This Data privacy policy (hereinafter referred to as the “Privacy Policy”), together with the terms of use, describes the firm’s policies and procedures on the collection, use and disclosure of the information provided by Users and Visitors (as defined herein below) of the Platforms. The firm shall not use the User’s information in any manner except as provided under this Privacy Policy. Every User who accesses or uses the Platforms shall be bound by this Privacy Policy.

I) Why This Data Privacy Policy?

This Data Privacy Policy is published pursuant to:

A) Section 43A of the Information Technology Act, 2000;
B) Regulation 4 of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information) Rules, 2011 (“SPI Rules”); and
C) Regulation 3(1) of the Information Technology (Intermediaries Guidelines) Rules, 2011.

This Data Privacy Policy sets out the type of information collected from the Users, including the nature of the sensitive personal data or information, the purpose, means and modes of usage of such information and how and to whom the firm shall disclose such information.

II) What Type Of Information Is Covered By this Data Privacy Policy?

The Data Privacy Policy applies to information collected and processed by the firm consisting of following:

Personal information is information related to a visitor, or a combination of pieces of information that could reasonably allow him to be identified. Personal information may consist of full name, personal contact numbers, residential address, email address, gender or date of birth. While information such as date of birth in isolation may not be enough to uniquely identify the visitor, a combination of full name and date of birth may be sufficient to do so.

Sensitive personal data or information is such personal information that is collected, received, stored, transmitted or processed by the firm, consisting of:

Financial information such as bank account or credit card or debit card or other payment instrument details;
Physical, physiological and mental health condition/orientation; Medical records and history;
Biometric information;

Any detail relating to the above personal information categories as provided to the firm for providing service; and
Any of the information received under above personal information categories by the firm for processing, stored or processed under lawful contract or otherwise.
Please note that any information that is freely available or accessible in public domain or furnished under the Right to Information Act, 2005 or any other law for the time being in force shall not be regarded as sensitive personal information.
i. A condition of each User’s use of and access to the Platforms and to other services provided by the firm to Users (collectively referred to as the “Services”), is his/her/its acceptance of the terms of use which also involves acceptance of the terms of this

ii. Privacy Policy. Any User who does not agree with any provisions of the Terms of Use or this Privacy Policy is advised not to accept the Terms of Use and may leave the Platforms.

iii. . While browsing the Platforms, a User is not required to provide personal information as set out under paragraph 4.1 and paragraph 4.2 until and unless such User chooses to avail or sign up for any of the Services. All the information provided to the firm by a User, including personal information and personally identifiable information, is voluntary. The User has the right to request the withdrawal of his/her/its consent at any time, in accordance with the terms of this Privacy Policy and the Terms of Use. It is the User’s duty to ensure strict caution while giving out any personally identifiable information about himself/herself/itself or his/her family members in use of any of the Services. The firm does not endorse the content, messages or information found in any Services and therefore, the firm specifically disclaims any liability with regard to the Services and any actions resulting from the User’s participation in any Services. As a condition to use the Services, you as a User agree to waive any claims against the firm relating to the same, and to the extent such waiver may be ineffective, you agree to release any claims against the firm relating to the same.

iv. Users can access, modify, correct and eliminate the data about him/her/it which has been collected pursuant to his/her/its decision to become a User. Any grievances in relation to the information shared by the User with the firm may be brought to the attention of grievance officer in accordance with relevant clause of this Privacy Policy.

v. For the use of the Services and purchase of Products, you may be required to pay the firm with a credit card, wire-transfer, or debit card through the firm’s third party payment gateway provider and such third party payment gateway provider may be required to collect certain financial information from you including, but not restricted to, your credit/debit card number or your bank account details (collectively referred to as “Financial Information”). All Financial Information collected from the Users’ by the firm’s third- party payment gateway providers will be used only for billing and payment processes. The verification of the Financial Information shall be accomplished only by the User through a process of authentication in which the firm shall have no role to play.

vi. Personal information, personally identifiable information and / or Financial Information shall be collected by the firm on an ongoing basis, without need for further, separate consent from the User (aside from the acceptance of this Privacy Policy, as provided in paragraph 5.1) for one or more of the following reasons:

A) to identify the User, to understand his/her/its needs and resolve disputes, if any;
B) to set up, manage and offer products and to enhance the Services to meet the User’s requirements;
C) to provide ongoing service;
D) to meet legal and regulatory requirements;
E) to resolve technical issues and troubleshoot problems;
F) to aid the firm in collecting monies from Users for transactions carried out on the Platforms;
G) to keep Users apprised of the firm’s (or third parties’) promotions and offers;
H) to customize User experience;
I) to detect and protect the firm from error, fraud and other criminal activities;
J) to enforce the Terms of Use; and
K) other reasons which, prior to being put into effect, shall be communicated to the Users through an update carried out to this Privacy Policy.

vii. The Financial Information collected from the Users is transacted through secure digital platforms of approved payment gateways which are under encryption, thereby complying with reasonably expected technology standards. While the firm shall make reasonable endeavours to ensure that the User’s personal information and the Financial Information is duly protected by undertaking security measures prescribed under applicable laws, the User is strongly advised to exercise discretion while providing personal information or Financial Information while using the Services given that the Internet is susceptible to security breaches.

viii. Due to the communications standards on the Internet, when a User visits the Platforms, the firm automatically receives the uniform resource locator of the site from which such User visits the Platforms, details of the website such User is visiting on leaving the Platforms, the internet protocol (“IP”) address of each User’s computer operating system, type of web browser the User is using, email patterns, and the name of the User’s internet service provider. This information is used solely to analyse overall User trends and to help the firm in improving its Services. Please note that the link between the User’s IP address and the User’s personally identifiable information is not shared with third parties without such User’s permission or except when required by law or to provide or facilitate the User with the Services. Notwithstanding the above, the User acknowledges the firm’s right to share some of the aggregate findings, including the personal information provided by the Users in an unidentifiable form, and not the specific data with advertisers, sponsors, investors, strategic partners, and others in order to help grow the business. The amount of information sent to the firm depends on the settings of the web browser used by the User to access the Platforms. The User may refer to the browser used, if the User wishes to learn what information is provided to the firm.

ix. The Platforms use temporary cookies to store certain data. The firm does not store personally identifiable information in the cookies. Information collected by the firm, by any means whatsoever, that does not personally identify the User as an individual (such as patterns of utilization described above) is exclusively owned by the firm and may be used by the firm and third-party service providers for technical administration of the

x. Platforms, user administration, research, development, and other purposes. Additionally, the firm may sell or otherwise transfer such research, statistical or intelligence data in an aggregated or non-personally identifiable form to its parent firm, group companies, subsidiaries, associates, affiliates, suppliers, vendors, sister concerns, service providers and service partners and other third parties (collectively referred to as “Other Parties”).

xi. A User may set or amend his/her/its web browsers to delete or disable cookies. If a User chooses to disable cookies on his/her/its computer or mobile telecommunication device, it may impair, degrade or restrict access to certain areas of the Platforms. Merely closing the web browser should ordinarily clear all temporary cookies installed by the firm. However, Users are encouraged to use the “clear cookies” functionality of their browsers to ensure deletion, as the firm cannot guarantee, predict or provide for the behaviour of the equipment of all the Users of the Platforms. You can learn more about the type of cookies that the Platforms may use during your visit below.

xii. The firm may allow other companies or entities to serve advertisements to Users. These companies or entities include third party advertisement servers, advertisement agencies, advertisement technology vendors and research firms. The firm may target some advertisements to Users that fit a certain general profile. The firm does not use personally identifiable information to target advertisements to specific Users. In the course of serving advertisements or optimizing the Services to its Users, the firm may allow authorised third parties to place or recognize a unique cookie on the User’s browser.

xiii. The firm does not exercise control over the websites displayed as search results or links from within the Services. These other sites may place their own cookies or other files on the Users’ computer, collect data or solicit personal information or Financial Information from the Users, for which the firm shall not be held responsible or liable. The firm does not make any representations concerning the privacy practices or policies of such third parties or terms of use of such websites, nor does the firm guarantee the accuracy, integrity, or quality of the information, data, text, software, sound, photographs, graphics, videos, messages or other materials available on such websites. The inclusion or exclusion does not imply any endorsement by the firm of such websites, the websites’ provider, or the information on the website.

When a User visits or uses the Platforms, the firm may access, collect, monitor and/or remotely store data in relation to the User’s location, which may also include global positioning system coordinates or similar information regarding the location of the device using which the User has visited or used the Platforms. The location data does not collect or share any personally identifiable information about the User.