or securities advised by the adviser.
  • To provide clear guidance and adequate caution notice to clients when providing investment advice for dealing in complex and high-risk financial products/services.
  • To ensure confidentiality of information shared by clients unless such information is required to be provided in furtherance of discharging legal obligations or a client has provided specific consent to share such information.
  • To disclose the timelines for the various services provided by the investment adviser to clients and ensure adherence to the said timelines.

D. Details of grievance redressal mechanism and how to access it

1. Investor can lodge complaint/grievance against Investment Adviser in the following ways

Mode of filing the complaint with investment adviser

In case of any grievance / complaint, an investor may approach the concerned Investment Adviser who shall strive to redress the grievance immediately, but not later than 21 days of the receipt of the grievance.

Mode of filing the complaint on SCORES or with Investment Adviser Administration and Supervisory Body (IAASB)
  1. SCORES 2.0 (a web based centralized grievance redressal system of SEBI for facilitating effective grievance redressal in time-bound manner) (https://scores.sebi.gov.in). Two level review for complaint/grievance against investment adviser: the first review is done by the investment adviser and the second review is done by SEBI.
  2. Email to designated email ID of IAASB.

2. Online dispute resolution

If the Investor is not satisfied with the resolution provided by the Market Participants, then the Investor has the option to file the complaint/ grievance on SMARTODR platform for its resolution through online conciliation or arbitration.

3. Physical complaints

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

E. Rights of investors

  • Right to Privacy and Confidentiality
  • Right to Transparent Practices
  • Right to fair and Equitable Treatment
  • Right to Adequate Information
  • Right to Initial and Continuing Disclosure
    • Right to receive information about all the statutory and regulatory disclosures.
  • Right to Fair & True Advertisement
  • Right to Awareness about Service Parameters and Turnaround Times
  • Right to be informed of the timelines for each service
  • Right to be Heard and Satisfactory Grievance Redressal
  • Right to have timely redressal
  • Right to Suitability of the Financial Products
  • Right to Exit from Financial product or service in accordance with the terms of agreement with the investment adviser
  • Right to receive clear guidance and caution notice when dealing in Complex and High-Risk Financial Products and Services
  • Additional Rights to vulnerable consumers
    • Right to get access to services in a suitable manner even if differently abled
  • Right to provide feedback on the financial products and services used
  • Right against coercive, unfair, and one-sided clauses in financial agreements

F. Expectations from the investors (Responsibilities of investors)

Do's

  1. Always deal with SEBI registered Investment Advisers.
  2. Ensure that the Investment Adviser has a valid registration certificate.
  3. Check for SEBI registration number. Please refer to the list of all SEBI registered Investment Advisers which is available on SEBI website: SEBI list of registered Investment Advisers (opens in new tab)
  4. 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. You may make payment of advisory fees through Centralised Fee Collection Mechanism (CeFCoM) of IAASB if investment adviser has opted for the mechanism.
  5. 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.
  6. Ask all relevant questions and clear your doubts with your Investment Adviser before acting on advice.
  7. Assess the risk-return profile of the investment as well as the liquidity and safety aspects before making investments.
  8. 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.
  9. Be vigilant in your transactions.
  10. Approach the appropriate authorities for redressal of your doubts / grievances.
  11. Inform SEBI about Investment Advisers offering assured or guaranteed returns.
  12. Always be aware that you have the right to exit the service of an Investment Adviser.
  13. Always be aware that you have the right to seek clarifications and clear guidance on advice.
  14. Always be aware that you have the right to provide feedback to the Investment Adviser in respect of services received.
  15. Always be aware that you will not be bound by any clause, prescribed by the investment adviser, which is contravening any regulatory provisions.

Don'ts

  1. Don't fall for stock tips offered under the pretext of investment advice.
  2. Do not provide funds for investment to the Investment Adviser.
  3. 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.
  4. Don't fall prey to luring advertisements or market rumors.
  5. Avoid doing transactions only on the basis of phone calls or messages from any Investment adviser or its representatives.
  6. Don't take decisions just because of repeated messages and calls by Investment Advisers.
  7. Do not fall prey to limited period discount or other incentive, gifts, etc. offered by Investment advisers.
  8. Don't rush into making investments that do not match your risk taking appetite and investment goals.
  9. Do not share login credential and password of your trading, demat or bank accounts with the Investment Adviser.

Regd. Office: 302, Sunset Heights, Kanjurbhatwadi, Eknath Hatiskar Marg, Prabhadevi, Mumbai, Maharashtra, India, 400030, email id: care@finkasturi.com

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MITC (Most Important Terms and Conditions)

FinKasturi Nivesh Private Limited · CIN: U65999MH2018PTC317677

Download the tagged PDF version (PDF, 3 pages)

[Forming part of the Investment Advisory Agreement]

In accordance to SEBI Circular No. SEBI/HO/MIRSD/MIRSD-PoD/P/CIR/2025/19 dt. February 17, 2025 and further updated by SEBI Circular No. SEBI/HO/MIRSD/MIRSD-PoD/P/CIR/2025/48 dt. April 2, 2025.

  1. The Investment Adviser (IA) shall only accept payments towards its fees for Investment Advisory Services and is not permitted to accept funds or securities in its account on the client's behalf.
  2. The IA does not guarantee returns, accuracy, or risk-free investments. All advice is subject to market risks, and there is no assurance of any returns or profits.
  3. Any assured/guaranteed/fixed returns schemes or any other schemes of similar nature are prohibited by law. No scheme of this nature shall be offered to the client by the IA.
  4. Investment advice, only related to securities shall fall under the purview of SEBI. In case of any services offered by IA related to products/services not under the purview of SEBI, IA shall make disclosure to the client and take appropriate declaration and undertaking from the client that such products/services and the services of IA in respect of such products/services do not come under regulatory purview of SEBI and that no recourse is available to the client with SEBI for grievances related to such products/services or services of IA in respect of such products/services.
  5. This agreement is for the investment advisory services provided by the IA and IA cannot execute/carry out any trade (purchase/sell transaction) on behalf of the client without his/her/its specific and positive consent on every trade. Thus, the client is advised not to permit IA to execute any trade on his/her/its behalf without explicit consent.
  6. The fee charged by IA to the client will be subject to the maximum of amount prescribed by SEBI/Investment Adviser Administration and Supervisory Body (IAASB) from time to time (applicable only for Individual and HUF Clients).

    Note:

    1. The current fee limit under Fixed Fee mode is Rs 1,51,000/- per annum per family of client. Under Assets under Advice (AUA) mode, maximum fee limit is 2.5 per cent of AUA per annum per family of client.
    2. The IA may change the fee mode at any time with the client's consent; however, the maximum fee limit in such cases shall be higher of fee limit under the fixed fee mode or 2.5 per cent of AUA per annum per family of client.
    3. The fee limits do not include statutory charges.
    4. The fee limits apply only for investment advice related to securities under purview of SEBI.
    5. The fee limits do not apply to a non-individual client / accredited investor.
  7. IA may charge fees in advance if agreed by the client. Such advance shall not exceed the period stipulated by SEBI; presently it is maximum one year. In case of pre-mature termination of the IA services by the client or the IA, the client shall be entitled to seek refund of proportionate fees only for unexpired period. However, IA is entitled to retain a maximum breakage fee of not greater than one-quarter fee.

    Note: These fee related provisions do not apply to a non-individual client / accredited investor.

  8. Fees to IA may be paid by the client through any of the specified modes like cheque, online bank transfer, UPI, etc. Cash payment is not allowed. Optionally the client can make payments through Centralized Fee Collection Mechanism (CeFCoM), managed by BSE Limited (i.e. currently recognized IAASB).
  9. The IA is expected to know the client's financial details for providing services. Hence, the client is required to share the financial information (e.g. income, existing investments, liabilities, etc.) with the IA.
  10. The IA is required to carry out the client's risk profiling and suitability analysis before providing services and thereafter on an ongoing basis. The services provided will be in line with the assessed risk profile. IA shall also communicate the assessed risk profile to the client.
  11. As part of conflict of interest management, the client or the client's family members will not be provided any distribution services by IA or any of its group entity/ family members. IA shall, wherever available, advice direct plans (non-commission based) of products only.

    The IA shall endeavor to promptly inform the client of any conflict of interest that may affect the services being rendered to the client.

  12. For any grievances:

    Step 1: The client should first contact the IA using the details on its website or following contact details:

    Grievance contact details (Step 1)
    DesignationContact person nameAddressMobileEmailWorking hours
    Customer CareNivel Monteiro#4-71/7, Adam Kudru, Permannur, Mangalore - 575017 Karnataka7666985008Nivel.Monteiro@finkasturi.com10:00 AM to 5:00 PM
    Principal Officer, Head of Customer CareNirakar Pradhan302, Sunset Heights, Eknath Hatiskar Marg, Prabhadevi, Mumbai-4000309833999267Nirakar@finkasturi.com10:00 AM to 5:00 PM
    Compliance Officer, CEOAshwin Dsouza1001 Proximus Apartments, Ashoknagar Road, Urwa Stores, Mangalore 575006, Karnataka.9632165857Ashwin.dsouza@finkasturi.com10:00 AM to 5:00 PM

    Step 2: If the resolution provided by IA is unsatisfactory, the client can lodge grievances through SEBI's SCORES platform at www.scores.sebi.gov.in.

    Step 3: If the client remains dissatisfied with the outcome of the SCORES complaint, the client may consider the Online Dispute Resolution (ODR) through the Smart ODR portal at https://smartodr.in.

  13. The SEBI registration, enlistment with IAASB, and NISM certification do not guarantee the performance of IA or assure returns to the client.
  14. Clients are required to keep contact details, including email id and mobile number/s updated with the IA at all times.
  15. The IA shall never ask for the client's login credentials and OTPs for the client's Trading Account, Demat Account and Bank Account. Never share such information with anyone including IA.

Regd. Office: 302, Sunset Heights, Kanjurbhatwadi, Eknath Hatiskar Marg, Prabhadevi, Mumbai, Maharashtra, India, 400030, email id: care@finkasturi.com

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Action Taken Report, FY 2025-26

FinKasturi Nivesh Private Limited · CIN: U65999MH2018PTC317677

Download the tagged PDF version (PDF, 2 pages)

The original is a digitally signed PDF; this reproduction is not itself digitally signed.

Investment adviser details

Details of the Investment Adviser
ItemDetail
Name of Investment AdviserFinkasturi Nivesh Private Limited
SEBI Registration No.INA000014128
BSE Enlistment No.1643
Entity TypeCorporate body
Financial Year2025-2026

Findings and actions taken

Findings and actions taken, financial year 2025-2026
Sr. NoRegulationParticularsCompliance statusReason for non-complianceAuditor comments accepted (Yes/No)Action taken on adverse findings
1Regulation 7 And SEBI Master Circular HO/38/12/11(2)2026-MIRSD-POD/I/4300/2026 clause 1(v)Qualification and certification requirement. An individual investment adviser or a principal officer of a non-individual investment adviser registered as an investment adviser under these regulations and persons associated with investment advice shall have minimum qualification and certification requirements as mentioned in Regulation 7(1) and 7(2).Not-CompliedNISM was not valid during the period April 2025 to August 2025. The certification gap happened as company was going through a change in control process, a new PO was proposed for the role which was subsequently rejected by BSE, as PO was not meeting the expected criteria, and the freshly introduced NISM Series-XC renewal guidelines delayed the certification renewal process.YesThe gap in NISM Certifications was triggered by two significant changes, 1 Change of Management Control and SEBI waiver of PO from NISM XA XB exams with the introduction of X C Certificate. However, we have now put in place a compliance calendar for continuous monitoring to avoid recurrence of such gaps in future.
2SEBI Master Circular HO/38/12/11(2)2026-MIRSD-POD/I/4300/2026 clause 5 and (SEBI/HO/MIRSD2/DOR/CIR/P/2020/221 dated November 03, 2020)Advisory for Financial Sector Organizations regarding Software as a Service (SaaS) based solutions Compliance of the SEBI circular for Advisory for financial Sector Organizations regarding Software as a Service (SaaS) based solutions for half-yearly ended 31st March and 30th September.Not-CompliedIA has complied with the SaaS compliance and have undertakings from the service providers, It is to note that submission was on the portal was not made or the periodYesFinkasturi has put in a Compliance Calendar based reminder process on 1st Oct and 1st April each FY to avoid future instances. Also we will take screenshots of all BSE/SEBI submissions to retain proof of submission and not depend on portal records
3SEBI Master Circular HO/38/12/11(2)2026-MIRSD-POD/I/4300/2026 clause 31.1Other reporting requirements. Whether Undertaking on compliance of the advisory for Financial Sector Organizations regarding Software as a Service (SaaS) based solutions to be submitted half yearly.Not-CompliedIA has complied with the SaaS compliance and have undertakings from the service providers, It is to note that submission was on the portal was not made or the periodYesFinkasturi has put in a Compliance Calendar based reminder process on 1st Oct and 1st April each FY to avoid future instances. Also we will take screenshots of all BSE/SEBI submissions to retain proof of submission and not depend on portal records

Signature

Signature of IA / Partner / Director: Digitally signed by Ashwin Albert Dsouza. Date of digital signature: 28 September 2026, 21:00:15 IST (+05:30).

Date and Place: not stated in the original document.

Regd. Office: 302, Sunset Heights, Kanjurbhatwadi, Eknath Hatiskar Marg, Prabhadevi, Mumbai, Maharashtra, India, 400030, email id: care@finkasturi.com

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Policies

Privacy Policy

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.

We use Your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions.

The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

  • You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.
  • Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to FInkasturi Nivesh Private Limited, 302, Sunset Heights, Kanjurbhatwadi, Prabhadevi, Mumbai, India, 400030.
  • Affiliate means an entity that controls, is controlled by or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
  • Account means a unique account created for You to access our Service or parts of our Service.
  • Website refers to Finkasturi, accessible from www.finkasturi.com
  • Service refers to the Website.
  • Country refers to: Maharashtra, India
  • Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.
  • Third-party Social Media Service refers to any website or any social network website through which a User can log in or create an account to use the Service.
  • Personal Data is any information that relates to an identified or identifiable individual.
  • Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.
  • Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

  • Email address
  • First name and last name
  • Phone number
  • Address, State, Postal code, City
  • Usage Data
Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service.

You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service.

Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close your web browser.

We use both session and persistent Cookies for the purposes set out below:

  • Necessary / Essential Cookies Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.
  • Cookies Policy / Notice Acceptance Cookies Purpose: These Cookies identify if users have accepted the use of cookies on the Website.
  • Functionality Cookies Purpose: These Cookies allow us to remember choices You make when You use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website.

For more information about the cookies we use and your choices regarding cookies, please visit our Cookies Policy.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

  • To provide and maintain our Service, including to monitor the usage of our Service.
  • To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
  • For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.
  • To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
  • To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
  • To manage Your requests: To attend and manage Your requests to Us.

We may share your personal information in the following situations:

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. We do not share and will never share any confidential data such as user's investment details, contents of user's gmail, bank details, transaction details, income or any other sensitive details with these third party analytics service providers.

The Prevention of Money Laundering Act 2002 and SEBI (Investment Advisors) Regulations, 2013 require record retention for a period of up to 5 years post the deletion of your account. In the event of the pendency of any legal/ regulatory proceeding or receipt of any legal and/or regulatory direction to that effect, we may retain your information for a longer period.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

Transfer of Your Personal Data

We only transfer the data to others if necessary to provide or improve user-facing features that are prominent in the requesting application's user interface. We may also transfer data as necessary to comply with applicable law or as part of a merger, acquisition, or sale of assets with notice to users.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

Disclosure of Your Personal Data

Business Transactions

finkasturi is a investment advisory firm that provides financial advisory services to you. We receive information you knowingly provide to finkasturi or with your explicit consent. This information enables you to organise and aggregate your financial information in one place on finkasturi Services. The information also enables finkasturi Application to help you assess your risk profile from time to time and create your investment plans and make decisions on investments & execute purchase and sale of investment products and also enables you to manage your taxation.

Law enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

  • Comply with a legal obligation
  • Protect and defend the rights or property of the Company
  • Prevent or investigate possible wrongdoing in connection with the Service
  • Protect the personal safety of Users of the Service or the public
  • Protect against legal liability

Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

Children's Privacy

Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.

We also may limit how We collect, use, and store some of the information of Users between 13 and 18 years old. In some cases, this means We will be unable to provide certain functionality of the Service to these users.

If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent's consent before We collect and use that information.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Changes to this Privacy Policy

We may update our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, You can contact us:

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Terms and Conditions

Introduction

These Terms & Conditions govern the use of the online payment facility provided by FinKasturi Nivesh Private Limited (hereinafter referred to as "the Company") for the collection of fees for Investment Advisory services. By making a payment through this platform, you agree to the terms set forth below.

Service Scope

  • The payment made is towards the Investment Advisory services provided by the Company, as per the agreement signed between the client and the Company.
  • The Company reserves the right to modify the terms of its services in compliance with SEBI guidelines.

Payment Confirmation

  • Upon successful payment, a confirmation email and receipt will be sent to your registered email address.
  • Clients are advised to verify the payment details and report any discrepancies immediately.

Fee Structure

Fees are charged in advance for the agreed-upon term of the Investment Advisory services.

Non-Compliance and Termination

The Company reserves the right to suspend or terminate services in case of non-payment or violation of agreed terms.

Regulatory Compliance

The Company operates in compliance with SEBI regulations and other applicable laws in India.

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Refund and Cancellation Policy

Refund Policy

  • Fees paid in advance are non-refundable.
  • In cases where services cannot be delivered due to reasons attributable to the Company, a pro-rata refund may be issued at the Company's sole discretion.

Cancellation Policy

  • Clients may choose to discontinue services by notifying us in writing at least 30 days before the expiration of the current term.
  • Advance fees paid for the term will not be refunded for mid-term cancellations initiated by the client.

Force Majeure

The Company shall not be held responsible for delays or cancellations due to events beyond its control, including but not limited to natural disasters, regulatory changes, or technical failures.

Dispute Resolution

Any disputes regarding payments or refunds will be addressed in accordance with Indian laws and SEBI regulations.

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Accessibility Statement

FinKasturi Nivesh Private Limited is committed to making its website usable by everyone, including persons with disabilities, in line with the Rights of Persons with Disabilities Act, 2016 and SEBI's digital accessibility circulars for regulated entities.

Standard

This website is designed to conform to the Web Content Accessibility Guidelines (WCAG) 2.2 Level AA. Conformance has not yet been verified by an independent audit.

Audit status

[To be completed after the IAAP-certified auditor's report: auditor name, certification, audit date and report reference.]

Feedback

If you face any difficulty using this website, write to care@finkasturi.com or call +91 77109 16346 (Mon to Fri, 10 am to 5 pm IST). You may also raise an accessibility complaint through our grievance process or SCORES (opens in new tab).

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