Privacy Policy

Prosper is a technology platform operated by Valuationary Edtech Private Limited ("Prosper", "Company", "we", "us", or "our"). The purpose of Prosper is to enable users to discover, subscribe to, and receive research and advisory services offered by SEBI-registered Research Analysts ("Research Analysts") through a digital platform.

User Consent and Agreement

By submitting personal information through our Platform or Services, you agree to the terms of this Privacy Policy and you expressly give your voluntary consent to the collection, use, and disclosure of your personal information in accordance with this Privacy Policy.

Information You Provide to Us

If you provide us feedback or contact us via email, we will collect your name and email address, as well as any other content included in the communication, in order to send you a reply.

We may collect personal and financial information provided by you, such as your first and last name, phone number, email address, date of birth, PAN, bank account details, and investment-related information, while you access services on the Platform.

We may also collect personal information on the Platform when we make clear that we are collecting it and you voluntarily provide the same.

You must ensure to recheck the information or data being provided to us. In case any of the data or information is found to be inaccurate or incorrect, the same shall be informed to us for immediate amendment. We shall not be responsible for the authenticity of any information including personal information submitted to us.

Information Collected via Technology

To make our Platform and Services more useful to you, our servers, which may be hosted by a third-party service provider, collect information from you, including your browser type, operating system, Internet Protocol (IP) address, device identifiers, and domain name.

Use of Personal Information

In general, personal information you submit to us is used either to respond to requests that you make, or to aid us in serving you better. We use such personal information in the following ways:

1. To identify you as a user in our system;
2. To provide improved administration of our Platform and Services;
3. To provide the Services you request, including facilitating your subscription to Research Analyst services;
4. To complete KYC verification as required under applicable law, including SEBI (Research Analysts) Regulations, 2014 and the Prevention of Money Laundering Act, 2002;
5. To facilitate payment processing and remittance to Research Analysts through our payment gateway partners;
6. To improve the quality of experience when you interact with our Platform and Services;
7. To send you email and other notifications related to your subscriptions and account;
8. To send newsletters, surveys, offers, and other promotional materials related to our Services and for other marketing purposes, where you have provided your consent;
9. To prevent and detect fraud or abuse of our Services, as well as to prevent, detect, and investigate any potential unlawful or prohibited activities;
10. To comply with applicable regulatory obligations, including reporting requirements under SEBI regulations, RBI guidelines, and the PMLA, 2002.

Disclosure to Third Parties

We do not sell your personal information. We may be required from time to time to disclose any personal information collected by us to governmental or judicial bodies or agencies or our regulators based on their requirement, or to comply with applicable law.

Specifically, the following data may be shared with authorised third parties in the course of providing Services:

1. Name, PAN, email address, and contact number may be shared with the Research Analyst to whom you have subscribed, solely for the purpose of service delivery;
2. Payment information is processed by our RBI-compliant payment gateway partners. The Company does not store full card details. Card transaction data may be processed by PCI-DSS compliant third-party tokenisation service providers in accordance with applicable RBI regulations;
3. KYC-related information may be shared with KYC Registration Agencies (KRAs), the CKYC Registry, or other SEBI-authorised verification entities for the purpose of identity verification;
4. Email address and phone number may be shared with communication service providers for the purpose of transactional notifications and service communications;
5. Data may be shared with cloud infrastructure providers, including for storage and processing of data on servers hosted in India.

Creation of Anonymous Information

We may create anonymous information records from personal information by excluding information that can identify an individual. We use this anonymous information to analyse request and usage patterns so that we may enhance the content of our Services and improve Platform navigation. The Company reserves the right to use anonymous information for any purpose and disclose anonymous information to third parties at its sole discretion.

Third-Party Websites

When you click on a link to any other website or location, you will leave our Platform and go to another site, and another entity may collect personal or anonymous information from you. We have no control over, do not review, and cannot be held responsible for, these outside websites or their content. The terms of this Privacy Policy do not apply to such outside websites.

Cookies

Cookies are pieces of information that a browser can record after visiting a website. We may use cookies for technical purposes such as to enable better navigation through our site, or to store user preferences for interacting with the site. We use strictly necessary cookies, functional cookies, and analytics cookies. Marketing cookies are used only with your consent. If you turn off the option to have cookies stored on your browser, it will affect your experience on the Platform.

Security of Your Information

The Company is committed to protecting the security and privacy of your personal information. We endeavour to have suitable technical, operational, and physical security controls commensurate with the nature of our business at all times, including encryption of data in transit (TLS 1.2 or higher) and at rest (AES-256), and role-based access controls. We use a variety of industry-standard security technologies and procedures to help protect your personal information from unauthorised access, use, or disclosure, and periodically review the same. In the event of any breach of our security control measures resulting in unauthorised access to your information, we will endeavour to inform you of the extent of such breach, subject to applicable law and cooperation with the relevant authorities.

Retention and Destruction of Information

Personal information provided by you shall be retained for a minimum duration of 5 years from the completion or termination of Services, in accordance with the requirements of the Prevention of Money Laundering Act, 2002 and applicable RBI guidelines, unless a longer period is required under law or regulatory mandate.

For any data or consent that you may have provided and want to be deleted or revoked, fully or partially, please send an email to support@getproposer.club stating the details of the data and/or consent provided and the scope of the deletion or revocation desired. However, in the event of you withdrawing such consent or making a request to delete the data, you may not be able to continue using the Services. Upon receipt of a valid data deletion request, it is assessed for authenticity and the legitimacy of the request is evaluated. Anonymisation is considered prior to deletion, provided it does not conflict with applicable laws or legal obligations. We endeavour to delete the relevant personal information based on a valid request within a reasonable period not exceeding 30 days of receiving a valid and legitimate data deletion request, unless retention is required for compliance with applicable law.

All information is stored on cloud infrastructure hosted in India.

Notwithstanding the above, certain data may be retained beyond the specified timelines where there is an unresolved dispute or claim relating to your account; where retention is required under applicable law or regulatory mandate; where the data is retained in aggregated or anonymised form; or where retention is necessary for legitimate business interests such as fraud prevention or platform security.

Amendments and Modifications

This Privacy Policy is current and valid. However, the Company reserves the right to amend or modify any sections of this policy at any time, and users are requested to keep themselves updated by reading the same from time to time. Material changes will be notified via email or a prominent notice on the Platform.

Contact Information

The Company welcomes your grievances, comments, or questions regarding the terms of this Privacy Policy, the Platform, or the Services. Please email us at support@getproposer.club.

Definitions

Anonymous Information - Anonymous information means information that does not directly or indirectly identify, and cannot reasonably be used to identify, an individual user.

Internet Protocol (IP) - Internet Protocol (IP) is the principal communications protocol for exchanging messages between computers across networks using the Internet Protocol Suite.

Personal Information - Personal information means any information that relates to a natural person, which, either directly or indirectly, in combination with any other information available, is capable of identifying such person.