Legal Framework

General Conditions
of Use.

Effective: May 5, 2026Version: 2026.05CIN: U62099BR2025PTC079540

Revision History: v2026.05

  • Initial platform release framework.
  • Alignment with DPDP 2023 and CERT-In 2022.

1. Introduction

Welcome to XC0MRADE, a technology-enabled vulnerability management marketplace operated by XC0MRADE Technologies Private Limited (the company, we, us, or our), incorporated under the Companies Act, 2013 with CIN U62099BR2025PTC079540.

This GCU governs your access to and use of xcomrade.tech, including related applications, APIs, and services. By creating an account, clicking I Agree, or using the services, you agree to be legally bound by this GCU and the Privacy Policy.

If you do not agree to these terms, you must stop using the platform.

2. Definitions

ASM

Attack Surface Management - continuous discovery and monitoring of an organisation's external digital assets.

BBP

Bug Bounty Programme where an organisation offers rewards for qualifying vulnerabilities in defined scope.

CERT-In

Indian Computer Emergency Response Team under Section 70B of the IT Act, 2000.

Commission

Company fee retained from reward disbursement, presently 15% to 20% [TBC], subject to notice.

Customer / Organisation

Any legal entity registered on the platform to host programmes or procure services.

DPDPA

Digital Personal Data Protection Act, 2023, including applicable rules and directions.

Escrow Wallet

Platform ledger account holding organisation funds pending researcher disbursement.

GCU

These General Conditions of Use, as amended from time to time.

KYB

Know Your Business verification for organisations, including CIN/GST and bank validation.

KYC

Know Your Customer verification for researchers, including Aadhaar/PAN/bank validation.

MFA

Multi-factor authentication using TOTP or email OTP for account login security.

Out-of-Scope Testing

Any testing against assets not explicitly listed in the programme scope.

P-Tier

Three-level reputation system (P3, P2, P1) based on Sketch Score and conduct.

Platform

xcomrade.tech infrastructure, software, APIs, dashboards, and associated services.

Programme

Any BBP, VDP, or PTM engagement hosted through the platform.

PTM

Penetration Test Management service for structured tests by vetted researchers.

Qualifying Vulnerability

In-scope, reproducible, non-duplicate vulnerability meeting programme thresholds.

Report

Submission by a researcher containing technical details, PoC, impact, and remediation.

Reward

Monetary or non-monetary consideration offered for accepted qualifying reports.

Safe Harbour

Legal protection for authorised, in-scope testing as per Section 12 of this GCU.

Scope

Specific systems, applications, IP ranges, and parameters defined by organisation.

Security Researcher

Independent individual registered to discover and responsibly disclose vulnerabilities.

Sketch Score

Reputation score calculated as per Schedule A points and deductions.

Sketcher

Platform visual tool for exploit-chain diagrams attached to reports.

VDP

Vulnerability Disclosure Programme with responsible disclosure but no reward obligation.

Wallet

Researcher wallet tracking reward credits, deductions, and payout status.

zerod

Platform learning module for CTFs, educational paths, and skill development.

3. Eligibility and User Status

3.1 Age Requirement

Platform usage is restricted to individuals at least 18 years of age.

3.2 Independent Contractor Status

Security Researchers are independent contractors, not employees, agents, or partners of the company.

3.3 Organisation Eligibility

Organisations must be valid legal entities and authorised representatives must have authority to bind them to this GCU.

3.4 Restrictions

  • Users from sanctioned jurisdictions are prohibited.
  • Users convicted for serious cyber offences may be denied access.
  • The company may apply geo-restriction controls for compliance.

4. Registration and Account Management

4.1 Account Creation and Roles

Users must provide accurate information. Roles include Security Researcher, Organisation, Verifier, Admin, and Superadmin.

4.2 MFA Requirement

MFA (TOTP or email OTP) must be enabled within 72 hours of registration.

4.3 KYC for Researchers

  • Aadhaar OTP-based verification where legally permitted.
  • PAN validation for tax compliance.
  • Bank account verification for payouts.
  • Additional checks required by applicable AML/PMLA obligations.

4.4 KYB for Organisations

  • GSTIN or CIN verification.
  • Authorised signatory validation.
  • Bank account validation for escrow funding.
  • Organisational PAN documentation where required.

5. Services Offered

Bug Bounty (BBP)

Organisation-run programmes with rewards for qualifying vulnerabilities.

Disclosure (VDP)

Non-monetary disclosure channel with recognition and reputation impacts.

PTM

Managed penetration testing engagements under separate statements of work.

ASM

Continuous external attack surface monitoring for subscribed organisations.

zerod

Learning and CTF module for capability growth and community participation.

Sketcher

Diagramming tool for exploit chain visuals attached to reports.

6. Researcher Obligations

6.1 Authorised Testing Only

Testing must remain strictly inside programme scope.

6.2 Prohibited Conduct

  • Data exfiltration beyond minimal proof.
  • DoS/DDoS activity.
  • Social engineering unless explicitly authorised in writing.
  • Testing unlisted third-party or partner assets.
  • Public disclosure before permitted coordinated timeline.
  • Account abuse, platform abuse, or severity manipulation.

6.3 Coordinated Disclosure

PeriodDescription
Day 0Report submitted via platform
Day 1-3Initial triage by verifier
Day 4-7Organisation notified; acknowledgement required
Day 8-30Organisation remediation window
Day 31-90Extended remediation for complex/critical issues
Day 91+Researcher may request disclosure with company approval

7. Intellectual Property

7.1 Platform IP

All platform software, tooling, branding, and proprietary systems are company intellectual property.

7.2 Report Licence

Accepted reports grant organisations a non-exclusive, irrevocable, perpetual, worldwide, royalty-free licence for remediation and security improvement purposes.

7.4 Research Graph

De-identified aggregate vulnerability pattern outputs are owned by the company.

8. Financial Conditions

8.2 Commission

Platform commission applies per programme terms, currently 15% to 20% [TBC] where applicable.

8.3 Wallet and Payouts

  • Accepted credits are held pending verification and KYC.
  • Payout target processing: 5 to 7 business days after approval.
  • Minimum payout threshold: INR 500 [TBC].
  • Fraud/compliance review may delay or withhold payouts.

8.4 Tax and TDS

TDS may be deducted as applicable law requires. Rates and treatment are subject to statutory requirements.

9. Confidentiality

9.1 Researcher Obligations

  • Do not disclose programme or report content without authorisation.
  • Use confidential information only for permitted programme activity.
  • Return or delete confidential information when required.

10. Personal Data and Privacy

10.2 Data Categories

CategoryExamplesLegal Basis (DPDPA)
Identity DataName, Aadhaar token, PAN, selfieConsent; Legitimate Use
Contact DataEmail, phone, addressConsent
Financial DataBank account, UPI ID, TDS recordsLegal Obligation
Technical DataIP address, logs, device infoLegitimate Use
Usage DataReports, zerod activity, actionsLegitimate Use
KYC/KYB DocumentsCIN, GST, board resolutionLegal Obligation
CommunicationsSupport tickets, legal appealsConsent / Legitimate Use

10.4 Retention Schedule

Data CategoryRetentionBasis
KYC/KYB Documents5 years after closurePMLA requirements
Financial and TDS Records7 yearsIncome tax requirements
Security Logs180 days rollingCERT-In directions
Accepted ReportsAs required by law or contractCompliance obligations
General Account DataAccount duration + 2 yearsLegitimate use
Support Communications3 yearsBusiness purpose

11. Limitation of Liability

To the maximum extent permitted by law, liability is limited as specified in this GCU and applicable law. Indirect, incidental, consequential, or special damages are excluded to the extent legally permitted.

12. Safe Harbour

Programme scope authorisation is a legal consent instrument for permitted testing. Safe Harbour applies only to authorised, in-scope testing and does not protect out-of-scope actions.

CRITICAL: Out-of-scope testing is not protected and may create civil and criminal exposure under applicable law.

14. P-Tier Reputation System

TierLabelSketch ScoreBenefits
P3Newcomer0-499Public programmes; core features
P2Trusted500-1,999Private programmes; priority verifier flow
P1Elite2,000+PTM eligibility; advanced trust features

Schedule A - Sketch Score

ActivityPointsNotes
Critical Severity Report Accepted+500Verifier + admin confirmation
High Severity Report Accepted+200Verifier confirmation
Medium Severity Report Accepted+100Standard verifier review
Low Severity Report Accepted+30Standard review
Informational Report Accepted+10Standard review
Sketch submitted with accepted report+20Linked accepted report required
First blood in programme+100First valid submission
CVE assignment for reported issue+150Verified CVE required
CTF challenge completed+15 / +40 / +100Per unique challenge
Skill badge earned+50Per badge
Community learning module completed+25Per completion
Duplicate report-10Deduction rule applies
Out-of-scope report (unintentional)-25Admin discretion
Low-quality insufficient report-15Verifier reviewed
Confirmed fraudulent report-500Human review required
Confirmed out-of-scope testing-1000Human review; suspension risk
Breach of confidentiality-2000Human review required
10 accepted reports milestone+200Cumulative milestone
50 accepted reports milestone+500Cumulative milestone
P2 tier attained+100Upgrade bonus
P1 tier attained+300Upgrade bonus

Schedule B - Ethics Certification

Every security researcher certifies at programme enrolment:

  • Testing is restricted to authorised scope only.
  • No data exfiltration beyond minimum proof requirements.
  • No destructive or disruptive activity (including DoS).
  • Responsible disclosure via platform before any external disclosure.
  • Strict confidentiality obligations are observed.
  • Compliance with applicable law and platform policy.
  • No undisclosed conflict of interest.
  • Tax and payout compliance responsibilities are accepted.
  • Submitted reports are accurate and non-fraudulent.
  • No attempt to manipulate platform systems or reputation scoring.

XC0MRADE Technologies Private Limited | Bihar, India

CIN: U62099BR2025PTC079540GCU: 2026.05