Privacy Policy
Note: This Privacy Policy is provided as a working template aligned with the Digital Personal Data Protection Act, 2023 ("DPDP Act") and reasonable practices for an India-based venture studio. Before deploying publicly, please have it reviewed by qualified legal counsel familiar with your specific data flows and the latest rules notified under the DPDP Act.
Xponents Ventures Pvt. Ltd. ("Xponents", "we", "us", or "our") respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, store, share, and protect personal data when you visit xponents.io or otherwise interact with us.
1. Scope and Applicability
This Policy applies to personal data we collect from or about you when you (a) visit our website, (b) submit information through our contact forms, (c) subscribe to our Insights publication, (d) engage with us in any business capacity — including as a prospective founder, investor, business owner, partner, vendor, or employee.
2. Data We Collect
Information you provide
- Contact information: name, email address, phone number, company or organisation name
- Professional information: role, stage of company, sector or theme of interest
- Communications: the content of messages, pitch materials, or other communications you submit to us
Information collected automatically
- Usage data: IP address, browser type, device information, pages visited, referring URL, time spent
- Cookies and similar technologies (see our Cookie Policy)
Information from third parties
Where you are introduced to us by a mutual contact, or where we conduct standard due diligence in connection with potential business engagements, we may collect information from publicly available sources, professional networks, references, and authorised information service providers.
3. How We Use Your Data
We process personal data for the following legitimate purposes:
- To respond to enquiries and provide requested information or services
- To evaluate prospective business opportunities, including diligence on founders and businesses
- To send our Insights publication and other communications you have subscribed to
- To comply with applicable legal, regulatory, and tax obligations under Indian law
- To prevent, investigate, and address fraud or misuse of our website and services
- To improve our website, services, and operations
4. Legal Basis for Processing
Under the DPDP Act, we process personal data primarily on the basis of your consent, or where processing is necessary for legitimate uses including the performance of contractual obligations, compliance with law, or our legitimate business interests, as applicable.
5. Sharing and Disclosure
We do not sell personal data. We may share personal data with:
- Service providers who help operate our business (email, hosting, analytics, CRM) under appropriate confidentiality and data protection commitments
- Professional advisors including legal counsel, accountants, and auditors
- Regulators and authorities where required by law or in response to lawful requests
- Successors in connection with a merger, restructuring, or change of control
6. International Transfers
Some of our service providers operate outside India. Where personal data is transferred outside India, we put in place appropriate safeguards in line with applicable Indian law to ensure your data continues to receive a reasonable level of protection.
7. Retention
We retain personal data only for as long as reasonably required for the purposes set out in this Policy, or as required by law. Retention periods vary by the nature of the data and the relationship: contact form submissions are typically retained for up to 24 months; subscriber records are retained until you unsubscribe; records relating to evaluated investments may be retained longer for diligence trail and compliance purposes.
8. Your Rights
Subject to applicable law and the DPDP Act, you have rights in respect of your personal data, including:
- The right to confirmation of and access to your data we hold
- The right to correction or updating of your data
- The right to erasure of your data, subject to retention requirements
- The right to grievance redressal
- The right to nominate a person to exercise rights in the event of incapacity or death
- The right to withdraw consent at any time, where processing is based on consent
To exercise any of these rights, please write to us at privacy@xponents.io.
9. Security
We implement reasonable technical and organisational measures designed to protect personal data against unauthorised access, alteration, disclosure, or destruction. However, no system is perfectly secure, and we cannot guarantee absolute security.
10. Children's Data
Our website and services are not directed to children under the age of 18. We do not knowingly collect personal data from children. If you believe a child has provided us with personal data, please contact us so we can take appropriate action.
11. Changes to this Policy
We may update this Policy from time to time. Material changes will be notified by updating the "Last updated" date at the top of this page and, where appropriate, by additional notice. Continued use of our website after changes take effect constitutes acceptance of the revised Policy.
12. Grievance Officer
In accordance with applicable law, you may contact our Grievance Officer in respect of any complaint regarding this Policy or our handling of your personal data:
Grievance Officer — Xponents Ventures Pvt. Ltd.
805 Devika Tower, Nehru Place
New Delhi 110019, India
Email: privacy@xponents.io
13. Contact
For any questions about this Privacy Policy or our data practices, please contact us at privacy@xponents.io.