Privacy Policy

We appreciate your visit to the website and/or mobile application (collectively “Technology Platform”) of 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, Haryana, India, 122018  and includes its affiliates, group companies, officers, employees, agents and authorized representatives or person(s)/entity(ies) associated/connected with it (herein referred to as “Fairvalue” / “we”/”us”/ “our”) and your interest in our products and Services. At Fairvalue, safeguarding your Personal Data and ensuring your trust are of paramount importance to Us. We want you to feel confident and secure while engaging with our Platform. Fairvalue processes Personal Data in compliance with applicable laws including the Digital Personal Data Protection Act, 2023 and the rules thereunder.

Notwithstanding the foregoing, You acknowledge and accept inherent risks of internet-based data transmission for Users (hereinafter referred to as “You” “Your” “Yourself”) accessing the Platform.

This Privacy Notice explains how we collect, use, process, transfer, and protect your personal information during and after your interactions with the Platform. It also outlines the purposes for which we process your Personal Data, how it may be shared, and the rights available to you in relation to your personal information. We encourage you to read this notice carefully before using or registering on the Technology Platform or accessing any material, information or Services through the Technology Platform or otherwise to understand how we handle your data and our commitment to protecting your privacy.

Please note that this Privacy Notice applies solely to information collected through your use of the Platform. There might be other sites linked to Fairvalue. Personal information that you provide to those sites is not our property. These affiliated sites may have different privacy practices, and we encourage you to read privacy policies of these websites when you visit them.

Accessing, browsing or otherwise using the Technology Platform indicates Your agreement to all the terms and conditions under this Privacy Notice and your express, free, specific, informed, unconditional and unambiguous consent (as defined under the Digital Personal Data Protection Act, 2023 read with rules thereunder) to processing, retention and disclosure of Your Personal Information or Personal Data and Non-Personal Information for lawful purposes as described in this Privacy Notice.

The terms outlined in this Privacy Notice are intended to complement, and not replace, any other agreements or privacy statements you may have entered with Fairvalue, including client-specific notices, and remain subject to applicable laws and regulatory requirements. The terms of this Privacy Notice should be considered part of the Terms of Use of Technology Platform as provided separately in the Platform. If You do not agree to these terms, You agree that Your sole and exclusive remedy is to discontinue using the Platform. Your compliance with these terms is a condition to Your right to access the Platform. 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 Technology Platform

We may update this Privacy Notice periodically to reflect changes in legal requirements, our business practices, or the Services we provide. We encourage you to revisit this page regularly to stay informed about how we continue to protect your Personal Data.

To the maximum extent permitted under applicable laws, 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 or registering on the Technology Platform 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 Platform.

Where Fairvalue's processing of Your Personal Data is based on Your consent, 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 Privacy Notice, without deactivating Your account, unless the Personal Data concerned is necessary for the continued provision of a Service, in which case Fairvalue will indicate which Service(s) are affected before giving effect to the withdrawal.

Upon a valid withdrawal request, Fairvalue will, within a reasonable time, cease, and shall cause its data processors to cease,  processing Your Personal Data for the relevant purpose, except to the extent such processing is required or authorized under the Digital Personal Data Protection Act, 2023, the rules made thereunder, or any other law for the time being in force in India (including retention obligations under applicable RBI, PMLA, or other sectoral regulations, where relevant to Fairvalue's business.

You acknowledge and understand that withdrawal of consent shall not affect the lawfulness of any processing carried out on the basis of Your consent before such withdrawal. Where the withdrawn data is necessary for a particular Service, that Service, or part of it, may become unavailable to You as a consequence of withdrawal.

You hereby agree that Fairvalue may seek Your explicit consent — captured through Digital Consent Acquisition (OTP-verified) and recorded on the DLT Consent Register in accordance with the Telecom Commercial Communications Customer Preference Regulations, 2018, as amended — to contact You with promotional or commercial communications by call or SMS notwithstanding Your registration under DND/NCPR. Such consent is specific to the purpose/category disclosed at the time it is captured and remains valid only for so long as You continue to be a customer of Fairvalue, or until You withdraw it, whichever is earlier.

You may withdraw this consent at any time — independent of whether You continue Your account with Fairvalue — by replying STOP, clicking the unsubscribe link in the communication or writing to_marketing@thepolicyexchange.com or info@thepolicyexchange.com. Account deactivation is not a precondition for withdrawing consent to promotional communications, and withdrawal will take effect within the timelines prescribed under applicable TRAI regulations.

This Clause does not restrict Fairvalue's ability to send transactional or service communications reasonably necessary to operate Your account or deliver Services You have availed, which continue on the basis of the underlying contract between You and Fairvalue.

For the purpose of this Privacy Notice:

1- ‘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, Technology Platform types, preferences You submit and preferences that are generated based on the data You submit and number of clicks.

2- ‘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 Digital Personal Data Protection Act 2023 read with rules thereunder, as amended from time to time. Personal Information for the purposes of this Privacy Notice 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, loan details, income details, identification number or documents etc. disclosed by You to access the Services.

3- ‘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 Privacy Notice.

4- ‘Service(s)’ refers to Fairvalue’s services accessed via the Platform, in which You can view and participate in opportunities available in financial products including policy support solutions for life insurance policyholders to strengthen their value proposition by preventing losses arising out of policy lapses.

Disclosure

Fairvalue may disclose Your Personal Data (including information that may identify You) where such disclosure is required to comply with an order of a court of competent jurisdiction, or a direction of a government or law enforcement agency lawfully authorized to make such a request, including under the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021, the Digital Personal Data Protection Act, 2023, the rules made thereunder, or any other applicable law.

Except where prohibited by law, or where doing so would defeat the purpose of the disclosure (such as in an ongoing investigation), Fairvalue will make reasonable efforts to notify You of a disclosure made.

You acknowledge and agree that Fairvalue may preserve any communication by You with Fairvalue through the Website/App, 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.

Information we collect and its usage:

You may need to provide Fairvalue Your Personal Information and Personal Data including sensitive Personal Information, during the course of availing the Services, for instance, while creating a User ID, or provide information in Your User Account while registering on the Platform, upload content, communicate with Fairvalue by email or otherwise, provide reviews for the content available on the Technology Platform and such information shall be provided by You voluntarily with free, specific, informed and unambiguous consent.

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 laws.

Fairvalue records Your consent, including a version identifier of the notice/consent form, timestamp, user ID, device ID, and IP address, and maintains such records for audit and compliance purposes in accordance with applicable laws.

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 Technology Platform 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 – www.thePolicyexchange.com (“Website”), new features, to follow up with You after Your visit to the Platform, to otherwise support Your relationship with Fairvalue or to prevent fraud and unlawful use of the Technology Platform and for compliance with legal obligations and legitimate business purposes as permitted under applicable laws.

Personal Information provided by You is used only:

a. To facilitate Your use of the Platform.

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 Platform. d.  To personalize Your experience on the Technology Platformand Fairvalue’s other websites by presenting advertising, products and offers tailored to You;

e. To help You address Your problems with the Platform;

f. If You post any comments or feeds on the Platform, to process and upload the same;

g. For proper administering of the Platform;

h. To conduct internal reviews and data analysis for the Platform;

i. To improve the Services, content and advertising on the Platform;

j. To protect the integrity of the Platform;

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 Platform, and for any other purpose permitted under applicable laws.

In an effort to make our Technology Platform effective, certain information may automatically be collected each time You visit the Technology Platform 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 Technology Platform and the type of User who is accessing Our Technology Platform 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 Technology Platform is also stored in the session along with the date and time of Your access and such processing is undertaken for legitimate business purposes.

The personal information we collect may vary based on the nature and context of your interactions with us, and may include:

Category of Personal Information/Types of Information Collected:

1. Personal Identifiers :

a)      Name

a)      Date of Birth

a)      Gender

b) Aadhaar Number (masked)

e)      PAN Number

f)      Passport Number

g)      Driving License

h)     Nominee/Beneficiry Data

2. Contact Information

a)      Phone Number

b)      Email Address

c)      Permanent Address

d)      Current Residential Address

e)      Emergency Contact Details

3. Demographic Identifiers

a)      Age

a)      Marital Status

c)      Nationality

d)      Dependents’ Information

4. Employment Information       

a)      Occupation

b)      Employer Name

c)      Job Title

d)      Employment Status

e)      Income Range

5. Education

a)      Educational Qualifications

b)     Certifications (if relevant to financial product)

6. Financial Information

a)      Bank Account Details (for premium payments)

b)      Income Proof

7. Health Information     

a)      Medical History

b)      Pre-existing Conditions

8. Multimedia Data

a)      Photographs

b)      Video Recordings

c)      Voice Recordings

d)      Signature Images

9. Digital Interaction Data

a)      IP Address

b)      Browsing History

c)      Cookies

d)      Device Information

e)      Clickstream Data

We use this information to provide Services to you. If you don’t give us the correct information or ask us to delete it, we might not be able to provide you with the Service you requested from us.

Shared Personal Information and Modification

At the time of registering on the Platform, You will be required to provide Your name, phone number, and email address. If You choose to register using Your phone number, You will additionally be required to verify it via OTP; if You choose to register using email and password, You will set a password, which Fairvalue stores using industry-standard security safeguards. Where You post a comment or feed on a news thread, blog, or article without separately registering, Fairvalue collects only the name and email address (or display handle) associated with that submission.

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.

If You are below the age of 18 (Eighteen), You must register only with the involvement and consent of Your parent or lawful guardian, in accordance with the Digital Personal Data Protection Act, 2023 read with the rules made thereunder.

Communications and Data From Other Sources

Fairvalue may contact You in relation to a pending or completed transaction You have entered into with Fairvalue (including to share or seek information about that transaction) through service or transactional communications. Such communications relate to an existing transaction between You and Fairvalue and are not treated as commercial/promotional communications for the purposes of the Telecom Commercial Communications Customer Preference Regulations, 2018, as amended, regardless of Your registration under DND/NCPR.

Fairvalue may supplement the Personal Data You provide with limited additional information — such as city, pin code, etc obtained from Fairvalue's own service providers acting as its data processors, for the purposes such as fraud checks, address verification, etc. Fairvalue does not purchase or use demographic or profiling data (such as age, gender, household income, job title, or job industry) about You from third-party marketing or data-analytics providers without Your specific consent for that purpose.

Where Fairvalue processes Personal Data that You, or another person legally obligated to do so, have made publicly available, such processing is not governed by this Privacy Notice to the extent it falls outside the scope of the Digital Personal Data Protection Act, 2023 under Section 3(c)(ii) of that Act. Fairvalue does not combine such publicly available data with other Personal Data about You to create a profile beyond what is reasonably necessary for the purpose for which it was collected.

If You are a registered user, Fairvalue provides tools and account settings that allow You to access, correct, or update the Personal Data associated with Your account ("User Account"), consistent with Your rights under the Digital Personal Data Protection Act, 2023 read with the Rules made thereunder, as amended from time to time.

You may deactivate or permanently delete Your User Account at any time by writing to Fairvalue and using the instructions available on the Technology Platform or as informed by Fairvalue to you. Once Fairvalue deactivation, Your User Account will no longer be viewable on the Technology Platform.

If Your User Account is not restored within 30 (thirty) days, Fairvalue will begin deleting the Personal Data associated with it from its systems, a process that may take up to one week to complete across all systems and backups.

Notwithstanding anything to the contrary, Fairvalue may retain specific items of Personal Data beyond deletion of Your User Account only where, and only for so long as:

(a) retention is necessary to comply with a specific obligation under applicable law (including, where applicable, retention requirements under RBI, SEBI, PMLA, the Income Tax Act, or the Companies Act);

(b) retention is necessary to establish, exercise, or defend a legal claim; or

(c) the data forms part of processing logs or traffic data that Fairvalue is required to retain for a minimum period under the Digital Personal Data Protection Rules, 2025.

Where Fairvalue engages data processors in connection with Your Personal Data, Fairvalue shall ensure such processors also erase the corresponding Personal Data in accordance with this Clause, except to the extent retention by the processor is separately required in accordance with applicable laws

In addition to the account-level deletion described above, You may request deletion of Your Personal Data at any time by contacting Fairvalue through the details provided in this Privacy Notice. Fairvalue will verify Your identity before acting on the request, and will process a valid request within reasonable period of time not exceeding 90 days of receipt.

Fairvalue may decline to delete, or may retain, specific items of Your Personal Data notwithstanding such a request, only to the extent that:

(a) retention is required or authorised under the Digital Personal Data Protection Act, 2023, the rules made thereunder, or any other applicable law (including sector-specific retention requirements, where applicable to Fairvalue);

(b) the data is reasonably necessary to establish, exercise, or defend a legal claim, including under a contract with You; or

(c) the data forms part of processing logs or traffic data Fairvalue is required to retain for a minimum period under the Digital Personal Data Protection Rules, 2025. Where Fairvalue relies on (a), (b), or (c) to retain any data, it will inform You of the specific ground relied upon if You ask.

Where a deletion request is processed, Fairvalue shall delete or irreversibly anonymise the relevant Personal Data such that it can no longer be linked to You, except for the data retained as per this Privacy Notice.

Third-Party Advertisements

The Technology Platform and any email sent to You may contain links to third-party websites ("Linked Sites") for informational or promotional purposes. Fairvalue is not affiliated with, and does not control, endorse, or take responsibility for, the content or practices of any Linked Site, except where expressly stated otherwise on the Website. Fairvalue makes no representation regarding the privacy practices, terms of use, or data handling of any Linked Site, and encourages You to review that site's own policies before sharing any information with it.

The Technology Platform uses cookies, pixels, and similar technologies including the Meta Pixel for advertising measurement and campaign attribution. Some of these are strictly necessary for the Technology Platform to function; others — including those used by third-party advertising or analytics partners such as Google Ads, Meta Pixel, analytics providers are used to personalize advertising or measure its effectiveness, and involve collection of Your browsing behavior on the Technology Platform. Your browsing/app-usage data and device or advertising identifiers are shared with Meta Platforms, Inc., only after You provide consent through the cookie/ad-preference tool, which You may withdraw at any time as per this Privacy Notice.

Strictly necessary cookies operate without requiring Your consent, as permitted under the Digital Personal Data Protection Act, 2023. All other cookies — including advertising and analytics cookies — will be activated only after You provide specific, informed consent through the cookie preference tool available on the Technology Platform. You may accept or decline each category independently, and non-essential cookies will not fire before You make a choice.

You may withdraw Your consent to non-essential cookies at any time through the same cookie preference tool. Withdrawal will not affect the lawfulness of processing carried out before withdrawal, and may affect the personalization of ads You see, but will not affect Your ability to use the core Platform.

Fairvalue is responsible for enabling the collection of information through cookies and pixels operating on the Technology Platform, in accordance with this Privacy Notice. Fairvalue does not control what the relevant third party does with that information after collection; for details of that party's own data practices, please refer to its privacy policy.

Where Fairvalue engages third-party advertising or analytics networks that collect information (such as device identifiers, cookies, or browsing behavior) for the purpose of ad targeting or measurement, such collection will occur only with Your consent, obtained through the cookie/ad-preference mechanism available on the Technology Platform, and will be limited to the categories of information disclosed to You at the point consent is sought. You may withdraw this consent at any time through [cookie settings / account preferences].

Fairvalue does not share Your Personal Data with third-party websites, agents, or advertisers for their own independent use without Your specific consent for that purpose, except where such sharing is required or authorized under the Digital Personal Data Protection Act, 2023, the rules made thereunder, or any other applicable law.

Cookies

Cookies are typically placed on your device whenever you visit us online. This allows the Technology Platform to remember your device and serves several purposes.

A notification banner may appear on Platform, allowing you to manage your consent to collect cookies. Below is a summary of the categories of cookies used and how your consent may impact your experience:

Strictly Necessary Cookies: Essential for Technology Platform functionality. These cannot be disabled as they ensure secure and reliable access to the Platform.

Optional Cookies: Optional cookies help us improve your experience by understanding how you use our website and by remembering your preferences. They may also help us assess the overall performance of our content and services.

For more information about managing cookies, refer to your browser’s help file or reach out to us at info@the policyexchange.com or you can refer to our Cookie Policy.

How we collect Personal Data:

We collect your Personal Data only where it is necessary for purposes of providing Services as more explicitly defined below, or as otherwise required during our engagement with you. This may include information obtained through the following means:

Direct Interactions: Information you share with us directly, such as when completing applications, documents, forms, claims, surveys, or when communicating with our representatives.

Third-Party Sources: Data received from issuers of financial products, insurance partners or their authorized service providers.

Fairvalue provides the services for,

a)      strengthening value proposition of financial products including but not limited to, providing documentation support, process coordination facilitation services to life insurance policyholders; and/or

b)      providing support to the life insurance policyholders to prevent losses arising out of policy lapses; and/or

c)      assisting policyholders in completion of documentation and process fulfillment as and when financial assistance options are undertaken by the policyholders.

(collectively referred to as “Services”)

How we use your personal information:

When you register or submit personal information to Fairvalue, we use this information only for the purposes outlined in this Privacy Notice or as explicitly stated during data collection. This includes:

Respond to queries or requests submitted by you.

Process requests, orders or applications submitted by you.

Administer or otherwise carry out our obligations in relation to any agreement with our authorized business partners in connection with our business operations and functions for the purpose of providing Services including pre/post sale services, and providing you any other services in relation to financial products as permissible under applicable laws.

Anticipate and resolve problems with any Services supplied to you.

To send you information about promotions or offers from issuers of financial products including insurance companies to the extent permissible under applicable laws. We might also tell you about new opportunities to strengthen value proposition of your financial products and provide support to the life insurance policyholders to prevent losses arising out of policy lapses; and/or assist policyholders in completion of documentation and process fulfillment as and when financial assistance options are undertaken by you.

To make our Services offered better, We may combine information we get from you with information about you we get from our business partners or third parties as permissible under applicable laws.

To send you notices, communications, offer alerts relevant to your use of the Services offered on this Platform.

Third parties and outsourced entities for the reasons consistent with the purposes for which the information was collected and/or other purposes as per applicable laws.

Where we need to comply with a legal obligation as per the applicable legal and regulatory framework.

As otherwise provided in this Privacy Notice.

Some features of this Technology Platform or our Services will require you to furnish your personally identifiable information as provided by you under your account section on our Technology Platform.

Legal Grounds for Processing Personal Information:

Fairvalue processes your personal information only where we have a lawful basis to do so, in accordance with applicable laws and regulations including Digital Personal Data Protection Act, 2023 and rules thereunder, as amended from time to time. The primary grounds on which we rely include:

Performance of Services: Processing is necessary to enter into or fulfil our Service obligations with you such as, to help you avail financial assistance options in relation to financial products, provide you support to prevent losses out of policy lapses, assisting you in completing documentation and process fulfillment as and when financial assistance options are undertaken by you, and support you in coordinating with issuers of financial products including issuers and their authorized service providers.

Compliance with Legal Obligations: We may use personal information collected for providing the Services to comply with applicable legal and regulatory requirements.

Legitimate Uses: We may process your Personal Data where it is necessary for the legitimate uses like facilitation of completion of documentation, process fulfillment, coordinating with issuers of financial products including issuers and their authorized service providers, performance of Services, and ensuring customer support. These uses do not, at any time override your rights as a data principal.

Consent: We require your explicit consent to send you promotional communications. You may manage your consent and update your communication preferences at any time by visiting https://myaccount.the policyexchange.com or by contacting us at info@thepolicyexchange.com.

We are committed to processing your Personal Data lawfully, fairly, and transparently, and will only use it for the purposes outlined in this Privacy Notice or as otherwise permitted under applicable laws including Digital Personal Data Protection Act, 2023 and rules thereunder, as amended from time to time.

Who do we share your data with?

We ensure that your Personal Data is processed in a manner that is compatible with the purposes specified above. We only share your Personal Data when it’s necessary to help serve you better, comply with the laws.

Your personal information may be shared with:

Insurance Companies: To help you maximise the benefits and value proposition offered under the policies owned by you, manage the Services you are availing from us.

Trusted Service Partners: Companies that support us in delivering our Services, such as:

Managing documents and records as required to provide you Services or by regulations

Storing data securely in cloud systems in our servers

To provide you logistic support

Third-party service providers providing services to us.

Service Providers of issuers of financial products including an insurance company for the following purposes:

Helping with availing certain features if required for certain policies

Assisting with documentation and facilitating provision of Services in coordination with issuers of financial products including the insurers or third-party administrators, or surveyors

Partnered agencies offering value-added services like IndiaFirst Life Insurance Company; Sud Life Insurance Company Limited; Aditya Birla Capital; Ageas Federal Life Insurance Company; Generali Central Life Insurance; IndusInd Nippon Life Insurance; Bandhan Life Insurance; Axis Max Life Insurance; Bharti Axa; Edelweiss Life Insurance; Bajaj Alliance Life Insurance; Insurance Dekho ; Tata AIA Life Insurance; HDFC Life Insurance; Kotak Life Insurance and Bajaj Capital.

Regulatory Authorities or Legal Requirements: We may disclose your information if required by law, government authorities, courts, or regulators—for example, to comply with legal processes, prevent fraud, or protect our legal rights.

Change in ownership: If Fairvalue is ever merged with or acquired by another company, your information may be transferred as part of that transaction. If this happens, we’ll ensure your data continues to be protected under this Privacy Notice or a similar standard.

We will always ensure that any third parties we work with handle your Personal Data safely, respect your privacy, and only use the information for the specific purposes we’ve explained. Wherever your consent is required by law for sharing your data, we will seek it explicitly, and you have the right to withdraw it at any time by writing to us at info@thepolicyexchange.com.

Mobile Application – SDKs, Analytics and Advertising Partners

The Mobile Application owned and operated by Fairvalue (“App”) integrates certain third-party software development kits (SDKs) and services to enable analytics, performance monitoring, and advertising measurement. Such SDKs may independently access and share certain device and usage-related information, as summarised below. Fairvalue reviews and updates this list from time to time to ensure it remains consistent with the SDKs actually integrated into the App and with Fairvalue’s Google Play Data Safety disclosures:

a.     Firebase (Google): used for App analytics, crash reporting and performance monitoring; accesses and shares device identifiers, App usage and diagnostic data, and crash logs with Google LLC.

b.     Meta/Facebook Pixel and Facebook SDK: used for advertising measurement and campaign attribution; this shares browsing and App-usage data, device and advertising identifiers, and interaction data with Meta Platforms, Inc.

c.      Payment gateway SDK(s): used for processing payments and transactions; accesses and shares transaction and payment-related data with the relevant licensed payment processor.

d.     Other analytics tools (e.g., Google Analytics): used for usage analytics and product improvement; accesses device and usage information.

You may control certain SDK-related data collection through Your device’s advertising and privacy settings, including by limiting advertisement tracking or opting out of advertisement personalization. Fairvalue requires all such SDK and service providers to process data in accordance with applicable laws, including the Digital Personal Data Protection Act, 2023 read with rules thereunder, as amended from time to time.

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 laws and appropriate safeguards.

You acknowledge that some of this information related to the Technology Platform and Your visit to the Technology Platform 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 Technology Platform on a need-to-know basis and in compliance with applicable laws. This anonymous information is collected using any prevailing industry standard technologies.

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 laws 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.

In the event Fairvalue uses Third-Party service providers to serve advertisements on behalf of Fairvalue across the internet including the Technology Platform, such service providers may collect anonymous information about Your visits to the Technology Platform, and Your interaction on the Technology Platform. 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.

Fairvalue engages certain service providers (including for payment processing, hosting and infrastructure, communications, customer support, and analytics) who process Your Personal Data solely on Fairvalue's instructions and solely for the purposes for which it was collected, under contracts requiring them to implement safeguards consistent with Fairvalue's obligations under the Digital Personal Data Protection Act, 2023 read with rules thereunder. This is not treated as disclosure to a third party for an independent purpose, and no such service provider may use Your Personal Data for its own purposes.

1.      Fairvalue does not sell or share Your Personal Data with third parties for their independent commercial use.

2.      Fairvalue may disclose Your Personal Data to a government agency, court, tribunal, or other authority where required to comply with any judgment, decree, or order issued by a court or tribunal in India, or where such disclosure is required or authorised under the Digital Personal Data Protection Act, 2023, the rules made thereunder, or any other law for the time being in force in India including, where applicable to Fairvalue's business, reporting obligations under RBI, SEBI, PMLA, or other sectoral regulation. Fairvalue will disclose only such Personal Data as is necessary to satisfy the specific legal requirement.

3.      In the event of a merger, acquisition, or sale of all or part of Fairvalue's business, Your Personal Data may be transferred to the successor entity, which shall continue to be bound by the purposes and protections described in this Privacy Notice.

4.      Any disclosure of Your Personal Data for a purpose materially different from those disclosed to You at the time of collection will only be made after providing You a fresh notice and obtaining Your consent for that purpose, except where such processing is permitted without consent under Section 7 of the Digital Personal Data Protection Act, 2023 and rules made thereunder, as amended from time to time.

5. 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.

Your Rights:

Where permitted by applicable laws or regulation, you have the right to:

Access Information About Personal Data: You can request a summary of your Personal Data we process, details of our processing activities, and information about any third parties with whom your data is shared.

Correction and Erasure of Personal Data: You may ask us to correct, complete, update, or erase your Personal Data if it’s inaccurate, incomplete, outdated, or no longer needed, subject to legal retention requirements.

Grievance Redressal: You have access to our grievance redressal process to address concerns about your Personal Data or your rights, with the option to escalate unresolved issues to the Data Protection Board.

Nominate: You can nominate someone to exercise your data rights on your behalf in case of your death or incapacity, by writing to Fairvalue at the contact details set out in this Privacy Notice.

To exercise these rights, contact us at puneet@thepolicyexchange.com. Fairvalue shall verify Your identity before acting on any such request and shall endeavour to respond within the timelines prescribed under applicable laws including Digital Personal Data Protection Act and rules thereunder, as amended from time to time.

Where your information is processed:

Your Personal Data may be stored, processed, or transferred to servers or service providers located outside India, including for hosting, analytics, or customer support purposes. Fairvalue shall undertake any such transfer in accordance with the Digital Personal Data Protection Act, 2023, and shall not transfer Personal Data to any country or territory restricted by the Central Government by notification. Fairvalue shall ensures that it takes appropriate technical and organizational measures to ensure your data always remains protected.

Security

We employ reasonable technical and organizational security measures at all times to protect the information we collect from you. We use multiple electronic, procedural, and physical security measures to protect against unauthorized or unlawful use or alteration of information, and against any accidental loss, destruction, or damage to information. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security. Further, you are responsible for maintaining the confidentiality and security of your login ID and password, and may not provide these credentials to any third party.

ISO 27001

ISO 27001 ISO/IEC 27001:2022 is the international standard for management of information security and provides a systematic approach to keep sensitive company information secure. Getting the ISO 27001:2022 certificate is a reassurance for our customers that ThePolicyexchange.com complies with the industry-accepted standards regarding information security. Fairvalue is an ISO/IEC 27001:2022 certified company. We have implemented the ISO/IEC 27001: 2022 standard for all processes supporting the development and delivery of Services by Fairvalue. Fairvalue understands that the confidentiality, integrity, and availability of your information are vital to our business operations and our own success.

How long is personal data retained for:

We will not retain your Personal Data for longer than is necessary, and we will hold it only for the purposes for which it was obtained and in accordance with the applicable laws. Our retention periods are based on business needs and statutory requirements.

Without prejudice to the general retention principles set out above, Fairvalue retains specific categories of personal data for the following periods:

·       KYC data: 5 years from the closure of Your account, in accordance with the Prevention of Money Laundering Act, 2002 and rules made thereunder.

·       Transaction data: 8 years, in accordance with the Companies Act, 2013.

·       Marketing data: until You withdraw Your consent.

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 defense of legal claims.

Where Fairvalue no longer has a lawful basis to retain Personal Data, including where you have withdrawn your consent or the purpose for which such Personal Data was collected has been fulfilled, Fairvalue shall erase such Personal Data and shall endeavour to cause any data processor engaged by it to likewise erase such Personal Data, save where retention is required for compliance with applicable laws including the Digital Personal Data Protection Act 2023 and rules made thereunder, as amended from time to time.

Upon expiry of the applicable retention period, Personal Data shall be deleted, anonymized, or archived in accordance with applicable laws. You acknowledge and understand that Fairvalue may retain anonymized or aggregated data for legitimate business purposes.

Security Measures and Breach Notification:

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 technical and organizational security safeguards 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. In particular, all Sensitive Personal Information, including PAN, Aadhaar, and bank account or payment details, is encrypted at rest using AES-256 encryption and in transit using TLS 1.2 or higher.

No method of electronic transmission or storage is entirely secure, and while Fairvalue takes reasonable measures to protect Your Personal Data, it cannot guarantee its absolute security.

In the event of a data breach that compromises the confidentiality or integrity of your Personal Data, we will notify you and the Data Protection Board as required by the Digital Personal Data Protection Act 2023 and rules made thereunder, as amended from time to time. This notification will be provided within 72 hours’ time of becoming aware of the breach, outlining:

The nature of the breach.

The likely consequences of the breach.

The measures we have taken to address the breach.

The steps you can take to mitigate potential risks.

Notwithstanding anything contained in this Privacy Notice 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.

Children's Data:

We do not process Personal Data of children (under the age of 18) unless we have obtained explicit parental/guardian consent.

Fairvalue does not undertake tracking, behavioural monitoring, or targeted advertising directed at any User known or reasonably believed to be a Child. If Fairvalue becomes aware that it has inadvertently collected a Child’s Personal Data without requisite consent, it shall take steps to delete such data at the earliest, unless retention is otherwise permitted under applicable laws.

Grievance Redressal:

We are committed to protecting your Personal Data and addressing your privacy concerns or queries in full compliance with applicable data protection and cybersecurity laws. In case you have any grievances with respect to, in accordance with applicable law, the name and contact details of the Grievance Officer are provided below:

Data Grievance Officer

Mr. Puneet Fairvalue Insuretech Private Limited Registered Office: Flat No. 701, Tower 5, Vipul Greens, Sohna Road, Sector-48, Gurgaon, Haryana, India, 122018 Email: puneet@thepolicyexchange.com

To submit your complaint, include your name, contact details, and a clear description of your concern (with any relevant documents). Submissions are accepted via email, phone, or our online portal.

The Grievance Officer shall endeavor to resolve your complaint/concern at the earliest and not later than 90 (Ninety) days of receipt, in accordance with applicable laws including Digital Data Protection Act, 2023 read with underlying rules, as amended from time to time.

Escalation:

If unsatisfied, you may escalate to the Data Protection Board of India (DPBI).

We are dedicated to resolving your concerns promptly, fairly, and in full compliance with applicable data protection laws.

Notification of Changes to the Privacy Notice

Fairvalue reserves the right to revise this Privacy Notice from time to time as per organization's needs or to abide by new regulations, by posting notice of the amendment as appropriate. To the extent permitted by applicable laws, such changes will be applicable from the time they are posted. Your continued use of the Technology Platform or Service will constitute your acceptance of the Privacy Notice.

Visitors are hereby informed that their information submitted on the website may be shared with issuers of financial products including the insurers.

Exclusion

This Privacy Notice applies only to Personal Data collected by Fairvalue through the Technology Platform or offline interactions and does not apply to information voluntarily disclosed by you in public areas of the Technology Platform or provided through unsolicited means, which may not be treated as confidential.

Terms of Use

This Privacy Notice is to be read in conjunction with the Terms of Use of the Technology Platform and all other terms will apply mutatis mutandis to this Privacy Notice. Capitalized used in this Privacy Notice used but not defined, will derive its meaning from Terms of Use of the Technology Platform.