Privacy Policy

Polemarch (“we,” “us,” or “our”) respects your privacy and is committed to protecting your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your data when you visit our website or use our services.

1. Information We Collect

a. Personal Information

• Full Name
• Email Address
• Phone Number
• PAN Card Number
• Aadhaar Number (if applicable)
• Bank Account Details (for transactions)
• KYC Documents

b. Transactional Data

• Investments made in unlisted/pre-IPO shares
• Payment details
• Communications regarding share transfers or trading

c. Technical Data

• IP address
• Device type
• Browser type and version
• Cookies and usage data

2. How We Use Your Information

We use your information to:

• Process investments in unlisted or pre-IPO shares
• Complete KYC and compliance verifications
• Communicate updates and transaction statuses
• Provide customer support
• Send promotional and informational content (with your consent)
• Detect and prevent fraud or misuse
• Comply with legal obligations

3. Disclosure of Information

We may share your data with:

• SEBI-registered intermediaries (brokers, custodians, registrars)
• Regulatory authorities (as required by law)
• Our service providers (IT, analytics, payment gateways)
• Legal and tax consultants (only when required)

We never sell or rent your personal information.

4. Data Retention Schedule

We retain your personal data only as long as necessary for the purposes described in this policy, or as required by applicable law:

After the applicable retention period, personal data is permanently and irreversibly deleted or anonymised.

5. Security of Your Information

We use industry-standard encryption and secure servers to protect your information. However, no method of transmission over the internet is 100% secure.

6. Your Rights

Depending on applicable laws, you may have the right to:

• Access the personal data we hold about you
• Request correction or deletion of your data
• Withdraw your consent for data processing
• Opt out of marketing communications

To exercise your rights, please contact us at support@polemarch.in.

7. Cookies

Our website uses cookies to enhance your experience and analyze web traffic. You can manage cookie preferences via your browser settings.

8. Third-Party Links

Our website may contain links to external sites. We are not responsible for the privacy practices or content of those websites.

9. Changes to This Policy

We may update this Privacy Policy periodically. Updates will be posted on this page with a revised “Last Updated” date.

10. DPDP Act 2023 Compliance

Polemarch operates as a Data Fiduciary under the Digital Personal Data Protection Act, 2023 (“DPDP Act”). We process your personal data only for lawful purposes and with your informed consent.

a. Your Rights as a Data Principal

• Right to Access — request a summary of your personal data being processed
• Right to Correction — request correction of inaccurate or incomplete personal data
• Right to Erasure — request erasure of your personal data, subject to legal retention obligations
• Right to Grievance Redressal — lodge a complaint with our Grievance Officer or the Data Protection Board of India
• Right to Nominate — nominate another individual to exercise your data rights in case of death or incapacity

To exercise any of these rights, you can either:

• Use the in-platform self-service controls at Dashboard → Privacy for export and deletion requests, or
• Write to grievance@polemarch.in for correction, grievance, or nomination requests.

We respond within 30 days.

b. Consent Mechanism

We collect your personal data only after obtaining your free, specific, informed, and unambiguous consent through clear affirmative action. You may withdraw consent at any time by writing to us.

c. Data Fiduciary Obligations

• Process personal data only for the purpose for which consent was given
• Implement reasonable security safeguards against data breaches
• Notify the Data Protection Board and affected individuals in the event of a breach
• Erase personal data once the purpose of collection has been fulfilled, unless retention is required by law

11. Grievance Officer

In compliance with the IT Act, 2000, IT (Intermediary Guidelines) Rules, 2021, and the DPDP Act, 2023:

12. Children's Data

Polemarch does not knowingly collect personal data from individuals under 18. Our services are intended exclusively for individuals legally competent to contract under the Indian Contract Act, 1872. If we discover that a minor's data has been collected, we will delete it immediately.

13. Cross-Border Data Transfers

All personal data is stored and processed within India. We do not transfer your data outside India unless:

• We have obtained your explicit prior consent
• The transfer is to a country notified as permissible under the DPDP Act, 2023
• The transfer is necessary for the performance of a contract to which you are a party

14. Contact Us