1. Purpose, Scope and Policy Hierarchy

Streetgains Technologies Private Limited (“Streetgains”) is a SEBI-registered Research Analyst under Registration No. INH000017082. This Policy explains how Streetgains Research Services are structured, delivered, used, accounted for and concluded.

This Policy applies to Streetgains research-call subscriptions and, where expressly stated, other research products. Product-specific terms may provide additional operational details but must be interpreted consistently with this Policy.

2. Core Definitions

Research Services — research reports, research recommendations, trade calls, model portfolios, market views, updates/closures to previously issued research recommendations and other research-related services lawfully provided by Streetgains as a Research Analyst. Streetgains does not execute trades, manage client funds/securities, provide assured returns or undertake discretionary portfolio management.

Service Activation Date — the date on which the Client’s paid Research Service commences after completion of applicable onboarding, KYC, client acceptance/consent/terms of service and payment requirements.

Service Tenure— the fixed calendar tenure applicable for the subscribed Research Service, beginning on the Service Activation Date and ending on the Service Expiry Date. As a Streetgains subscription policy, no single paid subscription cycle will exceed twelve (12) months from its Service Activation Date, subject to applicable SEBI/RAASB requirements.

Tenure Expiry Date — the last date of the agreed Tenure.

Research Credits — Research recommendations that are non-transferable internal service-accounting units used by Streetgains to record utilisation of eligible research calls under the subscribed plan.

Research Credit Balance — the number of Research Credits remaining under an active subscription.

Credit Exhaustion/ Subscription Expiry — the point at which all Research Credits allocated under the relevant subscription have been utilised.

Voluntary Research Delivery Hold — a temporary client-requested pause in delivery of eligible subscription-specific new research calls. It is not Cancellation, Premature Termination or a pause/extension of the Subscriptions.

3. Nature and Limits of Streetgains Research

• Streetgains provides research opinions and recommendations. The Client decides whether to act on any research call.
• Streetgains does not execute trades, operate the Client’s broker/demat account, manage the Client’s funds/securities or guarantee investment/trading outcomes.
• Research recommendations may change based on new information, market conditions, methodology, liquidity, volatility or risk controls.
• Past performance or historical research outcomes are not indicative of future results.
• No research call should be interpreted as a promise of profit, minimum return, accuracy or capital protection.

4. Structure and Use of Research Calls

A Streetgains research call may include the security/instrument, direction/view, entry level or range, target(s), stop-loss, time horizon/validity, trade type and relevant rationale/risk information.

Research calls are opportunity-based. Clients are not required to trade every research call, and Streetgains will not issue a research call merely for the purpose of consuming Research Credits.

• Read the complete research call before acting.
• Use appropriate capital allocation and position sizing.
• Do not deploy entire capital into a single research call.
• Follow the applicable stop-loss/exit updates where the Client elects to trade.
• Avoid revenge trading, emotional trading, excessive leverage and borrowed capital.
• Intraday and derivatives services require active monitoring and may not be suitable for Clients unable to track markets during trading hours.

5. Derivatives and High-Risk Research

Options and futures involve leverage, volatility, liquidity risk, time decay, gap risk and the possibility of rapid or substantial loss. Stop-loss levels reduce risk but cannot eliminate market-gap, slippage or execution risk.

The Client is solely responsible for whether the research category is appropriate for the Client’s knowledge, available capital, trading experience and ability to monitor the market. Streetgains’ Research Analyst service is not personalised investment advisory.

6. Research Credits – Purpose and Legal Character

Research Credits are an internal utilisation/accountability mechanism operating within an active Research Service. The subscription fee is paid for the Research Service under defined amount of Research Credits.

• Research Credits do not constitute a performance fee, profit-sharing arrangement or guaranteed-return structure.
• A Research Credit debit reflects the published research-call outcome under the applicable methodology, not necessarily the Client’s personal trading profit or loss.

The exact methodology applicable to each research category may differ and will be stated in the relevant product/Research Credits rules. A target-based Credit debit methodology is an accounting mechanism only and must not be represented as an assurance of profit, accuracy or future performance.

7. Research Credit Debit vs Client’s Actual Trade

Credit accounting is based on the published Streetgains research recommendation and official subsequent updates. It does not depend on whether the individual Client entered, entered at the exact research price, received the same broker execution, traded the stated quantity or made an actual profit/loss.

Actual Client results may differ because of slippage, market gaps, liquidity, latency, broker systems, order type, timing, position size and other factors outside Streetgains’ control.

8. Voluntary Research Delivery Hold – Premium / 300 Credits

Eligible Premium / 300 Research Credit subscriptions may request a Voluntary Research Delivery Hold for a genuine temporary or emergency circumstance.

• Available only once during the applicable subscription.
• Maximum fifteen (15) consecutive calendar days.
• Cannot be split, accumulated, repeated, carried forward, renewed or extended.
• Must be requested through an official Streetgains channel and recorded with a Hold Start Date and Hold End Date.
• Only the delivery of eligible new subscription-specific research calls is paused during the approved Hold.
• Research Credits are ordinarily not debited for new research calls that are not delivered because of the approved Hold.
• The Subscription Tenure continues to run and is not paused, frozen, reset or extended.
• The client will not have access of Research Credits deductions as the Credits are paused. However the Credits are generated and applied to the clients credits ledger upon activation.

9. Research Calls Already Open Before a Hold

A Hold pauses delivery of new eligible research calls. It does not abandon or cancel research recommendations that were already issued and active before the Hold began.

Streetgains may continue to issue necessary target, stop-loss, trailing, exit, closure or risk updates for a pre-Hold active research call. Any Research Credit treatment for such pre-Hold call will continue according to the original applicable Research Credit methodology.

10. Automatic Resumption After Hold

The Voluntary Research Delivery Hold automatically ends on the approved Hold End Date. Delivery of eligible new research calls automatically resumes from the immediately succeeding day.

• No fresh reactivation request from the Client is required.
• No salesperson, relationship manager or support executive is required to manually reactivate the service.
• A reminder call/message is a customer-service courtesy only and is not a condition for resumption.
• Failure of the Client to open the app, read alerts, respond to communications or act on research after automatic resumption does not extend the Hold.

11. Cancellation, Premature Termination and Refunds

A Voluntary Research Delivery Hold is not Cancellation or Premature Termination. A Client who intends to permanently discontinue an activated Research Service must submit a separate, express Premature Termination request through the prescribed channel.

Where a refund is payable upon Premature Termination under applicable SEBI/RAASB requirements, it will be calculated with reference to the applicable subscription fee in full (To the actual price of the Credits/Subscription Plans and not on offers and discounted prices) and the unutilized portion of the Credits.

• Market losses, non-achievement of expected returns, disagreement with research, non-trading or non-utilisation do not by themselves convert Credits into cash.

12. Official Research Delivery and Communication Channels

Subscription-specific research recommendations should be relied upon only when delivered through the official channels designated for the relevant Streetgains product, presently including the Streetgains mobile application and/or SMS where enabled.

WhatsApp, telephone and email may be used for onboarding, support, account/service communication, reminders and educational information. They should not be treated as official research-delivery channels unless the relevant product expressly designates them as such.

Clients should never share broker/demat passwords, OTPs, TPINs or account-control credentials with Streetgains or any person claiming to represent Streetgains.

13. Model Portfolio Research

Where Streetgains or a separately branded Streetgains research product offers model-portfolio research, it will be based on stated research methodology, investment horizon, risk characteristics, review/rebalancing framework and product-specific disclosures.

Model-portfolio research is distinct from trade-call Credit services unless a particular product expressly states otherwise. It does not involve discretionary management of Client assets.

14. Free Trials and Demonstrations

A free trial, where offered, is intended to demonstrate research format, delivery process and user experience. It is not intended to demonstrate profits, accuracy or guaranteed outcomes and does not automatically create a paid subscription.

15. No Oral Modification by Sales or Support

No salesperson, relationship manager, support executive or other employee/representative may, through an oral, telephonic, WhatsApp or informal statement, grant an indefinite Hold, stop/extend the Service Period, extend Credits beyond Service Expiry, convert Credits into money, promise a refund based on Credit Balance or vary a mandatory SEBI/RAASB right.

Any permitted change to an active subscription must be recorded through an authorised Streetgains system or official written communication and must remain consistent with the Client Acceptance, MITC and applicable law.

16. Research Credit Ledger and Records

Streetgains may maintain a Research Credit ledger showing opening Credit allocation, Credit debits, research-call references, qualifying-event date/time, adjustments and remaining Credit Balance.

The Research Credit ledger is an operational accountability record. It is not a Client profit-and-loss statement, portfolio performance statement or independently verified performance report.

17. Relationship With Other Streetgains Policies

Client Acceptance / Research Service Agreement: Mandatory regulatory and client-contract terms prevail. This Policy operates as Streetgains’ additional operational policy and must be read consistently with the Client Acceptance.

Research Credits Page:Explains the Research Credits model. Definitions relating to Credit validity, Service Period, Hold, termination and refund interpretation are governed by this Policy.

Premium Service Page:Describes Premium plan features. Premium Research Credits and Voluntary Research Delivery Hold features are governed by this Policy.

Refund & Cancellation Policy:Applies the definitions of Service Period, Natural Expiry, Premature Termination, Voluntary Research Delivery Hold and Research Credits set out in this Policy.

User Agreement: Governs general user and account matters. Paid Research Service matters are additionally governed by this Policy, the Client Acceptance and MITC.

Website Terms & Conditions: Governs general website use. Research-service matters are additionally governed by this Policy and the mandatory Client Acceptance/MITC.