Growsin — Refund, Cancellation & Replacement Policy

(SEBI RIA & RA Compliant)

Fairness, transparency and compliance for advisory & research clients.

Part 1: Introduction & Legal Framework

At Growsin, I believe that fairness, transparency, and compliance must guide every client interaction. When clients engage me for investment advisory or research services, they place not only their trust but also their hard-earned money in the relationship. It is therefore essential to have a clear framework that governs how cancellations, refunds, and replacements are handled. This Refund, Cancellation, and Replacement Policy (“Policy”) sets out those rules.

The Policy ensures that both clients and I know exactly what to expect if a service is terminated, if digital content is found defective, or if unexpected circumstances disrupt the delivery of services. It balances regulatory requirements under Indian law with practical safeguards to protect clients, while also allowing me to function responsibly as a registered investment adviser (RIA) and research analyst (RA).

This Policy is rooted in several legal and regulatory pillars:

  • SEBI Regulations: As a SEBI-registered Investment Adviser and Research Analyst, I must comply with the SEBI (Investment Advisers) Regulations, 2013 and the SEBI (Research Analysts) Regulations, 2014. These rules govern how client fees are collected, how refunds must be processed when services are terminated, and how fairness and transparency are to be maintained. In particular, SEBI’s circulars emphasize that unexpired portions of advisory fees must be refunded when services are cut short.
  • Indian Contract Act, 1872: Every engagement with a client is effectively a contract. Under contract law, both parties must act in good faith, and agreements must be enforceable and fair. This Policy helps operationalize those principles by spelling out clear rules for cancellation, refund, and replacement.
  • Information Technology Act, 2000 and SPDI Rules: Because much of my interaction with clients is digital, I must comply with provisions that protect sensitive personal data, especially when processing payments or storing client agreements. This Policy is aligned with those obligations, ensuring that cancellations and refunds are handled securely and lawfully.
  • Digital Personal Data Protection Act, 2023 (DPDP Act): While primarily a data law, the DPDP Act reinforces client rights and emphasizes that personal and financial data must be processed only for lawful purposes. Refund processing and replacements involve handling sensitive information, so this Policy reflects DPDP safeguards, such as minimization, security, and accountability.

In practical terms, the Policy provides clarity on:

  • When clients can cancel advisory or research services.
  • When refunds are applicable and how they are calculated.
  • When replacements apply for digital content or deliverables.
  • What timelines govern refund and replacement requests.
  • What exclusions apply, such as force majeure or consumed portions of services.
  • How disputes are resolved, including escalation to SEBI or other forums if required.

By documenting all of this in one place, the Policy creates predictability for clients and accountability for me. Clients know their rights, and I know my responsibilities. This reduces misunderstandings, prevents disputes, and ensures that Growsin operates in line with both regulatory requirements and professional ethics.

This Policy is also designed to be client-friendly in tone. Legal rules can often seem complicated, but here they are presented in clear, accessible language. My goal is to empower clients with understanding, not overwhelm them with jargon.

In summary, the Refund, Cancellation, and Replacement Policy forms part of the larger framework of transparency at Growsin. It reflects SEBI’s mandate, Indian law, and global best practices, while staying practical for a solo-adviser model. With this foundation in place, the following sections explain the objectives, definitions, applicability, and detailed rules that govern how cancellations, refunds, and replacements are handled in my practice.

Part 2: Objectives of the Policy

A policy is only useful if its objectives are clear. The Refund, Cancellation, and Replacement Policy at Growsin is not just a formality — it is a practical guide that ensures clients know how their money and services are handled in different situations. This part explains the main objectives of the Policy and why it matters to clients as well as to me as an adviser.

Fairness to Clients

The first and most important objective is fairness. Clients who subscribe to advisory or research services are entitled to value for the fees they pay. If services are canceled early, clients should not lose the unexpired portion of their fees. Similarly, if digital content is defective, clients should have the right to a replacement.

For example, if a client pays for a six-month advisory plan but decides to cancel after three months, the client should get a refund for the remaining three months. This principle ensures that clients are not disadvantaged and that trust in the adviser-client relationship remains strong.

Compliance with SEBI Regulations

As a SEBI-registered Investment Adviser and Research Analyst, I am bound by strict regulatory rules. SEBI circulars clearly state that advisers cannot retain fees for unexpired services and must have a documented refund policy. This Policy ensures that Growsin remains in full compliance with those obligations.

Transparency in Processes

Another key objective is transparency. Clients should never be left guessing about what happens if they cancel, request a refund, or seek a replacement. By documenting all the rules in this Policy, I make sure that everything is spelled out in advance.

Protection of Client Rights

This Policy also ensures that clients’ rights are recognized and upheld. Refunds, cancellations, and replacements are not discretionary — they are rights that flow from SEBI regulations and Indian law. By embedding those rights in this Policy, I make sure that clients are empowered to exercise them easily.

Professional Accountability

Finally, this Policy reinforces my accountability as an adviser. Since Growsin operates as a solo practice, I am directly responsible for implementing these rules. There is no compliance officer or internal committee; accountability rests with me. This direct responsibility makes the process faster, simpler, and more personal.

Part 3: Key Definitions

To make this Policy easy to understand and to avoid confusion, a few key terms are defined here. These terms are used throughout the Refund, Cancellation, and Replacement Policy, and they should be read in the context of how services are delivered by me at Growsin.

Advance Fee

An Advance Fee is the amount a client pays before advisory or research services begin. SEBI requires advisers to collect fees in advance only for the agreed service period, and never beyond that. For example, if you sign up for a one-year advisory plan and pay the full fee upfront, that amount is the Advance Fee. If services are canceled midway, the unutilized portion of the Advance Fee becomes refundable.

Unexpired Period

The Unexpired Period means the portion of the service term that remains unused when a cancellation takes place. Refunds are always calculated with reference to this period. For example, if you subscribed for 12 months and cancel after 4 months, the Unexpired Period is 8 months. Refunds are based on that 8-month portion.

Breakage Fee

A Breakage Fee refers to a small deduction that may apply when a service is terminated early. This fee covers costs already incurred in onboarding, KYC, and administrative processes. SEBI allows such fees as long as they are fair, transparent, and disclosed upfront.

Consumed Fee

The Consumed Fee is the portion of the Advance Fee that has already been utilized by receiving services. Once a service has been consumed, that part of the fee is non-refundable.

Defective Content

In the context of research services, Defective Content means digital material that is not delivered as promised, is corrupted, or is otherwise unusable. Clients are entitled to a replacement if the content is defective.

Force Majeure

Force Majeure refers to events beyond my reasonable control that may prevent services from being delivered as planned. Examples include natural disasters, internet outages, government restrictions, or pandemics.

Part 4: Applicability

This Refund, Cancellation, and Replacement Policy applies specifically to the services I provide as a SEBI-registered Investment Adviser (RIA) and Research Analyst (RA). Because the nature of these services is different, the rules for cancellations, refunds, and replacements are also explained separately for each category.

Investment Advisory Services (RIA)

This Policy applies fully to all advisory services. That means:

  • Clients may cancel advisory services before the end of the service period.
  • Refunds will be calculated based on the Unexpired Period.
  • A Breakage Fee may apply for early termination, but it will be reasonable and disclosed upfront.

Research Services (RA)

As a Research Analyst, I provide clients with research reports, recommendations, and digital publications on securities and investment trends. This Policy applies to research services in two key ways:

  • Clients may cancel a subscription before its term ends and seek a refund for the Unexpired Period.
  • If research content provided is Defective Content (e.g., corrupted files or inaccessible links), clients may request a Replacement.

Inclusions

This Policy covers:

  • All paid advisory and research services under SEBI registration.
  • Digital research content provided through email, website portals, or client dashboards.
  • Refunds, cancellations, and replacements arising from service terminations, defective content, or lawful client requests.

Exclusions

This Policy does not cover:

  • Third-party platforms such as broker portals, trading apps, or social media channels where I do not control the systems.
  • Services or products not offered directly by me under SEBI registration.
  • Situations caused by Force Majeure, such as internet outages, regulatory restrictions, or natural disasters.

Part 5: Cancellation – Advisory Services (RIA)

Right to Cancel

Clients have the right to cancel advisory services at any time during the service period. SEBI regulations allow clients the flexibility to withdraw from an advisory relationship if they no longer wish to continue.

Process of Cancellation

The cancellation process is designed to be simple and transparent:

  • Written Request: Clients should send a cancellation request by email to support@growsin.in (or the official communication channel provided at the time of engagement).
  • Acknowledgment: I will acknowledge the request within a reasonable time, usually within 3 business days.
  • Calculation of Unexpired Period: The effective date of cancellation will be the day the request is received. Refunds will then be calculated based on the remaining Unexpired Period.
  • Confirmation: Once the refund calculation is made, I will share the details with the client and proceed with processing.

Effective Date

The cancellation becomes effective from the date I receive the request, not from the date of client decision or verbal communication.

Impact on Services

Once cancellation is effective:

  • Advisory services stop from that date.
  • Clients will no longer receive portfolio reviews, recommendations, or financial planning updates.
  • Access to advisory tools, if any, will be withdrawn.

Breakage Fee

A small Breakage Fee may be deducted to cover administrative and onboarding costs already incurred. The fee will always be reasonable, disclosed upfront, and aligned with SEBI’s guidance.

Part 6: Cancellation – Research Services (RA)

Right to Cancel

Clients may cancel a research subscription at any time during the subscription period. SEBI regulations allow for refunds of the unexpired portion of fees.

Process of Cancellation

The cancellation process for research services is straightforward:

  • Written Request: Clients should send an email to support@growsin.in requesting cancellation of their research subscription.
  • Acknowledgment: I will confirm receipt of the request within 3 business days.
  • Effective Date: The cancellation will be effective from the date the written request is received.
  • Refund Calculation: Refunds will be based on the unused portion of the subscription (the Unexpired Period).

Digital Nature of Services

Because research services involve digital content, once a report or recommendation has been delivered, that portion of the service is considered consumed and is not refundable.

No Hidden Deductions

Research subscription cancellations do not typically involve a breakage fee. The refund is a straightforward calculation of the unexpired portion of the subscription fee.

Part 7: Refunds – Advisory Services (RIA)

Refunds are always calculated with reference to the Unexpired Period — the portion of the advisory service that remains unused after cancellation. Clients are entitled to get back the unutilized part of their Advance Fee, minus any permissible deductions.

Breakage Fee Deduction

SEBI allows advisers to charge a nominal Breakage Fee to cover onboarding and administrative costs already incurred. At Growsin, I keep this fee minimal and transparent. It is disclosed in advance at the time of engagement.

Consumed Fee Non-Refundable

The portion of the fee that covers services already delivered is called the Consumed Fee. Once services such as portfolio reviews, financial plans, or advisory consultations are provided, that part of the fee is non-refundable.

Timelines for Processing

Refunds are usually processed within 15 business days of receiving a valid cancellation request. Payment is typically made using the same method by which the fee was collected (such as bank transfer or UPI).

Transparency in Calculation

When a refund is issued, I provide clients with a clear breakdown of the calculation: original fee paid, duration of service consumed, duration of service unexpired, breakage fee deduction (if any), and net refund amount.

Refunds in Special Cases

  • Client-Initiated Cancellation: Refunds apply for the unexpired portion.
  • Adviser-Initiated Cancellation: If I terminate the service due to regulatory or operational reasons, clients receive a pro-rated refund without any breakage fee.
  • Force Majeure: Refunds may not apply where services cannot be delivered due to events beyond my control.

Part 8: Refunds – Research Services (RA)

Refunds for research services are guided by the same principle as advisory services: clients should never be charged for periods or services they have not used.

No Breakage Fee

Unlike advisory services, research subscriptions typically do not involve significant onboarding costs. For this reason, I do not deduct a breakage fee when processing refunds for research services.

Consumed Content Is Non-Refundable

Research content delivered before the cancellation date is considered consumed. Refunds are not issued for this portion since the service has already been rendered.

Timelines for Processing

Refunds for research services are processed within 15 business days of receiving a valid cancellation request.

Adviser-Initiated Refunds

If I ever discontinue research services due to regulatory or operational reasons, clients will receive a pro-rated refund for the unexpired portion.

Part 9: Replacements – Digital Content & Advisory Deliverables

In addition to refunds, clients also have the right to expect that the services and content they receive are usable, accessible, and of the promised quality. Since research services and some advisory deliverables are provided digitally, there may occasionally be situations where content is defective, incomplete, or inaccessible. In such cases, the appropriate remedy is not a refund but a replacement of the content.

What Is Defective Content?

Defective Content refers to any digital material provided under a research or advisory service that cannot be accessed, is corrupted, incomplete, or otherwise not delivered as promised.

Process for Requesting Replacement

  1. Report the Issue: The client should email me at support@growsin.in , describing the problem.
  2. Verification: I will verify the issue, usually within 3 business days.
  3. Replacement: If the issue is confirmed, I will provide a corrected or new version of the content promptly (usually within 7 business days).

No Extra Cost

Replacements are provided at no additional cost to the client.

Limitations

Replacements do not apply where the issue is due to client-side technical problems (e.g., missing PDF reader).

Part 10: Refund Request & Processing

How to Request a Refund

Clients can request a refund by sending an email to support@growsin.in. The request should include: full name and registered email ID, service subscribed (Advisory or Research), date of subscription and payment details, and reason for cancellation or refund request.

Acknowledgment of Request

Once I receive a refund request, I send an acknowledgment within 3 business days.

Verification of Records

I review the client’s subscription details, payment records, and service usage to determine the Consumed Fee and Unexpired Period.

Refund Calculation

Refunds are calculated in line with SEBI regulations: Unexpired Period → Refundable; Consumed Fee → Non-refundable; Breakage Fee (for advisory services only) → May be deducted.

Timelines for Processing

Refunds are processed within 15 business days of receiving a valid and complete request.

Mode of Refund

Refunds are issued using the same mode of payment originally used by the client, wherever possible.

Compliance Trail

I maintain proper records of refund requests received, verification steps taken, calculation and breakdown of refund amounts, and proof of refund payment.

Part 11: Non-Refundable Items & Force Majeure

Non-Refundable Items

  • Consumed Fees: Fees for services already delivered are non-refundable.
  • Delivered Content: Reports or recommendations already provided are consumed.
  • Breakage Fee: Small deduction may apply for advisory services to cover onboarding costs.
  • Third-Party Charges: Transaction/gateway fees retained by banks or payment processors may not be refundable.

Force Majeure

In Force Majeure events (natural disasters, government restrictions, internet outages, pandemics), refunds or replacements may not be possible. I will, however, communicate promptly and attempt reasonable alternatives where feasible.

Part 12: Dispute Resolution, Compliance & Contact Information

Internal Resolution First

The first step in any grievance or dispute is to contact me directly. Clients may email privacy@growsin.in or support@growsin.in . I will acknowledge your concern within 3 business days and aim to resolve it within 15–30 business days.

Escalation to SEBI

If you are not satisfied with the resolution provided by me, you have the right to escalate the matter to SEBI via SCORES (https://scores.gov.in).

Legal Recourse

Clients retain the right to pursue legal remedies under Indian law, including consumer forums, civil courts, or arbitration as applicable.

Compliance Obligations

I maintain full records of refunds, cancellations, replacements, and disputes, and comply with DPDP Act, 2023 and IT Act/SPDI rules when handling client data in these processes.

Contact Information

Email (Compliance): compliance@growsin.com
Email (Support): support@growsin.in
Registered Office Address: Door No. 14-1-3/5, 2nd Floor, Donkada Colony, Aganam, Gajuwaka Mandal, Visakhapatnam District., VISAKHAPATNAM, ANDHRA PRADESH, 530046
Contact Number: 8500660421