Identity and Registration

Windmill Capital Private Limited (CIN: U74999KA2020PTC132398) is incorporated under the laws of India with its registered office at No 51, 3rd Floor, Le Parc Richmonde, Richmond Road, Shanthala Nagar, Bangalore – 560025. Windmill Capital Private Limited is registered with SEBI as a research analyst (SEBI Reg. No.with INH200007645) and as a portfolio manager (SEBI Reg. No. INP000009852).

Research Division

The research services in this factsheet are prepared and published by a separate Global Securities Research Division (the "Division") of Windmill Capital Private Limited. The Division is a separately identified department/division of the Manager, constituted specifically for the purpose of conducting research on foreign securities listed on stock exchanges in foreign jurisdictions, including the United States of America. The Division operates independently from the Manager’s other SEBI-regulated activities.

The Manager has not obtained, and is not required to obtain, any approval or registration with Securities and Exchange Board of India (“SEBI”), International Financial Services Centre Authority (“IFSCA”), or any other financial sector regulator in India or the United States in respect of its research activity on US-listed securities.

The securities covered in this factsheet are listed on foreign stock exchanges (like the United States) and do not constitute "securities" within the meaning of the Securities Contracts (Regulation) Act, 1956.

No SEBI registration number of the Manager should be construed as applicable to the foreign research services described in this factsheet.

General Disclaimers

The Manager does not provide any promise or assurance of favourable outcomes for any particular sector or business group. Investors should take professional advice before investing.

The Manager reserves the right to modify, withdraw, or discontinue any US Basket at any time without prior notice or liability to any user.

The Manager does not execute or carry out any trade on behalf of any user.

Conflict of Interest Disclosures

The Manager and its associates, officers, directors, and employees may from time to time have long or short positions in, and buy or sell, securities forming part of the US Baskets.

The Manager is an associate company of ATPL (both ATPL and the Manager are wholly owned subsidiaries of CASE Platforms Private Limited), which acts as the referral entity to VTI IFSC (a broker-dealer and Global Access Provider duly registered with IFSCA) for enabling users to access and transact in global securities. ATPL receives a share of the brokerage fee charged by VTI IFSC on each securities transaction executed by a user including in connection with US Basket(s). Accordingly, ATPL has a financial interest in users investing and transacting in the Manager’s US Baskets.

User Terms

Security and Account Responsibility

Users will not hold the Manager or ATPL liable in case of any improper, fraudulent, unauthorised, duplicate, or erroneous use of the user's mobile or web-based access. If any third party gains access to the US Baskets through a user's credentials, the user will be responsible and shall indemnify the Manager and ATPL against any liability, costs, or damages arising out of such misuse. Users are fully and solely liable for any unauthorised use of their mobile or email account and all authorised transactions on the same. The Manager and ATPL shall never ask for login credentials or OTPs for any Trading Account, Demat Account, or Bank Account. Never share such information with anyone.

Disclosure of Information

The Manager and ATPL may access, preserve, and disclose information relating to a user's access to the US Baskets if required to do so by law, or if reasonably necessary to respond to claims, comply with legal process, or protect the rights, property, or safety of the Manager, ATPL, or members of the public. The Manager and ATPL may engage agents and/or third-party vendors (including group companies and authorised agents) for carrying out acts in relation to providing these services, to the extent permissible under applicable law. Users consent to the sharing of account-related information with such authorised technology vendors and partners engaged by ATPL.

Indemnity

Users shall keep the Manager and ATPL indemnified from and against any and all liability (including liabilities, judgments, damages, losses, claims, costs, and expenses) or any other loss arising from or relating to any claim, suit, or proceeding brought by another user or third party due to: (i) a breach, non-performance, or inadequate performance by the user of any term, condition, representation, obligation, or warranty made by them; or (ii) any acts, errors, misrepresentations, wilful misconduct, or negligence of the user in connection with their use of the US Baskets.

Limitation of Liability

To the maximum extent permitted by law, the entire risk arising out of a user's access to and use of the US Baskets remains with the user. The Manager and ATPL shall not be liable for any incidental, special, exemplary, or consequential damages, including lost profits, investment losses, loss of data or goodwill, service interruption, or the cost of substitute services arising from a user's use of the US Baskets, whether based on warranty, contract, tort (including negligence), or any other legal theory, and whether or not the Manager or ATPL has been informed of the possibility of such damage.

Force Majeure

Neither the Manager nor ATPL shall be liable for any failure to perform obligations due to any force majeure event such as act of God, fire, lightning, explosion, flood, power failures, epidemic, pandemic, failure of communication systems, equipment breakdown, strikes, lock-out, or any other cause beyond their reasonable control.

CONTACT DETAILS

Email: globalresearch@windmill.capital

Registered Office: No 51, 3rd Floor, Le Parc Richmonde, Richmond Road, Shanthala Nagar, Bangalore – 560025