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Grievance Redressal Policy

Effective Date: [TO BE INSERTED ON PUBLICATION]

This Grievance Redressal Policy is published by SMF Technologies LLP ("Company") in accordance with:

  • the Information Technology Act, 2000 and the IT (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021; and
  • the Digital Personal Data Protection Act, 2023.

It applies to all users of the Nexora platform ("Service").

1. What You Can Raise a Grievance About

You may raise a grievance regarding:

  • the operation, performance, or availability of the Service;
  • billing, subscription, or refund issues;
  • handling of your personal data, including requests to access, correct, or erase your data, or to withdraw consent;
  • suspected unauthorized access to your account; or
  • any other concern regarding your use of the Service or our compliance with the Terms of Service, Privacy Policy, or any other policy referenced therein.

This Policy does not cover disputes with your broker (Upstox) regarding order execution, margin, or account management — these should be raised directly with Upstox and, if unresolved, escalated through SEBI's SCORES portal (https://scores.gov.in) or the relevant exchange's investor grievance mechanism, as Upstox's own communications will direct.

2. How to Raise a Grievance

Level 1 — Support

Email [SUPPORT EMAIL] with a description of your issue, your registered email/account identifier, and any relevant screenshots or order/trade references. We aim to acknowledge all Level 1 requests within 24 hours and to resolve straightforward issues within 5 business days.

Level 2 — Grievance Officer

If your issue is not resolved at Level 1 within the timeline above, or if it relates to personal data/privacy, you may escalate directly to our Grievance Officer:

Name: Abbas Shanmugam Designation: Grievance Officer Phone: +91 92931 00200 Email: abbas@smf.zone Address: [REGISTERED OFFICE ADDRESS] Hours: [e.g., Monday–Friday, 10:00–18:00 IST]

The Grievance Officer will acknowledge receipt within 24 hours and aim to resolve the grievance within 15 days, in line with the timelines prescribed under the IT Rules, 2021 and the DPDP Act.

Level 3 — Data Protection Board of India

If you are dissatisfied with the resolution of a grievance relating to your personal data, you may file a complaint with the Data Protection Board of India, established under the DPDP Act, through its official portal.

3. Grievances Relating to Securities Market Activity

To the extent any grievance relates to order execution, strategy behaviour, or trades placed in your brokerage account through the Service, and the Company is determined to be subject to SEBI's investor grievance mechanisms (see the SEBI Algo Trading Compliance Disclosure), such grievances may additionally be escalated via:

  • SCORES (SEBI Complaints Redress System) — https://scores.gov.in; and/or
  • The Online Dispute Resolution (ODR) mechanism for the securities market, if and when applicable to the Company.

This section will be updated with specific SCORES registration details, if applicable, once the assessment described in the SEBI Algo Trading Compliance Disclosure is complete.

4. Record-Keeping

We maintain a record of all grievances received, their status, and resolution, for at least [NUMBER, e.g., 3] years, and may be required to report grievance statistics periodically as required by applicable law.

5. No Retaliation

Raising a grievance in good faith will not result in any adverse action against your account.