1. Purpose

Finanjo exists to help young earners build better money habits. That only works if users trust us, and trust depends on how we behave when something goes wrong. This policy sets out how a user or client can raise a complaint, who handles it, how fast we respond, and what escalation options exist if the user is not satisfied.

This policy is adopted in compliance with the SEBI (Investment Advisers) Regulations, 2013, SEBI's circular on redressal of investor grievances through the SCORES platform and Online Dispute Resolution (SEBI/HO/OIAE/IGRD/CIR/P/2023/156 dated 20 September 2023, as amended), the grievance redressal obligations of a Data Fiduciary under Section 13 of the Digital Personal Data Protection Act, 2023 read with the DPDP Rules, 2025, and the obligations applicable to Finanjo as a specified user of credit information under the Credit Information Companies (Regulation) Act, 2005.

2. Scope

This policy covers all grievances relating to:

• Investment advisory services provided by Finanjo in its capacity as a SEBI Registered Investment Adviser, including advice, fees, onboarding, risk profiling, and suitability.
• The Finanjo app and its features, including Account Aggregator based data services, subscription tracking, budgeting, credit score services sourced from TransUnion CIBIL, and Money Stories.
• Personal data handling, including consent, data accuracy, data sharing, erasure, and any exercise of rights under the DPDP Act, 2023.
• Service quality issues such as app errors, billing or payment failures, and delayed responses.

A grievance is any communication in which a user expresses dissatisfaction and expects a response or remedy. Routine service requests, feedback, and suggestions are not grievances, but any of them can be escalated into one at the user's request.

3. Guiding Principles

• Every complaint is acknowledged, tracked, and closed with a written response. Nothing is closed silently.
• Raising a complaint is free. No charges, no conditions.
• Plain language. Responses are written the way we write everything else at Finanjo: simple, honest, and specific.
• No retaliation. Filing a complaint never affects the service a user receives.
• Root cause over patchwork. Recurring complaints trigger a product or process fix, not just individual resolutions.

4. Grievance Redressal Officer

Finanjo has designated a Grievance Redressal Officer (GRO) responsible for receiving, tracking, and resolving all complaints under this policy. The GRO's contact details are published on the Finanjo website, inside the app, and in the investment advisory agreement.

If the GRO is unavailable for more than five working days, the Principal Officer assumes the GRO's responsibilities so that timelines under this policy are not affected.

5. How to Raise a Complaint

Users can raise a complaint through any of the following channels. All channels feed into a single complaint register.

A complaint should include the user's registered mobile number or email, a description of the issue, and the relevant date or transaction where applicable. If details are missing, the GRO will ask for them within two working days; the resolution clock pauses until the user responds.

6. Process and Timelines

The 21 calendar day resolution timeline is the standard mandated by SEBI for its regulated entities. If a complaint cannot be resolved within 21 days for reasons outside Finanjo's control, the GRO informs the user in writing before the deadline with the reason and a revised date.

7. Escalation: SCORES and ODR

If a user is not satisfied with Finanjo's resolution, or receives no response within 21 calendar days, the following escalation routes are available. Finanjo discloses these on its website, in the app, and in the advisory agreement, and cooperates fully with each forum.

Level 1 — SEBI SCORES

• The user may lodge a complaint on SEBI's SCORES 2.0 platform at https://scores.sebi.gov.in or through the SCORES mobile app.
• Complaints are auto-routed to Finanjo, which must submit an Action Taken Report within 21 calendar days.
• SCORES provides a two-level review: first by the Designated Body if the user seeks review within 15 days of Finanjo's response, and then by SEBI.

Level 2 — Online Dispute Resolution (ODR)

• If still unresolved, the user may initiate online conciliation and arbitration through the SMART ODR portal at https://smartodr.in, established under SEBI's ODR framework.
• The advisory agreement includes the clause required by the ODR circular recording both parties' agreement to online conciliation and arbitration.

Data protection complaints

• For grievances relating to personal data that remain unresolved after Finanjo's internal process, the user may complain to the Data Protection Board of India through its digital complaint mechanism.

Nothing in this policy prevents a user from approaching any court, consumer forum, or other body of competent jurisdiction.

8. Mandatory Disclosures

• A link to the SCORES portal and the SMART ODR portal is displayed on the home page of the Finanjo website and within the app.
• The grievance redressal mechanism, including the GRO's contact details, is displayed at Finanjo's office and on the website, as required for Investment Advisers.
• Finanjo publishes its monthly complaint data on its website in the format prescribed under the Investor Charter for Investment Advisers, including complaints received, resolved, and pending, and average resolution time.
• The Investor Charter for Investment Advisers is available on the website and shared with clients at onboarding.

9. Records and Reporting

• The GRO maintains a complaint register recording, for each complaint: ticket ID, date received, channel, user identifier, category, description, action taken, resolution date, and status.
• All complaint records, correspondence, and Action Taken Reports are retained for a minimum of five years, consistent with record-keeping obligations under the SEBI (Investment Advisers) Regulations, 2013.
• A summary of complaints, resolution times, breaches of timeline, and recurring root causes is placed before the Board (or the compliance review meeting) every quarter.
• SCORES credentials are kept current and the platform is checked at least once every working day.

10. Complaint Categories and Internal Routing

Routing is internal only. The GRO remains the single owner of every complaint and the single point of contact for the user.

Credit information disputes

Where a user disputes the accuracy of credit information appearing in a report sourced from TransUnion CIBIL, Finanjo assists the user in raising the dispute with TransUnion CIBIL through the bureau's consumer dispute resolution process, and shares any information in Finanjo's possession that is relevant to the dispute. Finanjo handles such requests within the timelines set under the Credit Information Companies (Regulation) Act, 2005 and rules made under it, which require credit information disputes to be resolved within thirty days. Where the underlying correction lies with the credit institution that reported the data, Finanjo tells the user this plainly and points them to the right forum rather than leaving the complaint open-ended.

11. Review

This policy is reviewed by the Board at least annually, and immediately upon any material change to the SEBI grievance framework, the SCORES or ODR circulars, or the DPDP Act and Rules. The Compliance Officer is responsible for keeping the published version current.