A. Introduction

We reserve our right to change and update this Privacy Policy from time to time, therefore, you should regularly check for any changes in our Privacy Policy. We will notify all users of any material changes, to the extent practical, to this Privacy Policy and the Privacy Policy document will also signify the date of Last update for user’s convenience. Your continued access to or use of our Platform and services after the date of the update in Privacy Policy constitutes your acknowledgment and agreement that you have read, understood and accepted the terms of the updated Privacy Policy. If you do not agree to the updated Privacy Policy, you must stop accessing or using our Platform and/or our Services.

B. What data we collect from you

We may collect and process the following data about you:

1. You may be required to give us sensitive personal data about yourself before, during or after creating an Account, or while corresponding with us through any means of communications. Sensitive personal data that you will voluntarily provide us may include information such as your name, photograph, postal address, e-mail address, phone number, details/copy of Govt. Issued National Identity documents (i.e. Passport, Aadhaar Card etc.), details/copy of documents used as proof of address (i.e. Driving licence, utility bills, bank passbook etc.), details/copy of your Tax Identification Details (i.e. Permanent Account Number - PAN card) and other identification documents.
2. Details of your activities, all transactions, actions or tasked performed on or through our Platforms including transactions relating to buying, selling, transferring, bidding and otherwise dealing with any Virtual Digital Assets (VDA) or non-fungible tokens (NFT) or viewing any web-page, product, services or other online activity performed by you on Our Platform.
3. Your financial and credit card information, details of your Linked Bank Account, location details or other information requested by us to detect and protect against frauds and similar criminal activity and such other information required by us from time to time for providing the Services.
4. Technical information, including the Internet protocol (IP) address used to connect your device to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, material or information that you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-hovers), and methods used to browse away from the page and any phone number used to call our customer service number.
5. Cookies: Our Platform uses Cookies and tracking technology in order to distinguish you from other Users of our Platform and enables us to serve you better and provide you a customised and personalised user experience. Cookie and tracking information collected by Us may be shared with third-parties which directly help us in development or improvement of Our Platform.

C. Use of your data

The data that we collect from or about you may be used and/or processed:

• to verify, maintain, update and retain your personal details and details relating to your identity, address, financial information and other aspects as may be required as per our Company’s policy or to comply with applicable laws and regulations;
• to facilitate and provide the services offered through our Platform;
• to inform you of our products, services, promotions, offers, surveys and events which may be of interest to you;
• to carry out update, upgrade, maintenance, customization and other changes in our products and services to serve you better;
• to provide you with the information and Services, that you request from us;
• to enhance the security and user experience of our Platform;
• To track and remember information and details relating to the transactions executed by You on or through our Platform;
• to send you Service related notices or emails and other non-essential promotional material (you will be provided an option to unsubscribe to such email or other communications);
• for KYC verification, ourselves or through a Selected Third Party, of the details of Tax Identification and other Identification documents provided by you. You understand that in order to verify that such information belongs to you, we may send you a verification emails/one-time password.

D. Disclosure and sharing of your data

1. We reserve the right to share any data that we collect from you, as prescribed above with our Affiliates. Your personal data may be processed and stored in a foreign country or countries in compliance with applicable laws. In this regard, we will take such necessary measures to ensure that such overseas recipients are bound by legally enforceable obligations to ensure that they will provide a standard of protection that is at least comparable to the protection to your personal data under the applicable law of India. Under those circumstances, the governments, courts, law enforcement, or regulatory agencies of that country or those countries may be able to obtain access to your personal data under relevant foreign laws.
2. We further reserve the right to share your personal data to any third party when we are under obligation to share such information under applicable laws or under the order of any competent authority/court.

E. Your Consent

By using any of the Platform, you agree and consent to the collection and use of data collected to the extent and in the manner described above and in accordance with this Privacy Policy. You also agree and consent to any changes made to this Privacy Policy in due course and without notice. If you do not agree with the terms of this Privacy Policy, please do not provide any information to us. If you refuse or withdraw your consent, or if you choose not to provide us with any information as required by us, we may not be able to provide you access to our Platform or extend our Services that are being offered to you through the Platform.

You also agree that all your data and/or information shared with us is accurate, correct and complete, at all times. You understand that you must promptly inform us of any changes to your data and/or information which may impact your use of our Platform.

F. Assignment

We may assign, novate, or transfer any or all rights and obligations that accrued in our favour under this Privacy Policy, at our sole discretion, to our subsidiaries, affiliated entities or Selected Third Parties to offer you a full suite of services through the Platform.

G. Data Security

1. Your personal data is accessible only by our authorized employees and Selected Third Parties, and is otherwise kept secure. The security standards and policies followed by the Third Party service provider can be assessed here:_______<link to the security policy & standard of cloud service provider>_____________________________.
2. We have in place appropriate technical and security measures to prevent unlawful access to or accidental loss of information collected including those prescribed under applicable laws. We have taken the following steps to ensure data security:
   1. All the user information can only be accessed by authorized employees;
   2. Users need to authenticate themselves with a username-password combination; and
   3. We store our data on third party hosting service providers which follow reasonable and robust security standards.
3. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee, give no warranties, and shall not be liable for breach of the security of your data transmitted through the Platform due to malicious attacks, errors, commission or omissions not willfully initiated by us. Any transmission is at your own risk. Once we have received your information, we will use reasonable standards and practices to strict physical, electronic, and procedural safeguards to try to prevent any unauthorised access.

H. Data Retention

1. We may, at our sole discretion, retain any information and/or data provided by you for as long as your Account is active, and even subsequently as allowed under applicable laws, for resolution of any disputes, for enforcement of any agreements, and/or as necessitated under applicable laws.
2. We make no warranties and shall not be liable regarding non-availability or non-retention of any information and/or data provided by you beyond the deletion of your Account.

I. Data retention period

We will retain your personal data for a period of 5 years after the end of the relationship between us as a company and you as a user. This period may be further extended in certain cases as per applicable laws.

J. Your Legal rights

1. The right to access - You have the right to request our Company for copies of your personal data. We may charge you a small fee for this service.
2. The right to rectification - You have the right to request that our Company correct any information you believe is inaccurate. You also have the right to request our Company to complete the information you believe is incomplete.
3. The right to erasure - You have the right to request that our Company erase your personal data, under certain conditions and we will accept such requests in compliance with applicable laws.
4. The right to restrict or object to processing - You have the right to request that our Company restrict or stop the processing of your personal data, under certain conditions.

If you make a request, we have one month to respond to you.

K. Data protection officer

The data controller responsible for your personal data is Famil Technologies Pvt. Ltd.. In case you have any queries, please write to our Data Protection Officer at ________________.