https://www.thepolicyexchange.com  (hereinafter referred to as “Website”) is an internet-based portal/platform is owned and operated by M/s. Fairvalue Insuretech Private Limited (CIN: U72900HR2022PTC105640), a private company limited by shares incorporated under the provisions of Companies Act, 2013 (Act No. 18 of 2013) having its registered office at FLAT NO. 701 TOWER 5, VIPUL GREENS SOHNA ROAD SECTOR 48, GURGAON, Gurgaon, Haryana, India, 122018  and includes its affiliates, group companies, officers, employees, agents and authorized representatives or person(s)/entity(ies) associated/connected with it (hereinafter referred to as “Fairvalue”/ “We”/”Us”/Our/”) to provide technology-enabled facilitation services  for financial products and alternate investment opportunities. Fairvalue is committed to processing personal data in compliance with applicable laws including the Digital Personal Data Protection Act, 2023 and adopts reasonable security safeguards, however You acknowledge and accept inherent risks of internet-based data transmission for users (hereinafter referred to as “You” “Your” “Yourself”) accessing the Website. We have designed this Privacy Policy (“Privacy Policy”) to help you understand how we collect, use and safeguard the information you provide to us and to assist you in making informed decisions when using our Services. Please read the terms of the Policy carefully before using or registering on the Website or accessing any material, information or services through the Website. Accessing, browsing or otherwise using the Website indicates your agreement to all the terms and conditions under this Policy and your free, specific, informed, unconditional and unambiguous consent (as defined under the Digital Personal Data Protection Act, 2023) to processing, retention and disclosure of your Personal Information, Personal Data and Non-Personal Information for lawful purposes as described in this Policy. The terms of this Policy should be considered part of the terms of use of Website as provided separately in the Website. If you do not agree to these terms, you agree that your sole and exclusive remedy is to discontinue using the Website. Your compliance with these terms is a condition to your right to access the Website. Your breach of any provision of these terms will automatically, without the requirement of notice or other action, revoke and terminate your right to access the Website. To the maximum extent permitted under applicable law, Fairvalue disclaims all liability arising from unauthorized access, data breach, loss, misuse, alteration or unavailability of information, except where such liability cannot be excluded under applicable law, and you acknowledge the inherent risks of transmission over the internet. By using Website and/or registering on the Website i.e. www.thepolicyexchange.com, you may choose to provide your consent to Fairvalue to contact you via email, phone call, SMS or WhatsApp, or other electronic modes for the purposes of i) providing its services; ii) sharing product information; iii) informing you about promotional or marketing offers available on the Website. Your personal data will be processed in accordance with this Policy and applicable law. You may withdraw your consent at any time through the opt-out mechanisms provided in the communication or by contacting us using the details set out in this Policy. Upon withdrawal of consent, Fairvalue will cease processing your personal data for the relevant purpose, unless such processing is required for compliance with legal obligations, enforcement of legal rights, fraud prevention or is otherwise permitted under applicable law, and You acknowledge that certain services may become unavailable upon such withdrawal. You hereby agree that Fairvalue may contact you for the above-mentioned purposes even if you have registered yourself under DND or DNC or NCPR services, to the extent permitted under applicable law. This authorization shall remain valid until your account is deactivated by either you or Fairvalue.

For the purpose of this Policy:

• ‘Non-Personal Information’ shall mean and refer any information/data pertaining to You, which cannot be used to personally identify You such as anonymous usage data, general demographic information We may collect, referring/exit pages and URLs, platform types, preferences you submit and preferences that are generated based on the data You submit and number of clicks.
• ‘Personal Information’ shall mean the information/data that can be used to uniquely identify or contact a single person and shall include “personal data” as defined under applicable law. Personal Information for the purposes of this Policy shall include, but not limited to, information regarding Your name, address, telephone/mobile number, date of birth/date of incorporation (as may be applicable), gender (applicable to individual user only), e-mail address, bank details, insurance policy details, income details, identification number or documents etc. disclosed by you to access the Services.
• ‘Sensitive Personal Information’ shall mean such Personal Information which consists of information relating to password; financial information such as bank account or credit card or debit card or other payment instrument details; or such other information which is so classified under the applicable laws in India. However, any information that is freely available or accessible in public domain or furnished under the Right to Information Act, 2005 or any other law for the time being in force shall not be regarded as Sensitive Personal Information for the purposes of this Policy.
• ‘Service(s)’ refers to Fairvalue’s services accessed via Website, in which users can view and participate in various alternate investment opportunities.
• ‘Third Party’ refers to any person or entity other than you or us.
  This Privacy Policy explains how Fairvalue collects Personal and Non-Personal Information, which may either be mandatory or voluntary, and stores, uses, discloses and protects such information. Fairvalue reserves the right to use, process, retain and share such information with affiliates, service providers, partners and regulatory authorities for legitimate business purposes including service delivery, compliance, analytics and fraud prevention, to the extent permitted under applicable law, and shall not be liable for any actions of third parties beyond its reasonable control.

Information and Usage

1. You may need to provide Fairvalue Your Personal Information and Personal Data including certain sensitive Personal Information, during the course of using the services, for instance, while creating a User ID, or provide information in Your User Account while registering on the Website, upload content, communicate with Fairvalue by email or otherwise, provide reviews for the content available on the Website etc., ., and such information shall be provided by You voluntarily with free, specific, informed and unambiguous consent.
2. Fairvalue collects only such Personal Information that Fairvalue believes to be relevant and is required to understand You or Your interests and render Services or for lawful purposes as permitted under applicable law.
3. Fairvalue collects your personal information in order to record, support and facilitate Your participation in the activities You select, track Your preferences, to provide You with a customized Website experience, to notify You of any updated information and new activities and other related functions offered by Fairvalue, keep You informed about latest content available on the Website, new features, to follow up with You after Your visit to the Website, to otherwise support Your relationship with Fairvalue or to prevent fraud and unlawful use of the Website and for compliance with legal obligations and legitimate business purposes as permitted under applicable law.
4. Personal Information provided by you is used only:
   a. To facilitate your use of the Website.
   b. To respond to your inquiries or fulfill your requests for information about the various Services .
   c. To provide you with various news and related contents on the Website.
   d. To personalize your experience on the Website and Fairvalue’s other websites by presenting advertising, products and offers tailored to you;
   e. To help you address your problems with the Website;
   f. If you post any comments or feeds on the Website, to process and upload the same;
   g. For proper administering of the Website;
   h. To conduct internal reviews and data analysis for the Website;
   i. To improve the Services, content and advertising on the Website;
   j. To protect the integrity of the Website; and
   k. To respond to judicial process and provide information to law enforcement agencies or in connection with an investigation on matters related to public safety, as permitted by law.
   l. To enforce Fairvalue’s legal rights, prevent fraud, security incidents or misuse of the Website, and for any other purpose permitted under applicable law.
5. In an effort to make our Website effective, certain information may automatically be collected each time You visit the Website and such information may be stored in server logs. These statistics do not identify You personally, but provide Us the information regarding Your visit to the Website and the type of user who is accessing Our Website and certain browsing activities by you. Fairvalue uses them solely to analyse trends, administer the site, track a User’s movement and gather broad demographic information for aggregate use. The duration of Your stay on the Website is also stored in the session along with the date and time of Your access and such processing is undertaken for legitimate business purposes.
6. You acknowledge that relevant information of yours may be shared with the third-party service providers for KYC purposes and other verification, compliance or service-related purposes, subject to applicable law and appropriate safeguards.
7. You acknowledge that some of this information related to the Website and Your visit to the Website may be shared with the sponsors, investors, advertisers, developers, strategic business partners of Fairvalue (collectively “Business Partners”) to enhance and grow the business of Fairvalue through the Website on a need-to-know basis and in compliance with applicable law. This anonymous information is collected using any prevailing industry standard technologies.
8. Fairvalue is concerned of Your privacy and ensures that this information which are shared with the Business Partners will not include any of Your Personal Information except where necessary and permitted under applicable law or with Your consent. Also, all Sensitive Personal Information collected from You (if any) are used, stored or disseminated strictly in compliance with the Information Technology Act, 2000 and Digital Personal Data Protection Act, 2023 and the rules made thereunder, as amended from time to time.
9. When You use the Website, Fairvalue ‘s servers (which may be hosted by a Third-Party service provider) may collect information indirectly and automatically about Your activities on the Website; for instance, by way of cookies. A cookie is a small amount of data that is sent to a user’s browser from a web server and is eventually stored on a user’s computer hard drive and is used for enhancing user experience, analytics and lawful business purposes.
10. Whether You want Your web browser to accept cookies or not is up to You. In the event You choose to decline cookies, You may not be able to fully experience all features of the Website. You can also delete Your browser cookies or disable them entirely, but this may significantly impact Your experience with the Website and may make parts of the Website non-functional or inaccessible and You acknowledge that Fairvalue shall not be liable for any such limitations.
11. In the event Fairvalue uses Third-Party service providers to serve advertisements on behalf of Fairvalue across the internet including this Website, such service providers may collect anonymous information about Your visits to the Website, and Your interaction on the Website. Fairvalue assures You that this is solely for the purpose of business promotion and growth of Fairvalue and no Personal Information of Yours is collected or used in this process.
12. Fairvalue assures You that it DOES NOT trade or sell Your Personal Information in any manner, except as specified herein, or if express consent is sought from You or where otherwise permitted under applicable law.
13. Fairvalue does not disclose Personal Information to Third-Parties in the normal course of operations. However, You understand that, in situations when Fairvalue is legally obligated to disclose information to the government or other Third-Parties, Fairvalue will do so and may also disclose such information for compliance with legal obligations, enforcement of legal rights, or prevention of fraud as permitted under applicable law.
14. Fairvalue assures You that it implements reasonable security safeguards in accordance with the Digital Personal Data Protection Act, 2023 and applicable laws to protect your personal data. However, while we strive to use reasonable and commercially acceptable security practices and procedures to safeguard information, no method of transmission over the internet or electronic storage can be guaranteed to be completely secure, and You expressly acknowledge and agree that Fairvalue shall not be liable for any unauthorized access, disclosure, alteration, loss, or destruction of data arising from events beyond its reasonable control, including but not limited to cyber-attacks, system failures, force majeure events, or acts/omissions of third parties.

Shared Personal Information and Modification

1. You shall be required to submit Your Personal Information such as name, phone number, email address etc. at the time of registering or making any comments or posting feeds to any news thread/blogs/articles on the Website. Registration on Website can also be done by supplying a unique phone number/OTP, email address and password, or by linking your Facebook or Google accounts. If you choose to link your social-media account or account relating to other Third-Party services to the our Services, you may be asking Third Parties to send us certain information from those social media accounts or services accounts, and You are authorizing us to collect, store, and use what they send us in accordance with this Policy. You can disassociate your registration from Third-Party accounts any time.
2. Fairvalue reserves the right to contact you for sharing or seeking information about you and your pending or completed transaction and such communication shall be deemed lawful and shall not constitute a breach of the DND/DNC/NCPR regulations, to the extent permitted under applicable law. We may use publicly available databases, including privately-held marketing and data analytics resources. For example, we may receive demographic information (age, gender, household income, job industry and job title) from these sources and process such information solely for lawful purposes, including personalization, analytics, and improvement of Services, without violating your privacy rights.
3. . If You are a registered user of our services, We provide You with tools and account settings to access or modify the Personal Information You provided to Us and associated with your account (“User Account”). You can also modify or even permanently delete your User Account as per the instructions on Our Website. If You follow the instructions, Your User Account will be deactivated and then deleted. When Your User Account is deactivated, it is not viewable on the Website. For up to 30 (thirty) days after deactivation it is still possible to restore Your User Account if it was accidentally or wrongfully deactivated. After 30 (thirty) days, We begin the process of deleting Your User Account from Our systems, which can take up to a week. However, You acknowledge that for our internal purposes, auditing, fraud prevention, or any requirements under applicable law including the Digital Personal Data Protection Act, 2023, Fairvalue may retain certain information provided by You in Your User Account for the period required under law or regulation.
4. Without prejudice to the foregoing, users may also request deletion of their Personal Data by contacting Fairvalue through the details provided in this Policy. Upon receipt of such request, Fairvalue shall verify the identity of the user and process the request within a reasonable timeframe. Notwithstanding any such request or account deletion, Fairvalue shall have the right to retain Personal Data to the extent required for compliance with applicable law, regulatory requirements, audit purposes, fraud prevention, enforcement of contractual rights, or for the establishment, exercise, or defence of legal claims. Where deletion is carried out, such Personal Data shall be deleted or anonymized in accordance with applicable law. Fairvalue shall not be responsible for deletion of data that is required to be retained under applicable law or for legitimate business purposes.

Links to Third Party Websites

1.The Website and any e-mail sent to You may also contain/display third-party advertisements and links to other websites or products and services. Fairvalue does not share any Personal Information or Personal Data with these third-party websites, agents, or advertisers without Your explicit consent, unless required by applicable law. However, Fairvalue reserves the right to share with You the advertisements on behalf of any other parties. 2. Fairvalue may provide links to other websites (“Linked Site”) on the Website or any e-mail sent to You. However, Fairvalue has no control over such websites and its affiliates with, responsible for, or liable for the actions such third party websites unless expressly specified on the Website. These Linked Site are solely for advertisement or informational purposes and Fairvalue is not responsible for any form of transmission, whatsoever, received by You from any Linked Site. Accordingly, Fairvalue make no representations concerning the privacy practices or policies of such third parties, the terms of use. 3. Fairvalue may allow certain third-party websites, advertisers, or ad networks to serve ads on the Website. These third parties may use cookies, pixels, or similar technologies to collect information about your browsing behaviour on the Website. This information may be used to personalize advertising or measure ad effectiveness. Fairvalue does not have access to or control over such third-party practices, and the information practices of these third parties are not covered by this Policy. For details about their data collection and privacy practices, you should review the respective third party’s privacy policy. By using the Website, You acknowledge and consent that such third parties may collect and process information in accordance with their policies, and Fairvalue shall not be responsible or liable for their data practices or any resulting impact on Your privacy.

Security

1. Fairvalue strives to ensure the security, integrity and privacy of Your Personal Information and to protect Your Personal Information against unauthorized access or unauthorized alteration, disclosure or destruction. For this purpose, Fairvalue adopts reasonable and commercially acceptable standards and practices for data collection, storage, and processing, including appropriate encryption, access controls, and physical security measures to safeguard Your Personal Information in compliance with applicable laws, including the Digital Personal Data Protection Act, 2023.
2. Fairvalue shall not be responsible for any breach of security or unauthorized use of Your Personal Information caused by third parties, including but not limited to hackers, cyber-attacks, or acts of Linked Sites, except to the extent caused by Fairvalue’s gross negligence or willful misconduct.
3. The Website may be linked to many other sites and Fairvalue is not and shall not be responsible for the privacy policies or practices of such third-party sites, as such matters are beyond Our control.
4. Notwithstanding anything contained in this Policy or elsewhere, Fairvalue implements reasonable technical and organizational security measures in accordance with applicable law, including the Digital Personal Data Protection Act, 2023, to protect Your Personal Information. Fairvalue shall not be held liable for any loss, damage, or misuse of Your Personal Information arising from events beyond its reasonable control, provided such events occur despite Fairvalue’s implementation of reasonable and commercially acceptable security safeguards. This includes, without limitation, acts of government, natural disasters, cyber-attacks, computer hacking, unauthorized access to computer data or storage devices, system failures, breaches of security or encryption, or any acts or omissions by Linked Sites or other third parties. Fairvalue is also not responsible for the privacy practices, content, or security of independently operated Linked Sites or third-party websites.
5. Data Breach Notification and Response:
   In the event of a data breach involving Personal Data, Fairvalue shall: .Take immediate steps to contain, investigate, and mitigate the breach ; . Assess the risk and impact on affected users; . Notify relevant regulatory authorities as required under applicable law; . Inform affected users where the breach is likely to result in significant harm; . Maintain records of such breaches and remedial actions taken.

Disclosure

1. Fairvalue will use information only in accordance with the Policy under which the information was collected, unless Fairvalue has obtained Your explicit, free, specific, informed, and unambiguous consent or is required to disclose the information under applicable law. 2. Fairvalue may share Your Personal Data with authorized third-party service providers strictly for KYC, verification, regulatory, and compliance purposes, or where such processing is necessary to provide Our Services or required under applicable law. Fairvalue ensures that such service providers are contractually obligated to implement reasonable and commercially acceptable security safeguards, process Personal Data solely in accordance with Our instructions and applicable law, and not use Your Personal Data for any other purpose.
2. Based on your explicit consent, Fairvalue reserves the right to disclose any information Fairvalue may have about You (including Your identity) if Fairvalue determines that such disclosure is reasonably necessary in connection with any investigation or complaint regarding Your use of the Website, or to identify, contact or take legal action against any person or entity that may cause injury, interference, or violation of Fairvalue’s rights, property, or the rights or property of other Users, including Fairvalue’s contributors.
3. Fairvalue may disclose Personal Data as required to comply with applicable laws, regulations, legal processes, or governmental requests. Such disclosure may also be made to other companies or organizations for fraud prevention, security, or risk management purposes, to the extent necessary and permitted by law. Fairvalue will take reasonable measures to ensure that such disclosures comply with applicable laws in India and, where legally permissible, will make reasonable efforts to inform You of such disclosure. Fairvalue reserves the right to disclose any information, including Personal Information, whenever Fairvalue deems it necessary to comply with applicable law, regulation, legal process, or governmental request, and shall use reasonable measures to ensure such disclosure is lawful and proportionate.
4. You acknowledge and agree that Fairvalue may preserve any communication by You with Fairvalue through the Website, and may also disclose such data if required to do so by law or if Fairvalue determines that such preservation or disclosure is reasonably necessary to: (i) comply with legal process; (ii) enforce this Policy; (iii) respond to claims that such data violates the rights of others; or (iv) protect the rights, property, or personal safety of Fairvalue, its employees, users, visitors, or the public. Fairvalue will use reasonable efforts to inform You in the event of such disclosure where legally permissible.
5. Fairvalue does not share Your Personal Information with third-party advertisers, Linked Sites, or other websites without Your explicit consent. Any interaction with third-party websites or services is at Your own risk, and Fairvalue shall not be responsible for their privacy practices, content, or security.
6. . Fairvalue ensures that any third-party service providers, SDKs, or partners integrated into its Digital Lending Applications (DLAs) collect Personal Data strictly on a need-to-know basis and only after obtaining explicit user consent.
7. No third party shall be permitted to access or collect Personal Data directly from the user through the DLA without: . Prior disclosure to the user; . Explicit and informed consent; . Compliance with applicable data protection laws. Fairvalue remains responsible for ensuring that such third parties adhere to equivalent data protection and security standards.

Exclusion

This Policy applies only to Personal Data collected by Fairvalue through the Website or offline interactions in accordance with Clauses 1 and 2 above and does not apply to information voluntarily disclosed in public areas of the Website or provided through unsolicited means, which may not be treated as confidential. However, to the extent such information constitutes Personal Data under applicable law, including the Digital Personal Data Protection Act, 2023, Fairvalue shall process it solely for legitimate purposes related to the Website and in compliance with applicable laws, while implementing reasonable and commercially acceptable safeguards, and without limiting its statutory or contractual obligations.

General Provisions

1. Unless stated otherwise, the Policy applies to all information that Fairvalue has about You and Your User Account with Fairvalue.
2. . If You choose to visit the Website, Your visit and any dispute over privacy or Personal Data shall be subject to this Policy and the Website’s Terms of Use. You acknowledge that this Policy, together with the Terms of Use as updated by Fairvalue from time to time, shall govern Your relationship with Fairvalue in respect of Your use of the Website.
3. Data Retention: Fairvalue shall retain Personal Data only for as long as necessary to fulfil the purposes for which it was collected and to comply with applicable law.
4. Notwithstanding the foregoing, Fairvalue may retain Personal Data for longer durations where necessary for compliance with legal or regulatory obligations, audit and internal record-keeping, fraud prevention and investigation, enforcement of contractual rights, or for the establishment, exercise, or defence of legal claims.
5. In particular: . KYC and identity-related data shall be retained in accordance with applicable regulatory requirements; . Transactional and financial data shall be retained for the minimum period prescribed under applicable law; . Account-related data may be retained for the duration of the account and thereafter as required for business, legal, or regulatory purposes. Fairvalue may retain Personal Data notwithstanding withdrawal of consent or account deletion, to the extent permitted under applicable law.
6. Upon expiry of the applicable retention period, Personal Data shall be deleted, anonymized, or archived in accordance with applicable law. Fairvalue may retain anonymized or aggregated data for legitimate business purposes without restriction.
7. Fairvalue shall ensure that Personal Data is securely destroyed or anonymized upon expiry of the retention period or upon fulfilment of the purpose for which such data was collected, unless retention is required under applicable law. Data destruction shall be carried out using industry-standard secure deletion methods to prevent unauthorized access or recovery.
8. You have the right at any time to prevent us from contacting You for marketing purposes. When we send a promotional communication to a user, the user can opt out of further promotional communications by following the Unsubscribe instructions provided in each promotional email.
9. This Privacy Policy shall be made available and accessible on all Digital Lending Applications (DLAs), websites, and platforms through which Fairvalue provides its services. Users shall be able to access, review, and download this Privacy Policy prior to onboarding and at all times during usage of the services.
10. This Privacy Policy has been reviewed and approved by the Chief Information Security and Chief Risk and Compliance Officer of fair value Insurtech Private Limited. Any changes to this Policy shall be subject to internal review and approval in accordance with applicable laws and governance standards.

Modification of Policy

Fairvalue may update or replace this Policy from time to time to reflect changes in law or our practices regarding the processing of Personal Data. Material changes that affect how your Personal Data is collected, used, or shared will be communicated to you through reasonable means, such as email or website notification. Your continued use of the Website or Service after such notification constitutes your acceptance of the updated Policy. Where required by law, your consent will be obtained before implementing changes that affect the processing of your Personal Data..

Governing Law

1. This Policy shall be governed by and construed in accordance with the applicable laws in India. Subject to the arbitration provisions below, the courts at Delhi, India, shall have exclusive jurisdiction over the subject matters of this Policy.
2. Any disputes relating to this Policy shall be referred to and finally resolved by arbitration in accordance with the Arbitration and Conciliation Act, 1996, (the “Arbitration Act”) as amended from time to time. The arbitration shall be conducted by a sole arbitrator jointly appointed by the Parties. If the Parties are unable to agree on a sole arbitrator within fifteen (15) days, the arbitrator shall be appointed in accordance with the rules of the Arbitration Act. The seat and venue of arbitration shall be Delhi, India. The language of the arbitration shall be English. The arbitral award shall be final and binding on both Parties and enforceable in any court of competent jurisdiction.

Severability

Fairvalue endeavors and has made every effort to ensure that this Policy complies with applicable laws. If, for any reason, a court of competent jurisdiction finds any provision of this Policy, or portion thereof, to be unenforceable, the invalidity or unenforceability of such part shall not prejudice or affect the validity or enforceability of the remainder of the Policy.

Integration

This Policy as posted on the Website constitutes the sole and complete statement of Fairvalue’s Privacy Policy with respect to the Website. No summary, modification, restatement, or other privacy statement or policy in any form shall be valid unless Fairvalue posts a new or revised Policy on the Website.

Contact Us

For any query or assistance, You may contact Fairvalue’s customer service team at at  info@thepolicyexchange.com.

Grievance Officer

Name : Kashish Jain
Contact : kashish@thepolicyexchange.com