This privacy policy (“Policy”) explains how KWAPIO TECHNOLOGIES PRIVATE LIMITED or any of its affiliates or subsidiaries (hereby collectively referred to as “OrangeScape”, “We”, “Us”, “Our”) Processes Personal Data collected from You.

This Policy applies to all the services, and websites offered by OrangeScape and its affiliates/partners, except specified otherwise. In this document, OrangeScape explains what information will be collected when You access the Services, how such Personal Data will be used, and how You can control the collection, correction, and/or deletion of your Personal Data. OrangeScape will not use or share Your Personal Information with anyone except as described in this Privacy Policy. The use of information collected through Our Sites shall be limited to the purposes under this Privacy Policy and Our Terms of Service.

Capitalized terms not explicitly defined herein shall have the same meaning as ascribed to them in the Terms.

1.DEFINITIONS

Unless otherwise defined in this Policy, capitalized terms shall have the meaning assigned to them in Our Terms of Service. Where not defined in the Terms of Service, such terms shall have the meaning given to them under the applicable data protection laws, including the EU General Data Protection Regulation (EU GDPR), the UK General Data Protection Regulation (UK GDPR), the Swiss Federal Act on Data Protection (FADP), the California Consumer Privacy Act as amended by the California Privacy Rights Act (CCPA/CPRA), the Digital Personal Data Protection Act, 2023 (India), and any other applicable data protection law.

2. PERSONAL DATA COLLECTED BY US

2.1. You directly provide Us with most of the data We collect. We collect Personal Data from You directly as follows: a) When You subscribe to any of Our Service(s) by agreeing to the Terms of Service, We collect Your name, e-mail address, geolocation, and contact details; b) When You submit web forms on Our Website(s) or as You use interactive features of the Website(s), including providing feedback or suggestions, making requests, or participation in surveys, contests, webinars, events, podcasts, promotions, sweepstakes, requesting customer support, or otherwise communicating with Us; c) When You provide testimonials, forms or information to Us in other contexts; or d) When You authorize Us to connect with a Third Party Service(s), We will access and store Your Personal Data that the Third Party Service(s) makes available to Us, which may include Your email address, location or profile information.

2.2. We may also receive Your Personal Data indirectly as follows: a) from third party sources like marketing lists, databases and social media but only where We have checked that these third parties either have Your consent or are otherwise legally permitted or required to disclose Your Personal Data to Us; b) When You download and/or use the Service(s), We automatically collect information on the type of device You use, and the operating system version, to perform Our agreement with You; c) When You use or view Our Website(s), information is collected via Your browser’s cookies as described in Clause 10 herein; d) We may also collect or receive Your Personal Data from other sources such as Our business or channel partners through whom You create or access Your Account, publicly available sources, email add-ons and/ or through the combining of information We obtain from third parties along with the Personal Data You provide to Us.

2.3. The Website(s) includes social media features and widgets that are either hosted by a third-party or hosted directly on the Website(s) and Your interaction with these social media features and widgets is governed by the privacy statement of the companies that provide them. You should check Your privacy settings on these third-party services to understand and change the information sent to Us through these services.

2.3. The Website(s) includes social media features and widgets that are either hosted by a third-party or hosted directly on the Website(s) and Your interaction with these social media features and widgets is governed by the privacy statement of the companies that provide them. You should check Your privacy settings on these third-party services to understand and change the information sent to Us through these services.

3. LEGAL BASIS FOR PROCESSING

If You are a data subject located in the European Union, the United Kingdom, California, India, or any other jurisdiction, Our legal basis for collecting and using the Personal Data described above will depend on the Personal Data concerned and the specific context in which We collect it.

3.1. European Union (EU GDPR): We will normally collect Personal Data from a data subject only where We need it to perform a contract with the data subject, where the Processing is in Our legitimate interests and not overridden by the data subject’s data protection interests or fundamental rights and freedoms, or where We have the data subject’s consent. In some cases, We may also have a legal obligation to collect Personal Data. If We Process Personal Data with reliance on consent, the data subject may withdraw such consent at any time.

3.2. United Kingdom (UK GDPR and Data Protection Act 2018): We will normally collect Personal Data from a data subject only where We need it to perform a contract with the data subject, where the Processing is in Our legitimate interests and not overridden by the data subject’s rights, or where We have the data subject’s consent. In some cases, We may also have a legal obligation to collect Personal Data. If We Process Personal Data with reliance on consent, the data subject may withdraw such consent at any time.

3.3. California (CCPA/CPRA): We will normally collect Personal Information from a Consumer (as defined under the CCPA/CPRA) only where We need it to provide the Services, maintain or improve Our operations, ensure security, or otherwise comply with applicable law. We do not “sell” or “share” Personal Information for cross-context behavioral advertising without the Consumer’s consent. If We Process Personal Information with reliance on consent, the Consumer may withdraw such consent or opt out of such “sale” or “sharing” at any time.

3.4. India (Digital Personal Data Protection Act, 2023): We will normally collect Personal Data from a Data Principal (as defined under the Act) only where We need it to perform a contract with the Data Principal, where the Processing is necessary for compliance with legal obligations or for certain legitimate uses permitted under the Act (including responding to medical emergencies or ensuring the safety of individuals), or where We have the Data Principal’s consent. If We Process Personal Data with reliance on consent, the Data Principal may withdraw such consent at any time in accordance with the Act.

3.5. Other jurisdictions: For data subjects located outside the regions listed above, We will collect and use Personal Data only where We have a lawful basis to do so under applicable local laws. Such basis may include the performance of a contract, compliance with legal obligations, reliance on Our legitimate interests (where these are not overridden by the rights of the data subject), or the data subject’s consent, as required under the laws of the jurisdiction concerned.

4. PURPOSES FOR WHICH PERSONAL DATA WILL BE PROCESSED

We Process Your Personal Data to: a) facilitate Your access to the Website(s) and Service(s); b) process and complete payment transactions; c) provide customer service and support; d) send You communication on Your use of the Service(s), updates on Our Terms of Service or other policies; e) send You communication on new features in the Service(s) or new service offerings; f) conduct research, analysis and development activities (including but not limited to data analytics, surveys and/or profiling) to improve Our Service(s) and facilities in order to enhance Your relationship with Us or for Your benefit or to improve any of Our Service(s) for Your benefit; g) organise events or for other marketing/ promotional activities; h) investigate and prevent fraudulent transactions, unauthorized access to the Websites and Service(s), and other illegal activities; i) personalize the Websites and Service(s); and j) for other purposes for which We obtain Your consent.

5. SHARING OF PERSONAL DATA

5.1. You acknowledge that We will share Your Personal Data with Our group companies and third-party service providers so that they may offer You Our Service(s) and/or to send information or updates on the Service(s) if You are a Subscriber.

5.2. When We Process Your order where You are a Subscriber, we may send Your Personal Data to and also use the resulting information from credit reference agencies to prevent fraudulent purchases.

5.3. We share Personal Data with Our third-party service providers that host and maintain the Our Website(s), applications, backup, storage, payment processing, analytics and other services. These third-party service providers may have access to or Process Your Personal Data for the purpose of providing these services to Us.

5.4. We may share Your Personal Data with third-party service providers who assist Us in marketing and promotions in compliance with applicable laws.

5.5. We may be required to disclose Your Personal Data in response to: a) lawful requests by public authorities, including to meet national security or law enforcement requirements; and/or b) subpoenas, court orders, or legal process, or to establish or exercise Our legal rights or defend against legal claims.

5.6. We may also share Personal Data to assist investigation and prevention of illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of Our Terms of Service, or as otherwise required by law.

6. INTERNATIONAL TRANSFER

We may Process and store Personal Data in multiple jurisdictions. Accordingly, We may transfer Your Personal Data outside of Your country of residence for the purposes referred to in Clause 4. Whenever We transfer Personal Data internationally, We will ensure that such transfers are made in compliance with applicable data protection laws and that the recipient of Your Personal Data provides a level of protection that is at least comparable to the protection required under applicable law.

7. RETENTION OF PERSONAL DATA

We retain the Personal Data collected where an ongoing legitimate business requires the retention of such Personal Data. In the absence of a need to retain Personal Data, We will either delete it or aggregate it, or, if this is not possible then We will securely store Your Personal Data and isolate it from any further Processing until deletion is possible.

8. SECURITY OF PERSONAL DATA

We use appropriate technical and organizational measures to protect the Personal Data that We collect and Process. The measures We use are designed to provide a level of security appropriate to the risk of Processing Your Personal Data. Further information about Our security practices can be found here. If You have questions about the security of Your Personal Data, please contact Us immediately as described in this Policy.

9.COOKIE POLICY

9.1. Cookies are text files that are placed on Your computer to collect standard internet log information and visitor behavior information by Us. When You visit the Website(s), We may collect Personal Data automatically from You through cookies or similar technology. We also set cookies to collect information that is used either in aggregate form to help Us understand how our Website(s) is being used or how effective Our marketing campaigns are, to help customize the Website(s) for You or to make advertising messages more relevant to You.

9.2. Essential Cookies: We set essential cookies that enable core functionality such as security, network management, and accessibility. You may not opt-out of these cookies. However, You may disable these by changing Your browser settings, but this may affect how the Website(s) functions.

9.3. Analytics, Customisation, and Advertising Cookies: OrangeScape also sets cookies to collect information that is used either in aggregate form to help OrangeScape understand how its Website(s) is being used or how effective marketing campaigns are, to help customize the Website(s) for You or to make advertising messages more relevant to You. We set these cookies to help Us improve Our Website(s) by collecting and reporting information on how You use it. The cookies collect information in a way that does not directly identify anyone

9.4. The list of cookies and opt-out mechanism will, as required by applicable law, be displayed when You visit Our Website(s).

10. PRIVACY OF CHILDREN

We recognize the importance of protecting children’s privacy. We do not knowingly request or collect any Personal Data from children. The age at which an individual is considered a child differs by jurisdiction:

10.1. In the European Economic Area (EU GDPR), We do not knowingly collect Personal Data from children under the age of 16 (or a lower age, not below 13, where permitted by local law).

10.2. In the United Kingdom (UK GDPR and Data Protection Act 2018), We do not knowingly collect Personal Data from children under the age of 13.

10.3. In Switzerland, We do not knowingly collect Personal Data from children under the age of 13.

10.4. In California (CCPA/CPRA), We do not knowingly sell or share the Personal Data of Consumers under 16 years of age without the required consent.

10.5. In India (Digital Personal Data Protection Act, 2023), We do not knowingly collect or Process Personal Data of children under the age of 18 without verifiable parental or guardian consent.

10.6. In other jurisdictions, We will apply the age threshold required by applicable local law.

10.7. If a parent or guardian becomes aware that his or her child has provided Us with Personal Data, they should contact Us using the details set out in Clause 13.

11.NOTICE TO END-USER AND OTHER EXCLUSIONS

11.1. Our Service(s) are intended for use by commercial and organizational users. Where the Services are made available to an End-User through a Subscriber, that enterprise is the Controller of the End-User’s Personal Data. In such a case, the End-User’s data privacy questions and requests should be submitted to the Subscriber in its capacity as the End-User’s Controller. If the End-User is an individual who interacts with a Subscriber using Our Services, the End-User will be directed to contact Our Subscriber for assistance with any requests or questions relating to their Personal Data. We are not responsible for Subscribers’ privacy or security practices which may be different from this notice. Subscribers to Our Services are solely responsible for establishing policies for and ensuring compliance with all applicable laws and regulations, as well as any and all privacy policies, agreements, or other obligations, relating to the collection of Personal Data in connection with the use of Our Services by End-Users.

11.2. Our Website(s) contain links to other websites. Our Policy applies only to our Website(s), so if You click on a link to another website, You should read their privacy policy. We encourage You to review the privacy statements of any such other websites to understand their Personal Data practices.

11.3. This Policy does not apply to aggregated information that summarises statistical information about groups of members and does not include names, contact information, or any other information that would allow any particular individual to be identified.

12. CONTACT INFORMATION

You may contact us if You have any inquiries or feedback on Our personal data protection policies and procedures, or if You wish to make any request, in the following manner:

Kind Attention: Kamel, Data Protection Officer

Email Address :[email protected]

13. CHANGES TO THE POLICY

We keep this Policy under regular review and may update this webpage at any time. This Policy may be amended at any time and You shall be notified only if there are material changes to this Policy.