Legal

Surge Website Terms of Use and Privacy Policy.

Surge Website Terms of Use

Last updated: 2 April 2026

Thanks for your interest in our website available at https://www.surgeahead.com/ (the “Website”). These Peak XV Partners Website Terms of Use (“Terms”) govern your use of this Website, including the content, materials and information available on or through this Website (together, the “materials”).

Who We Are. This Website is maintained and operated by Peak XV Partners Operations LLC (“Peak XV Partners” or “we”, “us” or “our”). In accordance with industry custom, this Website occasionally uses terminology that may be interpreted to suggest that we are actually a single entity. However, there is no such single entity and all of the entities that comprise us have their own separate legal existence.

By accessing, browsing, or using this Website, you (“you”, “your”, “yourself” or “Users”) acknowledge that you have read, understood, and agree to be bound by these Terms and our Privacy Policy [∙]. If you do not agree, you must discontinue using or browsing the Website.

1. Purpose of the Website

General Information Only. The information contained on the Website or social media sites operated by Peak XV Partners, including but not limited to, social media posts, blog posts, portfolio company announcements, videos and podcasts is provided solely for general informational purposes. It serves as a digital profile for Peak XV Partners and its investment activities.
No Offer, Solicitation or Advice. Except to the extent expressly set forth in materials provided through the Services (defined below) or as otherwise specified in writing by a duly authorised representative, nothing on this Website is intended to constitute:
1. an offer to sell, or a solicitation of an offer to purchase or sell any security, asset, or service;
2. investment, legal, tax, or other professional advice or an offer to provide such advice;
3. a basis for making any investment decision; or
4. a commitment or promise by Peak XV Partners to invest or provide financing.

Except as expressly stated by our duly authorised representative in writing, neither this Website nor any of the materials hereunder make any effort to present a comprehensive or balanced description of Peak XV Partners’ investment activities and any reliance placed thereon is at your sole risk. You should consult your own advisors as to legal, business, tax, and other related matters concerning any investment.

2. Eligibility

You represent that you are:
1. of a legal age to give consent; and
2. legally capable of entering into binding agreements under applicable law.
The Website is not intended for use by children, and we do not knowingly permit use by individuals under 18 years of age.

3. Privacy and Additional Terms

Your use of the Website is subject to our Privacy Policy, which forms an integral part of these Terms. By using the Website, you consent to the collection, processing, transfer, storage and retention of information as described in the Privacy Policy, including cross-border data transfers and processing by affiliates and service providers.
Password Protected Areas and Additional Terms.
1. Certain materials may be made available through a password protected area on this website, specifically the Surge and Spark platforms (“Services”). Each password is intended to be confidential and used only by the individual or entity to whom it is issued.
2. Use of these Services is subject to additional terms, conditions, and written agreements (collectively, "Additional Terms") presented at the time of access. In the event of a conflict between these Terms and the Additional Terms, the Additional Terms shall prevail.
3. Do not disclose your password to any unauthorised person. If you access the Services, please note that the written agreements between you and the applicable legal entities, as well as any provisions set forth in those materials, govern the parties’ respective rights and obligations with regard to such Services.
4. In particular, materials provided through the Services are confidential and subject to limitations on disclosure and use, and Peak XV Partners’ individuals/employees/consultants and affiliates generally have limited liability with respect to the accuracy and completeness of such materials.

4. Permitted Use and Restrictions

Limited License. You agree to access and use this Website only in strict accordance with these Terms. We grant you a limited, non-exclusive, non-transferable, and revocable license to:
1. access and view the Website and its content for your personal, non-commercial, and informational purposes; and
2. download or print copies of materials where a specific “download” link is provided, solely for your internal reference, provided that all copyright and proprietary notices remain intact.
No Implied License. Nothing contained on this Website grants any license, by implication, estoppel, or otherwise, any license or right to use any Website IP (defined below), except as expressly provided in these Terms or as otherwise agreed upon in writing between Peak XV Partners and you.
Prohibited Conduct. You shall not, and shall not permit any third party to:
1. copy, reproduce, modify, distribute, create derivative works from, or publicly display any portion of the Website IP or its content without prior written consent;
2. use any data scraping, robots, spiders, or similar data gathering and extraction tools to access the Website for any purpose, including indexing or commercially exploiting any portion of the Website;
3. interfere with or disrupt the operation, integrity, or security of the Website, or attempt to gain unauthorized access to any systems, servers, or data;
4. upload or transmit any malicious code, viruses, or harmful material, or attempt to reverse engineer or decompile any software or algorithms used on the Website;
5. use the Website for any unlawful, fraudulent, or unauthorized purpose; and
6. misappropriate the design or content of this Website and/or alter or deface such design or content in any way.
Termination. We reserve the right to restrict, suspend, or terminate your access to the Website at any time, without notice, if we believe in our sole discretion that these Terms have been violated.

5. Intellectual Property Rights

Ownership. All content, materials and functionalities, including but not limited to the text, photos, graphics, trademarks, trade names, logos, trademarks, trade names, images, videos, research resources, present or displayed on this Website, as well software, algorithms, models, code, embedded in this Website (collectively, the "Website IP") are proprietary to Peak XV Partners, its affiliates or their respective owners, or their licensors and this Website grants no license thereto. The Website IP, whether or not registered is protected by applicable copyright, trademark, and/or other applicable intellectual property laws.
Peak XV Partners reserves all rights not expressly granted herein. Any unauthorized use of the Website IP may violate copyright laws, trademark laws, the laws of privacy and publicity, and/or civil or criminal statutes.

6. Third-Party Information and Links

You should be aware that a significant portion of the materials on this Website includes or consists of information that has been provided by third parties and has not been validated or verified by us. In connection with our investment activities, we often become subject to a variety of confidentiality obligations to funds, investors, portfolio companies and other third parties. Any statements we make may be affected by those confidentiality obligations, with the result that we may be prohibited from making full disclosures. Without limitation on the effect of other provisions and disclaimers set forth in these Terms, you should interpret any statements we make on this Website or otherwise in that context.
Sites. The Website may contain links to third-party websites, platforms, or services. We do not control and accept no responsibility for third-party sites available through this Website, via hyperlink or otherwise, for:
1. the content, accuracy, or availability of third-party sites;
2. their privacy practices or terms.
You are encouraged to review the terms of use applicable to those sites. Any access to, or use of, a third-party site is solely at your own risk. Please ensure that your own computer security is comprehensive and up to date. We accept no responsibility for viruses, malware or other malicious or damaging software contained in the materials or otherwise.

7. Disclaimers and Disclosures

THE WEBSITE AND ALL CONTENT AND/OR MATERIALS ON THIS WEBSITE ARE PROVIDED ON AN “AS IS,” AND “AS AVAILABLE” BASIS AND MAY NOT BE RELIED UPON FOR ANY PURPOSE, AND ARE NOT SUBJECT TO EXPRESS OR IMPLIED WARRANTIES OF ANY KIND. WE MAKE NO REPRESENTATIONS OR WARRANTIES AND TO THE MAXIMUM EXTENT PERMITTED BY LAW, DISCLAIM ALL WARRANTIES, EXPRESS OR IMPLIED WITH REGARDS TO THE WEBSITE’S ACCURACY, AVAILABILITY, COMPLETENESS, NON-INFRINGEMENT OR FITNESS FOR A PARTICULAR PURPOSE. WE DO NOT WARRANT THAT THE WEBSITE WILL BE UNINTERRUPTED, ERROR-FREE, OR SECURE.
Certain views and opinions expressed in social media posts, blog posts, portfolio company announcements, videos and podcasts may be those of the individual Peak XV Partners personnel and may not represent the views of Peak XV Partners or its affiliates. The posts are not directed to any investors or potential investors, and do not constitute an offer to sell, or a solicitation of an offer to buy any securities, and may not be used or relied upon in evaluating the merits of any investment.
The portfolio companies identified do not represent all of the investments made or recommended for Peak XV Partners funds. It should not be assumed that investments made in the future will be profitable or will equal the performance of the investments in this list. The historical performance achieved by any prior investments made by Peak XV Partners funds is not a prediction of future performance or a guarantee of future results, and there can be no assurance that comparable future performance will be achieved in any fund. An indicative list of investments made by funds managed by Peak XV Partners is available here: https://www.peakxv.com/our-companies/.
Opinions, estimates, and projections constitute the current judgment of Peak XV Partners and are subject to change without notice. Any projections, forecasts, and estimates are necessarily speculative in nature and are based upon certain assumptions. It can be expected that some or all of such assumptions will not materialize or will vary significantly from actual results. Accordingly, any projections are only estimates and actual results will differ and may vary substantially from the projections or estimates shown.
All content speaks only as of the date indicated. Peak XV Partners has no obligation to update, modify, or amend or to otherwise notify a User thereof in the event that any matter stated herein, or any opinion, projection, forecast, or estimate set forth herein, changes or subsequently becomes inaccurate.
Founders identified and providing quotes have not received compensation for their statements which are solely representative of their opinion and experience with Peak XV Partners.
The quotes provided by personnel of certain portfolio companies of funds managed by Peak XV Partners may not be representative of the experience of personnel of other portfolio companies, and are not a guarantee of future performance or success.

8. Indemnification and Limitation of Liability

You agree to indemnify and hold harmless Peak XV Partners, its affiliates, directors, officers, employees, and agents from any claims, damages, losses, or expenses arising out of: therewith
1. your use of the Website;
2. your violation of these Terms;
3. your infringement of any third-party rights.
TO THE MAXIMUM EXTENT PERMITTED BY LAW, NEITHER PEAK XV PARTNERS NOR ANY INDIVIDUAL OR ENTITY AFFILIATED FORTHWITH SHALL HAVE ANY LIABILITY FOR ANY DIRECT, INDIRECT, INCIDENTAL, CONSEQUENTIAL, SPECIAL, OR PUNITIVE DAMAGES, INCLUDING LOSS OF DATA, BUSINESS, REVENUE, OR PROFITS BASED UPON YOUR USE OF, OR RELIANCE UPON THIS WEBSITE OR THE MATERIALS, EXCEPT AS SPECIFICALLY AND EXPRESSLY AGREED BY AND BETWEEN US AND THE USERS IN WRITING.
Some jurisdictions limit our ability to disclaim liability. With regard to those jurisdictions, our liability shall be limited to the greatest extent permitted by applicable law.

9. Governing Law and Jurisdiction

These Terms, and any disputes relating to these Terms or your use of this Website or the materials, shall be governed in all respects by the laws of Singapore, without regard to conflicts of laws principles. Except as otherwise agreed in writing, any disputes relating to these Terms shall be resolved exclusively by courts in Singapore.

10. Miscellaneous

Entire agreement. These Terms and the Privacy Policy, set forth the entire agreement and understanding between you and us with respect to the Website and supersede any and all prior or contemporaneous agreements, communications and proposals, whether oral or written, relating thereto. Any ambiguities in the interpretation of these Terms shall not be construed against the drafting party.
Third-party beneficiaries. All individuals and entities affiliated to Peak XV Partners are intended third-party beneficiaries of these Terms. Our rights under these Terms may be waived by us only in writing. These terms are binding on you as well as your successors and permitted assigns.
Compliance with laws. If it is illegal or prohibited in your country of origin to access or use this Website, then you should not do so. You are accessing the Website on your own initiative and are responsible for compliance with all local laws and regulations applicable to you.
Severability. In the event any provision of these Terms is determined to be invalid or unenforceable, such provision shall be deemed severed from the remainder of these Terms and replaced with a valid and enforceable provision as similar in intent as reasonably possible to the provision so severed, and shall not cause the invalidity or unenforceability of the remainder of these Terms.
Contact Information. For any questions, concerns or complaints regarding these Terms, please contact:
Email: pr@peakxv.com
Modification of these Terms. We reserve the right to modify these Terms at any time. Please check these Terms periodically for changes. Your continued use of this Website after the posting of changes constitutes your binding acceptance of such changes.

Privacy Policy

Last updated: 2 April 2026

Peak XV Partners Operations LLC, its affiliates and funds (“Peak XV”, “us”, “our” or “we”) value your privacy and is committed to safeguarding personal data relating to you. Personal Data refers to information that can identify you, such as your name, email address, or phone number) (“Personal Data”). This Privacy Policy explains what Personal Data we process, why we process it, how we use it, with whom we share your Personal Data, and your rights regarding your Personal Data. It describes how we handle your Personal Data when you interact with us through our website located at https://surge.peakxv.com/ (the “Site”), Surge Community mobile application, any instant messaging groups and forums, (together, the “Platform”).

This Privacy Policy should be read along with our Terms and Conditions [∙], any privacy notices provided when your Personal Data is collected. If there is a conflict between this Privacy Policy and a specific privacy notice, the terms of the specific privacy notice will prevail.

If you provide Personal Data or other information about someone other than yourself, or on behalf of an entity, organization, or body corporate, you confirm that you have the legal right, including consent where necessary, to provide the information for the specified purpose.

Depending on where you are located and your interactions with the Platform, certain processing of your Personal Data by Peak XV may be subject to data protection and privacy laws. If you are located in India, we will process your personal data as per the Digital Personal Data Protection Act, 2023 and the rules framed thereunder (“DPDPA”), (the “India Processing”); if you are an individual located in the EU, your data will be processed under the EU’s General Data Protection Regulation (the “GDPR”); if you are in the UK, it will be processed under the UK Data Protection Act 2018 (the “DPA”) (collectively the “EU/UK Processing”); and if you reside in California, it will be subject to the California Consumer Privacy Act (the “CCPA”), (the “CCPA Processing”).

This Privacy Policy makes clear where its disclosures apply only to specific processing, such as the EU/UK Processing, the CCPA Processing or India Processing.

Personal Data We Collect and Why

We process your data when you interact with us through our website, or third party platforms. The data that we process depends on the activity and the purposes for which the data is used. Here is an activity-wise description:

1. When you browse or visit our Platform

When you visit our Platform, we may process certain technical and behavioural data via automated means, to help us understand how you use the Platform. The Personal Data that we collect includes:

Your IP address, computer or device type, browser type, device operating system, referring website, general geographic location (based on IP address), web-browsing behaviour, and interactions with our Platform (e.g., pages or screens accessed, duration of visits, activity on a page or screen, access times, and length of access);
To the extent you have consented, we may collect your precise location data.

We process your Personal Data for the following purposes:

we may combine this data with other Personal Data in a manner that enables us to trace an individual user.
administering our Platform, including internal operations like updating, testing, securing, and troubleshooting;
customizing your experience by remembering preferences such as language and region, and displaying personalized content on our Platform;
aggregating Personal Data on an anonymous basis with other data for various purposes;
collecting statistics on your usage and interactions with our Platform, as well as gathering feedback on our services;
improving our services to provide you and others with a better experience, both online and offline;
promoting our services and the Platform, apprising you of news and industry updates through our newsletter;
monitoring, maintaining and protecting the security of our Platform, while preventing and detecting security threats, fraud, and other criminal or malicious activities;
investigating any complaints received from you or others about the Site;
sending you direct marketing by email in relation to our services;
cooperating with public authorities, courts, regulatory bodies, and supervisory authorities as required by law, responding to legal requests, resolving disputes, managing risks, seeking legal advice, enforcing our policies and contractual terms, and protecting our business and Platform.

2. When you apply for our services

When you apply for our services through the ‘Apply’ section on our Platform, we may process your Personal Data which includes:

Contact details such as your full name, email address, phone number, link to your LinkedIn profile, location;
Details of your company including its general overview and services it offers, registered address, customer details, funding details, pitch decks, demos, screenshots of your company’s product, details of your references and other relevant materials related to your company that you share with us during the application stage;
Recordings of your interactions with us, including call and meeting recordings.

We process your Personal Data for the following purposes:

verifying your identity and managing our relationship with you;
verifying details of your company, assessing your application, selecting companies for the ‘Surge Cohort’ and to provide you seamless access to our services;
to contact you via email, text message, phone, or social media (e.g., WhatsApp) regarding your interest in our services;
gathering feedback on our services;
improving our services to provide you and others with a better experience;
maintaining and protecting the security of our services and Platform, while preventing and detecting security threats, fraud, or other criminal or malicious activities;
cooperating with public authorities, courts, tribunals, regulatory bodies and supervisory authorities as required by law, responding to legal requests, resolving disputes, managing risks, seeking legal advice, enforcing our terms and protecting our business and Platform.

3. When you apply for a job through our Site

When you interact with us about job openings, such as through our Site's ‘Startups section, we process Personal Data such as:

Contact details including your full name, email address, and mobile number;
Data about your qualifications/skills; Data about your job preferences, including role, skills, industry, location, company stage and salary range.

We process your Personal Data for the following purposes:

showing you job openings based on your preferences and qualifications;
communicating with you regarding job applications;
verifying your data;
cooperating with public authorities, courts, tribunals, regulatory bodies and supervisory authorities as required by law, responding to legal requests, resolving disputes, managing risks, seeking legal advice, enforcing our policies and contractual terms, and protecting our business and platforms.

4. When you interact with us through any of our marketing communication

You may engage with our marketing communications (e.g., while accessing or subscribing to our newsletter, insights) through our Platform. We process the following Personal Data to send you marketing communications:

Information you provide when subscribing to marketing communications, such as name, email address.

We process your Personal Data for the following purposes:

providing you with marketing communications or to share relevant commercial opportunities;
gathering feedback on our products and services;
improving our products and services to provide you and others with a better experience.

5. When you engage with us on social media platforms

When you interact with us on social media (e.g., sharing comments on posts of our official page on any social media platform), we may process your Personal Data publicly available on these platforms. This includes:

Your full name or username (as displayed on the social media platform), your profile picture (if publicly available) and country (if indicated on your profile);
Any comments or content you post publicly regarding us.

We process such data (which may include your Personal Data) for the following purposes:

responding to your comments and posts about our services;
gathering feedback on our services;
improving our services;
cooperating with public authorities, courts, tribunals, regulatory bodies and supervisory authorities as required by law, responding to legal requests, resolving disputes, managing risks, seeking legal advice, enforcing our policies and contractual terms, and protecting our business and Platform.

6. When you send us media queries or generally enquire about us

When you send us media queries or otherwise contact us regarding the Surge program or services, we process your Personal Data, which includes:

Contact details such as your full name, professional affiliation and email address, to identify you and communicate with you;
Professional and location information, such as your organisation, role, city, and country, to connect you with the appropriate representatives,
Details of your inquiry, including information about your media request or other questions;
Records of our interactions, including correspondence and, where legally permitted, call recordings; and
Any other information you choose to provide in connection with your inquiry.

We process your Personal Data for the following purposes:

verifying your identity and to manage our relationship with you;
responding to your media inquiries or other requests;
communicating with you regarding our program, services or events;
providing information, updates, or communications that may be of interest to you, subject to applicable law and your preferences;
gathering feedback and to improve our communications and outreach;
maintaining and protecting the security of our services and Site, while preventing and detecting security threats, fraud, or other criminal or malicious activities;
cooperating with public authorities, courts, tribunals, regulatory bodies and supervisory authorities as required by law, responding to legal requests, resolving disputes, managing risks, seeking legal advice, enforcing our terms and protecting our business and platforms.

Where We Collect Your Personal Data From

Information You Submit

This includes Personal Data you provide us through our Platform, information about your communications with us, including the Personal Data you provide to us in email or in conversations with our employees and personnel, your marketing preferences, including any consents you have given us. If your Personal Data is shared by any person other than yourself, we will ensure that such Personal Data is collected with your consent, is used for the purpose for which it is disclosed to us and ensure that such person is legally permitted to disclose your Personal Data.

Information We Collect Automatically

We automatically collect certain Personal Data to help us understand how you use the Platform, through automated means such as cookies and similar technologies.

Information We Collect From Third Parties

On occasion, we may receive Personal Data from third party sources, such as suppliers providing web analytics and reporting services, marketing partners, advertising partners, affiliates among others. We take steps to ensure that the information we receive from these third parties has been collected with your consent or that these parties are otherwise legally permitted to disclose your Personal Data to us. We may also obtain information through our business partners or co-create datasets with them as part of our business operations. In some cases, we combine your Personal Data that we receive from multiple sources, including directly collected from you. This aggregated data is utilized for various purposes, including improving algorithms and data models.

Cookies

We may use cookies (which are small amounts of data sent from a web server to your browser that are stored on your computer’s hard drive) and similar tracking technologies to keep track of your use of the Platform, to validate your identity, to remember your password and preferences, to tailor the Platform and our services to your account and to meet your interests, and to improve our services and the quality of the Platforms. We collect data such as your IP address, browser type, and device type (e.g., PC, smartphone), access time, the webpage from which you came and the webpage(s) that you access during your visit, and identify your subsequent visits to our Platform. Generally, you can control how cookies are used through your browser or device settings, where you can disable or delete all or some cookies. Please note that if you do set your browser not to accept cookies, the Platform may not function properly.

Children

We do not knowingly collect Personal Data from minors nor do we target the Site or the Platform to minors.

Our Use of Personal Data

(a) The following table describes the purposes for which we process the Personal Data referred to above, and any information you give us, as well as the legal basis for the use of Personal Data that is subject to the EU/UK Processing.

Purpose of Processing	EU/UK Disclosure: Legal Basis
Verifying your identity. Communicating with you in relation to the products and services we provide on the Platform.	Where necessary to fulfil a contract or purchase, or take steps linked to a contract or purchase.
In response to requests from government law enforcement authorities conducting an investigation.	Where necessary to comply with a legal obligation.
Providing services to our clients and other individuals. Promoting our services (including the Platform) to clients, potential clients and other individuals and advising you of news and industry updates. Monitoring the use of the Platform and using Personal Data to help us improve and protect the Platform, both online and offline. Investigating any complaints received from you or others about the Platform. In connection with legal claims and for compliance, regulatory and investigatory purposes.	Where necessary for Peak XV's or another party's legitimate interests and where those interests are not overridden by your data protection rights.
Sending you direct marketing by email in relation to our services (including the Platform). On other occasions where we ask you for consent, we will use your Personal Data for the purpose(s) that we explain at that time.	Where you give us your consent.

Our Personal Data Sharing Practices

We employ other companies and individuals to perform functions on our behalf, such as for analyzing data and providing certain services. These third-party service providers have access to Personal Data needed to perform their functions, but we require that they do not use Personal Data for other purposes. Personal Data is not shared with any unaffiliated third parties for their marketing purposes unless we have obtained your consent to do so in accordance with applicable law.

We may share Personal Data, as permitted by law, with third parties: (1) in response to subpoenas, court orders, regulatory requests or legal process, or to establish, protect or exercise our legal rights and interests or defend against legal claims; (2) if we believe it is necessary in order to investigate, prevent or take action regarding inappropriate or illegal activities, fraud or situations involving potential threats to the safety of any person or property; (3) if we believe it is necessary to investigate, prevent or take action regarding inappropriate use of the Platform; (4) to our parent company, subsidiaries, joint ventures or other companies under common control with us (in which case we will require such entities to honor this Privacy Policy); (5) as part of a corporate transaction with a successor or affiliate or in connection with any acquisition, merger or sale of assets; (6) to organise and administer offsites and internal programmes; and (7) with your consent, for purposes not covered in this Privacy Policy.

India Disclosure: We may disclose your Personal Data to an overseas recipient under certain circumstances. For example, where you have provided your consent or to an overseas server for storage. However, we only ever share your Personal Data outside of India where we are permitted to do so under applicable laws and subject to requirements under the DPDPA. We will not transfer your Personal Data to any country or territory outside India, where such transfer is restricted as per the DPDPA.

CCPA Disclosure: We may disclose the following categories of Personal Data to our service providers for the performance of business services on our behalf: (1) identifiers, including your name, user name and password, and contact details, such as your personal or work postal address, email address and phone number; (2) commercial information, including your marketing preferences and any consents you have given us; (3) internet or other electronic network activity information, including information related to the browser or device you use to access the Platform, your IP address and cookie preferences; and (4) audio, electronic and visual information, including your communications with us and the Personal Data you provide to us in email or in conversations with our employees and personnel. We do not sell your Personal Data and have not sold your Personal Data in the last 12 months. We do not sell the Personal Data of minors.

EU/UK Disclosure: Your Personal Data may be transferred to, processed in and accessed from jurisdictions outside the EU and the UK by Peak XV and the third parties with which we share your Personal Data. Specifically, your Personal Data could be transferred to Peak XV entities and third parties in the United States of America. When we transfer your Personal Data among Peak XV entities, or to other third party organizations, we will do in accordance with the GDPR and/or the DPA, including through the use of European Commission-approved standard contractual clauses, a third party’s binding corporate rules or where we are entitled to rely on one of the other safeguards permitted by the GDPR and/or the DPA.

Your Rights

We have controls in place designed to ensure that the Personal Data we collect and process is relevant, accurate and appropriate for the purposes it is used. If you believe that any Personal Data about you is inaccurate or should no longer be retained by us, please contact us at compliance@peakxv.com. Please note that any Personal Data we have copied may remain in back-up storage for some period of time after your request, and that if you delete certain Personal Data, you may not be able to use the Platform in the future without re-submitting such information. Please also note that we will maintain Personal Data whenever we are required to do so by law or regulation.

Individuals in Andorra, Argentina, Australia, Canada, Faroe Islands, Guernsey, Hong Kong, Israel, Isle of Man, Japan, Jersey, Mexico, New Zealand, Singapore, South Korea, Switzerland, Uruguay and certain other jurisdictions may have certain rights in relation to their Personal Data. These rights vary, but they may include the right to: (1) request access to and rectification or erasure of their Personal Data; (2) restrict or object to the processing of their Personal Data; and (3) obtain a copy of their Personal Data in a portable format. Individuals may also have the right to lodge a complaint about Peak XV’s processing of their Personal Data with a data protection authority. The rights described herein are not absolute and may not be applicable to you. We reserve all of our rights available to us at law in this regard. If you wish to exercise any of the rights described in this Your Rights section, please email compliance@peakxv.com.

If you wish to exercise your rights, we will need to verify your identity. To do so, we will request that you match specific pieces of information you have provided us previously, as well as, in some instances, asking you to provide a signed declaration under penalty of perjury that you are the individual whose Personal Data is the subject of the request. If it is necessary to collect additional information (including Personal Data) from you, we will use the information only for verification purposes and will delete it as soon as practicable after complying with the request. For requests related to particularly sensitive Personal Data, we may require additional proof of identification. If you make a request through an authorized agent, we will require written proof that the agent is authorized to act on your behalf. We will process your request within the time provided by applicable law.

India Disclosure: If you are located in India,, you are entitled to the following rights: (i) request access to a summary of your Personal Data processed, the processing activity, and the recipients with whom we have shared your Personal Data, along with a description of the Personal Data we shared, subject to applicable law; (ii) you may write to us if you believe that the Personal Data we hold is inaccurate, incomplete or outdated; (iii) you may request deletion of your data; however, in certain cases, we may need to retain it for legal or regulatory reasons; (iv) you can nominate another individual to exercise your rights under this Privacy Policy on your behalf in the event of your death or incapacity; (v) if we are processing your Personal Data based on your consent, you may withdraw your consent at any time. Should you do so, you may not be able to access some of our services. You may choose to opt out of receiving marketing communication from us; (vi) if you wish to file a grievance, you may contact us in accordance with this Privacy Policy.

EU/UK Disclosure: You may be entitled to ask Peak XV for a copy of your Personal Data, to correct, delete or restrict processing of it, and to obtain the Personal Data you provide in a structured, machine-readable format and ask us to share this Personal Data to other organizations. You may also have the right to object to processing in some circumstances and can ask us not to send you direct marketing or to carry out profiling at any time. You have the right to lodge a complaint about Peak XV’s processing of your Personal Data with a data protection authority in the place you live, work or where the breach occurred. Where we have asked for your consent, you may withdraw consent at any time. If you ask to withdraw your consent to Peak XV processing your Personal Data, this will not affect any processing that has already taken place. These rights may be limited, for example if fulfilling your request would reveal Personal Data about another person, where they would infringe the rights of a third party (including our rights) or if you ask us to delete Personal Data that we are required by law to keep or have compelling legitimate interests in keeping. We will inform you of relevant exemptions we rely upon when responding to any request you make.

CCPA Disclosure: If you are a California resident, you may be entitled to request access to the Personal Data that Peak XV collects about you, to request that Peak XV deletes your Personal Data and to opt out of the sale of your Personal Data. The CCPA prohibits Peak XV from discriminating against you for exercising your applicable CCPA rights. Under California Civil law, Californians are also entitled to request information relating to whether a business has disclosed Personal Data to any third parties for the third parties’ direct marketing purposes. If you are making a request for access, we may not be able to provide specific pieces of Personal Data if the disclosure creates a substantial, articulable, and unreasonable risk to the security of your Personal Data, your account with us, or our systems or networks. If you are making a request for erasure, we will ask that you confirm that you would like us to delete your Personal Data again before your request is submitted.

Retaining Your Personal Data

India Disclosure: We keep your Personal Data for as long as necessary for the activity for which it was collected and to fulfill the purposes outlined in this Privacy Policy. Once the data is no longer needed for these purposes or to meet legal, regulatory, or business requirements, we will securely delete it.

EU/UK Disclosure: Where we process your Personal Data in connection with the Platform, we keep the Personal Data to comply with our legal obligations or to communicate with you because you still have another connection with Peak XV. Where we process your Personal Data for marketing purposes or with your consent, we process the data until you ask us to stop and for a short period after that (to allow us to implement your requests). We also keep a record of the fact that you have asked us not to send you direct marketing or to process your Personal Data so that we can respect your request in future. We maintain administrative and financial records and use multiple methods to back up our data and systems to ensure reliable data recovery in the event of a significant business disruption, and retain this information in accordance with our Personal Data Retention and Destruction Policy.

SEC Regulations S-P, S-AM and the Gramm-Leach-Bliley Act

Some regulators, such as the Securities and Exchange Commission, the U.K. Information Commissioner and the Federal Trade Commission, have adopted rules that require financial institutions, like Peak XV, to provide privacy policy notices to their clients. If you are a natural person who invests with us, that notice will govern how we use your Personal Data for the purposes specified in that notice.

Security

We have implemented appropriate technical and organisational measures to help protect Personal Data from loss, misuse or unauthorized access or disclosure. While we strive to protect Personal Data, we cannot guarantee its security.

Vulnerability Reporting

If you believe you have found a vulnerability or security concern with a Peak XV application or product, please submit a report to our Global Security team at security@peakxv.com.

Please include the type of issue, the name of the application or a URL, a proof of concept, and the detailed steps required to reproduce the issue. We take all disclosures very seriously.

Links

The Platform may contain links to other websites. We are not responsible for the privacy practices of any such other website (whether accessed through an advertisement, service or content link) and urge you to review such practices prior to submitting any information or Personal Data to such websites.

Changes

We may update this Privacy Policy from time to time. If under any such update we make any material change to the way in which we treat your Personal Data, we will inform you of such change via e-mail or by posting a notice on relevant areas of the Platform. Any updated version of this Privacy Policy will be effective as of the date set forth therein. If you are located in the United States of America or otherwise outside the EU or the UK, by continuing to use the Platform after such updates you expressly agree to the terms of the updated Privacy Policy.

Questions

If you have any questions about this Privacy Policy, want to exercise your rights or notify discrepancies / raise grievances with respect to your Personal Data you provide to us or on any other aspect of this Privacy Policy please feel free to contact us by e-mail at compliance@peakxv.com.

India Disclosure: We will acknowledge your communication within 90 (ninety) days of receipt. If your grievance remains unresolved or you are not satisfied with our response, you are entitled to make a complaint to the Data Protection Board.

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