1. WHO WE ARE

X'ALAER ("we", "us", "our") is a trade intelligence platform operated from India and accessible at xalaer.com. We provide geopolitical trade risk data, commodity price signals, shipping intelligence, and regulatory information to individual and institutional subscribers. The operator is the founding director, reachable at [email protected].

For the purposes of the Digital Personal Data Protection Act, 2023 (DPDP Act) and the Digital Personal Data Protection Rules, 2025 (DPDP Rules), we are a Data Fiduciary. You are the Data Principal.

2. WHAT DATA WE COLLECT AND WHY

We collect the minimum personal data required to deliver our service. We do not collect data beyond what is listed below.

3. WHAT WE DO NOT COLLECT

• We do not use cookies for tracking or advertising. We do not use analytics cookies.
• We do not collect biometric data, government ID numbers, or financial account details beyond what a payment gateway requires for transaction processing.
• We do not collect children's data. Our platform is strictly for users aged 18 and above. If you are under 18, do not use this platform or provide personal data.
• We do not collect sensitive personal data as defined under the IT (SPDI) Rules 2011 (passwords, health information, financial information beyond billing) unless strictly necessary for the service and with explicit consent.

4. HOW WE SHARE DATA

We do not sell, rent, or trade your personal data. We may share data only in the following limited circumstances:

• Payment processors: To process subscription payments. These processors are contractually bound to protect your data and may not use it for other purposes.
• Legal obligation: If required by law, court order, or a lawful government request, we will disclose the minimum necessary data and, where legally permitted, notify you promptly.
• Platform infrastructure: Our hosting provider (Cloudflare) may process technical data (server logs, IP addresses) strictly to deliver the platform. This is governed by Cloudflare's Data Processing Addendum.

5. YOUR RIGHTS AS A DATA PRINCIPAL

Under the DPDP Act 2023, you have the following rights. To exercise any right, email [email protected] with the subject line "Data Rights Request". We will respond within 30 days.

• Right to Access: Request a summary of the personal data we hold about you and how it is processed.
• Right to Correction: Request correction of inaccurate or incomplete personal data.
• Right to Erasure: Request deletion of your personal data. Upon verified request, we will erase your data within 30 days, subject to legal retention requirements.
• Right to Withdraw Consent: Withdraw consent for processing at any time. Withdrawal does not affect the lawfulness of processing before withdrawal. Withdrawal may result in termination of your subscription.
• Right to Grievance Redressal: File a complaint with our Grievance Officer at [email protected]. If unsatisfied with our response, you may approach the Data Protection Board of India once constituted under the DPDP Act.
• Right to Nominate: Nominate another individual to exercise your rights in the event of your death or incapacity.

6. DATA SECURITY

We implement reasonable technical and organisational security measures to protect your personal data, including:

• HTTPS encryption for all data transmission (TLS 1.2+)
• No server-side storage of card or payment details — processed directly by PCI-DSS compliant payment gateways
• Access controls limiting data access to authorised personnel only
• Cloudflare DDoS protection and edge security for the platform

No transmission over the internet is completely secure. We cannot guarantee absolute security, but we will notify you promptly of any personal data breach that may affect you, as required under the DPDP Rules 2025.

7. CROSS-BORDER DATA TRANSFERS

Our platform is hosted on Cloudflare's global network. Some technical data (server logs, edge caching) may be processed in data centres outside India. We rely on standard contractual protections with Cloudflare for any such transfers. We do not proactively transfer your personal identifiable data outside India for any purpose beyond technical platform delivery.

The DPDP Act 2023 permits cross-border transfers subject to the Central Government's restrictions. We will update this policy if transfer restrictions change.

8. GRIEVANCE OFFICER

As required under the Information Technology Act, 2000 and the DPDP Rules 2025, we have designated a Grievance Officer:

9. CHANGES TO THIS POLICY

We may update this Privacy Policy to reflect changes in law, our practices, or the platform. We will notify subscribers by email at least 14 days before material changes take effect. The updated policy will always be available at xalaer.com/legal. Continued use of the platform after changes take effect constitutes acceptance of the updated policy.

10. CONTACT

For all privacy-related queries: [email protected]

1. ACCEPTANCE OF TERMS

These Terms of Service ("Terms") govern your access to and use of the X'ALAER global trade intelligence platform available at xalaer.com ("Platform"), operated by Vikas Raghav ("Operator", "we", "us"). By creating an account, subscribing, or accessing any part of the Platform, you ("User", "Subscriber", "you") agree to these Terms in full.

These Terms must be read together with our Privacy Policy and Disclaimer, which are incorporated by reference.

You must be at least 18 years of age and legally capable of entering contracts under Indian law to use this Platform. Use by persons under 18 is strictly prohibited.

2. DESCRIPTION OF SERVICE

X'ALAER provides a curated trade intelligence service including:

• Live and editorial geopolitical shipping route risk assessments
• Commodity price signals (gold, silver, crude, copper) sourced from public market data
• Regulatory calendar and event monitoring for Indian and international financial bodies
• Human intelligence (HUMINT) field reports published by the Director (Atlas and Enterprise plans)
• Futures market squeeze monitoring and analysis across COMEX, MCX, and SHFE
• India ports status, chokepoint intelligence, and trade route risk overlays
• Custom research requests on a best-efforts basis

The Platform provides information and editorial intelligence only. It does not constitute financial advice, investment advice, or regulated financial services. See the Disclaimer for full details.

3. SUBSCRIPTION PLANS AND PAYMENT

The Platform is available under the following subscription tiers. Pricing is displayed on the platform and subject to change with 14 days' notice to existing subscribers.

• Signal Plan: Core signals, route risk, and commodity intelligence.
• Meridian Plan: Signal features plus AI digest, chokepoints, and regulatory calendar.
• Atlas Plan: Full platform access including HUMINT field reports.
• Enterprise Plan: Custom institutional access with bespoke research support.

All subscriptions are prepaid, billed monthly or annually as selected. Payments are processed by our third-party payment gateway. We do not store payment card details. All prices are in Indian Rupees (INR) inclusive of applicable taxes unless stated otherwise.

Subscriptions auto-renew unless cancelled before the renewal date. You will receive a reminder 7 days before renewal.

4. PROHIBITED USES

You must not use the Platform to:

• Reproduce, redistribute, resell, or publicly share any part of the intelligence content without written permission
• Reverse engineer, scrape, or systematically copy the Platform's architecture, design, or data
• Use the intelligence to facilitate or advise on activities that are illegal under Indian law or the laws of your jurisdiction
• Impersonate any person or entity, or falsely represent your affiliation with any organisation
• Use the Platform in any way that could damage, disable, or impair its operation
• Share your account credentials with any third party — subscriptions are personal and non-transferable
• Use automated bots or scripts to access the Platform

5. INTELLECTUAL PROPERTY

All content on the Platform, including but not limited to intelligence reports, HUMINT briefings, map overlays, editorial signals, brand elements, and platform design, is the exclusive intellectual property of X'ALAER and its Operator. It is protected under the Indian Copyright Act, 1957 and applicable international intellectual property laws.

Subscribers are granted a personal, non-exclusive, non-transferable, revocable licence to access and read the intelligence content for their own internal business purposes only. No content may be reproduced or redistributed without prior written consent.

The name "X'ALAER" and all associated marks are proprietary. Unauthorised use is prohibited.

6. ACCOUNT TERMINATION

We reserve the right to suspend or terminate your access without notice if you breach these Terms, engage in fraudulent activity, or if we believe your use poses a risk to the Platform or other users. On termination, your licence to use the content ceases immediately. Termination does not entitle you to a refund unless provided under the Refund Policy.

You may cancel your subscription at any time through your account settings or by emailing [email protected]. Cancellation takes effect at the end of your current billing period.

7. LIMITATION OF LIABILITY

To the maximum extent permitted by applicable Indian law:

• The Platform is provided "as is" without warranties of any kind, express or implied.
• We do not warrant that the information is accurate, complete, current, or suitable for any particular purpose.
• We are not liable for any direct, indirect, incidental, consequential, or special damages arising from your use of or reliance on the Platform's intelligence content, including but not limited to trading losses, business losses, or missed opportunities.
• Our total aggregate liability to you for any claim shall not exceed the total subscription fees paid by you in the 3 months preceding the claim.

8. FORCE MAJEURE

We shall not be liable for any failure or delay in performance of our obligations under these Terms arising from causes beyond our reasonable control, including but not limited to natural disasters, government actions, internet infrastructure failures, cyberattacks, or force majeure events.

9. AMENDMENTS

We reserve the right to amend these Terms at any time. Material changes will be notified to subscribers by email at least 14 days in advance. Continued use of the Platform after the effective date of changes constitutes acceptance. If you do not agree to amended Terms, you may cancel your subscription before the effective date and request a pro-rata refund of unused prepaid subscription fees.

10. GOVERNING LAW AND DISPUTE RESOLUTION

These Terms are governed by the laws of India. Any disputes arising from or relating to these Terms shall first be attempted to be resolved through good-faith negotiation. If unresolved within 30 days, disputes shall be subject to the exclusive jurisdiction of the courts of New Delhi, India. We do not participate in any alternative dispute resolution scheme outside India.

11. GRIEVANCE REDRESSAL

As required under the IT Act 2000 and Consumer Protection (E-Commerce) Rules, 2020, our designated Grievance Officer for service complaints is Vikas Raghav, reachable at [email protected]. Complaints will be acknowledged within 48 hours and resolved within 30 days.

12. SEVERABILITY

If any provision of these Terms is found unlawful, void, or unenforceable by a court of competent jurisdiction, that provision shall be deemed severable and shall not affect the validity and enforceability of the remaining provisions.

1. OVERVIEW

X'ALAER offers a subscription-based trade intelligence service. This Refund Policy explains your entitlements under Indian consumer protection law and our contractual terms. We aim to be fair and transparent.

2. 7-DAY COOLING OFF PERIOD

Under the Consumer Protection Act, 2019, you are entitled to cancel a new subscription and receive a full refund within 7 calendar days of your first payment, provided:

• This is your first subscription to X'ALAER
• You notify us at [email protected] within 7 days of your payment date
• You have not downloaded, exported, or redistributed any intelligence content

Full refunds under the cooling off period are processed within 7 business days to the original payment method.

3. STANDARD REFUND POLICY

After the 7-day cooling off period, our refund policy is as follows:

4. NON-REFUNDABLE ITEMS

The following are not eligible for refunds:

• Subscriptions cancelled after the 7-day cooling off period where you have accessed the platform content
• Custom research requests once work has commenced
• Subscriptions where access has been terminated due to a breach of our Terms of Service
• Partial months on monthly plans
• Subscription fees where the user has shared or redistributed content in violation of the Terms of Service

5. HOW TO REQUEST A REFUND

1. Email [email protected] with subject line "Refund Request — [Your Name]"
2. Include: your registered email address, subscription plan, payment date, and reason for refund
3. We will acknowledge your request within 48 hours
4. We will review and respond with a decision within 7 business days
5. Approved refunds are processed to the original payment method within the timelines stated above

6. DISPUTES

If you are unsatisfied with our refund decision, you may escalate to our Grievance Officer at [email protected]. If still unresolved, you may approach the consumer courts under the Consumer Protection Act, 2019 or file a complaint at the National Consumer Helpline (1800-11-4000). We respect and comply fully with consumer protection law.

7. CHANGES TO THIS POLICY

We may update this Refund Policy from time to time. Any material changes will be communicated to subscribers by email with at least 14 days' notice.

1. NATURE OF THE SERVICE

X'ALAER is a trade intelligence and geopolitical risk information service. The platform aggregates publicly available data, editorial signals, field intelligence, and commodity market information to support supply chain professionals, commodity traders, export managers, and institutional researchers in understanding macroeconomic and logistical conditions.

The platform is not a financial service, investment service, brokerage, or regulated advisory service under any Indian or international law. It does not hold any licence, registration, or authorisation from SEBI, RBI, IRDAI, or any other regulatory body.

2. NOT INVESTMENT ADVICE — SEBI COMPLIANCE STATEMENT

All content on X'ALAER — including but not limited to commodity price signals, futures market analysis, chokepoint risk assessments, HUMINT briefings, and AI digest — is published for informational and situational awareness purposes only. It does not constitute:

• Investment advice as defined under the SEBI (Investment Advisers) Regulations, 2013
• Research reports or recommendations as defined under the SEBI (Research Analysts) Regulations, 2014
• Trading calls, buy/sell recommendations, or portfolio advice of any kind
• Financial planning services regulated under any Indian law

SEBI has clarified through multiple orders and circulars (including the October 2024 and January 2025 circulars on finfluencers) that providing buy/sell signals or trading calls without SEBI registration constitutes a violation. X'ALAER does not provide such signals. Commodity price monitoring and geopolitical risk assessment are editorial intelligence functions distinct from regulated investment advisory.

3. ACCURACY OF INFORMATION

X'ALAER aggregates data from multiple sources including public APIs, open-source intelligence, editorial analysis, and field reports. While we strive for accuracy:

• We do not guarantee the accuracy, completeness, timeliness, or fitness for any purpose of any data or intelligence published on the Platform.
• Geopolitical situations evolve rapidly. Intelligence may be outdated by the time you access it.
• Commodity price data on the Platform is sourced from third-party APIs and may differ from exchange-official prices. It is indicative only.
• Regulatory calendar dates are compiled from official sources and verified at the time of publication, but dates may change. Always verify with the relevant official body before making decisions.
• HUMINT field reports contain unverified intelligence graded by source reliability but are not independently verified facts. They are intelligence inputs, not confirmed ground truths.

4. SHIPPING AND LOGISTICS INTELLIGENCE

Route risk assessments, chokepoint status, insurance premium estimates, and port intelligence are editorial assessments based on available open-source information. They are not:

• Official war risk assessments from Lloyd's or any insurance body
• Binding insurance quotations
• Operational route clearances or safety guarantees
• Recommendations from any government authority

Always consult your freight forwarder, insurer, and relevant government advisories before making shipping decisions.

5. INTERNATIONAL USERS

Users accessing X'ALAER from outside India acknowledge that the platform is operated from India and governed exclusively by Indian law. The content may reference international commodities, foreign exchange rates, and geopolitical events. Nothing on the platform constitutes advice or a recommendation regulated under the laws of the user's home jurisdiction. International users are solely responsible for ensuring their use of the platform complies with the laws of their own country.

6. HUMAN INTELLIGENCE DISCLAIMER

HUMINT (Human Intelligence) field reports are sourced from a private field network of human sources. All source identities are permanently anonymised. Sources are graded using NATO intelligence grading standards (reliability A–E, accuracy 1–6) as indicators only. These grades do not guarantee accuracy. HUMINT reports must be treated as intelligence inputs for situational awareness, not as confirmed facts. They do not constitute legal, financial, operational, or security advice.

Redistribution of HUMINT content in any form is strictly prohibited. X'ALAER and its Operator are not liable for any action taken based on HUMINT content.

7. THIRD-PARTY LINKS AND DATA

The Platform contains links to third-party websites and sources for reference. We are not responsible for the content, accuracy, or practices of any third-party site. Links do not constitute endorsement.

8. LIMITATION OF LIABILITY

To the fullest extent permitted by Indian law, X'ALAER, its Operator, and its contributors expressly disclaim all liability for:

• Financial losses arising from use of or reliance on platform intelligence
• Interruption of service, data loss, or inaccurate data
• Decisions made based on platform intelligence that result in harm of any kind
• Actions of third-party service providers referenced or linked on the platform

OUR MISSION

X'ALAER delivers real-time trade intelligence — geopolitical risk overlays, commodity market signals, shipping chokepoint assessments, regulatory calendars, and field intelligence — designed specifically for Indian SME exporters and institutional commodity operators who need intelligence-grade situational awareness without a Bloomberg terminal or an in-house research team.

The platform aggregates data from live maritime AIS feeds, flight tracking systems, commodity exchanges (COMEX, MCX, SHFE), regulatory bodies, GDELT geopolitical event databases, and a private field intelligence network — and presents it in a single, actionable map interface.

WHAT WE COVER

FOUNDING TEAM

THE ARCHITECTURE

X'ALAER is a three-layer intelligence platform:

• Layer 1 — Live Data: AIS vessel tracking, ADS-B flight data, forex (USD/INR), weather (maritime), GDELT geopolitical events, commodity prices — all updating in real time.
• Layer 2 — Editorial Intelligence: Our signals, chokepoints, routes, futures analysis, AI digest, and India ports data are curated and updated by the Director with active intelligence context that raw data cannot provide.
• Layer 3 — HUMINT: Private field reports from our human source network — available exclusively to Atlas and Enterprise subscribers — providing on-the-ground intelligence that no algorithm can replicate.

LEGAL IDENTITY

CONTACT GUIDELINES

To help us respond accurately, please include the following in your email:

• Your registered email address (the one used for your X'ALAER subscription)
• A clear subject line identifying your query type (e.g., "Refund Request", "Data Rights Request", "Formal Grievance")
• Relevant details including dates, transaction IDs, or screenshots where applicable

RESPONSE TIMELINE

PLATFORM OPERATED FROM

X'ALAER operates from India. All correspondence and disputes are governed by Indian law, with jurisdiction of the courts of New Delhi.

ESCALATION

If your grievance is not resolved within 30 days, you may escalate to:

• Data Protection Board of India (for data-related complaints)
• National Consumer Helpline — 1800-11-4000 (for consumer disputes)
• Consumer Forum — under the Consumer Protection Act, 2019