Privacy Policy

Sorigin Insurance Brokers- Privacy Policy

We, Sorigin Insurance Brokers Private Limited, having its registered office at AP81,B Wing,17 th Floor, Mundhwa, Pune , Maharashtra , India , 411036  (referred to as “Sorigin” or “We”, “Us” and “Our”), are a licensed insurance broker duly registered with the Insurance Regulatory and Development Authority of India (“IRDAI”). We operate as an intermediary facilitating the purchase, renewal, and management of insurance products and services offered by various third-party insurance companies (collectively referred to as “Insurance Companies” and individually referred to as “Insurance Company”) in accordance with applicable regulatory guidelines (“Services”).

We are the exclusive owner and operator of [soriginxure.com] (“Website”), through which We offer Users information with respect to the Services We offer. The Website does not currently facilitate online policy purchase, account creation, or online payment, and is intended solely for the dissemination of information regarding Sorigin’s Services. In addition to any Personal Data collected through the Website, Sorigin may also collect Your Personal Data through other channels, including telephone, email correspondence, and offline forms, for the purpose of facilitating the Services. This Policy governs Sorigin’s Processing of Personal Data collected through all such channels, and not only through the Website.

Sorigin is committed to protecting Your Personal Data and ensuring transparency in how We collect, use, otherwise Process and safeguard Your Personal Data. This Privacy Policy (“Policy”) is designed to inform You about Your rights, Our data handling practices, and the measures We take to ensure Your privacy is maintained in compliance with applicable laws. Our goal is to help You make informed choices while interacting with Our Website and/or accessing any information in relation to the Services.

This Policy describes the policies and procedures with respect to the collection, usage, handling, storage, and disclosure of Personal Data of, or relating to, the person who accesses or uses the Website. Any reference to “You”, “Your”, and/or “User” refers to You as the User of the Website, including as a User having access to any information in relation to the Services offered by Us.

This Policy is a standalone document setting out Sorigin’s data protection practices. For matters not addressed in this Policy, including use of the Website generally, please refer to Our Terms of Use, available at [soriginxure.com/terms-of-service/]. The capitalized terms used in this Policy, but not defined herein, shall have the meaning given to such terms in the Terms of Use and/or the Digital and Personal Data Protection Act, 2023 and the Rules made thereunder (collectively “the Act”).

Your privacy is important to Us, and this Policy will explain how We Process information that relates to You, which shall mean and include any operations We perform on such information, including its collection, storage, use, alteration, retrieval, sharing, disclosure, restriction or erasure, (“Process” or “Processing”) which information, either directly or indirectly, in combination with other information available or likely to be available with Us, is capable of identifying You (“Personal Data“).

Protecting Your privacy and ensuring that Your Personal Data is held securely is very important to Sorigin. We want You to be confident that We are looking after Your interests and that is why We have set out Our information practices in this Policy. Before You access or use the Website, including any access to information with respect to the Services offered by Us, and submit any information to Us, please read this Policy to understand how We will treat Your Personal Data.

Prior to using any part of the Website, including any access to information with respect to the  Services offered by Us, You will be asked to provide Your consent through a clear affirmative action such as ticking a box or clicking ‘I Agree’, to the Processing of Your Personal Data for the purposes outlined in this Policy. Such consent shall be sought through a request that is kept distinct from other terms and conditions, and that clearly sets out the Personal Data proposed to be collected and the purpose of such collection and shall not be inferred merely from Your continued use of the Website.

At the time We seek Your consent, We will provide You a notice specific to that instance of collection, describing the Personal Data being collected and the purpose for which it is sought, and the manner in which You may lodge a complaint or grievance. This Policy sets out Our data practices on a comprehensive and ongoing basis, while the point-of-collection notice will be specific to that instance of collection.

The consent given by You shall be free, specific, informed, unconditional and unambiguous with a clear affirmative action, and shall signify Your agreement to the Processing of your Personal Data for the purposes described in the notice given to You. You may withdraw Your consent at any time, with the same ease as when it was given in accordance with Paragraph 7 (Withdrawal of Consent and Opting Out) below. If You do not provide the consent sought, You may be unable to access certain features of the Website. This requirement, however, shall not apply where Sorigin Processes Your Personal Data on the basis of the legitimate uses described in Paragraph 2 (vi) below, for which Your consent is not separately required under applicable law.

The use of the Website and/or access to information related to Services offered by Us is available only to persons who can form a legally binding contract under the applicable law. We do not knowingly solicit or collect Personal Data from children under the age of 18 (eighteen) years or of persons with disabilities. Notwithstanding the foregoing, Sorigin shall not Process the Personal Data of a child or of persons with disabilities without obtaining verifiable consent of their parent or lawful guardian of such child, in the manner prescribed under applicable law and this Policy, and shall not undertake tracking, behavioural monitoring, or targeted advertising directed at children.

1. Purpose of Collection of Personal Data

We may collect the Personal Data, when You visit or access Our Website, including any information related to the Services offered by Us, specifically, for the purpose of the policy solicitation process, pre/post-sale servicing, and providing You any other services as permissible under applicable laws.

In addition to the above, We may collect contact information from You when You subscribe to Our newsletter, register for an event, respond to a survey, or fill out a form (as may be available on our Website), or such information which You voluntarily share with Us while sharing the feedback.

2. Collection of Information

For the purposes of this Policy, and subject to the definition of Personal Data, as provided above, we may collect the following information from You:

• Contact information, such as name, email address, phone number, and postal address;
• Demographic details, such as Your date of birth, age, gender, race, photo, marital status, lifestyle, and insurance requirements;
• Occupation including job title, employment status, salary, employment benefits, and employment history and qualifications;
• Health information such as medical records, health status and medical assessment outcomes;
• Information regarding Your interactions; or
• Any other personal data or information relevant for the purpose of Your use of the Website or any of its functionalities.

You understand that certain Personal Data such as name, age, gender, email, and personal data or information such as Aadhaar, PAN, address, profession details, health details and other details may be made mandatory to be submitted by the User as may be required to get price quotations from Insurance Companies as well as for issuance of policy document.

We may collect such Personal Data:

1. When You request assistance or more information related to insurance offerings

If You request for Our help while using the Website and/or availing any of the Services, then We may collect Your Personal Data through chat, e-mail, or telephone, which may override Your NDNC (National Do Not Call) registration, if any. This is for identifying You as a User or prospective, or existing customer, and in order to serve You better.

1. When You request a quote

If You request a quote for any of the products/Services with respect to which information is provided on the Website, We may collect Your Personal Data which may be required to process Your request.

• When You Contact Us

If You send Us personal correspondence, such as emails or letters, We may collect such Personal Data contained in such correspondence.

1. Based on Your use of the Website:

When You use the Website, We may choose to collect Your Personal Data through the standard medium used for receiving information from a User, like cookies (please see our Cookie Policy).

1. Gathered through third- parties:

We may also receive Personal Data about You from third parties, such as external APIs (Application Programming Interface) and social media services. If You access the Website through an external API or a social media service, the Personal Data We collect may include, Your user name associated with that social media service, any Personal Data or content the social media service has the right to share with Us. When You access the Website through external APIs or social media services, You are authorizing Sorigin to collect, store, use, and retain such Personal Data in accordance with this Policy.

1. For Legitimate Business Purposes

Where You voluntarily provide Us Your Personal Data for a specified purpose (such as requesting a quote, callback, or a policy document) and have not indicated that You do not consent to such use, We may Process Your Personal Data for that specific purpose in accordance with the provisions of the Act, without separately seeking Your consent.

• Other Sources:

As soon as You provide Your personal details like Your mobile number using any section of the Website, it is captured in the company customer relationship management, and auto/manual communication provisions are made for a faster service using channels such as automatic calls, manual calls, SMS, WhatsApp, email, notifications, and others. In Our efforts to continually improve Our product and service offerings, We collect and analyse demographic and profile data about Our Users’ activity on Our Website.

We may occasionally ask You to complete optional online surveys. These surveys may ask You for contact information and demographic information (like postal/ zip code, age, or income level). We use this data to tailor Your experience at the Website, providing You with content that We think You might be interested in and to display content according to Your preferences.

We may collect Non-personal data:

We may collect non-personal data about You whenever You interact with Our Website. Non-personal data may include, without limitation, the browser name, the type of computer or other communication device and technical information about Your means of connection to Our Website, such as the operating system and the internet service provider utilized, an IP address, assigned to the computer which You use, the domain server through which You access the Website, and other similar information. This non-personal data would not assist Us to identify You personally.

3. Usage and sharing of Personal Data

All information, including Your Personal Data, We collect is used for legitimate business purposes, only to the extent required or otherwise reasonably necessary for one or more of Our functions or activities, and while maintaining Your right to privacy.

We may Process Your Personal Data for any or all of the following purposes:

1. For responding to Your queries or requests, in connection with the use of the Website and/or to avail any of the Services as well as to send You notices, communications, offer alerts in connection with such Services.

1. For policy issuance and underwriting with various Insurance Companies. The necessary information differs from Insurance Company to Insurance Company and product to product.

• While developing Our business, We might purchase or sell some assets. In such cases, as a business transfer asset, some Personal Data related to You may be transferred.

1. In order to serve You better, We will, from time to time, use data analytics vendors to Process Your Personal Data to understand User preferences. During the transfer of data, the data will be pseudonymised to ensure User privacy. We will, from time to time, use marketing vendors to better understand User preferences. Personal Data shared in these cases will be limited to name, phone number, address, age, and email to reach out to the User. No other Personal Data will be passed. We will keep updating this section as and when new use cases of Personal Data transfer become a necessity.

1. We may identify and use Your Personal Data to help administer Our Website.

1. We will use and share Your Personal Data with Our staff and employees to Process Your Personal Data on Our behalf, on a need-to-know basis, for the purposes detailed under this Policy. Your Personal Data may also be used to suggest to You other insurance offerings. Such suggestions will be made by Sorigin, which might be of relevance to You or to process Your claims or manage Your relationship with Us.

• We may share Your Personal Data, strictly on a need-to-know basis, with third parties that provide services to help with Our business activities. These third parties are authorized to use Your Personal Data only as necessary to provide certain services to Us, including but not limited to:

• Providing cloud infrastructure;
• Sending transactional and service communications;
• Sending marketing communications;
• Providing customer service;
• Conducting research, or
• Payment processing.

Sorigin shall engage such third parties as Data Processors only under a valid contract, and shall, notwithstanding any such engagement, remain responsible for compliance with applicable law in respect of any Processing undertaken on its behalf by such Data Processors.

• We use Your Personal Data to identify and authenticate Users; understand Your needs and confirm Your application information and assess Your eligibility for products and services; establish and maintain communication; investigate and settle Your claims/requests, and determine Your eligibility for benefits; resolve disputes; troubleshoot problems; help promote a safe service; billing and collect money; measure consumer interest in Our products and services, and providing You any other services as permissible under applicable laws or any other insurance related purposes and as otherwise specified in the Policy.

1. Personal Data collected can be used by Sorigin within Sorigin or by its affiliates/ contractors/ agents for analysis and determination of statistics, demand and supply, pattern of usage, etc.

1. We may use Your Personal Data to comply with a legal obligation as per applicable legal and regulatory framework and as otherwise provided in this Policy.

1. We may disclose certain Personal Data to Point of Sales Persons (POSPs) solely for the purpose of soliciting Our business and/or for provision of any Services, in accordance with applicable laws and regulations.

• Sorigin undertakes not to disclose (including selling, sharing, and renting) Your Personal Data collected by Sorigin at any time to any third party without Your consent, except in accordance with this Policy. However, Sorigin reserves the right to disclose Personal Data in good faith:

• if required by law or any authority, provided however, in such event, We will use reasonable endeavours to notify You before Your Personal Data is transferred or disclosed;

• if We have reasons to believe that use and/or disclosure of such Personal Data is helpful or reasonably necessary to enforce Our other policies/Terms of Use, including investigations of potential violations thereof, investigate, detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues;

• to protect and defend the rights and interests of Sorigin, employees/ agents of Sorigin, other users, or the general public, where such disclosure is necessary.

• Furthermore, for marketing communications, We may use Your contact details to send You information regarding Our products and services, including those that may be added or made available in the future, via calls, emails, text messages, or similar means, where You have consented to receive such communications. You may opt out of receiving marketing communications at any time in accordance with Paragraph 7 (Withdrawal of Consent and Opting Out) below.

4. Processing of Children’s Personal Data

Where any Service requires Sorigin to Process the Personal Data of a child or person with disability, including where such child or person with disability is proposed to be included as a dependent or insured member under a policy, Sorigin shall obtain verifiable consent of the parent or lawful guardian of such child or person with disability before such Processing. Such verification shall be carried out by reference to the identity and age details voluntarily provided by the parent or lawful guardian , including through a virtual token linked to such details issued by an entity authorised by the Central Government (such as the DigiLocker service). Sorigin shall not use any Personal Data of a child or any person with disability for tracking, behavioural monitoring, or targeted advertising.

5. Retention of Your Personal Data

We retain Your Personal Data only for so long as is necessary for the specific purpose for which it was collected. We shall erase Your Personal Data as soon as it is reasonable to assume that the specified purpose is no longer being served or upon withdrawal of Your consent, whichever is earlier, unless retention is necessary for compliance with any law for the time being in force. Where required under applicable law, Sorigin shall notify You a reasonable period, and in any event not less than 48 (forty-eight) hours, before the erasure of Your Personal Data, to enable You to engage with Sorigin to prevent such erasure where permissible. This assessment is made individually in respect of each User’s Personal Data, and not by reference to a fixed or uniform retention period.

6. How do We protect Your Personal Data?

1. We take the safety of Your Personal Data and its confidentiality very seriously and provide reasonable security safeguards commensurate with the sensitivity of the personal data or information being handled and have implemented security practices, including but not limited to physical, electronic, and procedural safeguards to protect Your Personal Data. We implement a variety of security measures when You submit or share Your information with Us to maintain the safety of Your Personal Data.

1. The Website is scanned on a regular basis for any known vulnerabilities in order to make Your use as safe as possible. We also use regular malware scanning.

• Your Personal Data is contained behind secured networks and is only accessible by a limited number of persons on a need-to-know basis only and who have special access rights to such systems and are required to keep the information confidential.

1. Please be aware that, although We endeavour to provide reasonable security for Your Personal Data, no security system can prevent all potential security breaches.

1. We endeavour to ensure, to the best of Our ability, that all third-party service providers whose services We may use maintain security standards that are equivalent to Our security standards and commensurate with market practices, in the context of the sensitivity of Your Personal Data being stored or handled. However, We do not guarantee the security of Our data systems, as no system is impenetrable. If You suspect vulnerability of Your data, please feel free to inform Us.

1. Although Sorigin has ensured the security of Personal Data collected, considering the open nature of the internet, such Personal Data may be accessed by unauthorised entities/ software/ codes in a cybersecurity incident. In the event of a Personal Data breach, Sorigin shall, without delay, notify the Data Protection Board of India in such form and manner as may be prescribed, and shall intimate each affected User of the details and likely impact of such breach along with the measures being implemented to mitigate the risk arising therefrom. This paragraph shall not be construed to derogate from Sorigin’s obligations under applicable law.

7. Withdrawal of Consent and Opting Out

You may request the deletion of all Your Personal Data stored with Us at any time by submitting a written request to the contact details provided in Paragraph 12 (Contact Us) below.

Additionally, You have the right to withdraw Your consent for the Processing of Your Personal Data by notifying Sorigin in writing at the contact details provided in Paragraph 12(Contact Us) below. In the event You decide to withdraw Your Consent in relation to the Personal Data, We may prevent You from accessing Our Website.

You may choose to opt out of Our marketing services by using the unsubscribe button in the email, talking to one of Our executives, or by contacting Us at the details mentioned at Paragraph 12 (Contact Us) of this Policy. After this, You will not receive any updates on Our promotional offers or offerings in general.

You may also opt out of having Your Personal Data shared by Us with third-party business partners by contacting Us at the details mentioned at Paragraph 12 (Contact Us) of this Policy.

8. Correction, Completion, Erasure and Updating of Personal Data

You are always free to review and submit a request to edit Your Personal Data available with Us. It is of prime importance that the Personal Data We have about You is accurate, complete, and up to date. You have the right to seek correction of inaccurate or misleading Personal Data, completion of incomplete Personal Data, updating of Your Personal Data, and erasure of Personal Data that is no longer necessary for the purpose for which it was collected, by writing to Us at the contact details provided in Paragraph 12 (Contact Us) of this Policy. We will act on such request in accordance with this Policy and applicable law, including the retention and erasure provisions set out in Paragraph 5 (Retention of Your Personal Data) above.

We reserve the right to decline requests to access, correct or remove information that is unreasonably repetitive or systematic, require disproportionate technical effort, jeopardise the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on a backup drive), or for which access is not otherwise required. Sorigin shall endeavour to respond to and dispose of any such request within a period not exceeding 90 (ninety) days from the date of receipt thereof.

9. Nomination

You have the right to nominate any other individual who shall, in the event of Your death or incapacity, be entitled to exercise Your rights under this Policy and applicable law, in such manner as may be prescribed. You may record such nomination by contacting Us in accordance with Paragraph 12 (Contact Us) below.

10. Updating and Modification of the Policy

We may review, change, or update this Policy periodically and reserve the right to change the Policy at any time at Our discretion by posting such changes on the Website. We will publish the updated Policy on the Website and changes will take effect immediately at the time of publication. Your continued use of the Website following publication will constitute Your acceptance of those changes. You should review this Policy regularly and remain familiar with its terms.

11. Grievance Redressal

Sorigin is committed to resolve any Grievance or Complaint (as defined below) raised by You, in a prompt and fair manner, in accordance with applicable laws and in the manner described below.

For the purposes of this Policy, a “Grievance” or “Complaint” shall mean any written expression (including communications made through electronic means) of dissatisfaction submitted by You with regard to the Processing of Your Personal Data, any act or omission by Sorigin in performance of its obligations under the Act in relation to Your Personal Data. or exercise of Your rights under the Act. .

If You have any Grievances or Complaint, You may raise the issue with Our designated Grievance Redressal Officer using the contact details provided below:

Name: Minal Salunkhe

Email: Minal.Salunkhe@Sorigin.co

Telephone: 020-48450230

Postal Address: AP81,B Wing,17 th Floor, Mundhwa, Pune , Maharashtra , India , 411036

We shall acknowledge the receipt of a Grievance or Complaint within 24 (twenty-four) hours of receiving such Grievance or Complaint. Based on the nature and type of the Grievance or Complaint and subject to applicable laws, shall take adequate steps for the redressal of such Grievances or Complaints of Users. Sorigin shall endeavour to redress such Grievance or Complaint within a period not exceeding 90 (ninety) days from the date of receipt thereof, failing which You may approach the Data Protection Board of India.

12. Contact Us

If You have any questions or concerns with regard to this Policy, or if you wish to withdraw your consent, You may write to Us at insurance@sorigin.co.