PRIVACY POLICY Last updated on 03 April 2025 Capitalized terms not defined herein shall have the meaning ascribed to them under the Terms of Use. This Privacy Policy (“Policy”) shall be read in conjunction and together with the Terms of Use available on _______________ and forms an integral part of the Terms of Use between you and the Company. The aforementioned Terms of Use and Privacy Policy constitute the entire User Agreement and a legally binding contract between the Company and you governing your use/access of the Service. Providing information to the Company is your choice. You understand that any data, information, content or information that you post, submit or upload to the Service will be stored on Company’s servers for the purposes of making the Service available to you. The Company advises you to be selective about what information you post. Please do not post, submit or upload to the Service any data, information, content or information which would include any personal data/personal information/information that you do not wish to be made available to the Company or to the public at the large. If you do not agree with any or all of the terms of this Privacy Policy, please do not provide any information to the Company. The terms of the Policy provided herein govern your use of Service and the information accessible on or from the Service. The Policy also lays down how the Company may collect, use and share any information you provide. This Privacy Policy shall also construe as a “Notice” required to be given under Section 5 of Digital Personal Data Protection Act 2023 (“DPDPA”). By accessing and/or using the Service, You signify Your agreement to accept this Policy. IF YOU DO NOT AGREE WITH ANY OR ALL OF THE FOLLOWING TERMS OF THE PRIVACY POLICY AND/OR THE TERMS OF USE, PLEASE DO NOT ACCESS AND/OR USE THE SERVICE. ANY USE AFTER THAT SHALL BE UNAUTHORISED. This Policy is subject to modification based on changes in the business, legal and regulatory requirements and will be made available to you on the Service. Any such modifications/changes shall be effective immediately upon them being posted. The Company reserves the right, at its sole discretion, to change, modify or otherwise alter this Policy at any time with or without prior notice (to the maximum extent permissible under law). You are encouraged to periodically review the Policy and any changes hereto. Your continued use of the Service following the posting of changes and/or modifications will constitute your acceptance of any revised Policy. The Company retains the right at any time to deny or suspend access to all or part of the Service to anyone who the Company believes has violated any condition of this Policy (as modified from time-to-time). SENSITIVE PERSONAL DATA OR INFORMATION THE COMPANY WILL NEVER ASK YOU AND YOU MUST NEVER PROVIDE SENSITIVE PERSONAL DATA OR INFORMATION TO THE COMPANY OR TO ANY PERSON/ENTITY REPRESENTING THE COMPANY. ANY DISCLOSURE OF SENSITIVE PERSONAL DATA OR INFORMATION SHALL BE AT YOUR SOLE RISK AND WITHOUT ANY LIABILITY TO THE COMPANY (INCLUDING ITS DIRECTORS, KEY MANAGERIAL PERSONNEL, OFFICERS AND EMPLOYEES). YOU UNDERSTAND, ACKNOWLEDGE AND AGREE THAT THE COMPANY OR ANY OTHER PERSON ACTING ON BEHALF OF THE COMPANY SHALL NOT IN ANY MANNER BE RESPONSIBLE FOR THE AUTHENTICITY OF THE PERSONAL INFORMATION OR SENSITIVE PERSONAL DATA OR INFORMATION PROVIDED BY YOU TO THE COMPANY. YOU MUST NOT DISCLOSE YOUR FOLLOWING SENSITIVE PERSONAL DATA/INFORMATION: passwords; financial information such as bank account details, credit card details, debit card details, secure pin number, passwords, etc.; physical, physiological and mental health condition; sexual orientation; medical records and history; biometric information; national identification numbers; and such other sensitive personal data or information. However, you must 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 Personal Information or Sensitive Personal Data or Information for the purposes of this Policy and the Company shall not be obliged to take any measures to protect the same since the same is freely available in the public domain. The Company does not and will not, at any time, request your credit card information, debit card information, financial pin numbers, passwords etc. If the Service is available to access by making a payment of subscription fee, then such information (only to the extent necessary) shall be collected, stored and/or processed by the third-party payment gateway directly, without any access to the Company to any such payment information. You shall then be governed by the terms of use of such third-party payment gateway. You are expected to read and fully understand the privacy policy of such third-party payment gateway or third-party service providers, as the case maybe, before sharing any information with such third-party payment gateway. Other than providing a confirmation upon receipt of payment from you against your Account, the Company disclaims all liabilities in relation to your payment processing by such third-party payment gateway and/or third-party service provider, as the case maybe, and the collection and processing of any payment information provided by you to such party(ies). You agree and acknowledge that the Company shall not be liable or and in no way be held responsible for any losses whatsoever, either direct, indirect, incidental, or consequential/special, including without limitation any losses due to delay in processing of payment instruction or any credit card/debit card/banking/payment fraud. WHAT DATA/INFORMATION IS COLLECTED The Company may collect: (a) personal data/personal information i.e. any data about an individual who is identifiable by or in relation to such data; and (b) non-personal data/non-personal information i.e. information that does not identify you or any other individual, and includes session, cookies, web beacons and usage data, log data, aggregate information, etc. You represent that the information or data you provide from time-to-time is and shall be correct, current and updated and you have all the rights, permissions and consents to provide such information or data. You may decline to share your digital personal information with the Company in which case, the Company will not be able to provide you the access to the Service. If you choose to provide such information, during registration or otherwise, you are giving the Company the consent to use, process, and store it consistent with this Privacy Policy. Your provision of the information or data to the Company and the Company’s consequent storage, collection, usage, transfer, access or processing or deletion of the same shall not be in violation of any third-party agreement, laws, judgments, orders or decrees. The Company implements appropriate technical and organisational measures to ensure a level of security appropriate to the risk of processing of information about individuals such as (i) only sharing and providing access to your information to the minimum extent necessary, subject to confidentiality restrictions where appropriate, and on an anonymised basis wherever possible; (ii) using secure servers to store your information; (iii) verifying the identity of any individual who requests access to information prior to granting them access to information; and (iv) using Secure Sockets Layer (SSL) software or other similar encryption technologies to encrypt any payment transactions you make on or via the Site. HOW IS THE DATA /INFORMATION COLLECTED The primary purpose of collection of personal data set out in Clause 3 (a) hereinbelow and other information set out in Clause 3 (b) to 3 (h) hereinbelow, is to allow you to access and use the Service and various features on or in relation to the Service provided by the Company, and for such purpose as set out under Clause 4 below. The Company may obtain information about your name, email address, date of birth, age, device, device id, contact details, gender, location, pin code, area code, occupation, provided by you either on the Service and/or which may be available to the Company or other users as a result of you publishing User Submissions on the Service and/or which may be available to the Company if you access the Service through any linked social media platforms; The Company may also obtain information about you, from any e-mails, letters, communication, etc. that you send to the Company. The Company may receive information that you submit to any third party services you access from links contained within the Service. You should check the privacy policy of such third-party services to find out how they will use your personal data and/or sensitive personal data or information. The Company shall not be responsible or liable for use or misuse of the same by third-party services. The Company may obtain information about your IP address, operating system, browser type, browser version, browser configuration, name of internet service provider, and other types of computer and connection related information relevant to identifying your type of device, geographic location, usage history, etc. The Company may also obtain information about how the Service is used by you. Such information may include but shall not be limited to: User Submissions that you publicly post or share on the Service; login information (date and time of login, number of logins, etc.); destinations/ pages visited within the Service; advertisements viewed and measurement of advertisement effectiveness; content viewed; content shared; User preferences (eg. program preferences, language, preferred social media, searched items, etc.); Third-Party Services visited while on the Service; service requests; etc. The Company may also obtain information collected by cookies or similar technologies (as described below), through contest and promotions held by the Company, newsletter subscriptions, enrollment for promotions, campaigns, special offers, surveys, feedback, analytics, research, information posted in social communities on the Service, etc. or otherwise shared on the Service. The Company may also obtain information collected as a result of You hosting, displaying, uploading, modifying, publishing, transmitting, updating and sharing User Submissions on the Service. If you access the Service through a social media platform, the Company may collect your user ID or user name, any information you have permitted the social media service to share with the Company, and any information you have made public with the social media service. In such a case, you undertake to comply to the Terms of Use including the Privacy Policy of the Service and any additional terms and conditions stipulated by such social media platforms. In the event of any inconsistency, the Terms of Use including the Privacy Policy of the Service shall prevail to the extent of conflict. The Company may combine your personal information with information collected from tracking technologies and aggregate it with information collected from other users using the Service to attempt to provide you with the services and a better experience on the Service. You understand, agree and acknowledge that the collection, storage and processing of your personal data/personal information by the Company is for a lawful purpose connected with the functioning of the Service. You hereby consent to the collection, storage, use, disclosure, transfer, processing of the personal data/personal information for the purposes set out herein. PURPOSE AND USE OF DATA/INFORMATION COLLECTION You may need to provide the Company with your personal data/personal information while registering yourself on the Service and/or subscribing to the Service. Your personal data and non-personal data as provided by you to the Company or otherwise captured by the Company may be used for a number of purposes connected with the Company business operations which may include the following for the following purposes: When the Company engages in digital advertising, the following categories of personal information may be used for purposes of cross-context behavioural advertising, or use for targeted advertising: personal identifiers (IP address,); and internet or other electronic activity information. These categories of personal information are shared for cross-context behavioural advertising or targeted advertising with, advertising networks and other companies that facilitate digital advertising. The Company engages in such sharing to facilitate digital advertising that is able to reach people that are most likely to be interested in the Services. The Company does so by allowing third parties to place cookies or other tracking technologies on our website that may collect information about your online activities over time and across different websites or applications. To opt out of such sales and sharing of personal information, please write to ______________ COOKIES & WEB BEACONS The Service and/or third parties may use cookies, web beacons, and other similar tracking technologies (collectively, “Tracking Technologies”) to collect information automatically as you browse the Service and the internet. For the purposes of this clause below terms have the meanings as set out below: The Company may use Tracking Technologies to help tailor the Content, understand Service and internet usage, improve or customize the Content, offerings or advertisements on this Service, personalize your experience on this Service (for example, to recognize you by name when you return to the Service), save your password in password-protected areas, save your settings, help us offer you programs or services that may be of interest to you, deliver relevant advertising, maintain and administer the Service, etc. These Tracking Technologies collect ‘click stream’ data and other additional information regarding your visits to the Service, such as your visits to the Service's webpages, use of features, or preferences and may also collect Your IP address or some other identifier unique to the device you use to access the Service (“Identifier”). Your Identifier is automatically assigned to the device you use to access the Service. By visiting the Service, whether as a registered user or otherwise, you acknowledge, understand and hereby agree that you are giving us your consent to track your activities and your use of the Service through these Tracking Technologies. The Service may additionally use a variety of third-party advertising networks, data exchanges, traffic measurement service providers, marketing analytics service providers and other third parties (collectively, “Third-Party Advertising Service Providers”) to, for example, serve advertisements on the Service, facilitate targeting of advertisements and/or measure and analyze advertising effectiveness and/or traffic on the Service (“Targeting Services”). These Third-Party Advertising Service Providers may enable the Company to display advertisements based on your visits to the Service and other services you have visited. Targeting Services enable the Company to, among other things, help deliver advertisements or other content to you for services that you might be interested in, to conduct research regarding the usefulness of certain advertisements to you, etc.  The Third-Party Advertising Service Providers, as well as advertisers, may themselves set and access their own Tracking Technologies on your device if you choose to have Tracking Technologies enabled in your browser (or, for flash cookies, if you have not removed them) and/or they may otherwise have access to information about you. Cookie and IP address information of a request to any Third-Party Advertising Service Provider may be transferred to the responding data centers outside the territory of India as well and these may include countries where applicable data protection laws provide a lesser degree of protection than India. By using this Service, you consent to the processing of data about you by such Third-Party Advertising Service Providers. In the event of any inconsistency, the Terms of Use including the Privacy Policy of the Service shall prevail to the extent of conflict only. You may also configure your browser/set your cookie preferences in such a manner so as to accept all cookies, reject all cookies, or notify you when a cookie is set. You may also prevent the installation of cookies through your browser settings, in which case not all functionalities/ features of the Service may be available to you. Information collected by cookies and other technologies are treated as non-personal information. Your personal data/personal information will be kept confidential to the maximum possible extent. Any personally identifiable information provided by you will not be considered as sensitive if it is freely available and/or accessible in the public domain. Further, any comments, messages, blogs, scribbles etc. posted/uploaded/conveyed/communicated by you on the public sections of the Service becomes published content and is not considered personally identifiable information subject to this Policy. PLEASE UNDERSTAND THAT, WHILE THE COMPANY STRIVES TO PROTECT YOUR PERSONAL DATA/PERSONAL INFORMATION AGAINST POTENTIAL RISKS AND EXPOSURES, THERE IS NO ABSOLUTE SECURITY IN THE ONLINE/ INTERNET SPACE. THEREFORE, YOU MUST NOT DISCLOSE ANY INFORMATION ON THE SERVICE THAT IS SENSITIVE PERSONAL DATA OR INFORMATION. YOU UNDERSTAND THAT THE TRANSMISSION OF INFORMATION OVER THE INTERNET IS NOT COMPLETELY SECURE AND THERE ARE RISKS ASSOCIATED WITH IT. ALTHOUGH THE COMPANY STRIVES TO PROTECT YOUR PERSONAL DATA/PERSONAL INFORMATION, THE COMPANY CANNOT GUARANTEE THE SECURITY OF THE SAME WHILE IT IS BEING TRANSMITTED TO THE SERVICE AND ANY TRANSMISSION IS AT YOUR OWN RISK. DISCLOSURE The Company does not sell or rent personal information. Your personal information may be disclosed under certain circumstances including: The Company may disclose your personal information to the Company Entities to provide various services including, contact information verification, payment processing, customer service, Service hosting, data analysis, infrastructure provision, IT services, marketing, research, communication, advertisements, software, technology and other similar services, under confidentiality restrictions, in order to enable such vendor and service providers to provide the services subscribed to by you; ​ The Company may provide your information or data to its partners, associates, advertisers, service providers or other third parties to provide, advertise or market their legitimate products and/or services which may be of your interest. You will have the choice to ‘opt-out’ of such marketing or promotional communications at your will; ​ As necessary or appropriate: (i) in any manner permitted under applicable law; (ii) to comply with legal process; (iii) to respond to requests from public and government authorities, including public and government authorities; (iv) to enforce the terms and conditions under the Terms of Use and this Privacy Policy; (v) to protect the Company’s s rights, privacy, safety or property, and/or that of the Company’s affiliates, you or others; and/or (vi) to allow the Company to pursue available remedies or limit the damages that the Company may sustain. ​ The Company may disclose to third party services certain personally identifiable information that you provide such as name, email, mobile phone number; that the Company collect as you access and use the Service, including device information, location and network carrier. This information is shared with third party service providers so that the Company can: (i) Personalize the Service for you; (ii) Perform behavioural analytics. INFORMATION SECURITY AND STORAGE The Company uses commercially reasonable security measures, practices and procedures, at the minimum those mandated under the Act and the Rules, to safeguard and protect your data and information. The Company implements such measures, as stated above, to protect against unauthorized access to, and unlawful interception of, personal information. You accept the inherent security implications of providing information over internet/cellular/data networks and acknowledge that the Company cannot ensure, warrant or guarantee the security of your data/ information while it is being transmitted to the Service. You also acknowledge and confirm that any such transmission is at your own risk and that you will not hold the Company responsible for any breach of security or the disclosure of personal information unless it is proven that the Company has been grossly and wilfully negligent. Your information or data will primarily be stored in an electronic form. However, certain data can also be stored in physical form. The Company may store, collect, process and use your data in countries other than India but under compliance with applicable laws. Notwithstanding anything contained in this Policy, the Company shall not be held responsible for any loss, damage or misuse of Your personal data/personal information, if such loss, damage or misuse is attributable to a Force Majeure Event. A “Force Majeure Event” shall mean any event that is beyond the reasonable control of the Company and shall include, without limitation, sabotage, fire, flood, explosion, acts of God, civil commotion, strikes or industrial action of any kind, riots, insurrection, war, epidemic, pandemic, acts of government, computer hacking, unauthorized access to computer data and storage device, computer crashes, breach of security and encryption, etc. DATA RETENTION / DATA DELETION The Company shall retain the categories of personal information collected for the length of time necessary to provide the Services and to comply with legal obligations, resolve disputes or to protect the Company’s legal rights. The criteria used to determine the retention periods include: how long the personal information is needed for a particular purpose and to operate the business; the type of personal information collected; and whether the Company is subject to a legal, contractual or similar obligation to retain the personal information (e.g., mandatory data retention laws, government orders to preserve data relevant to an investigation, or data that must be retained for the purposes of litigation or disputes). The Company may retain your personal information for an additional period to the extent deletion would require the Company to overwrite its automated disaster recovery backup systems or to the extent the Company deems it necessary to assert or defend legal claims during any relevant retention period. The Company will also delete your personal information when you withdraw your consent (where applicable), provided that the Company is not legally required or otherwise permitted to continue to hold such personal information. CHILDREN The Terms of Use available at ______________ contain restrictions on how minors can access and use the Website. You are required to carefully read and comply with the same. Any collection of Personal Information of children is intended to comply with applicable laws of India. The Company requires parental consent before Personal Information belonging to children is submitted or collected, unless the information concerned falls within an exception recognized under applicable law. The Company does not make Personal Information collected from children publicly available nor do we enable children to do so on the Site. A child’s participation in any activity or service contained on the Site is not conditional upon disclosure of more Personal Information than reasonably necessary to participate in such activity or service. Parents may contact the Company at the E-mail ID mentioned herein to review, update or delete any of their children’s Personal Information and to elect for the Company not to collect any additional Personal Information from their children. The Company will not change how the Company handle previously collected information without providing notice and obtaining parental consent wherever necessary. SUPPORT You have full control regarding which emails, push notifications, text messages you want to receive. If you decide at any time that you no longer wish to receive such text messages from the Company, please write to the Company at , instructing an Opt-Out. Please note that once the Company receives your request, it may take an additional period of time for you to opt-out to become effective. If you no longer want to receive certain communications from the Company via email, simply click the ‘unsubscribe’ link in the email. Please note that you cannot unsubscribe from service-related correspondence from the Company, such as messages relating to your account transactions. You can choose to receive mobile push notifications from the Company. On some device operating systems, you will be automatically enrolled in the notifications. If you subsequently decide you no longer wish to receive these notifications, you can use your mobile device's settings functionality to turn them off. The Company also offer push notifications on certain web browsers. If you agree to receive those notifications and subsequently decide you no longer wish to receive these notifications, you can use your browser’s settings to turn them off. If you no longer wish to receive WhatsApp messages in connection with your account, then you can use ‘opt-out’ mechanism available on the welcome message sent by the Company, reply STOP or you can either use your WhatsApp application settings functionality to block. If you have any further questions, queries with respect to the Service, then such correspondence should be directed to . RIGHTS Right to information: In case you are desirous of knowing the information about yourself stored with the Company, you may write to . Right to correction: In case you are desirous of editing or correcting the information about yourself stored with the Company, you may write to . Right to erasure: If you wish to have the information or data that you have provided to the Company deleted, you can always do so by sending a request to the Company on . The Company will respond to such requests within 45 days from the date of receipt of your request, although the Company may be allowed to take longer to process your request under certain circumstances. If the Company expects your request is going to take longer than normal to fulfill, you shall be intimated by the Company. You may note that correction or deletion of certain information or data may lead to cancellation of your registration with the Service(s) or your access to certain and/or all features of the Service. You also agree and acknowledge that certain data or information cannot be corrected or deleted or prohibited to be deleted as required under any applicable law, law enforcement requests or under any judicial proceedings, or for archival/ data retention/ record keeping purposes. Right to grievance redressal: In case of any grievance, you may write to the Grievance Officer and Compliance Officer as set out herein below Name: __________________ E-mail: Name: __________________ E-mail: Right to nominate: You can nominate any other individual to exercise these rights in the event of death or incapacity. GENERAL PROVISIONS This Privacy Policy, and any other documents, instructions, etc. included within the Service/App shall be read into this and shall form an integral part of the User Agreement. The aforementioned together constitute the entire user agreement and a legally binding contract between the Company and you governing your use/access of the Service/App. Wherever relevant, references to the User Agreement shall mean to include the Privacy Policy (as amended from time-to-time). This Privacy Policy shall be governed by and construed in accordance with the laws of the India and be subject to the exclusive jurisdiction of the Courts at Bengaluru, without giving effect to any principles of conflicts of law.