Privacy Policy

This Privacy Policy (“Policy”) explains the manner in which Vimano EWA Private Limited (“Company” “us”, “our” or “we”) processes your personal data. We respect your privacy and are committed to the protection of your personal data. This Policy outlines our practices in relation to the collection, storage, usage, processing, and disclosure of personal data that you have consented to share with us when you access, use, or interact with the our website or when you avail our services or products. The website, services and products shall be collectively referred to as the “Services”.

By using the Services offered by us, you confirm that you have read and agree to be bound by this Policy and consent to the processing activities described under this Policy.

1. BACKGROUND AND KEY INFORMATION

1.1. How this Policy applies: This Policy applies to individuals who access or use our Services (“User”, “you”, or “your”).

1.2. Review and Updates: We periodically update our Policy and encourage you to regularly review this Policy for any changes.

2.THE DATA WE COLLECT ABOUT YOU

2.1. We collect, use, store, disclose, transfer, retain, and otherwise process different types of personal data about you, as may be applicable, depending on the Services we provide to you. This includes, but is not limited to:

(a) Identity Data: This includes data such as your first and last name, date of birth, gender, designation, contact details and address.

(b) Profile Data: This includes data such as your username and password, where applicable.

(c) Marketing and Communications Data: This includes information posted in service requests, offers, feedback, comments, responses to user surveys and polls, your preferences in receiving marketing communications from us and third parties, and your communication preferences.

(d) Technical Data: This includes data such as your internet protocol address, time zone settings, operating systems, location data, device information and other technology that you use to access and use the Services.

(e) Usage Data: This includes information about how you use the Services, your activity on the website, user taps and clicks, user interests, time spent on the site, details about user journey, and page views.

2.2. We also collect, use, and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data under law as it is not directly or indirectly linked to your identity. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data, which will be used in accordance with this Policy.

2.3. We are required to collect certain personal data to provide you with the Services. If you fail to provide us that data as and when requested by us, we will not be able to perform our obligations under the arrangement we have with you or wish to enter into with you. In this case, we may have to cancel or limit your access to our Services (or part thereof).

3. HOW DO WE USE YOUR PERSONAL DATA?

3.1. We will only use your personal data when the law allows us to. We and our partners may use your personal data for the following purposes:

(a) to provide you with our Services;

(b) to monitor trends and personalise your experience;

(d) to improve customer service and to effectively respond to your service requests and support needs;

(e) to send periodic notifications to manage our relationship with you including to notify you of changes to our Services, send you information and updates pertaining to our Services that you have availed or sought to avail, and to send updates related to us or our Services;

(f) to market and advertise our Services to you;

(g) to respond to court orders, establish or exercise our legal rights, or defend ourselves against legal claims; Privileged and Confidential Draft for discussion 3

(h) to administer and protect our business and our Services, including for troubleshooting, data analysis, system testing, and performing internal operations;

(i) to improve our business and delivery models;

(j) for fraud prevention and detection;

(k) for compliance with applicable law;

(l) to perform our obligations that arise out of the arrangement we may enter or have entered with you.

3.2. You agree and acknowledge that by using the Services, you authorise us and our service providers to contact you via email, phone, or otherwise. This is to provide the Services to you and ensure that you are aware of all the features of the Services, and for sales and marketing purposes.

4. DISCLOSURE OF INFORMATION

4.1. You agree and acknowledge that any and all information pertaining to you, including but not limited to personal correspondence such as emails, instructions from you, information collected through our website, and any information you post online about our Services, may be collected, compiled, and disclosed by us in order to render the Services to you or improve the Services, pursuant to our arrangement with you or your consent. This may include but not be limited to third party service providers, third party partners, marketing and advertising partners, storage providers, data analytics providers, consultants, lawyers, and auditors. We may also share this information with our affiliates and subsidiaries in connection with the above-mentioned purposes.

4.2. You agree and acknowledge that we may share your personal data without your consent, when required by law or by any court or a government or regulatory authority.

5. THIRD PARTY LINKS SERVICES

5.1. Our Services may, from time to time, contain services provided by our partner networks, advertisers, and affiliates (“Third Party Services”). Please note that the Third Party Services that may be accessible through our site or Services have their own privacy policies. We do not accept any responsibility or liability for the policies or for any personal data that may be collected through the Third Party Services. Please check their policies before you submit any personal data to such websites or use their services. Privileged and Confidential Draft for discussion 4

5.2. Your relationship with these third parties and their services and tools is independent of your relationship with us. These third parties may allow you to permit or restrict the information that is collected. It may be in your interest to individually restrict or enable such data collections.

5.3. The place of processing information depends on each third-party service provider and you may wish to check the privacy policy of each service provider to identify the data shared and its purpose. You will be subject to a third party’s privacy policy if you opt in to receive communications from third parties. We will not be responsible for the privacy standards and practices of third parties.

6. COOKIES

6.1. Cookies are small files that a site or its service provider transfers to your device’s hard drive through your web browser (where applicable) that enables the sites or service providers’ systems to recognise your browser, and capture and remember certain information.

6.2. We use cookies to help us distinguish you from other users of our Services, understand and save your preferences for future visits, keep track of advertisements, and compile aggregate data about site traffic and site interaction so that we can offer you a seamless user experience. We may contact third party service providers to assist us in better understanding our site visitors. These service providers are not permitted to use the information collected on our behalf, except to help us conduct and improve our business.

6.3. Additionally, you may encounter cookies or other similar devices that are placed by third parties. We do not control the use of cookies by third parties.

7. YOUR RIGHTS IN RELATION TO YOUR PERSONAL DATA

7.1. Under certain circumstances and subject to applicable laws, you may have certain rights in respect of your personal data, such as the right to review and correct your personal data or revoke or deny consent.

7.2. If you wish to exercise any of the rights set out above, please write an email to the Grievance Officer, whose details are mentioned in Section 12 of this Policy.

8. TRANSFER OF PERSONAL DATA

8.1. We comply with applicable laws in respect of storage and transfer of personal data. As a part of your use of our Services, the information and personal data you provide to us may be transferred to and stored in countries other than the country you are based in. This may happen if any of our servers are from time to time located in a country other than the one you are based in, or one of our service providers is located in a country other than the one you are based in. Privileged and Confidential Draft for discussion 5

8.2. In the event we go through a business transition, including but not limited to a merger, acquisition by another organisation, or sale of all or a portion of our assets, your personal data might be among the assets transferred. 8.3. By submitting your information and personal data to us, you agree to the transfer, storage, and processing of such information and personal data in the manner described above.

9. DATA RETENTION

9.1. You agree and acknowledge that your personal data will continue to be stored and retained by us for as long as necessary to fulfil our stated purpose(s) and for a reasonable period thereafter to comply with our legal rights and obligations.

9.2. In some circumstances, we may de-identify information and create anonymous and aggregate datasets to improve the quality of the Services and for other business purposes, in which case we may use this information indefinitely without further notice to you.

10. DATA SECURITY

10.1. We implement reasonable security procedures to protect your personal data from unauthorised access and disclosure, including managerial, technical, operational, and physical security control measures that are commensurate with the information assets being protected.

11. CHANGE IN PRIVACY POLICY

11.1. We keep our Policy under regular review and may amend it from time to time at our sole discretion.

11.2. The terms of this Policy may change, and if they do, these changes will be posted on our website and, where required by applicable laws, notified to you.

12. GRIEVANCE OFFICER

12.1. If you have any questions about this Policy, or how we process or handle your personal data, or otherwise seek to enforce any of your legal rights with respect to your personal data, please reach out to our grievance officer whose details are provided below:

Name: Ramkumar Ganesn

Address: IndiQube-Delta, No 6, 14th Main Road, Sector 5, HSR Layout,

Bangalore – 560102

Email Address: ram@vimano.biz