PRIVACY POLICY

We, Udbhata Technologies Private Limited, are a company existing under the Companies Act, 2013, and have our registered address at 91Springboard, Plot #71, LVS Arcade, Jubilee Enclave, Hitech City, Madhapur, Hyderabad 500081, Telangana,IN (hereinafter referred to as “We ”, “Company”, “Our” or “Us”, which expression shall, unless repugnant to the context thereof, be deemed to include its respective representatives, administrators, permitted successors and assigns). This Privacy Policy explains how We use and maintain the privacy of the personal data of Our employees, contractors, vendors, interns, associates, business partners and the Users (collectively referred to as our “Data Subjects”) of Our websites www.udbhata.com, www.qoris.io, software application Qoris® on android and ios (collectively, “Application" / “ Platform”) which has been applied for registration (collectively referred to as our “Data Subjects”).

Scope

This Privacy Policy is applicable to all Our Data Subjects who may receive personal information, have access to personal information collected or processed by Company, or who provide such information to Us. All employees of Our Company are expected to comply with this Privacy Policy when they collect and / or handle personal information, or are involved in the process of maintaining or disposing of personal information. Any and all third party(ies) working with or for Us, and who have or may have access to personal information will be expected to have read, understood and complied with this Privacy Policy. No third party may access personal information held by Us without having first entered into a confidentiality agreement. Responsibilities

The owner for this Privacy Policy shall be Mr Kishore Varanasi (Consultant, Risk Management), who shall act as the Data Privacy Officer and shall be responsible for the maintenance and accuracy of this Privacy Policy.

What data do We collect?

We collect the following data provided by the Users on Our Website / Application from time to time:

• Personal Information, which shall have the meaning ascribed to it under Rule 2(1)(i) of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, as may be amended from time to time (“Rules”);
• Sensitive Personal Data or Information, which shall have the meaning ascribed to it under Rule 3 of the above mentioned Rules;
• The User’s [username, password, email address, phone number, full name, address, age, date of birth, gender, nationality, and city]; and
• Information pertaining to the User’s computer and web browser, IP address and device ID.

We may also request for such additional information from the Users as may be required from time to time in order to ensure continuous provision of the services available on the Platform. Information that is freely available in the public domain or is accessible under the Right to Information Act, 2005 or any other applicable law is not covered within ‘Personal Information’ and ‘Sensitive Personal Data or Information’.

As far as Our remaining Data Subjects are concerned, We may collect data pertaining to them in accordance with the respective contract(s) / agreement(s) entered by Us with such individuals.

How will We use your data?

We collect User data so that We can:

• Provide services and features targeted to meet the User’s needs and to improve his / her experience of Our Website / Application.
• Certain information that may be tracked by Us on the basis of the User’s IP address and behaviour on Our Website / Application will be used for undertaking internal research on User demographics, interests and behaviour to enable Us to understand and cater to such User interests in a better way.
• Contact and demographic information pertaining to such User’s zip code, income bracket, gender, etc. that may be collected by Us in online surveys will be used to customise Our Website / Application and provide the User with services that We believe the User may be interested in availing.
• Records of electronic communications and telephone calls received and made for support or other purposes will be used by Us for the purpose of administration of services, customer support, research and development, and for better assistance to the User.
• We may use the data provided by the User at the time of registration for the purpose of contacting him / her.

Data pertaining to Our employees, contractors, vendors, interns, associates and business partners will be used by Us to fulfil the purposes of the respective SOW’s / contract(s) / agreement(s) that We may have entered into with such individuals. The personal information obtained from such Data Subjects will be used by Us to provide them with information and services and to help Our personnel better understand the needs and interests of these Data Subjects. Occasionally, We may use the personal information to contact the Data Subjects to complete surveys that are used for marketing and quality assurance purposes.

We may share data collected from the Data Subjects with:

• Government agencies that are required to obtain such information under any applicable law; and
• law enforcement agencies, government officials and other third party(ies) in order to co-operate with them to enforce laws relating to intellectual property rights, fraud, other illegal activities, and activities that may expose Us or such Data Subjects to any legal liability(ies).

Further, third parties may view and have access to the information that Users make publicly available on Our Application. We also collect human resources data in connection with administration of Our human resources programs and functions and for the purpose of communicating with Our employees. These programs and functions may include compensation and benefit programs, employee development planning and review, performance appraisals, training, business travel expense, identification cards, access to Company facilities and computer networks, employee profiles, internal employee directories, human resource record keeping, and other employment related purposes. We also collect and use personal information to consider candidates for employment opportunities with Our Company. Human resources data may be shared with third party vendors and service providers for the purpose of enabling the vendor or service provider to provide service and / or support to Us in connection with these human resources programs and functions. We will not share human resources data with third parties for non-employment purposes. Company requires third parties receiving personal information to apply the same level of privacy protection as contained in this Privacy Policy and as required by applicable law.

How do We collect your data?

By affirming assent to this Privacy Policy and by clicking on the “I agree with the Terms and Policy” option at the time of registration, the User shall be deemed to have agreed to collection of his / her data by Us.

Consent shall be obtained either in writing or electronically from the remaining Data Subjects before or at the time of collecting Personal Information or as soon as reasonably practical thereafter. If We intend to use such Personal Information for purposes not identified in the respective contract / agreement at the time of collection, We will document the new purpose and notify the Data Subject and obtain his / her consent prior to such new use or purpose.

How do We store your data?

The computers / servers on which We store personally identifiable information about Our employees, contractors, vendors, interns, associates and business partners are kept in a secure environment. Any and all data that is collected from the Users by Our Company is stored in a secure cloud based platform. Data pertaining and belonging to such Users, which may include personal correspondence in the nature of emails, letters, feedback from other users or Third Parties regarding the User’s activities or posting on Our Application, that may be directly or indirectly collected by Us may be compiled into files or folders that may be specifically created for or allotted to such Users.

Marketing

We would like to send the Users of Our Application offers and promotions, whether or not based on their previous interests. If the User no longer wishes to be contacted for such marketing or promotional purposes, he / she may opt-out by clicking on the ‘Unsubscribe’ link available at the end of every such promotional communication.

What are your data protection rights?

The Data Subjects are entitled to the following:

• The right to access: The User will have a personal, non-exclusive, non-transferable, revocable and limited privilege to enter, access and use Our Website / Application so long as such User continues to abide by the terms of this Privacy Policy and the Terms of Service.
• The right to rectification: We shall allow the Users to correct, delete or amend their personal information at any time by making such changes on Our user account information page, or by contacting Us. The employees, contractors, vendors, interns, associates and business partners of Our Company may also do so by reaching out to Us. We may make such changes as soon as reasonably practicable.
• The right to exit: If the User wishes to delete his / her account or no longer wants Us to use his / her data for the purpose of providing services, the User may contact Us.
• The right to confidentiality: We will not disclose the information provided by the Data Subjects to any third party, unless We are required to do so under this Privacy Policy and / or any applicable law. However, We will inform you in writing in the event of any such mandatory disclosure. We will not sell, share or rent your personal information with any marketing agency or company that indulges in unsolicited communications.
• Protection from unauthorized access: We will employ generally accepted industry standards to protect your data from loss, misuse and unauthorized access, disclosure, alteration and destruction by members inside and outside Our Company. However, We will not be liable for any security breach that may arise as a result of causes beyond the control of Our standard security procedures.
• The right to be informed: We will inform all Data Subjects about any changes or modifications that We may make to this Privacy Policy.

What are cookies?

Cookies are data collection devices in the form of small files on certain pages of Our Application which are sited on the User’s hard drive and assist Us in providing customized services that are targeted to the User’s interests and in identifying logged in or registered Users. Some of Our features are available only through the use of such cookies.

Geographical Extent

Our Application / Platform can be used within and outside India. We make no representation that materials or content available through Our Application is appropriate or available for use outside India. Until this Privacy Policy is suitably updated for a country or location other than India, You shall not hold us responsible for compliance with necessary laws and regulations for use of the Application.

Legal framework

This Privacy Policy is published in accordance with the Information Technology (Intermediaries Guidelines) Rules, 2011; and being an electronic record as per the provisions of the Information Technology Act, 2000 and the rules framed thereunder, it does not require any physical or digital signatures.

Other conditions

• The use of Our Application by the Users is solely governed by this Privacy Policy and the Terms of Service; This Privacy Policy is co-terminus with the Terms of Service and the expiry or termination of either one will lead to the expiry or termination of the other;
• Your act of visiting and using Our Application signifies your unequivocal acceptance of this Privacy Policy and the Terms of Service and the same are legally binding between you and the Company;
• We reserve the sole right to amend any provision of this Privacy Policy and the Terms of Service without obtaining your prior approval and the User and the remaining Data Subjects will be deemed to have consented to such amendment so long as he / she continues to use Our Application; or continues to have an ongoing relationship with Us following such amendment;
• Reviews of Our services that may be provided by the User along with his / her username and certain contact details may be published by Us;
• We are not under an obligation to store, upload, publish or display in any manner content, reviews, surveys or feedback submitted by the User and We may remove such information from Our Application, without cause and/or without giving such User any prior intimation about the same;
• The Users will maintain the accuracy of the information provided to Us and if We reasonably believe that any information provided by such User is or becomes untrue, inaccurate, out of date or incomplete, then We may, at Our sole discretion, terminate the services provided to the User;
• We may retain User information so long as he / she has an active account on Our Application and for the purpose of providing services to him / her. However, We will retain such data only for such period as is legally permissible;
• We do not collect information about visitors to Our Application from other sources such as public records or bodies, or private organizations, save and except for the purposes of registration of the Users;
• The data pertaining to the User; and Our employees, contractors, vendors, interns, associates and business partners will be disclosed and transferred by Us to another company in case We are merged with or acquired by such other company;
• We will retain in Our files, information that the User has requested to remove / edit for circumstances such as resolving disputes, troubleshooting problems and enforcing Our terms and conditions. All of the User’s personally identifiable information is not completely removed from Our databases due to technical and legal constraints, including stored ‘back up’ systems. We shall not use or disclose to third party(ies) any such personally identifiable information pertaining to the User after we receive the aforementioned requests from them.

Indemnity

The User will indemnify Us in any suit or dispute brought against Us by any third party that is unauthorized by Us in relation to disclosure of Personal Information by the User to such third parties either through Our Application or otherwise and his / her use and access of Our Application, and resources of such third parties. We will not be liable for any actions of unauthorized third parties with regard to the User’s Personal Information which the User may have disclosed to such third parties.

How to contact Us?

If you have any question, complaint or grievance in relation to Our Privacy Policy or the practices of Our Application, please do not hesitate to contact Us at:

Email: corp@udbhata.com
For Udbhata Technologies Private Ltd
Authorized Signatory
Approval date: June 20,2020