Terms & Conditions

1. Regulatory Status and Scope 

Windmill Capital Private Limited (“WCPL”, “Company”, “we”, “us”) is a company incorporated under the Companies Act, 2013 and registered with the Securities and Exchange Board of India (“SEBI”) as a Portfolio Manager under the SEBI (Portfolio Managers) Regulations, 2020 (“PMS Regulations”).

These Terms govern access to and use of this website and any associated digital interfaces (collectively, the “Platform”).

Important:
Access to the Platform does not automatically constitute availing of portfolio management services. Portfolio Management Services (“PMS”) are provided only pursuant to execution of a Portfolio Management Services Agreement (“PMS Agreement”) and subject to eligibility criteria prescribed under Applicable Law.

2. Acceptance of Terms

By accessing or using the Platform, You agree to be bound by these Terms, the Privacy Policy, Disclosures, and any other policies displayed on the Platform, as amended from time to time.

If You do not agree, You must discontinue use of the Platform.

3. Definitions

• “Applicable Law” means all statutes, rules, regulations, SEBI circulars, guidelines, directions and judicial decisions in force in India.

• “Associate Companies / Group” shall mean CASE Platforms Private Limited (formerly Smallcase Technologies Private Limited) and other group entities as disclosed in the Disclosure Document.

• “Client” means a person who has entered into a PMS Agreement with WCPL.

• “Content” includes all text, data, reports, graphics, logos, dashboards, software, and materials available on the Platform.

• “Services” includes access to the Platform, PMS (where applicable), client servicing tools, and non-advisory informational features.
  
  

Capitalised terms not defined here shall have the meaning assigned under the PMS Regulations or the PMS Agreement.

4. Nature of Services and No Public Solicitation

• The Platform is intended to provide general information, regulatory disclosures, and client-servicing interfaces.

• Nothing on the Platform constitutes:

  • a public offer,

  • solicitation to invest,

  • investment advice,

  • assurance or guarantee of returns.

• PMS is offered only to eligible investors and only after execution of contractual documentation, as required under the PMS Regulations.

5. No Guarantee of Performance

Investments in securities are subject to market risks. Past performance is not indicative of future results. WCPL does not guarantee capital protection or minimum returns. All investment decisions under PMS are taken in good faith and in a fiduciary capacity, subject to the terms of the PMS Agreement and Applicable Law.

6. Platform Content and Research Separation

• Any research, commentary, data visualisation or informational material available on the Platform:

  • is provided for informational purposes only, and

  • does not constitute investment advice, unless expressly provided under a PMS Agreement.

• WCPL may also be registered as a Research Analyst through a separately identifiable division, operating at arm’s length from PMS activities, in accordance with SEBI regulations.

7. User Obligations

You agree to:

• provide accurate and complete information when required;

• not misuse the Platform for unlawful, misleading or fraudulent purposes;

• not copy, scrape, reverse-engineer or commercially exploit the Platform or Content;

• comply with Applicable Law at all times.

8. Data Usage

Collection, storage, processing and sharing of personal data shall be governed by the Privacy Policy, which forms an integral part of these Terms.

9. Limitation of Liability

To the maximum extent permitted by law:

• WCPL shall not be liable for indirect, incidental or consequential losses;

• WCPL shall not be responsible for losses arising from market risks, third-party failures, or user-side technical issues;

• Nothing herein limits liability that cannot be excluded under Applicable Law.

10. Grievance Redressal

Clients may raise grievances:

1. Directly with WCPL (contact details provided on the Platform);

2. Through SEBI’s SCORES platform;

3. Through SEBI-prescribed Online Dispute Resolution mechanisms.

This clause shall be read in harmony with the grievance redressal mechanism set out in the Disclosure Document and PMS Agreement.

11. Amendments

WCPL may amend these Terms from time to time to reflect regulatory, operational or legal changes. Continued use constitutes acceptance of revised Terms.

12. Governing Law and Jurisdiction

These Terms shall be governed by Indian law. Courts at Bengaluru, Karnataka shall have exclusive jurisdiction.