Contents

1. Overview 2. Account & Registration 3. Service Description 4. Plans & Billing 5. Acceptable Use 6. Intellectual Property 7. Disclaimer 8. Liability 9. Termination 10. Changes 11. Governing Law 12. Contact

Legal Document

Terms of Service

📅 Effective: 1 May 2026 🔄 Last updated: 13 May 2026 🇮🇳 Portivo Technologies Pvt. Ltd.

Summary (Plain English): Portivo is a decision-support tool. We help you track and enforce your own investing rules. We do not provide investment advice, execute trades, or access your broker. You are always in control of your money.

1. Overview

These Terms of Service ("Terms") govern your access to and use of Portivo, operated by Portivo Technologies Private Limited ("Portivo", "we", "us", or "our"), including our website at portivoai.com and all related applications, features, and services (collectively, the "Service").

By creating an account or using any part of the Service, you agree to be bound by these Terms. If you do not agree to these Terms, do not use the Service.

Portivo is a portfolio discipline and decision-support tool. We are not a financial advisor, investment advisor, broker, or SEBI-registered entity. Nothing on Portivo constitutes investment advice.

2. Account & Registration

2.1 Eligibility

You must be at least 18 years old to create an account. By registering, you represent that you meet this requirement and that all information you provide is accurate and complete.

2.2 Account Security

You are responsible for maintaining the confidentiality of your login credentials. You must notify us immediately at hello@portivoai.com if you suspect any unauthorised access to your account. We are not liable for losses resulting from your failure to protect your credentials.

2.3 Account Information

You agree to keep your email address and other account information current and accurate. We use your email address to send important service notifications, billing information, and your weekly Dhruv reports.

2.4 One Account Per User

Each person may maintain only one Portivo account. Creating multiple accounts to circumvent plan limits is a violation of these Terms and may result in account suspension.

3. Service Description

Portivo provides the following core services:

Portfolio Tracking: Monitor your investment positions across multiple brokers via CSV import or manual entry.
Rule Enforcement: Set personal portfolio rules (position limits, stop-loss levels, take-profit targets) and receive alerts when rules are approached or breached.
AI Analysis (Dhruv): AI-powered analysis of your portfolio patterns, discipline scoring, and behavioural insights. All AI output is informational only.
Screeners: Stock screening tools filtered to your current portfolio rules and remaining budget.
Alerts: Notifications via email, Telegram, and WhatsApp (plan-dependent) for rule breaches and signals.
Algo Bots: Automated monitoring bots that send alerts (Power plan). Bots do not execute trades.

Important: Portivo does not execute trades, access your broker account, or hold your funds. All investing decisions remain entirely yours. Portivo is a decision-support tool, not an investment platform.

3.1 Broker Data

You import portfolio data to Portivo via CSV export from your broker or via API (Power plan). Portivo does not have direct access to your broker account and cannot initiate any transactions on your behalf.

3.2 AI Output Disclaimer

Dhruv AI Advisor provides analysis based on your portfolio data and general market information. AI output is for informational purposes only. Do not make investment decisions based solely on AI output. Portivo AI is not a SEBI-registered research analyst.

4. Plans & Billing

4.1 Plan Tiers

Plan	Price	Key Limits
Starter	₹0 / Free forever	5 positions, basic tracking, 3 AI scores/month
Pro	₹199/month or ₹1,990/year	Unlimited positions, full rule enforcement, Dhruv AI, Telegram
Power	₹499/month or ₹4,990/year	Everything in Pro + Algo Bots, auto broker sync, WhatsApp, API access

4.2 Free Trial

New Pro subscribers receive a 14-day free trial. Your payment method will not be charged until the trial period ends. You may cancel at any time before the trial ends with no charge.

4.3 Billing

Paid subscriptions are billed in advance on a monthly or annual basis. All prices are in Indian Rupees (INR) and inclusive of applicable taxes. Payments are processed securely via Razorpay.

4.4 Cancellation & Refunds

You may cancel your subscription at any time from your account settings. Upon cancellation, you retain access to paid features until the end of your current billing period. We do not provide prorated refunds for partial months, except where required by applicable law.

If you experience a technical failure on our part that prevents you from accessing the Service for more than 48 consecutive hours, you may request a prorated refund for the affected period by emailing hello@portivoai.com.

4.5 Plan Changes

You may upgrade or downgrade your plan at any time. Upgrades take effect immediately. Downgrades take effect at the end of the current billing period.

5. Acceptable Use

You agree not to:

Use the Service for any unlawful purpose or in violation of any Indian or applicable laws
Attempt to reverse-engineer, decompile, or extract the source code of the Service
Use automated tools to scrape, extract, or collect data from the Service beyond your personal use
Share your account credentials with others or allow multiple users to access a single account
Use the API access (Power plan) in ways that violate our API terms or that place unreasonable load on our systems
Misrepresent your portfolio data or attempt to manipulate AI outputs through false data
Attempt to circumvent plan limits through technical means

6. Intellectual Property

The Portivo name, logo, brand, software, AI models, screener methodologies, and all related intellectual property are owned by Portivo Technologies Private Limited. You are granted a limited, non-exclusive, non-transferable licence to use the Service for your personal, non-commercial investing purposes only.

Your portfolio data and any data you upload remains yours. By uploading data to Portivo, you grant us a limited licence to process that data for the sole purpose of providing the Service to you. We do not claim ownership of your data.

7. Investment Disclaimer

NOT INVESTMENT ADVICE. All content on Portivo, including AI output from Dhruv, screener results, rule suggestions, discipline scores, and portfolio analysis is for informational and educational purposes only. It does not constitute investment advice, financial advice, trading advice, or any other form of advice. Portivo is not a SEBI-registered investment advisor or research analyst. Past performance indicators shown are not reliable indicators of future results. Always consult a qualified financial advisor before making investment decisions.

Portivo provides tools to help you follow your own self-defined rules. The rules themselves — and all investing decisions — are entirely yours. We are not responsible for any investment losses, missed opportunities, or financial outcomes resulting from your use of or reliance on Portivo.

8. Limitation of Liability

To the maximum extent permitted by applicable law, Portivo shall not be liable for any indirect, incidental, special, consequential, or punitive damages, including but not limited to loss of profits, data, or investment returns, arising from your use of the Service.

Our total liability to you for any claims arising from the use of the Service shall not exceed the amount you paid to Portivo in the three months preceding the claim.

The Service is provided "as is" without warranties of any kind, express or implied, including but not limited to warranties of merchantability, fitness for a particular purpose, or accuracy of financial data.

9. Termination

You may terminate your account at any time from your account settings. Upon termination, your account data will be deleted within 30 days, in accordance with our Privacy Policy.

We reserve the right to suspend or terminate your account immediately, without prior notice, if you violate these Terms, engage in fraudulent activity, or if required by law. In such cases, no refunds will be issued.

10. Changes to Terms

We may update these Terms from time to time. We will notify you of material changes via email and by displaying a notice in the dashboard at least 14 days before changes take effect. Your continued use of the Service after changes take effect constitutes acceptance of the updated Terms.

11. Governing Law

These Terms are governed by the laws of India. Any disputes arising from these Terms shall be subject to the exclusive jurisdiction of the courts of [City], India, except where applicable law requires otherwise.

For users located in the European Union (including NRIs in EU countries), your rights under applicable EU consumer protection laws are not affected by these Terms.

12. Contact

Questions about these Terms?

📧 legal@portivoai.com — Legal enquiries

📧 hello@portivoai.com — General support

🌐 portivoai.com

📍 Portivo Technologies Private Limited, India

Contents

1. What We Collect 2. How We Use Data 3. Data Sharing 4. Data Storage 5. Security 6. Cookies 7. Retention 8. Your Rights 9. Children 10. Changes 11. Contact

Legal Document

Privacy Policy

📅 Effective: 1 May 2026 🔄 Last updated: 13 May 2026 🔒 GDPR Compliant

Our Privacy Promise: We make money from subscriptions — not from selling your data. We will never sell, rent, or share your personal portfolio data with advertisers, data brokers, or any third parties for commercial purposes. Ever.

1. What We Collect

Data Type	What It Includes	Why We Collect It
Account Data	Name, email address, password (hashed), account creation date	Create and manage your account
Portfolio Data	Stock symbols, quantities, buy prices, dates, broker names	Provide portfolio tracking and rule enforcement
Rule Preferences	Your position limits, stop-loss levels, profit targets, category assignments	Enforce your personalised rules
Usage Data	Pages visited, features used, session duration, clicks	Improve the Service, fix bugs
Payment Data	Billing plan, payment dates (card details stored by Razorpay, not us)	Process subscriptions
Communication Data	Emails sent to us, support tickets	Respond to your enquiries
Device Data	Browser type, IP address, operating system	Security, fraud prevention

What We Do NOT Collect

We do not collect your broker login credentials
We do not access your brokerage account directly
We do not track your actual trades executed on broker platforms
We do not collect biometric or sensitive personal data
We do not collect data from your contacts or social media

2. How We Use Your Data

We use your data solely to provide and improve the Portivo Service. Specifically:

To create and manage your account
To provide portfolio tracking, rule enforcement, and alerts
To power Dhruv AI Advisor analysis of your portfolio patterns
To send you transactional emails (signup confirmation, billing receipts)
To send you your weekly Dhruv report (if enabled)
To detect and prevent fraud and security breaches
To improve our algorithms and AI models using anonymised, aggregated data only
To comply with legal obligations

AI Training: We may use aggregated, anonymised portfolio patterns (never linked to your identity or individual stocks) to improve our AI models. We will never use your identifiable portfolio data to train AI systems accessible to other users.

3. Data Sharing

We do not sell your data. We share data only with:

Third Party	Purpose	Data Shared
Razorpay	Payment processing	Billing information only (not portfolio data)
Amazon Web Services (AWS)	Cloud hosting and storage	Encrypted data storage
Anthropic	Dhruv AI analysis	Anonymised portfolio summary for AI processing
Legal authorities	Compliance with law	Only when legally required

All third-party processors are bound by data processing agreements and may only process your data as instructed by us.

4. Data Storage & Location

Your data is stored on servers located in India and/or the European Union (AWS Mumbai / Frankfurt regions). We choose EU-region storage for users located in Europe, including NRIs in Germany, France, UK, and other EU/EEA countries.

For EU-based users: data transfers outside the EEA (if any) are protected by Standard Contractual Clauses (SCCs) in accordance with GDPR Article 46.

5. Security

We implement industry-standard security measures to protect your data:

Encryption at rest: AES-256 encryption for all stored portfolio and personal data
Encryption in transit: TLS 1.3 for all data transmitted between your browser and our servers
Password security: Passwords are hashed using bcrypt with a unique salt — we cannot read your password
Access controls: Only specific engineers with verified need can access production systems, with full audit logging
No broker access: We never store broker credentials or API keys that allow trading access

In the event of a security breach affecting your personal data, we will notify you and applicable supervisory authorities within 72 hours, as required by GDPR Article 33.

6. Cookies

We use essential cookies only — the minimum required to operate the Service:

Session cookies: Keep you logged in during your session
Preference cookies: Remember your theme and display preferences
Security cookies: CSRF protection tokens

We do not use advertising cookies, cross-site tracking cookies, or third-party analytics that share your data with advertisers. You can disable cookies in your browser settings, but this may prevent the Service from functioning correctly.

7. Data Retention

We retain your data for as long as your account is active. When you delete your account:

Your portfolio data is permanently deleted within 30 days
Your account information is deleted within 30 days
Billing records are retained for 7 years as required by Indian tax law
Anonymised, aggregated usage statistics (not linked to you) may be retained indefinitely

8. Your Rights

You have the following rights regarding your personal data. You can exercise most of these directly in your account settings:

👁️ Right to Access

Request a copy of all personal data we hold about you. Available from Settings → Download My Data.

✏️ Right to Rectification

Correct inaccurate data. Update your profile information directly in account settings.

🗑️ Right to Erasure

Delete your account and all associated data. Available from Settings → Delete Account. Data removed within 30 days.

🚫 Right to Object

Object to processing of your data for specific purposes. Contact us at privacy@portivoai.com.

📦 Right to Portability

Export your portfolio data in machine-readable format (JSON/CSV). Available from Settings → Export Data.

⏸️ Right to Restriction

Request we restrict processing of your data in certain circumstances. Contact privacy@portivoai.com.

To exercise any of these rights, or if you are unsatisfied with our response, you may also lodge a complaint with the relevant data protection authority in your country.

9. Children's Privacy

The Service is not directed at or intended for use by individuals under the age of 18. We do not knowingly collect personal data from children. If we become aware that a user is under 18, we will terminate the account and delete associated data promptly.

10. Changes to This Policy

We may update this Privacy Policy from time to time. For material changes, we will notify you by email at least 14 days before changes take effect. The current version will always be available at portivoai.com/privacy.

11. Contact & Data Protection Officer

Privacy Enquiries

📧 privacy@portivoai.com — Privacy & data requests

📧 dpo@portivoai.com — Data Protection Officer

📍 Portivo Technologies Private Limited, India

We aim to respond to all privacy requests within 30 days, as required by GDPR.

Contents

1. Our Commitment 2. Lawful Basis 3. Your GDPR Rights 4. Data Transfers 5. Data Breach 6. DPA Request 7. Supervisory Authority 8. Contact DPO

EU Regulation 2016/679

GDPR Data Protection

📅 Effective: 1 May 2026 🇪🇺 EU/EEA Compliant 🇩🇪 German Users — Applies Fully

GDPR at Portivo: We comply fully with EU Regulation 2016/679 (GDPR). This page explains your specific rights under GDPR and how we implement them. If you are an NRI based in Germany or any EU/EEA country, your full GDPR rights apply to your Portivo account.

1. Our GDPR Commitment

Portivo is committed to the principles of the General Data Protection Regulation. We apply these principles to all personal data we process:

Lawfulness, Fairness & Transparency: We tell you clearly what data we collect and why.
Purpose Limitation: We collect data only for specific, explicit, legitimate purposes.
Data Minimisation: We collect only what is strictly necessary for the Service.
Accuracy: We keep your data accurate and up to date.
Storage Limitation: We do not keep data longer than necessary.
Integrity & Confidentiality: We protect your data with appropriate security measures.
Accountability: We can demonstrate our compliance.

2. Lawful Basis for Processing

Under GDPR Article 6, we must have a lawful basis for each type of processing. Here is our lawful basis for each:

Processing Activity	Lawful Basis	GDPR Article
Creating and managing your account	Contract performance	Art. 6(1)(b)
Portfolio tracking and rule enforcement	Contract performance	Art. 6(1)(b)
Processing payments	Contract performance	Art. 6(1)(b)
Sending transactional emails	Contract performance	Art. 6(1)(b)
Sending weekly Dhruv reports	Legitimate interest / Consent	Art. 6(1)(a/f)
Security and fraud prevention	Legitimate interest	Art. 6(1)(f)
Improving our Service (anonymised)	Legitimate interest	Art. 6(1)(f)
Compliance with legal obligations	Legal obligation	Art. 6(1)(c)

3. Your Rights Under GDPR

As an EU/EEA resident, you have the following rights under GDPR. All requests will be fulfilled within 30 days, as required by GDPR Article 12.

📋 Right of Access (Art. 15)

Request a complete copy of all personal data we hold about you, how we use it, and who we share it with.

How to exercise: Settings → Download My Data, or email dpo@portivoai.com

✏️ Right to Rectification (Art. 16)

Have inaccurate personal data corrected without undue delay.

How to exercise: Update directly in account settings or email dpo@portivoai.com

🗑️ Right to Erasure (Art. 17)

"Right to be forgotten." Request deletion of your personal data. We will delete all data within 30 days, except billing records required by law (7 years).

How to exercise: Settings → Delete Account

⏸️ Right to Restriction (Art. 18)

Request we restrict processing of your data while a dispute is being resolved or while you object to processing.

How to exercise: Email dpo@portivoai.com

📦 Right to Portability (Art. 20)

Receive your personal data in a structured, machine-readable format (JSON or CSV).

How to exercise: Settings → Export My Data

🚫 Right to Object (Art. 21)

Object to processing based on legitimate interest, including for direct marketing or profiling.

How to exercise: Unsubscribe links in emails, or email dpo@portivoai.com

Response time: We will acknowledge your request within 72 hours and fulfil it within 30 days. If we cannot fulfil your request (e.g., due to legal obligations), we will explain why in writing.

3.1 Right to Withdraw Consent

Where processing is based on your consent (e.g., marketing emails, weekly reports), you may withdraw consent at any time without affecting the lawfulness of processing before withdrawal. Unsubscribe links are included in all marketing communications.

3.2 Automated Decision Making

Dhruv AI Advisor generates insights about your portfolio. However, no automated decisions with legal or similarly significant effects are made about you. All AI output is advisory only — you retain full control over all investment decisions.

4. International Data Transfers

Your data is primarily stored in AWS Mumbai (India) and AWS Frankfurt (EU) regions. Some service providers may process data outside the EEA:

Processor	Location	Safeguard
AWS (hosting)	India / EU (Frankfurt)	EU Standard Contractual Clauses
Anthropic (AI)	United States	Standard Contractual Clauses + Data Processing Agreement
Razorpay (payments)	India	No EEA transfer — India-only processing

All international transfers of personal data are protected by appropriate safeguards under GDPR Article 46, including Standard Contractual Clauses approved by the European Commission.

5. Data Breach Notification

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will:

Notify the relevant supervisory authority within 72 hours of becoming aware (GDPR Article 33)
Notify affected individuals without undue delay if the breach poses a high risk (GDPR Article 34)
Document all breaches internally, even those that do not require notification
Communicate clearly what data was affected, what happened, and what steps we have taken

6. Data Processing Agreement

If you use Portivo for business purposes (e.g., as part of a family office or investment club), a Data Processing Agreement (DPA) is available upon request. The DPA formalises our obligations as a data processor under GDPR Article 28.

To request a DPA, email dpo@portivoai.com with subject line "DPA Request".

7. Right to Lodge a Complaint

If you believe we have not handled your personal data in accordance with GDPR, you have the right to lodge a complaint with your national data protection authority:

Country	Authority	Website
Germany 🇩🇪	BfDI (Federal Commissioner for Data Protection)	bfdi.bund.de
European Union 🇪🇺	Your national DPA (each EU country has one)	edpb.europa.eu
India 🇮🇳	MeitY / Data Protection Board (DPDPA 2023)	meity.gov.in

We encourage you to contact us first at dpo@portivoai.com so we can resolve any concerns directly.

8. Contact Our Data Protection Officer

Data Protection Officer (DPO)

📧 dpo@portivoai.com — GDPR requests, complaints, DPA

📧 privacy@portivoai.com — General privacy enquiries

📍 Portivo Technologies Private Limited, India

⏱️ Response time: 72 hours acknowledgement · 30 days fulfilment

When contacting us about GDPR rights, please include your registered email address and specify which right you wish to exercise. We may request proof of identity to protect your data from unauthorised requests.