Grievance Redressal Policy

1. Why This Policy Exists

TruePrice (trueprice.pro), operated by Devesh Varshney as a SEBI-registered Research Analyst, is required to operate a structured grievance-redressal mechanism under multiple regulations including:

• The SEBI (Research Analysts) Regulations, 2014;
• SEBI master circulars and circulars on Online Dispute Resolution (ODR), including the SEBI ODR circular dated 31 July 2023;
• Rule 3(2) of the IT (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021;
• Section 8(9) of the Digital Personal Data Protection Act, 2023;
• Rule 4 of the Consumer Protection (E-Commerce) Rules, 2020.

This Policy sets out how to raise a complaint, our timelines for acknowledging and resolving it, and the escalation paths available to you if you remain dissatisfied.

2. Designated Grievance Officer

The Grievance Officer is responsible for receiving, reviewing, and resolving all User grievances, and for liaising with regulators (SEBI, CERT-In, DPB India) where required.

3. What You Can Complain About

This Policy covers grievances of any nature, including:

• The accuracy or quality of any Research Report or valuation;
• Account access, authentication, or login issues;
• Payments, refunds, or subscription billing;
• Privacy and personal-data handling under the DPDP Act;
• Content moderation, abuse, or impersonation under the IT Rules, 2021;
• Compliance with the SEBI (Research Analysts) Regulations, 2014.

4. How To Submit A Grievance

Email your grievance to support@trueprice.pro with the following details:

• Your registered email and / or mobile number;
• A clear and detailed description of the grievance;
• The date the issue arose or was first identified;
• Any relevant order ID, transaction reference, screenshot, or supporting document;
• Your preferred mode of communication for updates.

Grievances submitted without sufficient information may require follow-up before formal acknowledgement can be issued.

5. Acknowledgement & Resolution Timelines

• Acknowledgement: within 48 hours of receiving a complete grievance submission, including a unique grievance reference number.
• Resolution: within 30 days of acknowledgement, in line with the IT Rules, 2021, the SEBI (Research Analysts) Regulations, 2014, and the Consumer Protection (E-Commerce) Rules, 2020.
• Complex cases: where a grievance involves complex financial, regulatory, or technical issues requiring extended investigation, the resolution period may be extended once for up to 30 additional days. We will communicate the reason for the extension and the revised expected resolution date in writing.
• Recordkeeping: all grievances and their resolutions are logged and retained for at least 5 years, in line with SEBI requirements applicable to Research Analysts.

6. Escalation — SEBI SCORES

If you are not satisfied with our resolution, or if we fail to respond within the timelines above, you may escalate the complaint to SEBI through the SEBI Complaint Redress System (SCORES):

• Web: scores.sebi.gov.in
• SEBI toll-free helpline: 1800-266-7575 / 1800-22-7575
• Information to provide: our SEBI Registration Number (Pending issuance), our grievance reference number, copies of all prior correspondence with us, and the relief sought.

7. Escalation — SEBI Online Dispute Resolution (SmartODR)

For unresolved monetary disputes under the SEBI ODR framework (SEBI circular dated 31 July 2023 and subsequent circulars), you may use SEBI's Online Dispute Resolution platform:

• Web: smartodr.in
• SmartODR enables conciliation and arbitration of unresolved securities-market disputes through SEBI-empanelled ODR institutions.

8. Other Escalation Paths

• Data Protection Board of India — for matters under the Digital Personal Data Protection Act, 2023, once operational. Updates published at meity.gov.in.
• CERT-In — for cyber-incident reports under the CERT-In Directions of 28 April 2022, at cert-in.org.in.
• National Consumer Helpline — 1915 or consumerhelpline.gov.in for consumer grievances.
• Cashfree grievance redressal — for payment-related issues, see Cashfree's Customer Grievance Redressal Policy.
• RBI — Ombudsman Scheme for Digital Transactions, 2019 for unresolved payment system disputes.

9. Anonymous Complaints

Anonymous complaints will be reviewed but cannot be formally acknowledged or resolved with a reference number, since regulatory timelines require us to communicate with an identifiable complainant. We encourage you to provide at least your registered email or mobile number.

10. Updates & Related Policies

We may update this Policy from time to time. Changes are effective on the “Last updated” date. This Policy should be read with our Terms of Use, our Privacy Policy, our Refund & Cancellation Policy, and our Regulatory page.