Privacy Policy

This policy explains what Fairvalue Insuretech Private Limited (“Fairvalue”, “we”) does with your personal information when you use the The Policy Exchange – Investor Portal mobile app. It covers the app specifically.

Where it differs from the policy on www.thepolicyexchange.com, this one applies to the app.

1. What we do

Fairvalue runs a technology platform that helps transfer existing life insurance policies from policyholders who want to exit them to participants who take them over. That transfer is called an assignment, and it happens under Section 38 of the Insurance Act, 1938.

We are not an insurer, a lender, an NBFC, an investment adviser, a broker, a wealth manager or a marketplace. We do not sell insurance and no new policy is issued through the app. We do not collect money in the app. Knowing this explains why we ask for what we ask for, and why we do not ask for more.

2. What we collect

When you sign up we collect your mobile number, email address, name and date of birth. The mobile number and email are verified by one-time password. A referral code, if you have one, is optional.

Before an assignment can be documented in your name, the law requires us to verify who you are. At that point, and only after you have given us a separate consent, we collect:

. your bank account number, IFSC, account type and account holder name, with a cancelled cheque or bank statement;

· your photograph, address, gender, nationality and marital status;

·  your occupation, annual income and source of funds, and whether you are a politically exposed person, both of which anti-money-laundering rules require us to record;

· nominee details, if you choose to add a nominee. This is optional and you can skip it.

We read your cheque images automatically to fill the form for you, so that you confirm details rather than typing them. You can correct anything that comes out wrong.

While you use the app we also record a device identifier, your device name, the app version and, on our servers, your IP address. These tie your session to your device, help us spot unauthorised access, and form the record of consent the law requires us to keep. We record whether you are a smoker, because the underlying policy documentation asks for it.

You can upload documents we ask for in connection with a particular assignment, and a payment receipt once you have transferred funds. Those are stored with your account.

3. What we never collect

The app does not ask for, and cannot reach:

· your location, at any time, including in the background;

· your contacts, messages or call logs;

· your microphone;

· any advertising identifier — there is no advertising, analytics or tracking software in this app at all;

·  your card, UPI or other payment credentials, because no payment is made in the app.

The only permissions the app asks for are the camera and your photo library, and it asks for each one at the moment you choose to upload a document, never at start-up. If you say no, the rest of the app still works

4. Biometric sign-in

If you turn on fingerprint or face sign-in, your device does the checking. Your fingerprint or face never leaves your phone. We never receive it, never store it, and have no way to see it. All that reaches us is a setting saying you turned the feature on. It is optional, and one-time password sign-in always remains available to you.

5. How we use it

We use your information to run your account and keep it secure, to carry out the verification the law requires, to record your interest in an assignment and prepare the documentation, to put that documentation to the insurer for approval, to keep you and your relationship manager informed, to reconcile money you transfer and money due to you, to meet our obligations under tax, insurance and anti-money-laundering law, and to detect and prevent fraud.

We do not use your information to advertise to you or to profile you, and we do not sell it. Nothing about your account is decided by an automated process alone.

6. Who else sees it

We share only what is necessary, with:

· The insurance company whose policy is being assigned, which needs your identity, KYC, bank and nominee details to approve the transfer and issue the endorsement;

· The service providers who carry out PAN, Aadhaar and bank verification for us;

· The cloud providers that host our systems and store your documents, and the content provider that delivers material shown inside the app;

·  Our auditors and professional advisers, where the engagement requires it;

·  Regulators, courts and authorities, where the law requires it.

If our business is acquired or reorganised your information may transfer with it, subject to the same protection. We do not share your information with anyone for advertising.

7. Security

Everything between the app and our servers travels encrypted, and the app refuses unencrypted connections. Sign-in credentials sit in your phone’s secure hardware — the Keychain on iOS, the Keystore on Android. Documents are held in access-controlled storage reachable only through authenticated, time-limited links. Inside Fairvalue, access is limited to the people who need it. Sessions expire and ask you to sign in again.

No system is perfectly secure. If a breach affects your data we will tell you and the Data Protection Board of India, as the law requires.

8. How long we keep it

KYC records and identity documents are kept for at least five years after our relationship or your last transaction ends, because anti-money-laundering rules require it. Records of an assignment are kept for as long as tax, insurance and company law require, and for as long as a claim on the underlying policy remains possible. Consent records last as long as the data they relate to. One-time passwords are not kept at all once used.

9. Your rights

You can ask us for a summary of what we hold about you and who we have shared it with, have anything inaccurate corrected, ask us to delete what we are not required to keep, withdraw a consent you have given, and nominate someone to exercise these rights if you die or become unable to. Much of your profile you can edit yourself in the app. For anything else write to info@thepolicyexchange.com and we will respond within the time the law allows. We may need to confirm it is really you first.

Withdrawing your KYC consent means we can no longer facilitate an assignment for you. It does not undo processing already done, and it does not override what we must keep by law.

10. Deleting your account

You can ask us to delete your account from the side menu in the app, from www.thepolicyexchange.com/account-deletion without installing anything, or by writing to info@thepolicyexchange.com. We deactivate the account when you ask and erase your data thirty days later. Within that window you can contact us to bring it back. What the law requires us to keep — mainly KYC and transaction records — stays for the periods above and is not used for anything else. If an assignment is under way we keep what we need to finish it.

11. Children

The app is for people aged eighteen and over. We do not knowingly collect information about children, and we will delete it if we find that we have.

12. Changes

We may update this policy. The version and date are at the top. If a change matters to you we will tell you in the app or by email, and where it changes why or how we process your data we will ask you to accept it before you carry on.

13. Contact us

Write to us at info@thepolicyexchange.com or call +91 120-6939400. Our address is D-8, Sector-2, Noida, Uttar Pradesh 201301.