Most Important Terms & Conditions

1. Why You Are Reading This

This document sets out the Most Important Terms and Conditions (“MITC”) of the research services provided by Devesh Varshney, sole proprietor of TruePrice (“Research Analyst”, “we”, “us”), through trueprice.pro (the “Platform”).

It is published in compliance with the SEBI Circular dated 17 February 2025 on “Most Important Terms and Conditions (MITC) for Research Analysts”, the SEBI (Research Analysts) Regulations, 2014, and the standards issued by the Industry Standards Forum (ISF) in consultation with the Research Analyst Administration and Supervisory Body (RAASB). The MITC is intended to give you a clear, concise summary of the most important terms you should know before subscribing to or using our research services. It is in addition to, and does not replace, our full Terms of Use, Privacy Policy, Research Disclosures, Refund & Cancellation Policy, and Grievance Redressal Policy.

2. About The Research Analyst

3. Services Provided

Under our SEBI Research Analyst registration, we provide:

• Equity-valuation research for securities listed on the National Stock Exchange of India (NSE) and BSE Limited, in the form of Discounted Cash Flow (DCF) intrinsic-value research, Reverse DCF, Relative Valuation, Sum-of-the-Parts (SOTP), and (for banks / insurers) Excess-Returns / Residual-Income models;
• Earnings, guidance, and disclosure summaries derived from public filings;
• Watchlists, screeners, and a portfolio review feature that applies our valuation models to holdings you upload via Portfolio Sync.

Research outputs reflect the independent professional opinion of the Research Analyst as of the date of publication and are based solely on publicly available information.

4. Mandatory SEBI Disclosure — No Trade Execution

The terms and conditions and the consent thereon are for the research services provided by the Research Analyst and the Research Analyst cannot execute / carry out any trade (purchase / sell transaction) on behalf of the client.

We do not, and will not, accept money, securities, instructions, or authority to place or execute any trade on your behalf. We do not offer portfolio management, broking, or distribution services. Trade execution remains entirely your decision and your action, placed through your own broker.

5. Nature Of Research; No Personalised Advice

Research published on TruePrice is general in nature. It does not constitute personalised investment advice and does not consider your individual financial circumstances, investment objectives, risk tolerance, tax position, or suitability. Nothing on the Platform should be construed as a solicitation to buy, sell, or hold any security, or as a guarantee of returns. Past performance is not an indicator of future results.

Standard regulatory disclaimer: Registration granted by SEBI, membership of any administrative body of the Research Analyst Administration and Supervisory Body (RAASB), and certification from the National Institute of Securities Markets (NISM) in no way guarantee performance of the Research Analyst or provide any assurance of returns to investors.

6. Fees, Payment, And Modes Of Charging

• Pricing. Fees are charged per the price plans displayed on the Platform at checkout: Per-Stock Credits, Subscription, or Portfolio Review pack.
• Currency & tax. All fees are in Indian Rupees (INR), inclusive of applicable Goods and Services Tax (GST). The total amount payable, with the tax breakup, is shown before you confirm payment, in line with Rule 4(3) of the Consumer Protection (E-Commerce) Rules, 2020.
• Payment aggregator. Payments are processed by Cashfree Payments India Private Limited, an RBI-authorised Payment Aggregator. We never receive your card / UPI / netbanking credentials.
• Mode of receipt. Fees are received only via the Platform's checkout flow through the registered payment aggregator. We do not accept cash, bank transfers to personal accounts, gift vouchers, or any other off-Platform mode for research services.
• Maximum permissible fees. The fees we charge are within the maximum permissible fees prescribed under SEBI's Research Analyst framework where applicable.

For cancellation and refund rules, see our Refund & Cancellation Policy.

7. AI / Technology Disclosure

In compliance with the MITC requirement to disclose the extent of artificial-intelligence usage in research services, we disclose:

• We use commercial large-language-model APIs (Anthropic Claude and OpenAI) strictly as tooling to extract and structure data from publicly available documents (annual reports, earnings transcripts, exchange filings) and to parse user-uploaded portfolio screenshots.
• The valuation models on the Platform (DCF, Reverse DCF, Relative Valuation, SOTP, Excess-Returns) are rule-based and deterministic. They are not generative; they produce a numeric output from defined inputs and assumptions disclosed in each Research Report.
• We use AI providers under commercial / enterprise terms which contractually prohibit them from using our inputs or outputs to train their models.
• AI-extracted figures are validated against deterministic rules and cross-references (filing-level totals, prior-period continuity, accounting identities) before being used in valuation models.
• The Research Analyst remains solely responsible for the research output, methodology, and the conclusions drawn from any AI-assisted extraction, including for the security and confidentiality of any client information processed using AI tooling.

8. Conflict Of Interest

The Research Analyst certifies, in respect of each Research Report, that he does not hold any financial interest in the covered securities at the time of publication except where such interest is separately and explicitly disclosed within the report; that he has not received any compensation or benefit from the issuer; and that no part of his compensation is linked to the views expressed. See our full Research Disclosures.

9. Recordkeeping & Confidentiality

We maintain records of research reports, supporting analysis, disclosures, your KYC / contact details, payment records, and our correspondence with you, for the periods prescribed under the SEBI (Research Analysts) Regulations, 2014 (typically 5 years) and the Income-tax Act, 1961 (typically 8 years for transaction records). Your personal data is handled per our Privacy Policy.

10. Termination & Suspension

You may stop using the research services at any time by cancelling your Subscription, ceasing to redeem Credits, or deleting your account. We may suspend or terminate access for violation of our Terms of Use or our Acceptable Use Policy, for breach of law, or where required by SEBI / a court / a regulator.

11. Grievance Redressal & Escalation

Step 1. Write to support@trueprice.pro. Acknowledgement within 48 hours; resolution within 30 days.

Step 2. If not satisfied, escalate to SEBI through SCORES at scores.sebi.gov.in.

Step 3. For unresolved monetary disputes, use SEBI's Online Dispute Resolution platform at smartodr.in in line with the SEBI ODR circular dated 31 July 2023 and subsequent circulars. Full details in our Grievance Redressal Policy.

12. Updates To MITC

We may update this MITC from time to time, including following any update to the SEBI MITC standardised text. Material changes will be notified to existing Users on a preservable medium (email and / or WhatsApp registered with us) and posted on the Platform with the updated “Last updated” date. Continued use of the research services after the effective date of an update means you accept the updated MITC.

13. Acknowledgement

By signing up for or using our research services, you acknowledge that you have read, understood, and agreed to this MITC together with our Terms of Use, Privacy Policy, Research Disclosures, Refund & Cancellation Policy, Acceptable Use Policy, Cookie Policy, Regulatory page, and Grievance Redressal Policy.