OVERVIEW

1. Protecting your privacy is very important to us and we are committed to protecting the privacy of our users of our website(www.digismartassets.com) and or our mobile application(collectively Platform ), and the personal information provided by you.The terms“ DigiSmart ” or “ us ” or “ we ” refer to DigiSmart Assets Private Limited, the owner of the Platform, and its affiliates.The terms“ you” or“ users”, and all its grammatical variations, refer to the user or viewer of the Platform /
2. We are telling you about our privacy policy(“ Policy ”) so you know what information we collect, why we collect it, and what we do with it.The Policy sets out the nature and the type of information we collect from our users for the purposes of the services provided by us through the Platform, the usage and disclosure and the measures adopted by us to safeguard such information.
3. This Policy is only applicable to the users of the Platform or visitors of the Platform, located in India and the information and data gathered on the Platform and not to any other information or website.The Platform may include links to third - party websites, plug - ins and applications.Clicking on those links or enabling those connections may allow third parties to collect or share data about you.We do not control these third - party websites and are not responsible for their privacy statements or terms and conditions.
4. It is important that you read this Policy carefully(together with any other policy we may provide on specific occasions when we are collecting or processing personal data about you) so that you carefully and fully understand the nature and purpose of gathering and / or collecting your data and other information and why we are using your data.We also encourage you to read this Policy together with the“ Terms of Use” as the two form an integral part of the functioning of the Platform, and are to be interpreted harmoniously.
5. We do not collect name, contact information or other similar information unless you choose to provide it.We do collect other limited information automatically from visitors who read, browse, and / or download information from the Platform.We do this so we can understand how the Platform is being used and how we can make it more helpful.See the types of information we collect section below for more information.
6. By submitting your personal information to us, by using our Website and / or by using our services, you agree that we may collect your personal information in accordance with the terms of this Policy and as may be required by law.

THE DATA WE COLLECT FROM YOU

1. Personal data or personal information means and includes any information about an individual from which that person can be identified.It does not include data where the identity has been removed(anonymous data).We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes bank account, payment card details.UPI handles.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data includes internet protocol(IP) address, your login data, browser type and version, time zone setting and location, browser plug - in types and versions, operating system and platform, and other technology on the devices you use to access this website.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use the Platform, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
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 in law as this data will not directly or indirectly reveal your identity.For example, we may aggregate your usage data to calculate the percentage of users accessing a specific feature of the P.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.
3. Save and except as provided in clause B1 and B2, we do not collect any“ sensitive personal data or information”(as defined under Information Technology(Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules 2011) or special categories of personal data about you(this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership and biometric data).We do not store any biometric data used for KYC verification.Nor do we collect any information about criminal convictions and offences.
4. In the course of providing the services, we may share your personal information with our affiliates, third - party service providers, and you hereby consent to such transfer of personal information.We will take reasonable steps to ensure that these affiliates and service providers are obligated to protect the confidentiality and security of the personal information through confidentiality and non - disclosure agreements.
5. You acknowledge that in the course of providing the services, we will receive your personal information and you hereby consent and agree to allow the Platform and / or its third party service provider to store the personal information collected and disclose it in accordance with the terms of this Policy.In the event that the personal information provided by you relates to another person, you warrant and covenant that you have obtained the consent of such person to the disclosure and transfer of the personal information in accordance with this Policy or the“ Terms of Use”.In the event that such consent is not taken, the Platform will bear no responsibility whatsoever with respect to any information provided to us and shall in no manner be liable for any damages or indemnify any losses to you or any third party, that may be incurred in the absence of such explicit consent.
6. It is clarified that with respect to any personal information that you may share with us, you have the sole right to determine whether you want to share such information with us.However please be advised that where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you( for example, to provide you with goods or services).In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.For instance, if you are required to furnish the PAN card for transaction beyond a certain limit and you fail to do so, we will not be able to offer goods or services.

HOW IS YOUR PERSONAL DATA COLLECTED

1. In general, you can visit the Platform without revealing your identity or any personal information about yourself.However, you may not be able to access significant portions and sections of the Platform or use the services provided by us unless you register and sign up for the services or reveal your identity and / or other information about you.
2. Information that we collect from you at registration or at any other time will vary depending upon the activity you seek to engage in , and in this respect, if you choose to sign up for our services, we shall, at the first instance collect your name, email address, residential address and date of birth.
3. We use different methods to collect data from and about you including through:
• Direct interactions. You may give us your identity, contact and financial data by filling in forms or by corresponding with us by post, phone, email or otherwise.This includes personal data you provide when you:
• apply for our products or services;
• create an account on our Platform;
• subscribe to our service or publications;
• request marketing to be sent to you;
• enter a competition, promotion or survey; or
• give us feedback or contact us.
• Automated technologies or interactions. As you interact with our Platform, we will automatically collect Technical Data about your equipment, browsing actions and patterns.We collect this personal data by using cookies, server logs and other similar technologies.We may also receive Technical Data about you if you visit other websites employing our cookies.A“ cookie” is a small text file that may be used, for example, to collect information about your activity on our Platform.Some cookies and other technologies may serve to recall personal information previously indicated by you.Most browsers allow you to control cookies, including whether or not to accept them and how to remove them.You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser, but please note that if you choose to erase or block your cookies, you may need to re - enter your personal information to gain access to certain parts of our Platform.
• Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:

Technical Data from:

1. analytics providers[such as Google based outside the EU];
2. advertising networks[such as[NAME] based[inside OR outside] of India]; and
3. search information providers[such as[NAME] based[inside OR outside] of India].
• Contact, Financial and Transaction Data from providers of technical, payment and delivery services[such as[NAME] based[inside OR outside] of India].
• Identity and Contact Data from data brokers or aggregators[such as[NAME] based[inside OR outside] of India].
• Identity and Contact Data from publicly available sources.

HOW WE USE YOUR PERSONAL DATA

1. We will only use your personal data when the law allows us to.Most commonly, the personal data and other information received and collected from you will be used in the following circumstances:
• Where we need to perform the contract we are about to enter into or have entered into with you and provide the goods and services you have requested.
• Where it is necessary for our legitimate interests(or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation.
• To enable you to access and post comments on Platform, or any part thereof, and to contact you upon your request and when otherwise necessary.
2. We may also use personal data for auditing, research and analysis, and to operate and improve the services.In certain circumstances, we may share aggregated non - personal information with third parties but we shall in no circumstances share personal information with third parties except when complying with legal process.
3. Where we propose to use your personal information for any other uses we will ensure that we notify you first.You will also be given the opportunity to withhold or withdraw your consent for your use other than as listed above.
4. Promotional offers from us

We may use your personal data to form a view on what we think you may want or need, or what may be of interest to you.This is how we decide which products, services and offers may be relevant for you(we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.

5. Third - party marketing

We will get your express opt - in consent before we share your personal data with any third party for marketing purposes.

6. Opting out

You can ask us or third parties to stop sending you marketing messages at any time by logging into the Platform and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt - out links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product / service purchase, product / service experience or other transactions.

DATA SECURITY

1. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know in order for us to provide services to you or fulfil a contract you have entered into with us or may potentially enter into with us in order to provide the services.They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
2. Third party service providers may provide certain services available on our Platform and on our behalf.We will provide information, including personal information, to any third - party service providers to help us deliver our products, information, and services efficiently and effectively.
3. We will not transfer personal information without your consent to third parties unless such transfer is legally required.
4. If you choose to provide us with your personal information, we may transfer that personal information from your country or jurisdiction to other countries or jurisdictions around the world.Your personal information may be collected and stored on servers located in the territory of India and such other countries as we may disclose from time to time.
5. We will keep confidential and protect your personal information except where disclosure is required or permitted by law or under a court order.
6. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and, once we receive it, for storage and disposal.All information we gather is securely stored within databases controlled by us.The databases are stored on servers secured behind a firewall; access to the servers is password - protected and is strictly limited.No method of transmission over the Internet, or method of electronic storage, is 100 % secure, however.Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.The user agrees that she / he is aware of such limitation and consents to the use of personal information by DigiSmart in consonance with this Policy.
7. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

DATA RETENTION

1. We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
2. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
3. By law we have to keep basic information about our customers(including Contact, Identity, Financial and Transaction Data) for [Eight] years( in India) after they cease being customers for [tax] purposes.
4. In some circumstances you can ask us to delete your data: see section I[Your Legal Rights] below for further information.In some circumstances we will anonymise your personal data(so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

AUTHENTICITY AND ACCURACY

To the extent that you do provide DigiSmart with personal information, we wish to maintain accurate and current personal information.Where we collect personal information from you on our Platform, should you need to update or correct that personal information, please contact us and we will make reasonable efforts to incorporate the changes in your personal information that we hold as soon as practicable.You can obtain the information we currently hold on you by emailing at[insert email address].Failure to update or correct your personal information may impact in the quality of services provided by us to you or may affect the final outcome of the services.DigiSmart shall bear no responsibility whatsoever with respect to any information provided to us which is not accurate, updated or correct and shall in no manner be liable for any damages or indemnify any losses to you or any third party, that may be incurred in the absence of such updated, accurate and correct information.

TERMINATION OF USER ACCOUNT

In the event that you choose to terminate and delete your user account with us, or if your account has been terminated for any other reason, such as a violation of the Terms and Conditions, DigiSmart will within a reasonable time, delete and remove all personal information that you may have submitted and stored in your account with the Platform, subject to any legal obligations.You acknowledge and agree that generic, non - personally identifiable information may continue to be stored and / or displayed by DigiSmart as a part of any surveys or research or tabulations compiled on the Website.

YOUR LEGAL RIGHTS

1. Under certain circumstances, you have rights under data protection laws in relation to your personal data, which are as follows:
• Request access to your personal data (commonly known as a“ data subject access request”).This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you.This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it.You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing(see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law.Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest(or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.You also have the right to object where we are processing your personal data for direct marketing purposes.In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data.This enables you to ask us to suspend the processing of your personal data in the following scenarios:
1. If you want us to establish the data’ s accuracy.
2. Where our use of the data is unlawful but you do not want us to erase it.
3. Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
4. You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party.We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine - readable format.Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data.However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.If you withdraw your consent, we may not be able to provide certain products or services to you.We will advise you if this is the case at the time you withdraw your consent If you wish to exercise any of the rights set out above, please contact us at[sandeep.khamkar @digismartssets.com].
2. You will not have to pay a fee to access your personal data(or to exercise any of the other rights).However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.Alternatively, we could refuse to comply with your request in these circumstances.
3. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data(or to exercise any of your other rights).This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.We may also contact you to ask you for further information in relation to your request to speed up our response.
4. We try to respond to all legitimate requests within one month.Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests.In this case, we will notify you and keep you updated.

AMENDMENTS AND CHANGES TO THE PRIVACY POLICY

By using the Platform, you consent to the terms of this Policy and to our use and management of your personal information for the purposes and in the manner herein provided.We may update this Policy from time to time, with our without advance notice.Should this Policy change, we intend to take every reasonable step to ensure that these changes are brought to your attention by posting all changes prominently on the Platform for a reasonable period of time.Your visit and any dispute over privacy are subject to this Policy.

(iv) Governing law and jurisdiction

This Policy and information contained herein, shall be governed by the laws of the Republic of India and the courts at Mumbai, India shall have exclusive jurisdiction.

(v) Contact us

If you have any questions or concerns about the Policy or the collection, use, management or disclosure of your personal information or if need further assistance with respect to our Policy, you may contact the Grievance Officer appointed by DigiSmart, at the address mentioned below.We will use reasonable efforts to respond promptly to any requests, questions or concerns, which you may have regarding our use of your personal information.

Name: Roshan Jaisingh

Email: roshan @niwish.com