Privacy Policy

This Privacy Policy, inter alia, states the following:

i. The type of information collected from the Users, including Personal Information (as defined below) and Sensitive Personal Data or Information (as defined below) relating to an individual; ii. The purpose, means and modes of collection, usage, processing, retention and destruction of such information; and iii. How and to whom We will disclose such information. This Privacy Policy shall apply to any person who visits, browses, uses or accesses the Platform or use any Services on the Platform. This Privacy Policy is an electronic record in terms of the Information Technology Act, 2000 and rules and regulations made thereunder. Further, this electronic record is generated by a computer system and does not require any physical or digital signatures. Any new features and/or services that are added to Our current service at any point in the future shall also be subject to the terms set out in this policy.

“Personal Information” is defined under the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information) Rules, 2011 (the “SPI rules”) and means any information that relates to a natural person, which, either directly or indirectly, in combination with other information available or likely to be available to a body corporate, is capable of identifying such person. The SPI rules further defines “Sensitive Personal Data or Information” of a person to mean personal information about that person relating to: (i) passwords; (ii) financial information such as bank accounts, credit and debit card details or other payment instrument details; (iii) information received by body corporate under lawful contract or otherwise; (iv) visitor details as provided at the time of registration or thereafter; and (v) call data records. Please note that the information collected by Us from You may constitute ‘personal information’ or ‘sensitive personal data or information’ under the SPI Rules.

In order to have access to all the features, benefits or Services on Our Platform, a User must first create an account on Our Platform. To create an account and avail all the features, benefits or Services on Our Platform, a User is required to provide the following information, which such User recognizes and expressly acknowledges is personal information allowing others, including Us, to identify the User: name, User ID, email address, gender, country, ZIP/postal code, age, phone number, proof of identity and address documents such as Aadhar number etc., password chosen by the User. In addition, at the time of a registered User availing the Services, the User is required to provide certain sensitive personal information which includes its bank account or card details for undertaking transactions on the Platform for availing features and benefits on the Platform and the Services through the Platform. Other information requested on the account registration page, including the ability to receive promotional offers from Us, is optional. We may, in future, include other optional requests for information from the User to help Us to customize the Platform to deliver personalized information to the User.

DISCLAIMER- BY USING AND ACCESSING THE PLATFORM AND BY AVAILING THE SERVICES OR BY OTHERWISE GIVING US YOUR INFORMATION, YOU WILL BE DEEMED TO HAVE READ, UNDERSTOOD AND AGREED TO THE PRACTICES AND POLICIES OUTLINED IN THIS PRIVACY POLICY AND AGREE TO BE BOUND BY THE PRIVACY POLICY. YOU HEREBY CONSENT TO OUR COLLECTION, USE AND SHARING, DISCLOSURE OF YOUR INFORMATION AS DESCRIBED IN THIS PRIVACY POLICY. WE RESERVE THE RIGHT TO CHANGE, MODIFY, ADD OR DELETE PORTIONS OF THE TERMS OF THIS PRIVACY POLICY, AT OUR SOLE DISCRETION, AT ANY TIME. IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY AT ANY TIME, DO NOT USE ANY OF THE SERVICES OR GIVE US ANY OF YOUR INFORMATION. IF YOU USE THE SERVICES ON BEHALF OF OR FOR THE BENEFIT OF SOMEONE ELSE, YOU REPRESENT THAT YOU ARE AUTHORIZED BY SUCH INDIVIDUAL TO (I) ACCEPT THIS PRIVACY POLICY ON SUCH INDIVIDUAL’S BEHALF, AND (II) CONSENT ON BEHALF OF SUCH INDIVIDUAL TO OUR COLLECTION, USE AND DISCLOSURE OF SUCH INDIVIDUAL’S INFORMATION. YOU MAY NOTE THAT THIS PRIVACY POLICY IS BASED ON THE APPLICABLE LAWS OF INDIA AND GOOD DATA PRIVACY PRACTICES ADOPTED BY THE COMPANY IN INDIA AND MAY BE FOUND DEFICIENT WITH RESPECT TO CERTAIN PRIVACY LAWS OF SOME OTHER COUNTRIES. BY VISITING THE PLATFORM YOU AGREE TO BE BOUND BY THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY. IF YOU DO NOT AGREE WITH THE TERMS CONTAINED HEREIN, PLEASE DO NOT USE OR ACCESS OUR PLATFORM OR AVAIL ANY SERVICES ON THE PLATFORM. BY MERE USE OF THE PLATFORM, YOU EXPRESSLY CONSENT TO OUR USE AND DISCLOSURE OF YOUR PERSONAL INFORMATION IN ACCORDANCE WITH THIS PRIVACY POLICY.

PURPOSE OF THIS PRIVACY POLICY

We respect Your need to understand how and why information is being collected, used, disclosed, transferred and stored. Thus, We have developed this policy to familiarize You with Our practices and demonstrate Our commitment to the protection of Your privacy and Your personal information. This Privacy Policy sets out the way in which We process Your information when You visit the Platform or use the Services in accordance with applicable data protection laws. By accessing Our Platform or availing the Services, You agree to be bound by the terms of this policy. It is important that You read this policy together with any other policies that We may provide on specific occasions when We are collecting or processing your personal data, so that You are fully aware of how and why We are using your personal data. This policy supplements the other notices and is not intended to override them.

The information contained on this Platform and the personal information collected by using/ logging in and or accessing this Platform are stored at a secured server. It is stated by the server service provider that they have all the best security practices required for the server. The Platform is owned by Us and is located in India. Hence, We are bound by duty to abide by the laws, including but not limited to, regulations, rules, circulars and notifications governing privacy in India.

SCOPE OF THIS PRIVACY POLICY

We provide this Privacy Policy to inform You of Our policies and procedures regarding collection, storage, and processing and sharing of personal data that We receive from Users of the Platform or those which are stored or accessed by Us at the time of availing the Services or making transactions on the Platform.

With regard to this Privacy Policy, the terms “using” and “processing” information include, without limitation; the use of cookies; and the collection, storage, transfer, evaluation, deletion, disclosure, management, handling, modifying and use of personal data. This Privacy Policy applies only to personal data that You provide Us via the Platform.

We reserve the right to update this Privacy Policy from time to time to reflect any changes to Our Services. We will do this by amending the Privacy Policy on the Platform. The changes will take effect automatically, as soon as they are posted on the Platform. This Privacy Policy is applicable to all Users of this Platform. By using the Services, registering with Us or by otherwise giving Us Your information, You will be deemed to have read, understood and agreed to the practices and policies outlined in this Privacy Policy and agree to be bound by the terms hereof. You hereby consent to Us collecting, using and sharing and disclosing Your information as described in this Privacy Policy.

We reserve the right to change, modify, add or delete portions of the terms of this Privacy Policy, at Our sole discretion, at any time. If You do not agree with this Privacy Policy at any time, do not use any of the Services, use or access the Platform or give Us any of Your information. Any User that does not agree with any provisions of the Privacy Policy has the option to discontinue the Services provided by Us immediately.

PROCESSING OF PERSONAL DATA

We may process your personal data for, including without limitation, the following purposes:

Providing Our services: We might process your personal data to provide Services so as to facilitate the interaction and transaction of the Users. For example, personal data is processed in order to set up your user account or facilitate you in the sale and purchase of the goods/products. For example, personal data is processed in order to set up your account, allow You to avail the Services. We process the following personal data: (i) name; (ii) phone number; (iii) email address; (iv) home address; (v) IP address; (vi) location; (vii) User account profile data.

Customer service: We need to process personal data for this purpose because it enables Us to adequately respond to Users’ questions/ concerns and to verify the correctness of the order placed by User on the Platform and to ensure the overall quality of the Services availed by a User on the Platform.

Marketing: We process Users’ data for marketing purposes. This means that We can contact customers to draw attention to Our services. For this purpose, We process the following personal data: (i) website behaviour; (ii) IP address;(iii) email address; (iv) postal address; (v) phone number (vi) online identifiers; (vii) order information; (viii) location; (ix) and account information.

Commercial Use: All the information provided to Us by a User, including personal information or any sensitive personal data or information, is provided voluntary. You understand that We may use certain information provided by You, which may include your personal information or sensitive personal data or information for (i) the purpose of providing the Services to You; (ii) in an aggregated and anonymized form for research, statistical analysis and/or business intelligence purposes; (iii) sale or transfer of such research, statistical or intelligence data in an aggregated or non-personally identifiable form to third parties and affiliates; (iv) communication purposes to enhance your experience and obtaining feedback in relation to the Services; (v) customer support related issues; (vi) and enabling you to complete any transaction through the Platform.

In addition to the above, We may also use Your personal data for several reasons, including but not limited to; (i) keep You informed of the transaction status; (ii) send You communication in relation to availing of the Services via SMS or any other messaging service; (iii) allow Our customer service to contact You, if necessary; (v) request You for reviews of the Services; (vi) send You verification message(s) or email(s); (vii) validate/authenticate Your account and to prevent any misuse or abuse; (viii) send You important notices and communications regarding Our services availed or changes to the terms and conditions and/or policies; (ix) to send You marketing related communications; (x) to deal with enquiries and complaints raised by You and to troubleshoot problems; (xi) ensure compliance with all applicable laws and to ensure safety of the Platform and all Users; (xii) to prevent fraud, errors and/or any illegal activity on the Platform; (xiii) to send invoices, statements, agreements and/or to collect payment from You.

DISCLOSURE OF DATA

It may be necessary for Us to disclose Your personal data whether by law, legal process and/or by request from public and/or governmental authorities within or outside of your country of residence. We may also disclose Your personal information if We determine that disclosure is necessary or appropriate for the purposes of law enforcement, national security or to prevent or stop any activity We may consider to be, or to pose a risk of being, illegal, unethical or legally actionable. Some sections on the Platform are freely accessible by all Users and visitors and require no prior registration. Further, certain sections on the Platform are accessible by Users only after entering their details, username and password. Therefore, We request You to use a safe and secure server to access the Platform to ensure the safety of Your username, password and other information. We do not guarantee the security and/or privacy of any information, which may be available to all Users and visitors of the Platform publicly.

We automatically receive the URL of the site from which anyone visits. We also receive the Internet Protocol (IP) address of each User’s computer (or the proxy server a User used to access the World Wide Web), User’s computer operating system and type of web browser the User is using, email patterns, as well as the name of

User’s ISP. This information is used to analyze overall trends to help Us improve Our Services. The linkage between User’s IP address and User’s personally identifiable information is not shared with or disclosed to third parties. Notwithstanding the above, We may share and/or disclose some of the aggregate findings (not the specific data) in anonymized form (i.e., non-personally identifiable) with advertisers, sponsors, investors, strategic partners, and others in order to help grow Our business.

Note that We maintain a strict no-spam policy and do not rent, sell, disclose or share personal information belonging to You with other people or non-affiliated companies without Your consent, except to provide promotions or otherwise as specifically provided for in this Privacy Policy.

You agree that in addition to as may be provided in this policy, We may also disclose Your personal information under the following

circumstances: Third party service professionals and/or providers: We engage, retain or might, as per requirement and business needs of the Company, employ, engage, contract with third party service professionals/providers to work on behalf of or with Us, under agreements containing confidentiality obligations and in accordance with law, in relation to the services provided by Us on the Platform. These third party service providers may use Your personal information in assisting Us to communicate with You about Our offers, feedback of Services, assisting in payment facilities, providing customer support, assisting in advertising on the Platform etc. We may employ third party companies and/or individuals to help improve or facilitate our service, to provide the Service on our behalf, to perform platform-related services, including but not limited to: payment processing, maintenance services, fraud detection services, database management, web analytics, monitoring, and evaluation services. In this event, your information may be shared with such third party companies and/or individuals;

Compliance with laws and protection of Users: We may release your personal information when the same is required in order to comply with the law, in response to court orders, court summons, judgments, decrees, injunctions, arbitral awards, administrative orders, governmental investigation or orders of any government authority or any other legal process, to establish/exercise Our legal rights or defend against legal claims or in the event We reasonably believe that doing so is legally required or is in your interest to protect Your property or other legal rights or property or rights of others. We may also share your personal information in order to enforce and fully comply with Our terms of service and other Company policies;

Business transfer and mergers: We may transfer Your personal information if the Company, is acquired by or merged with another Company, to the extent permitted by applicable law and/or required under the scheme/arrangement of merger, etc. In such an event We will notify You before Your personal information is transferred/shared with the other entity and hence becomes subject to a different Privacy Policy; With Your consent: In addition to the aforementioned circumstances, We may share Your personal information with third parties with Your prior consent and/or at Your request.

COLLECTION AND USE OF NON-PERSONAL DATA

Non-personal data is data that can never be used to identify an individual. We may collect information regarding customer activities on Our Platform. This aggregated information shall be used by Us in research, analysis, to improve and monitor Our services and for various promotional schemes. Such non-personal data may be shared in aggregated, non-personal form with third party to enhance customer experience, offerings or services.

The Platform uses cookies, and while using the Platform You will be prompted to accept all cookies. We may place text files in the browser files of Your computer system. A cookie itself does not contain personal information and it will only enable Us to relate Your use of the Platform and Your behaviour on the Platform to information that You have specifically and knowingly provided. The only personal information that a cookie can contain is the information You supply to the cookie. A cookie can’t read data off Your hard disk or read cookie files created by other websites.

We may place both permanent and temporary cookies. A permanent cookie will remain on your web browser until its expiry date, unless deleted prior to such expiry date. However, most cookies are “session cookies” meaning that they automatically get deleted from your computer system at the end of the session. You can refuse cookies by turning them off in Your browser or alternatively You can also set your browser to warn You before accepting any cookies. Therefore, You are always free to decline Our cookies if Your browser permits, however We use certain cookies to authenticate Users on each page after the User logs on to the Platform or accesses any Services. If you, as a casual visitor, have inadvertently browsed any other page of this Platform prior to reading this Privacy Policy, and you do not agree with the manner in which such information is obtained, collected, processed, stored, used, disclosed or retained, merely quitting this browser application should ordinarily clear all temporary cookies installed by Us. All visitors, however, are encouraged to use the “clear cookies” functionality of their browsers to ensure such clearing / deletion, as We cannot guarantee, predict or provide for the behavior of the equipment of all the visitors of the Platform. Note that You are not a casual visitor if you have willingly submitted any personal data or information to Us through any means, including email, post or through the registration process on the Platform. All such visitors will be deemed to be, and will be treated as Users for the purposes of this Privacy Policy, and in which case, this Privacy Policy applies in its entirety to such persons.

The data that cookies collect will be used to process and/or analyse information by third parties to help improve or facilitate Our services, to provide Service on Our behalf, to Platform-related services, including but not limited to; maintenance services; fraud detectio