1.1 Welcome to Tavaga Mobile Application. The App is owned and operated by Tavaga Advisory Services Private
Limited, whose registered office is located at 1502, Lakefront Solitaire, A S Road, Near Heera Panna Mall,
Powai, Mumbai – 400 076 (hereinafter referred to as “App”.)
“We”, “Us”, “Our” and “Tavaga” and
means Tavaga Advisory Services Private Limited and “You”, “Your” or “User”
means any person who accesses or uses the App or Our Services. Our “Services”, provided through the App,
(a) Providing a proprietary automated technology platform that allows You to generate a list of
Exchange Traded Funds (“ETFs”) based on Your personality, risk profile, and market conditions as more fully
(b) Should You choose to do so, assisting You in making an investment in the ETFs provided in the List if
1.3 For the purposes of this agreement, “Tavaga Advisory Services” means and refers to the following
(a) Tavaga Advisory Services Private Limited, a SEBI registered investment advisor bearing
registration number INA000013457 engaged in providing investment advisory and allied
1.4 Now, therefore by accessing or using this App for and in consideration of the mutual promises,
Use or any of Our Policies, please do not use or access the App.
binding contract as per applicable law, in particular, the Indian Contract Act, 1872.
1.6 Our Services are designed to be compliant with the laws of India. If You access Our Services from
locations outside India, You do so at Your own risk and You are solely liable for compliance with applicable
notice. Your continued use of the App or the Services following any such amendment indicates Your acceptance
of such amendment.
1.8 We reserve the right to restrict access to Our App and all of the Services provided therein, if
You have been or We have reasonable grounds to believe that You have been convicted of an offence which
involves moral turpitude or any offence under the Indian Penal Code, 1860.
revocable, limited privilege to access and use the App for personal, non-commercial use.
1.10 You may delete Your Account and discontinue the use of Our Services at any time in accordance with
Paragraph 23. Similarly, We will have the right to withdraw Our Services at any time without assigning any
2. Our Services
2.1 Our proprietary technology classifies ETFs into different categories based on market conditions, past
performance and other factors. You can use the App, and Your inputs with respect to Your Investment Profile
(as defined below), to generate a list of ETFs that is best suited to your Investment Profile.
2.2 Upon accessing the App, You will participate in a mock market simulation game (“Simulation”).
(a)The App will propose an approximate investment profile (“Investment Profile”) for You based on how You
play the Simulation. You may modify Your Investment Profile if You so choose.
(b)You will be able to generate a List of ETFs based on Your Investment Profile. It is clarified that the
List generated is specific to Your circumstances and does not in any manner constitute general public advice
or a recommendation that You make investments based on it. You make use of the App to generate Your
Investment Profile and Your List.
(c)While the App and the proprietary technology it uses takes various factors into account including Your
Investment Profile, market conditions, past performance and is based on information from sources that We
believe to be reliable, We do not guarantee the accuracy, timeliness and completeness of the information
(d)We do not warrant any results from the use of the App or Our Services nor guarantee the achievements of
Your Goal, whether or not You choose to invest through Us.
2.3 You acknowledge and agree that for the provision of services under this agreement:
(a)Tavaga shall carry out all activities that are required to fulfil its regulatory obligations for the
provision of Services under this Agreement.
(b)Your access to our Services is associated with a username and password (together “Login Credentials”) and
Tavaga will consider the instructions placed with the use of your Login Credentials to have originated from
You. You are solely responsible for the security of your Login Credentials. Tavaga shall not be held liable
for carrying out any instructions placed from your account utilising your Login Credentials which may be
unauthorized due to any reason including an information leak or security breach on your part.
(c)Tavaga may utilise third-party vendors (“Vendors”).
(d)Tavaga and its Vendors, may
1. Contact you on issues related to the provision of services;
2.Record all your interactions with them including phone calls, chats, Whatsapp conversations and emails,
with its employees for legal compliance, security, employee training and other lawful purposes.
3. Fees and Charges
3.1 We reserve the right to charge fees in the future for the Services or any other services offered by Us
in addition to any fees that may be charged from You under Paragraph 24.1. Any such changes will be
displayed on the App. Your continuous usage of Our Service even after the introduction of the fees shall
be treated as Your acceptance to pay Us the applicable fees.
4. User Obligations
4.1 Our Services are to be used only for their intended purpose and are not to be misused in any manner,
including for undertaking fraudulent transactions, impersonation, etc.
4.2 You warrant that You are using the App on Your own initiative and that You are responsible for
compliance with any and all applicable laws.
4.3 You shall use the App only for its intended purposes in a bona fide manner. You shall not:
Attempt to or gain unauthorized access to any portion or feature of the App including accounts, or any
other systems or networks connected to the App or to any server, computer, network, or to any of the
Services by hacking, password “mining” or any other illegitimate means;
Directly or indirectly solicit the account information of other users or access or try to access any
account which does not belong to You;
(d) Probe, scan or test the vulnerability of the App or any network connected to the App or Services
or breach the security or authentication measures on the App or any network connected to the App;
(e) Extract data from the
(f) Make any investment recommendations to any person on the basis of outputs from the App;
(g) Attempt to circumvent the regular operation of the App, or reduce the fees or consideration that
We may derive from the App by any means including by creating multiple accounts, redirecting traffic or
following other fraudulent or deceptive practices;
Collect any user information through automated means, including but not limited to bots, robots, spiders
and scrapers without Our prior written permission;
(j) Make any statement(s) or comment(s) on the App which is/are inaccurate, false, unfair or
defamatory to Us or other users or which violates the legal right of others.
4.4 Further, You agree not to upload, host, display, publish, share or otherwise make available on
the App any content or information that:
(a) Belongs to another person and to which You do not have any right;
(b) Contains any content which is non-compliant with the Information Technology Act, 2000, rules,
regulations, and guidelines made thereunder, including Rule 3 of The Information Technology
time to time; or
(c) Infringes any intellectual property rights of any third party.
4.5 You agree to be fair, accurate and non-disparaging while leaving comments, feedback,
testimonials and reviews on or about the App or the Services.
4.6 You will be responsible for payment of taxes and complying with any applicable laws in relation
to any interest or dividend earned by You.
5. Tavaga Intellectual Property
5.1 All intellectual property in the App, and in the proprietary material, content and information made
available on the App including the graphics, images, photographs, logos, trademarks, the appearance,
organisation and layout of the App and the underlying software code belong to Us.
5.2 Using Our services does not give you ownership of any intellectual property rights, including
any branding or logos in Our services or the content You access. You must not copy, modify, alter,
decompile, reverse engineer, publish, broadcast, distribute, sell or transfer (whether in whole or in
the App and through the Services is for Your personal and non-commercial use only. You may not use the
content from Our services unless you obtain Our permission first and attribute ownership appropriately.
5.3 You may not use the Tavaga logo or content in any manner that is deceptive or disparaging, or in
connection with any product or service that Tavaga does not explicitly endorse. If you wish to use
Tavaga’s intellectual property, please contact firstname.lastname@example.org.
5.4 If at any time, You make any submissions via or on the App, including but not limited to suggestions,
feature ideas, bug reports, comments, You assign all rights in these submissions to Us. Hereafter, We
shall be entitled to use the submissions for any purpose whatsoever, without compensation to the maker of
the submission. In any event, such submissions are not and will not be treated as confidential and We
shall not be liable for any disclosure of the submissions.
that Your use conflicts or interferes with Our reputation, interest or might subject Us to unfavorable
legal or regulatory action in any way, We can indefinitely suspend or terminate Your access to the App at
any time, and report such action to relevant authorities.
We reserve the right to take recourse to all available remedies under applicable law in furtherance of the
7.1 You agree to indemnify Us, Our owners, licensees, affiliates, group companies and their respective
officers, directors, agents, and employees, on-demand, against any claim, action, damage, loss, liability,
cost, charge, expense or payment which We may pay, suffer, incur or are liable for, in relation to any act
regulations or as result of any third party claims due to Your use of the App.
8. Disclaimer of Warranties and Limitations of Liabilities
8.1 We do not and are not obliged to, include all ETFs available in the market that may suit Your
Investment Profile, in the List. By limiting the number of schemes on the App, We do not make any
representation as to the quality, bona fides or nature of any ETFs, or any other representation, warranty
or guarantee, express or implied.
8.2 We shall not be liable for any inaccuracy or typographical error on our website or the app or
any written, E-mail and SMS communication. Tavaga specifically disclaims any liability for such
inaccuracies or errors.
8.3 We shall not be held liable for any loss or damage or failure to comply with or delay in complying
circumstances beyond Our reasonable control including due to system failure, network issues, technical
snags or loss of data due to any of the preceding force majeure events including but not limited to an act
of God, floods, epidemics, quarantine, riot, civil commotion, fire explosion, epidemics, pandemics, strike
You further acknowledge and agree that, to the maximum extent permitted by law, neither Tavaga nor any of
its Service Partners or Vendors will be liable for any incidental, special or exemplary or consequential
damages, including loss of profits, loss of data or loss of goodwill, service interruptions or in
connection with the terms of this Agreement, as a result of Your use of services.
9. Availability of App or Services
9.1 The App and Services are provided on an “as is” and “as available” basis without any representation or
warranty, express or implied. We do not warrant that:
(a) The App will be constantly available or available at all. We shall have no liability to You for
any interruption or delay in access to the App or Services availed through it, irrespective of the cause;
(b) The information on the App or given through Services is complete, true, accurate or
(c) That the App is secure or free of viruses, Trojans or other malware; or
(d) The contents
of the App do not infringe any intellectual property rights.
9.2 We reserve the right to modify the App, Our technology and the basis on which Lists and/or
Investment Profiles are generated from time to time. This may vary the results that You derive by using
selling or offering to buy or sell, or a recommendation for, security, or any other product or service, to
You or any person in any jurisdiction where such solicitation, offer, recommendation, purchase or sale
would be unlawful under the laws of that jurisdiction.
11.1 Under no circumstances will Tavaga sell or rent Your personal information, for any reason, at any
11.2 We reserve the right to store and retain any and all information provided by You including the
Services used, Information, Account details and details of the Transactions to comply with applicable
11.3 Any personal information You supply to Us when You use this App or the Services will be used in
12. Third Party Links
12.1 All third party advertisements, hyperlinks or other redirection tools on the App which take You to
content operated by third parties are not controlled by Us and do not form part of the App.
We are not liable for any loss or harm that occurs to You as a result of such sites.
13. Severability and Waiver
jurisdiction or arbitration panel, the invalidity of such provision shall not affect the validity of the
14. Governing Law and Jurisdiction
India as applicable between resident Indians.
14.2 Any disputes pertaining to the App shall be subject to the exclusive jurisdiction of the appropriate
courts in Mumbai, India.
14.3 This agreement can only be amended in writing with the mutual consent of You and Tavaga.
15. Dispute Resolution
15.1 All disputes arising from or in connection with this Agreement shall be settled amicably between the
Parties failing which it shall be referred to and finally settled by arbitration in accordance with the
Indian Arbitration and Conciliation Act, 1996 as amended from time to time, presided over by a sole
arbitrator appointed mutually by the Parties failing which it shall be appointed by the High Court of
Mumbai. Judgment upon the arbitral award may be entered in any court having jurisdiction over the Parties
or their assets. The seat and venue of the arbitration shall be Mumbai, India. The arbitration proceedings
shall be conducted in the English language.
15.2 The parties shall bear their own legal and other costs and expenses necessary for the
resolution of the dispute.
15.3 Notwithstanding the foregoing, a Party may seek appropriate interim or provisional reliefs including
any injunctive reliefs in any court having jurisdiction over the subject matter thereof to enforce and/or
prevent a breach of its rights and remedies in and arising out of this Agreement.
16. Grievance Officer
16.1 In accordance with the Information Technology Act, 2000 and the Rules made thereunder, the name and
contact details of the Grievance Officer are provided below:
You may write to her at the following address:
WeWork Chromium, Milind Nagar, L & T
Flyover, Andheri (East), Mumbai MH 400072.
Email her at email@example.com
16.2 Any of your queries and grievances shall be addressed within two working days of receipt. The
resolution, appropriate and to your satisfaction shall be provided as soon as possible depending on the
nature of the request.
17. Contact Us
17.1 Please Contact Us for any questions or comments (including all inquiries related to copyright
infringement) regarding this App.
18.1 This document is an electronic record under the Information Technology Act, 2000 and the rules
thereunder. This electronic record is generated by a computer system and does not require any physical or
19.1 This document is published in accordance with the provisions of Rule 3(1) of the Information
Technology (Intermediaries Guidelines) Rules, 2011 that require publishing the rules and regulations,
21. Optional Services
21.1 In order to use Our Optional Services, You are required to create an account (“Account”) by providing
the following details:
(b) Email Address;
(c) Mobile Number;
(d) PAN Number;
(e) Date of Birth;
(f) A PIN
code to be created by You which shall be required to be entered
each time You use Our Optional Services;
(g) Your bank
account details from which You could choose to make payments, if
(h) Details required for KYC forms and Account
Opening form; (Collectively, the “Information”). Any document as
required above shall be uploaded by You in soft copy on the App at
the time of creating the Account.
21.2 You will ensure that the Information provided by You is accurate, true and up to date at all
21.3 Upon successful creation of the Account, You will be issued a username and password, linked to
Your Account. User Accounts are personal, confidential and not transferable. You will be responsible for all
information and content posted under Your Account. You will create only one Account and will not create
successive Accounts unless the previous Account is duly deleted.
21.4 You shall be solely responsible for the confidentiality of the username, password and PIN used by
You to access the App and Our Services and shall not disclose the same to anybody and shall take all
possible care to prevent discovery of the username, password and PIN by any person. In any event, We are not
liable or responsible for any unauthorized access to Your Account. You will immediately notify Us of any
21.5 By providing Us with the Information, You agree that the contact number supplied by You is not
part of any “do not call” registry or its equivalent, anywhere in the world and that We may use the
Information to send You communication, notices or alerts that are transactional, informational and
promotional in nature, from time to time.
After the creation of Your Account, You will specify the amount You wish to
invest (“Investment Amount”) and the frequency with which You want to make the investment (“Investment
Frequency”). You may choose Your Investment Frequency to be monthly or one time. The App allows goal-based
investing, that is, it allows You to factor in Your personal financial goals, such as buying a house,
planning a vacation, foreign education, etc while making investments. Accordingly, You will need to set the
target amount to be achieved (“Goal”) and based on the combination of Your Investment Amount, Your
Investment Frequency, Your Investment Profile and Your Goal, (collectively, “Parameters”), You will be able
to estimate a reasonable time frame in which You can achieve You Goal. You may adjust the Parameters to
achieve Your desired time frame.
21.7 You may modify any of Your Parameters at any time and the App will accordingly modify the
selection of Your investment to match the new Parameters within a reasonable time.
21.8 You may also set multiple Goals and specify different Investment Amount for each of the Goals.
However, You cannot modify Your Investment Profile and it shall remain the same for all Your Goals.
21.9 Completion of KYC
After You provide Your Parameters, Your Account will be activated. You will provide the necessary
information to pass the “Know Your Customer” (KYC) checks before your account is activated.
If You have a KYC record with Central Depository Services Limited (“CDSL”), You authorize Us to obtain Your
details from CDSL. However, if You are not registered as a KYC compliant customer with CDSL, You will have
to get registered and complete all the formalities to ensure your Account will remain activated.
21.10 You shall provide any and all information that may be required by Us or the Broker from time to
time in compliance with existing legal norms and regulations, including but not limited to contact
information, address and tax-related information and any information required under existing or future KYC
norms and laws or as may be deemed necessary to authenticate Your profile or any action taken using Your
Account. You agree that We may take steps to verify the veracity of such information provided and You shall
cooperate with Us in providing all information requested by Us. You acknowledge that failure to provide such
information in a timely manner may result in ineligibility to avail some or all Our Services and We shall
not be liable for any losses of whatsoever nature resulting from such failure to provide information on Your
part. Any information provided by You may be required to be shared with relevant regulatory or statutory
authorities and You authorize Us to provide all information to such regulatory or statutory authorities as
and when required.
21.11 All transfers of Investment Amount shall be made by You directly through the Broker selected by
you. The Investment Amount is not a deposit with Us and is not insured.
21.12 You acknowledge and agree that processing of all Transactions from Your bank account, may take 1
(one) to 7 (seven) calendar days excluding bank holidays.
21.13 If for any reason the Broker is unable to allow a Transaction for purchase or redemption of the
full quantity of units of ETFs proposed to be transacted for You through Our Services, the Broker shall be
entitled to process a lesser quantity of units than the proposed quantity of units to be purchased or
redeemed. In such an event, We or the Broker shall not be liable for non-execution of Transactions for the
entire or remaining quantity of units.
21.14 If the Investment Amount specified by You cannot be invested in full due to the pricing of the
instrument and rounding-off errors, the balance amount would remain in Your brokerage account with the
Broker, which can be utilized by You for future investment.
21.15 You acknowledge and agree that any Transactions made cannot be cancelled. However, You may
choose to discontinue using Our Services as per Paragraph 23. We may consolidate Your Investment Amount from
Your different Goals for the purposes of the Transactions. However, You can track each of Your Goals
21.16 You may track Your Investment Amount, Transactions made and the progress made in relation to
Your Goal at any time on the App.
21.17 The App will remember Your Parameters and will suggest rebalancing Your investment portfolio on
the App to increase the chances of You achieving Your Goals in a timely manner. You may choose to undertake
Transactions based on the recommendations generated by the App. If You do not modify Your investment
portfolio on the App based on the recommendations, it may add additional uncertainty to the achievement of
21.18 You may request a copy of any scheme related or policy documents by emailing Us at
21.19 You shall inform Us promptly and in either case within 2 (two) business days if You have failed
to carry out Your commitments in relation to any securities or if You are in default with any other
stockbroker or sub-broker.
21.20 Compliance and Grievance Redressal: In case of any queries or grievance with respect to the
Transaction or any investments made by You by using Our Services, please contact firstname.lastname@example.org.
22. Services Disclaimers and Warranties
22.1 We will look to You for clear guidance on Your Goals and Investment Profile. We shall not review or
analyze Your Goals, Investment Profile or Your current financial position and shall not be liable for any
investments selected based on the information provided by You. Accordingly, before making an investment
decision, You need to consider whether the List or any other information generated by You using Our App is
appropriate for Your investment objectives, financial situations and needs. Moreover, the information
provided by using the algorithm and Our Services may not be suitable for all investors. You should undertake
an independent analysis of the suitability of Our Services, based on Your specific circumstances.
22.2 We shall not be liable for any losses, damages, expenses, costs or claims resulting out of
fraudulent or unauthorized use or access of Your Information or KYC records.
22.3 We do not in any manner:
(a) Guarantee payments
on any ETFs;
(b) Guarantee liquidity of any ETFs;
Guarantee the payments of any interest or dividends;
Promise good delivery; or
(e) Promise, indicate or guarantee
22.4 We shall be under no duty to verify compliance with any restrictions on Your authority or power
22.5 By using Our Services, You acknowledge and agree that investment in ETFs is subject to market
risks including the possible loss of the Investment Amount. Past performance may or may not be sustained. We
recommend that You invest only from Your disposable income. We do not recommend investing any monies by
taking a loan or investing the entirety of Your savings. Invest only that amount which You are willing to
22.6 It is clarified that We do not gain or seek to gain any direct or indirect personal advantage
from the Transactions and shall not consider Your interest inferior to Our own and will intimate You if
there is any conflict of interest.
22.7 We undertake to provide Our Optional Services on a best efforts basis within the ambit of SEBI
Regulations and any other applicable law.
22.8 We shall, at Our sole discretion, not process any Transactions where the Transactions are
designed in a manner to violate any law.
22.9 We reserve the right to amend, modify, restrict, suspend or discontinue Your access to any or all
parts of the App without prior notice. If Your Account has been disabled, suspended or discontinued by Us,
You will not create a new account, whether with Your information or otherwise.
25. App and Services risk
25.1 You choose to use the App and the Services at Your own risk. These risks may include, but not be
limited, to the following:
(a) Internet Frauds: We use the internet to provide Our Services and while We take measures to protect
Your data, using the internet has well-publicized risks including delays, non-delivery, data corruption,
hacking, interception, unauthorized amendment and other tampering and, in some cases may compromise
confidentiality. Additionally, viruses, worms, Trojan horses and other malicious code may add to the risk.
Because We cannot guarantee the security of data transmitted through the internet, We will not be liable if
data is delayed, not received, corrupted, used to hack into systems, intercepted, amended without authority
or otherwise tampered with or if confidentiality or privacy is lost.
(b) Mistakes and Errors: The filling in of applicable data for Transactions requires proper, accurate
and complete details. In the event You receive any incorrect credit by reason of a mistake by any Broker or
any third party, the concerned Broker or third party shall be entitled to reverse the incorrect credit at
any time whatsoever. You shall be liable and responsible to the Broker to accede to instructions without
questions for any unfair or unjust gain obtained by You as a result of the same.
(c) Technology Risks:
The technology for enabling Our Services may be affected by virus or other malicious, destructive or
corrupting code, program or macro. Further, the technology may require updates or maintenance and during
such time Our Services may not be available which could result in delays in processing Your Transactions.
Additionally, We may roll out updates to the App which You would be required to download. We shall not be
liable for any damages, loss of profits or prejudice suffered due to any of the technology risks outlined
above or Your failure to download and install the updates provided by Us from time to time.
(d) Limits: We may from time to time impose maximum and minimum limits on the Investment Amount and
You acknowledge and agree that the same is being imposed to reduce Your risk and that You shall be bound by
such limits and shall strictly comply with them.
27. General Declarations
27.1 Rights and responsibilities of Investment Adviser-
(a) The Investment Adviser is registered with SEBI under the Investment Advisers Regulation and is in
compliance with: (i) all provisions of the “Investment Advisers Regulations", including but not limited to
the code of conduct as specified in the third schedule, conducting a yearly audit, resolving grievances and
eligibility criteria for grant of registration; and (b) the notifications and circulars issued thereunder.
(b) The Investment Adviser, the principal officer and the persons associated with investment advice
have the necessary experience and knowledge to provide the services to the Advisory Client as outlined in
(c) The Investment Adviser shall put forth an investment policy statement for the Advisory Client
based on his/her objectives, needs and risk profile. Any recommendations from the Investment Adviser shall
be based on the mutually agreed upon investment policy statement. The objectives needs and risk profile
shall be reviewed at least once a year.
(d) The Investment Adviser requires to ensure proper planning of investment corpus and as a best
practice the Investment Adviser will allocate the initial corpus into liquid funds/liquid ETF as a temporary
& immediate asset allocation and there on using the same for further strategic investment planning. The
Investment Adviser allocates the cash balance arriving out of transfer into investment accounts and/or sale
proceeds of various investments, into liquid mutual funds/ETF until further allocation as per the investment
plan approved by the Advisory Client.
(e) The Investment Adviser, while providing investment advice, shall make adequate disclosure to the
Advisory Client of all material facts relating to the key features of the products/securities including
performance track record. The Investment Adviser shall specifically draw the Advisory Client’s attention
towards warnings, disclaimers in documents, advertising material related to its investment advice. The
Investment Adviser shall provide reports to the Advisory Client on potential and current investments.
(f) The Investment Adviser shall consider the Advisory Client’s experience, knowledge, investment
policy statement, risk appetite and capacity before recommending a financial product. The Investment Adviser
shall obtain all consents and permission from the Advisory Client prior to undertaking any actions in
relation to the securities or investment products advised by the Investment Adviser.
(g) The Investment Adviser shall not act on its own account, knowingly to sell securities or
investment products to or purchase securities or investment product from the Advisory Client.
(h) The Investment Adviser is carrying on its activities independently, at an arms-length basis with
its related parties and to the best of its ability, shall disclose all conflict of interest promptly to the
Advisory Client and shall not derive any direct or indirect benefit out of the Client’s
securities/investment products. The conflict, actual or potential, may pertain to association with any
issuer of product/securities, including any material information or facts that might compromise the
Investment Adviser objectivity or independence in the carrying on of investment advisory services.
(i) The Investment Adviser shall maintain all records pertaining to Know Your Client (KYC), Risk
and Profiling, Financial Planning, Analysis Report of Investment Advice and Suitability, Agreements,
Investment Advice, related books of accounts and register containing a list of clients along with dated
investment advice and rationale, Statements and relevant documents in electronic and/or physical form while
the Advisory Client is active and for a period of five years after the Advisory Client disengages with the
(j) The Investment Adviser shall not seek any power of attorney or authorizations from the Advisory
Client for the implementation of the investment advice.
The Investment Adviser shall not provide any distribution services for securities and investment products,
either directly or through its group to an Advisory Client.
The Investment Adviser shall not provide any investment advisory services, for securities and investment
products, either directly or through its group to any distribution client.
Investment advice implemented on the Advisory Client’s investment account is subject to market,
currency, economic, political and business risks. These risks may mean volatility in asset prices on a daily
basis including loss of capital permanently. The Investment Adviser shall disclose applicable risks related
to a particular product to the Advisory Client at the time of providing the investment advice.