Privacy Policy.

This Privacy Policy describes how JALAJ719 Consultants, which carries on business under the name “Fractional” (the “Company”), processes the personal data of individuals (each, a “User”) who access its website, tools or products, communicate with it, engage it, apply to it, or are associated with its clients, partners or expert network.

The Company processes such personal data as a data fiduciary in accordance with the Digital Personal Data Protection Act, 2023, the rules made under it and the Information Technology Act, 2000 (together, “Applicable Law”). Terms used in this Policy have the meanings given to them under Applicable Law.

Where the Company processes personal data on behalf of a client in the course of its services, it does so in accordance with that client’s instructions and clause 7.4 of the Terms of Service, and the client’s own privacy notice governs that processing.

The Company may collect (a) identity and contact details, such as name, email address, telephone number, designation and organisation; (b) onboarding and compliance information, such as identity documents, tax identifiers and details of ownership and authority; (c) billing and payment information; (d) communications and information exchanged in the course of an engagement; (e) technical data, such as IP address, device and browser information and usage logs; and (f) professional information, such as curricula vitae and work history.

Personal data is collected from Users directly, from their organisations, and from referrals, business partners, publicly available sources and service providers.

The Company’s website uses only such cookies as are necessary for its operation and security.

Personal data is processed to provide and administer the Company’s services; to onboard clients and verify identity, and to comply with legal, tax and regulatory obligations, including sanctions and anti-money-laundering screening; for billing and accounting; to respond to enquiries; to send business communications, from which a User may unsubscribe at any time; to recruit and engage personnel and experts; to operate, secure and improve the Company’s website, tools and services; and to establish, exercise or defend legal claims.

The Company processes personal data on the basis of consent, or for the legitimate uses permitted under Applicable Law. A User may withdraw consent at any time, without affecting the lawfulness of processing carried out before its withdrawal.

Personal data may be disclosed to (a) service providers and tool providers engaged by the Company; (b) the Company’s personnel, affiliates, consulting partners, experts and subcontractors; (c) its professional advisers and auditors; (d) any successor on a reorganisation or transfer of its business; and (e) governmental, regulatory or judicial authorities where required by law. Recipients are bound by obligations of confidentiality appropriate to the data disclosed.

The Company does not sell personal data.

Personal data may be transferred to and processed in countries outside India, other than any country to which transfer is restricted by the Central Government under Applicable Law.

Personal data is retained for as long as is necessary for the purposes for which it was collected, or as required by law, after which it is deleted or anonymised.

The Company implements reasonable security safeguards to protect personal data against unauthorised access, disclosure and loss, and shall notify any personal data breach as required under Applicable Law.

Subject to Applicable Law, a User may request access to, or the correction, completion, updating or erasure of, their personal data; may withdraw consent; may nominate another individual to exercise these rights; and may seek redressal of grievances, in each case in the manner provided under Applicable Law.

Requests shall be addressed to the Grievance Officer under clause 9.1. The Company may verify the identity of a User before acting on a request.

The Company’s website and services are not directed at individuals below eighteen (18) years of age, and the Company does not knowingly process their personal data.

The Company may amend this Policy by publishing a revised version on its website.

Any request, query or grievance concerning personal data may be addressed to the Grievance Officer, Fractional, at [email protected].