1. Introduction
This Privacy Policy explains how Marwar Mentors Private Limited, a company incorporated under the Companies Act, 2013, having its registered office in India (“Marwar Venture”, “we”, “us” or “our”) collects, uses, shares, stores and protects personal data when you visit or use our website, the Startup OS platform, our programmes, competitions, events, newsletters, magazine and related services (together, the “Platform”).
This Policy is published in accordance with the Information Technology Act, 2000 (“IT Act”), the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 (“SPDI Rules”), the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021 (“Intermediary Rules”) and the Digital Personal Data Protection Act, 2023 (“DPDP Act”) together with the rules notified under it, as amended from time to time (together, “Applicable Data Protection Law”).
By using the Platform or submitting your information to us, you acknowledge that you have read and understood this Policy. Where we rely on your consent, we will ask for it clearly and separately, and you may withdraw it at any time as explained below.
2. Who is responsible for your data
Marwar Mentors Private Limited is the “Data Fiduciary” under the DPDP Act and the “body corporate” under the IT Act for personal data processed through the Platform. Where we process data on behalf of another organisation (for example, a partner running a joint competition), we will tell you who the responsible organisation is at the point of collection.
3. Personal data we collect
We collect only the personal data that is necessary for the purposes described in this Policy:
- Identity and contact details: name, email address, mobile number, city and state, and LinkedIn or other professional profile links.
- Application details: information you share in startup, investor, mentor, competition, programme or job applications, such as your role, organisation, startup details, pitch decks, CVs, portfolio links, investment preferences and experience.
- Startup and business information: information about your venture, traction, financial information you choose to share, documents uploaded to Startup OS and communications with our team.
- Payment information: where you pay for a service, programme or event, payments are processed by our authorised payment gateway. We receive transaction details (such as the transaction reference, amount and status) but do not store full card numbers, CVV, UPI PIN or net-banking passwords.
- Technical and usage data: IP address, device and browser type, pages viewed, referring pages, approximate location derived from IP, and information collected through cookies and similar technologies.
- Communications: messages you send us, feedback, survey responses and records of your interactions with our team.
Sensitive personal data or information (such as passwords, financial information like bank account or card details, health information or biometric information, as defined in the SPDI Rules) is collected only where strictly necessary for a specific service, with your explicit consent, and is protected with additional safeguards.
4. How we collect personal data
- Directly from you, when you fill in a form, apply to a programme or competition, subscribe to our newsletter, create an account, attend an event or contact us.
- Automatically, when you use the Platform, through cookies, server logs and analytics tools.
- From third parties, such as co-organisers of competitions and events, partner institutions, referral partners, or publicly available professional sources, where permitted by law.
5. Why we use your personal data
We process your personal data on the basis of your consent or for legitimate uses permitted under Section 7 of the DPDP Act, for the following purposes:
- To review and respond to applications from startups, investors, mentors, applicants for roles and partners, and to evaluate, shortlist and communicate outcomes.
- To connect founders with mentors, investors and partners where you have asked us to, or have agreed to such introductions.
- To deliver our programmes, competitions, services, events and the Startup OS platform, including onboarding, scheduling, certificates and support.
- To process payments, issue invoices and handle refunds in accordance with our Refund Policy.
- To send newsletters, magazine issues and updates about opportunities, where you have opted in. You can unsubscribe at any time.
- To maintain the security of the Platform, prevent fraud and misuse, and enforce our Terms of Use.
- To improve the Platform through aggregated and, where possible, anonymised analysis.
- To comply with legal obligations, court orders, and requests from authorities empowered under law.
6. Consent and how to withdraw it
Where processing is based on consent, your consent is free, specific, informed, unconditional and unambiguous, and limited to the purpose stated at the time of collection. You may withdraw your consent at any time by writing to us through the Contact page of this website or by using the unsubscribe link in our emails. Withdrawal is as easy as giving consent.
Withdrawal does not affect processing carried out before withdrawal. If you withdraw consent that is necessary for a service (for example, reviewing an application), we may be unable to continue providing that service. You may also give, manage, review or withdraw consent through a Consent Manager registered with the Data Protection Board of India, once such managers are operational.
7. Sharing of personal data
We do not sell your personal data. We share it only as described below and only to the extent necessary:
- With mentors, investors, jury members and partners, when you apply to a programme or competition, request an introduction or ask us to share your profile. For startups, this may include your pitch deck and application summary.
- With service providers (data processors) who help us operate the Platform, such as hosting, email, form and CRM providers, analytics and payment gateways, under written contracts that require them to protect your data and use it only on our instructions.
- With co-organisers of a specific competition or event that you register for, as stated on the relevant page.
- With government authorities, regulators or law enforcement agencies where required by law or for the prevention, detection or investigation of offences, in accordance with the IT Act and other applicable laws.
- In connection with a merger, acquisition, restructuring or sale of assets, subject to the recipient being bound by obligations no less protective than this Policy.
8. Transfer of data outside India
Some of our service providers may store or process data on servers located outside India. Any such transfer will be made only to countries or territories not restricted by the Central Government under Section 16 of the DPDP Act, and subject to appropriate contractual safeguards.
9. How long we keep your data
We keep personal data only for as long as it is needed for the purpose for which it was collected, or as required by law (for example, under tax, accounting or company law). Unless a longer period is required by law or you ask us to keep it, applications that are not taken forward are deleted or anonymised within 24 months, and newsletter subscriber data is deleted within 30 days of unsubscribing. When data is no longer required, we erase it or anonymise it securely.
10. How we protect your data
We implement reasonable security practices and procedures as required under Section 43A of the IT Act and the SPDI Rules, and reasonable security safeguards under Section 8(5) of the DPDP Act, including encryption in transit (HTTPS), access controls on a need-to-know basis, secure hosting, and confidentiality obligations for our team and processors. No method of transmission or storage is completely secure, but we work to protect your data against unauthorised access, alteration, disclosure or destruction.
In the event of a personal data breach, we will notify the Data Protection Board of India and affected individuals as required under the DPDP Act and its rules, and report cyber security incidents to CERT-In as required under the IT Act and CERT-In directions.
11. Your rights
Subject to Applicable Data Protection Law, you have the right to:
- Obtain a summary of the personal data we process about you and the processing activities, and the identities of others with whom it has been shared (right to access information).
- Request correction, completion or updating of inaccurate or incomplete personal data.
- Request erasure of personal data that is no longer necessary for the purpose for which it was collected, unless retention is required by law.
- Withdraw consent at any time.
- Nominate another person to exercise your rights in the event of your death or incapacity.
- Have your grievances redressed by our Grievance Officer, and, if you are not satisfied, approach the Data Protection Board of India.
To exercise any of these rights, write to us through the Contact page of this website. We may need to verify your identity before acting on your request, and we will respond within the time required by law. As a Data Principal you also have duties under Section 15 of the DPDP Act, including not providing false information or impersonating another person.
12. Children
The Platform is intended for users who are 18 years of age or older. We do not knowingly process personal data of children (individuals under 18) without verifiable consent of a parent or lawful guardian as required under Section 9 of the DPDP Act, and we do not undertake tracking, behavioural monitoring or targeted advertising directed at children. Student applicants under 18 must apply with the consent of a parent or guardian. If you believe we have collected data of a child without such consent, please contact us and we will delete it.
13. Cookies and analytics
We use cookies and similar technologies that are essential for the Platform to work (for example, remembering your language choice), and, with your consent where required, analytics cookies that help us understand how the Platform is used. You can block or delete cookies through your browser settings; some features may not work properly without essential cookies.
14. Links to other websites
The Platform links to third-party websites, including news articles, partner websites and LinkedIn profiles. We are not responsible for the privacy practices or content of those websites, and we encourage you to read their privacy policies.
15. Grievance Officer
In accordance with the IT Act, the SPDI Rules, the Intermediary Rules and the DPDP Act, our Grievance Officer is:
The Grievance Officer, Marwar Venture (Marwar Mentors Private Limited). Complaints can be sent through the Contact page of this website by choosing the topic “Other” and starting the message with the word “Grievance”. Working hours: Monday to Friday, 10:00 am to 6:00 pm IST (excluding public holidays).
We will acknowledge complaints within 24 hours and resolve them within 15 days of receipt, or within such other period as may be prescribed under applicable law.
16. Changes to this Policy
We may update this Policy from time to time to reflect changes in law or in our practices. The updated Policy will be posted on this page with a revised “Last updated” date. Where changes are significant, we will notify you through the Platform or by email and, where required, seek your fresh consent.
17. Contact
For any questions about this Policy, write to us through the Contact page of this website.