Privacy Policy

Fynro Advisory Services Private Limited (“Fynro”, “Company”, “we”, “our”, or “us”) respects your privacy and is committed to protecting your personal and financial information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our website, mobile applications and related services (together, the “Platform”).

By accessing or using our services, you agree to the terms described in this Privacy Policy. Where we rely on your consent for a specific purpose, we will ask for it separately and clearly before that processing begins.

1. Information We Collect

We collect different types of information when you use our Platform.

1.1 Personal Information

Information that can identify you directly, such as:

• Full name
• Email address
• Phone number
• Date of birth
• PAN or other identification details, where required for KYC
• Address and demographic details

1.2 Financial Information

When you use financial services on our Platform, we may collect:

• Bank account information
• Investment portfolio details
• Mutual fund holdings
• Asset and liability information
• Financial transaction data
• Income, expense, goal and insurance details you enter

This information may be accessed through secure integrations with financial institutions, APIs, or RBI-licensed Account Aggregators, in each case only with your explicit consent.

1.3 Technical and Usage Information

We may automatically collect:

• IP address
• Browser type
• Device information
• Operating system
• Pages and screens visited
• Time spent on the Platform
• Access timestamps
• App installation and version information

1.4 Cookies and Tracking Technologies

Our website may use cookies and similar technologies to improve functionality, maintain secure login sessions, analyse usage patterns and enhance user experience. You may disable cookies in your browser settings, though some features may not function properly.

1.5 AI Interaction Information

When you use an AI-assisted feature, we record the request made, the response returned, and the time of the interaction. We retain this to deliver the feature, to audit the quality and safety of the output shown to you, and to meet our record-keeping obligations as a SEBI-registered Investment Adviser. Section 4 sets out in full what is shared with our AI service provider and what is not.

2. How We Use Your Information

We use the information we collect to:

• Provide financial planning and investment advisory services
• Create and manage user accounts
• Analyse financial data and generate insights, projections and plan documents
• Enable secure financial data integrations
• Power AI-assisted features, namely transaction categorisation and plain-language narration of your financial plan, subject to your consent (see Section 4)
• Review and improve the accuracy and safety of AI-generated content shown to you
• Process payments for advisory plans and consultation credits
• Improve our services and platform performance
• Communicate service updates or notifications
• Detect fraud and enhance security
• Comply with legal and regulatory obligations

3. Sharing of Information

We do not sell or rent your personal data to any third party.

3.1 Service Providers

We share information with the following categories of trusted third parties who help us operate the Platform. Each is bound by written contract to maintain confidentiality, to process data only for the stated purpose, and to apply protections equal to or greater than those set out in this Policy.

3.2 Legal and Regulatory Requirements

We may disclose information where required by law or in response to valid legal requests from regulatory authorities or government agencies, including SEBI.

3.3 Business Transfers

If Fynro undergoes a merger, acquisition, or restructuring, your information may be transferred as part of that transaction. You will be notified of any such transfer and of any change to how your data is handled.

4. Artificial Intelligence and Third-Party AI Services

Two features of the Fynro app are assisted by artificial intelligence provided by a third-party AI service provider. This section explains exactly what information is sent, who receives it, why, and how you control it.

4.1 Which features use AI

Artificial intelligence is used in only the following two features:

1. Transaction categorisation — classifying your bank and card transactions into spending categories such as groceries, utilities, travel or EMI.
2. Financial plan narration — converting the figures already computed in your financial plan into a plain-language written summary.

No other feature of the Platform transmits your data to an AI service. Fynro does not operate an AI chatbot or AI assistant that receives your data.

4.2 Who your data is sent to

We do not send your data to any other artificial intelligence service.

4.3 What data is sent

Only the minimum information required to produce the result is transmitted, and only at the moment the relevant feature runs:

For transaction categorisation:

• Transaction description or narration text
• Merchant name
• Transaction amount
• Transaction date
• Debit or credit indicator

For financial plan narration:

• Aggregated figures already computed within your plan — income, expense, asset, liability, goal and net-worth values
• Your age band, city tier and the currency in which the plan is denominated
• Goal names and target years as you have entered them

4.4 What data is never sent

We do not transmit the following to Anthropic or to any other AI service provider:

• Your name, email address, postal address or mobile number
• Your PAN, Aadhaar or any government identification number
• Your bank account number, demat account number, card number or UPI ID
• Your login credentials, passwords or OTPs
• Any KYC document, photograph or scanned identity document

Data sent to the AI provider is associated with a random internal reference, not with your identity, and cannot be traced back to you by the provider.

4.5 Your consent, and how to withdraw it

We ask for your explicit, opt-in permission inside the app before any of your information is sent to an AI service provider for the first time. If you decline, no data is transmitted and the two AI-assisted features are switched off — the rest of the Platform, including your financial plan, your projections, your advisory calls, your reports and your dashboards, continues to work normally. Transactions can be categorised manually, and your plan is presented in its standard numeric form.

You may withdraw your consent at any time from Profile → Privacy → AI & Data. Withdrawal takes effect immediately for all future processing. It does not affect the lawfulness of processing that took place while consent was active.

4.6 Protection at the AI provider

Anthropic, PBC is engaged as a processor under Anthropic’s commercial terms and data processing addendum, which provide that:

• data is processed solely to return the requested response, and only for the features described in §4.1;
• inputs and outputs from commercial API use are not used to train or improve Anthropic’s models by default;
• data is not sold, rented, published or disclosed to any further party except as required by law;
• inputs and outputs are deleted from the provider’s systems within the retention window specified in our agreement;
• organisational and technical safeguards, including encryption in transit and at rest, are applied at a standard equal to or greater than those described in Section 7 of this Policy.

4.7 Human oversight and the limits of AI

AI output within Fynro is a supporting tool only. It is not investment advice.

All financial calculations, projections, scores, goal values and plan figures in Fynro are produced by our own deterministic computation systems. Artificial intelligence is not used to compute any financial value. In the narration feature, AI is used only to describe figures that have already been calculated.

Any investment advice or recommendation you receive is issued by Fynro Advisory Services Private Limited in its capacity as a SEBI-registered Investment Adviser (INA000021942) and is subject to review by a qualified person associated with investment advice.

4.8 Cross-border transfer

Anthropic, PBC processes data in the United States. That transfer is made in accordance with the Digital Personal Data Protection Act, 2023, on the basis of the consent recorded under §4.5 and under the contractual safeguards described in §4.6.

5. Consent, and Withdrawal of Consent

Where we rely on your consent — including for Account Aggregator access and for AI-assisted features — that consent is requested separately, in plain language, before the relevant processing begins. It is never bundled into a general acceptance of this Policy or of our Terms.

You may withdraw any consent at any time from Profile → Privacy in the app, or by writing to supportit@fynro.in. Withdrawal is effective going forward and does not affect the lawfulness of processing carried out before withdrawal. Where a feature cannot be delivered without a particular consent, we will tell you clearly which feature will become unavailable.

6. Payments

Advisory plans and consultation credits are purchased on the Fynro website. Payments are processed in Indian Rupees by our payment processor, which receives your name, contact details and the transaction amount for that purpose.

Where you choose to pay through the Centralized Fee Collection Mechanism (CeFCoM) operated by BSE Limited, your payment is handled through that mechanism in accordance with its own terms.

Fynro does not store your full card number, CVV or banking credentials at any time, and does not accept or hold client funds or securities other than its own advisory fees.

7. Data Security

We implement appropriate security practices to protect your information, including:

• Encryption of sensitive data in transit and at rest
• Secure authentication systems
• Role-based access control
• Secure cloud infrastructure
• Controls aligned with SEBI’s Cyber Security and Cyber Resilience Framework

While we take strong measures to protect data, no system can guarantee complete security.

8. Data Retention

We retain personal and financial information only for as long as necessary to:

• Provide our services
• Meet regulatory and legal obligations, including SEBI record-keeping requirements
• Resolve disputes
• Enforce agreements

AI interaction records held by us are retained for the period required under SEBI record-keeping obligations, after which they are deleted or anonymised. Data transmitted to our AI service provider is deleted from that provider’s systems within the retention window set out in our agreement with them, and is not used to train their models.

Once data is no longer required, it is securely deleted or anonymised.

9. Your Rights

Subject to applicable law, including the Digital Personal Data Protection Act, 2023, you have the right to:

• Access the personal data we hold about you
• Request correction of inaccurate or incomplete information
• Request deletion of your personal data
• Withdraw consent where processing is based on consent
• Nominate another individual to exercise your rights in the event of death or incapacity
• Register a grievance with our Grievance Officer

Requests can be made in the app or using the contact details in Section 13.

10. Third-Party Services

Our Platform integrates with third-party financial service providers, payment processors, and the AI service provider identified in Section 4. Each such provider operates under its own privacy policy in addition to the contractual obligations we impose on it. We share only the specific data described in this Policy, and only for the stated purpose.

11. Children's Privacy

Our services are not intended for individuals under the age of 18. We do not knowingly collect personal information from minors. If we become aware that we have collected such information, we will delete it.

12. Changes to this Privacy Policy

We may update this Privacy Policy periodically. Updated versions will be posted on our website and in the app with a revised effective date and version number.

Where a change materially affects what data is shared with a third-party AI service — including a change of provider, of processing location, or of the fields transmitted — we will request your consent again before continuing to share that data. Consent given to an earlier version does not carry forward to a materially changed version.

Continued use of our services after a non-material update constitutes acceptance of the revised Policy.

13. Contact Us

Grievance Officer

For any question, complaint or request relating to your personal data — including access, correction, deletion, or withdrawal of consent — you may contact:

Escalation

For grievances relating to investment advisory services, if you are not satisfied with our resolution or your grievance remains unresolved within the prescribed timelines, you may escalate through:

• SEBI Complaints Redress System (SCORES): https://www.scores.sebi.gov.in/
• The Investment Adviser Administration and Supervisory Body (IAASB), or such other Administration and Supervisory Body recognised by SEBI
• SMART Online Dispute Resolution (SMART ODR): https://smartodr.in/

Nothing in this Policy restricts your right to seek any remedy available under applicable law.

Version 2.0 · Effective 24 July 2026