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Background
Fondos Technologies Private Limited (“FondosTech,” “Company,” “we,” “us,” or “our”) adheres to applicable Indian data protection law, including the Digital Personal Data Protection Act, 2023 (“DPDP Act”), the Information Technology Act, 2000, and the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011.
This Privacy Policy explains how FondosTech collects, receives, stores, processes, discloses, transfers, and otherwise handles data in connection with the website fondostech.in and the FondosTech platform, including FT POSP Sure, FT D2C Insure, FT Embedded Insure, FT Lending Insure, FT Digital Claims, FT EB Sure, FT Reconciliation, FT Payin/Payout, and FT Compliance (together, the “Website/App”).
Definitions
- “Personal Data” means any data about an individual who is identifiable by or in relation to such data.
- “Sensitive Personal Data” includes financial information and any other categories of sensitive data as defined under applicable law.
- “Data Principal” means the individual to whom the Personal Data relates.
- “Data Fiduciary” means the entity that determines the purpose and means of processing Personal Data.
- “Data Processor” means FondosTech, or any third party processing data on FondosTech’s behalf.
- “Customer Data” means all information described in Section 1 below.
Where a broker, POSP network, bank, or other business customer uses the FondosTech platform to process their own end-customers’/policyholders’ data, that customer is the Data Fiduciary for that data, and FondosTech acts as a Data Processor, strictly on that customer’s instructions and under the terms of the applicable Order Form/Data Processing Agreement (“DPA”). This Policy primarily addresses FondosTech’s own processing, as a Data Fiduciary, of data belonging to website visitors, prospects, and platform account users.
01Customer Data We Collect
We collect Customer Data in the following ways:
- (a) Information you provide when you register on the Website/App for an account, request a demo, or configure your details within our systems, such as your name, email address, password, phone number, company name, designation, and business address.
- (b) Business and professional information such as IRDAI registration details, POSP/broker license information, and other credentials required to onboard you as a customer or partner.
- (c) Information relating to payment of fees, such as billing details, where applicable.
- (d) Content stored in connection with your use of the platform, including quote data, policy details, claims information, and employee/POSP records entered by you or your team.
- (e) Information automatically received and recorded via server logs and cookies, including your IP address, browser type, operating system, and the pages you visit, collected via Google Analytics (GA4) and Google Tag Manager (GTM).
- (f) Information from advertising and marketing platforms (Google Ads, LinkedIn Ads and its Conversions API, HubSpot/Zoho CRM, Calendly) when you interact with our campaigns or communications.
Providing this Customer Data is necessary for the effective performance of the Website/App; certain features may not be available if you choose not to provide it.
02Consent
By installing, accessing, or registering for the Website/App, you agree to be bound by, and expressly consent to, this Privacy Policy. If you do not agree, please do not install, use, or access the Website/App. By using the Website/App, you expressly consent to FondosTech’s collection, receipt, storage, processing, disclosure, transfer, and handling of Customer Data as described here.
While your account is active, FondosTech, its subsidiaries, affiliates, and third parties engaged by it may retain your Customer Data and use it as necessary to comply with its contractual and other obligations under applicable law.
You may withdraw your consent to FondosTech’s collection and use of your Customer Data at any time by writing to the Grievance Officer at the contact details in Section 10. Withdrawal of consent will not affect the lawfulness of processing carried out before withdrawal, but FondosTech reserves the right to discontinue access to the Website/App where continued provision of the Services is not possible without that Customer Data.
03Lawful Basis and Purpose of Collection
We process Personal Data on one or more of the following lawful grounds:
- Explicit consent from the Data Principal;
- Necessity for the performance of a contract or provision of the Services;
- Compliance with a legal obligation; or
- Legitimate uses recognized under the DPDP Act, provided such uses do not override your privacy rights.
We collect and use Customer Data for the following purposes:
- To provide, operate, and maintain the FondosTech platform and its features (quote generation, POSP management, claims management, policy issuance, employee management, compliance tracking).
- To monitor use of the Website/App to provide value-added services, such as real-time notifications via SMS or email regarding account activity.
- To process fee payments through secure, PCI-compliant payment gateway partners, where applicable.
- To respond to inquiries, resolve complaints, and provide customer support.
- To notify you of technical updates or changes to our policies, and to improve the content and functionality of the Website/App.
- To send marketing communications, product updates, and industry content, where you have consented or as otherwise permitted by law.
- To run and measure advertising campaigns on Google and LinkedIn, including through remarketing and first- and third-party cookies.
- To comply with legal, regulatory, and IRDAI-related obligations.
Where automated tools are used to analyze data for fraud detection, lead scoring, or personalization, such processing remains subject to human oversight, and you may request review or clarification of any decision made solely through automated means.
We do not retain Customer Data for longer than necessary for these purposes; see Section 5.
04Disclosure of Customer Data
We may disclose Customer Data in the following circumstances:
- (a) Subsidiaries, affiliates, and service providers. We may share Customer Data with our subsidiaries, affiliates, and third-party service providers (including hosting providers, CRM platforms, analytics providers, email outreach and verification tools, and scheduling tools), whether located within or outside India, solely to the extent necessary for them to perform their specific services. We make commercially reasonable efforts to ensure such parties keep Customer Data confidential as per industry standards, and all such vendors are subject to contractual data protection obligations and periodic review.
- (b) Insurance partners and networks. Insurers, POSP networks, and other parties as necessary to deliver core platform functionality to our broker customers.
- (c) Statutory or legal obligation. We may disclose Customer Data where required to comply with a legal obligation, protect our rights or property, or respond to law enforcement, courts, or regulatory authorities, including IRDAI.
- (d) Business transfers. In the event of a merger, acquisition, reorganization, or sale of assets, Customer Data may form part of the transferred assets; we will make commercially reasonable efforts to ensure the acquirer keeps it confidential as per industry standards.
- (e) Third-party integrations. Where you elect to use third-party applications that interoperate with the Website/App, those applications may be given access to your Customer Data at your election. We are not responsible for the policies and practices of such third parties.
We do not sell Customer Data. Cross-border transfers of Personal Data occur only where the destination ensures adequate data protection measures or under contracts incorporating data protection clauses recognized under applicable law, and we maintain records of such transfers for compliance review.
05Retention
We retain Customer Data only for as long as necessary to fulfil the purposes described in Section 3, or as required to comply with legal, regulatory, or IRDAI-related obligations, resolve disputes, and enforce our agreements. Customer Data processed on a business customer’s instructions as a Data Processor is retained and deleted per the terms of the applicable Order Form/DPA.
06Security Practices
FondosTech has assessed security threats and risks and implemented managerial, technical, organizational, and physical measures appropriate to the risk associated with the Customer Data we process, integrating privacy and security principles into the design, development, and deployment of our systems.
- We maintain an information security management system aligned with recognized standards such as ISO/IEC 27001, and follow applicable IRDAI best-practice guidance for data handling in the insurance ecosystem.
- Access to Customer Data is restricted to authorized employees, subsidiaries, affiliates, and engaged third parties who require it to perform their obligations in connection with the Website/App.
- We conduct regular internal reviews and audits to help ensure controls remain effective and that there is no unauthorized handling of Customer Data.
No method of transmission or storage is completely secure, and we cannot guarantee absolute security.
07Account Suspension, Deletion, and Data Principal Rights
7.1 Suspension and deletion
You may request suspension of your account and deletion of your Customer Data by writing to us at the contact details in Section 10. Your Customer Data will be deleted as soon as reasonably practicable, subject to any Customer Data we are permitted or required to retain under applicable law (for example, to resolve disputes, troubleshoot issues, or enforce our policies).
7.2 Your rights
In accordance with the DPDP Act and other applicable law, you have the right to:
- Access the Personal Data we hold about you;
- Correct or update inaccurate or incomplete information;
- Erasure of your data when it is no longer necessary or upon withdrawal of consent;
- Data portability, where feasible;
- Withdraw consent at any time, without affecting the lawfulness of prior processing;
- Nominate another individual to exercise these rights on your behalf in the event of death or incapacity; and
- Lodge a grievance with our Grievance Officer or, if unresolved, with the Data Protection Board of India.
Requests can be sent to the contact details in Section 10 and will be acknowledged within 7 working days and resolved within 15 working days, or such other timeframe as applicable law may prescribe.
We do not knowingly collect Personal Data from individuals under 18 years of age. If such data is inadvertently collected, it will be deleted promptly upon discovery.
08Cookies
A “cookie” is a small piece of information a web server stores on your browser so it can later be read back. We use both permanent and temporary cookies, via Google Tag Manager, to operate essential website functions, measure traffic through Google Analytics (GA4), and support advertising and retargeting through Google Ads and LinkedIn Ads, including remarketing. You may set your browser to refuse cookies or alert you when cookies are being sent; disabling cookies may affect site functionality.
09External Links
The Website/App may contain links to third-party websites not maintained by FondosTech. The handling of your data on such third-party sites is governed by their own terms and privacy policies, over which we have no control. We encourage you to review the privacy policy of any third-party site before using it, and we disclaim liability for their data practices.
10Grievance Redressal
If you have questions or concerns about this Privacy Policy, or wish to exercise your Data Principal rights, please contact:
We will acknowledge and aim to redress grievances within 1 month from the date of receipt. Please quote your account details where applicable, to help us resolve your request efficiently. If you are not satisfied with our response, you may escalate your complaint to the Data Protection Board of India.
11Changes and Updates
This Privacy Policy is subject to change from time to time at FondosTech’s discretion, to reflect changes in our practices, technology, or legal requirements. Continued use of the Website/App after changes are posted constitutes your agreement to the updated Policy. The most current version will always be available at this URL, with the “Last Revised” date updated accordingly. Material changes affecting how we process your Personal Data will, where appropriate, also be notified by email.
12Governing Law
This Privacy Policy is governed by and construed in accordance with the laws of India, and is subject to any separate Order Form, DPA, or agreement you have executed with FondosTech.
