PRIVACY POLICY

We value the trust you place in Oculusindia.com. That’s why we insist upon the highest standards for secure transactions and customer information privacy. Please read the following statement to learn about our information gathering and dissemination practices. Please Note: In order to provide our customers with the best possible services, our policies will be governed by this and going further the privacy policy would be updated on a regular basis to reflect the same. We would request you to please review this policy periodically, to be aware of any changes. By accepting the Privacy Policy during registration, you expressly consent to our use and disclosure of your personal information in accordance with this Privacy Policy.

Collection of Personally Identifiable Information

We collect personally identifiable information (email address, name, phone number, etc.) from you when you set up a free account with Oculusindia.com. While you can browse some sections of our site without being a registered member, certain activities (such as placing an order) do require registration. You would be receiving offers and mailers from us, in case you do not wish to receive, you can choose to unsubscribe from the same.

Use of Demographic and Profile Data

We use personal information to provide the services you request. The information given by you will be used to provide you with the services offered on our website. We use your personal information to resolve disputes; troubleshoot problems; help promote a safe service; collect fees owed; measure consumer interest in our products and services, inform you about online and offline offers, products, services, and updates; customize your experience; detect and protect us against error, fraud and other criminal activity; enforce our terms and conditions; and as otherwise described to you at the time of collection. In our efforts to continually improve our product and service offerings, we collect and analyze demographic and profile data about our user’s activity on our website. We identify and use your IP address to help diagnose problems with our server, and to administer our website. Your IP address is also used to help identify you and to gather broad demographic information. We will occasionally ask you to complete optional online surveys. These surveys may ask you for contact information and demographic information (like zip code, age, or income level). We use this data to tailor your experience at our site, providing you with content that we think you might be interested in–and to display content according to your preferences.

Cookies

A “cookie” is a small piece of information stored by a Web server on a Web browser so it can be later read back from that browser. Cookies are useful for enabling the browser to remember information specific to a given user. Oculusindia.com. places both permanent and temporary cookies in your computer’s hard drive.Oculusindia.com’s cookies do not contain any of your personally identifiable information.

Sharing of personal information

We may share personal information with our other corporate entities and affiliates to: help detect and prevent identity theft, fraud and other potentially illegal acts; correlate related or multiple accounts to prevent abuse of our services; and to facilitate joint or co-branded services that you request where such services are provided by more than one corporate entity. Those entities and affiliates may not market to you as a result of such sharing unless you explicitly opt-in. We may disclose personal information if required to do so by law or in the good faith belief that such disclosure is reasonably necessary to respond to subpoenas, court orders, or other legal process. We may disclose personal information to law enforcement offices, third party rights owners, or others in the good faith belief that such disclosure is reasonably necessary to: enforce our Terms or Privacy Policy; respond to claims that an advertisement, posting or other content violates the rights of a third party; or protect the rights, property or personal safety of our users or the general public. Oculusindia.com and its affiliates will share some or all of your personal information with another business entity should we (or our assets) plan to merge with, or be acquired by that business entity. Should such a transaction occur that other business entity (or the new combined entity) will be required to follow this privacy policy with respect to your personal information.

Links to Other Sites

Our site links to other websites that may collect personally identifiable information about you. Oculusindia.com is not responsible for the privacy practices or the content of those linked websites.

Security Precautions

Our site has stringent security measures in place to protect the loss, misuse, and alteration of the information under our control. Whenever you change or access your account information, we offer the use of a secure server. Once your information is in our possession we adhere to strict security guidelines, protecting it against unauthorized access. We will endeavor to safeguard the confidentiality of your personal information; transmissions made by means of the Internet cannot be made absolutely secure. By using this Site, you agree that we will have no liability for disclosure of your information due to errors in transmission or unauthorized acts of third parties.

Products & Accessories Confirmation

As a policy on receipt of product, we request you to check and confirm the contents while accepting the delivery. Discrepancies, if any, must be brought to our notice, after which no further queries would be entertained. Kindly email us on customercare@Oculusindia.com or alternatively call on 022-61711122

Warranty

For all products procured fromwww.Oculusindia.com , warranty and service are provided by the manufacturing companies through their authorized service providers in India.

After Sales Service

We believe in providing our customer with the best and request you to kindly revert to us for any service related issues. The same would be followed up with the resp. manufacturing companies and we will ensure the service be made available to you as per the turnaround time wherever we are present.

Questions?

Questions regarding this statement should be directed to the following email id: ecustomercare@Oculusindia.com

Disclaimer

Oculusindia.com makes every effort to present correct data and timely information regarding the products on sale on our website. However discrepancies, if any, may arise due to inaccurate/incomplete information given suppliers or external sources. In case you come across any such information termed inaccurate, we would request you to kindly inform us at customercare@Oculusindia.com .

Disclaimers of Warranty and Product Liability.

Oculusindia.com will not be held liable for any damaged goods or injuries arising from the using the same. Warranties of products are provided by the Manufacturers and are liable for the same. Product information available on our website would be limited to the information given by the Manufacturer to us. Actual dimensions and colors may differ from the images shown on our website.

Liability of Information.

Oculusindia.com nor any of its sources would be liable for any direct, special, incidental, indirect, or consequential damages whatsoever (including but not limited to: damages for loss of business profits, business interruption, loss of business information, or any other pecuniary loss) arising out of the use of the information made available on this web site.

Information on the Oculusindia.com web site may not be reproduced, copied, or altered without the express written consent of Oculusindia.com and its affiliates.

Termination

Oculusindia.com may terminate this Agreement and these terms and conditions and/or the provision of any of the services at any time for any reason, including any improper use of this portal or your failure to comply with these terms and conditions. Such termination shall not affect any right to relief to which Oculusindia.com and its third party providers and distributors may be entitled, at law or in equity. Upon termination of this User Agreement and these terms and conditions, all rights granted to you will terminate and revert to Oculusindia.com and its third party providers, as applicable

No resale of service

You agree not to reproduce, duplicate, copy, sell, resell or exploit for any commercial purposes, any portion of the Service, use of the Service, or access to the Service.

Oculusindia DIRECTORY SECURITY, COOKIES & PRIVACY POLICY

What are cookies?

Cookies are small text files that are stored on your PC, phone or other web enabled device when you visit the Oculusindia website. They are not harmful and do not contain any confidential information such as your home address, date of birth or credit card details. Cookies are an essential part of how our site works. Some of these cookies are required by our site to enable you to transact whilst other cookies enable us to give you an enhanced, personalised web experience.By using our site, you also consent to the use of these cookies.

Cookies are used on our site for the following reasons:

To allow you to securely sign in to your Oculusindia Directory Account, so that you can use “My Account” features such as order information, making payments and viewing statements.

To store the content of your online shopping bag whilst you browse the site and to complete an order.

To record the areas of the website that you have visited, products you have viewed and time spent browsing, as well as the products you purchased. Oculusindia uses this information to help make the website more user friendly, develop our site design and to continuously improve the quality of the service we provide.

To distribute visitors to our site evenly across platforms to ensure the content is served at the fastest possible speed.

We also offer you the facility to share your experience on our site through social sites such as facebook and twitter. By using these features, you are also consenting to allow cookies from these providers. More information about how these providers use cookies can be found at their websites.

Are Cookies Safe?

Yes. The information stored in cookies is safe and anonymous. They do not contain any information which could personally identify you and your account security is never compromised. You can find more information about cookies at www.allaboutcookies.org and www.youronlinechoices.eu. For a video about cookies visit www.google.co.uk/goodtoknow/data-on-the-web/cookies.

Can I turn off cookies?

Oculusindia uses cookies to ensure that we provide the best possible standard of service to our online customers. However, as part of our privacy and security policy, we require your consent to use them. To withdraw your consent, or if you want to be notified each time a cookie is about to be used, you should amend the settings provided in your web browser to prevent us from storing cookies on your computer’s hard drive. For information on how to disable cookies, please consult the “Help” tab of your browser via the menu bar.It must be noted that if you choose not to consent to the use of cookies, your experience of our site will be severely impaired and many integral aspects of the site, including (but not limited to) adding items to your shopping bag and accessing your account, will not work at all.

Our use of advertisment tracking

We also allow selected third parties who participate with us in marketing programmes to place cookies when you visit our site. These cookies enable us to monitor which adverts you see and click on to get to our site. We currently use two companies for this and you can see their privacy policies at the following addresses:

Mediaplex: www.mediaplex.com/mojo-privacy-statement

DoubleClick: www.google.com/policies/privacy/

These cookies are as safe as the ones used whilst you browse our site and neither of these third parties collects any personal data from which they would be able to identify individual customers.Oculusindia is not responsible for the content or privacy policies of third parties or other websites.

Security

Oculusindia Directory takes online security very seriously and use registered secure site under Verisign Certificate Authority.

How Do We Protect Your Information?

We use a server certificate (also known as a digital certificate) to assure you of our identity and secure sockets layer (SSL) to encrypt data transmissions.

If you want to check our certificate/security you can do so using one of the following methods:

From your browser when you are within Oculusindia Directory Online

Microsoft Internet Explorer 4 or later

Click on the gold padlock at the bottom right of your browser to bring up the details of this Site’s Digital ID.

Mozilla Firefox

Click on the yellow padlock at the bottom left of your browser to bring up the security information.

Opera

Click on the padlock within the address bar of your browser to bring up the security information.

At the Verisign web site

The Verisign web site enables you to validate the security of our pages online, click on the Verisign Secured Seal throughout secure areas of Oculusindia.com.

The security measures described above ensure that all reasonable steps are taken to protect your personal information. However, the nature of the Internet means that an absolute guarantee of security cannot be offered, and you should be aware that there may be a small security risk in exceptional circumstances when disclosing information online.

Privacy

Oculusindia are committed to complying with the Data Protection Act 1998 and have published this guide to help you understand how and why Oculusindia collect information from you, to whom such information is disclosed and what your rights are. You can access our Website home page and browse our site without disclosing your personal data. However, when you register with Oculusindia you will be asked to provide certain information about yourself.

What Information Do We Collect And How Do We Obtain It?

We receive information in one of two ways either directly from you when you register with us or from a third party such as credit reference agencies (for example to assess your credit rating).

If you register with us you will be asked to provide certain information such as your name, address, details of your credit card (only if you are paying by credit card), telephone number and email address so that we can process and fulfil your order, notify you of your order status and inform you of special offers and promotions.

How Do We Use Your Information?

We use the information that we collect about you to:

Process your orders

Manage your account – see also “Use of credit reference agency information”.

Administer this website.

Monitor customer traffic patterns and site usage to help us develop and improve the design and layout of the site.

Notify you about enhancement to our services, such as changes to the website, new services and special offers that may be of interest.

You agree that we may use personal information in order to conduct appropriate anti fraud checks. Personal information that you provide may be disclosed to a credit reference or fraud prevention agency, who may keep a record of that information. If you have given us permission to send you information about our products and services by telephone, email or in writing, Oculusindia will do so in accordance with the Privacy and Electronic Communications Regulations 2003 and the Direct Marketing Association (DMA) Code of Practice.

Use of Credit Reference Agency Information and sharing of credit information.

In the interests of responsible lending and for security purposes we may carry out searches with credit reference agencies when you register with Oculusindia and further searches may be carried out before deciding whether to accept orders and/or grant further credit. The agencies record these searches. We may also share information about you and the conduct of your account with credit reference agencies, other lenders and relevant third parties               Information about you and other members of your household and those with whom you are financially linked maybe used to verify your identity and for the credit assessment of you and them.   We may also use your information for payment recovery or fraud and debt tracing. We will pass on details of defaulting accounts to debt collection agencies.              For details of the Credit Reference Agencies that we receive information from and share information with write to the Group Data Protection Manager at Head Office or via dataprotection@Oculusindia.com, quoting Security and Privacy Enquiry.

Who Does Oculusindia Disclose The Information It Collects To?

We use information about you for purposes other than the provision of a website shopping facility. As a result we may disclose your information to:

Credit Reference Agencies – for more information see above.

Legal and debt recovery representatives for debt collection and debtor tracing purposes.

Reputable companies to fulfil your order or process your data on our behalf.

We may combine your information with information we collect from other companies and use it to improve and personalize our services, content and advertising.

This may also be done on a reciprocal basis. From time to time, we make portions of our customer list available to carefully screened companies. If you do not want your name and mailing details made available, or no longer choose to receive a Oculusindia catalog or wish to alert us to duplicate mailings, please call us on our helpline number or email marketing@Oculusindia.com. Oculusindia is committed to respecting your privacy.

Keeping in Touch with You

We want to keep you up to date with information about new ranges, special offers and improvements to this site.

If you decide you do not want us to contact you, you can request that we stop using your information and that we stop mailing information to you by writing to the Group Data Protection Manager at Head Office or via dataprotection@Oculusindia.com, quoting Security and Privacy Enquiry.

You may continue to receive mailings which are already on route to you for a short period of time while your request is being dealt with.

Your Rights Under the Data Protection Act 1998

You have a right to access the personal data that we hold on you. If you would like to see a copy please send a £10 fee and a written request to the Group Data Protection Manager at Head Office, quoting Security and Privacy Enquiry.             If you think the information we hold on you is incorrect please contact the Group Data Protection Manager at Head Office or via dataprotection@Oculusindia.com, quoting Security and Privacy Enquiry.

The Direct Marketing Association

Oculusindia is a member of the Direct Marketing Association (DMA) and is required to operate within the rules of the DMA’s Code of Practice. This means that Oculusindia operate to a high level of commercial standards which are designed to :

Protect your privacy.

Ensure that payments are secure.

Let you know what you have agreed to.

Sort out any complaints.

Oculusindia is also a member of the Mail Order Traders Association (MOTA) and subscribes to their Code of Practice. We undertake to deal with any complaints sympathetically and speedily. If any complaint cannot be resolved to the satisfaction of the customer, we or the customer can refer the problem for conciliation by the Director, Mail Order Traders Association, PO Box 51909, London, SW99 0WZ.

Monitoring Communications

As part of our efforts to make further improvements to the service we provide to our customers, telephone calls to and from Oculusindia Directory may be recorded or monitored and used for training purposes. To protect the operation of our computer systems we monitor incoming and out going email.

Changes to the Privacy Policy

We keep our privacy policy under regular review and we will place any updates in this webpage. This privacy policy was last updated on 23rd February 2023.

Contact Us

If you have any questions relating to this policy or the use by Oculusindia of personal data please write to the Group Data Protection Manager at Head Office or via dataprotection@Oculusindia.com, quoting Security and Privacy Enquiry.

Head Office Contact Details

Group Data Protection Manager

OculusIndia Retail Ltd.

Desford Road,

Enderby,

Leicester.

LE19 4AT

INTRODUCTION

Infiniti Retail Limited owns and operates www.Oculusindia.com (“Website”) and Infiniti Retail Limited respects your privacy (“IRL” or “We”). We understand the importance of protecting your privacy. We are committed to safeguarding the privacy of the sensitive personal data or information that We collect, possess, use, process, record, store, transfer, disclose, deal, handle and receive, by and on behalf of our clients/customers including the sensitive personal data or information of their clients/customers, while rendering services to our clients/customers in connection with our businesses. Accordingly, following is our Privacy Policy setting out how We intend to safeguard such sensitive personal data or information received and used by us as aforesaid. This is in compliance with the prevailing Information Technology Act, 2000 and the Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011 made thereunder (“IT Act”).

SCOPE AND APPLICABILITY OF THIS POLICY

This Privacy Policy (the “Policy”) is effective from 1st April, 2012 as amended from time to time and applies to IRL, its affiliates and its subsidiary companies, its employees, staff and team members who collect, possess, use, process, record, store, transfer, disclose, deal, handle and receive, the sensitive personal data or information by and on behalf of IRL’s clients/customers (“Client(s)”) including the sensitive personal data or information of the clients/customers of such Clients (“Client Contacts”) which has been given to IRL by such Clients and/or the Client Contacts (“You” or “Your”) while rendering services to them and third parties in India or overseas including but not limited to any consultants, contractors, advisors, accountants, agents, person, representatives of IRL and/or service providers etc who provide services to or on IRL’s behalf in connection with its business (“Third Party”). This Policy summarizes what type of Sensitive Personal Data or Information (as defined hereinafter) We collect about You, purpose of collection, storage and usage of such data or information, to whom such data or information may be disclosed/transferred and how We protect Your privacy.

TYPES OF SENSITIVE PERSONAL DATA OR INFORMATION WE COLLECT

The term “Sensitive Personal Data or Information” in this Policy refers to personal information which does and/or is capable of identifying You as an individual. The types of Sensitive Personal Data or Information that We may collect consist of following personal information relating to You:

name, gender, home address, telephone number, date of birth, marital status, email address, emergency contacts or other contact information (including the gender, age, nationality and passport information of any relatives and beneficiaries);

photographs; racial or ethnic origin, nationality and passport information; religious or philosophical beliefs;

financial information such as bank account/credit card/debit card or other payment instrument details; taxpayer identification number;

physical, physiological and mental health condition; sexual orientation;

medical and health records and history; biometric information;

affiliations, interests, work history, technical skills, educational background, professional certifications and registrations, language capabilities, training courses attended;

voicemails, e-mails, password, correspondence and communications;

About the pages You visit/access, the links you click on our Website, the number of times you access the page, items bought by You, loyalty points, pre-nomination, notification, Opinions of features on our Website.

the results of credit and criminal background checks, screening, health certifications, driving licence number, vehicle registration and driving history;

information required to comply with laws, statutory obligations, the requests and directions of law enforcement authorities or court orders;

acknowledgements regarding IRL policies, including ethics and/or conflicts of interest policies and computer and other corporate resource usage policies;

any detail relating to the above clauses as provided to IRL; and

any of the information received under above clauses by IRL for collecting, receiving, possessing, using, processing, recording, storing, transferring, dealing, handling and disclosing under lawful contract or otherwise.

Most of the Sensitive Personal Data or Information We collect is the data or information that is willfully and knowingly provided to us by You. However, in some instances, We collect Sensitive Personal Data or Information about You, based on our inferences about You, from other information provided to us by You or on our interactions with You or on such personal information about You that We receive from a third party with Your knowledge.

This Policy does not apply to any information that You may disclose publicly and which is freely available or accessible in public domain or furnished under the Right to Information Act, 2005 or any other law for the time being in force and such information shall not be regarded as Sensitive Personal Data or Information for the purposes of this Policy. Further, the Sensitive Personal Data or Information of You shall not be disclosed to any third person unless the said third person is required to have the Sensitive Personal Data or Information of You to provide required services to You and/or with your permission and/or to help investigate, prevent or take action regarding unlawful and illegal activities, suspected fraud, potential threat to the safety or security of any person, violations of www.Oculusindia.com terms of use or to defend against legal claims and special circumstances such as compliance with the rules of any stock exchange, subpoenas, court orders, requests/order from legal authorities or law enforcement agencies requiring such disclosure. We share your information with advertisers on an aggregate basis only.

YOUR CONSENT

We will obtain Your permission in writing through a letter or fax or email (“Consent”) before collecting Your Sensitive Personal Data or Information with respect to the purpose of usage of such data or information. If You give Your Consent, it means You have done so freely and voluntarily and agree to this Policy. You always have the right to refuse or withdraw Your Consent for the Sensitive Personal Data or Information sought to be collected or withdraw Your Consent given earlier to us. We will always respect such a refusal or withdrawal, but it might mean that We are unable to perform all services, arrangements or contracts with You and will have the option to discontinue the same. We will inform You of these inabilities, if they occur. However, We reserve the right to retain such Sensitive Personal Data or Information as may be necessary for providing our pending services to You and in accordance with this Policy.

We will while collecting Sensitive Personal Data or Information directly from You take such reasonable steps to ensure that You are aware of the –

fact that the Sensitive Personal Data or Information is being collected;

purpose for which the Sensitive Personal Data or Information is being collected;

intended recipients of the Sensitive Personal Data or Information; and

name and address of the agency that is collecting the Sensitive Personal Data or Information and retaining the same.

We respect Your privacy rights, therefore, IRL will observe the following guidelines when collecting, receiving, possessing, using, processing, recording, storing, transferring, dealing, handling, and disclosing:

Sensitive Personal Data or Information will be collected, received, possessed, used, processed, recorded, stored, transferred, dealt, handled and disclosed in compliance with the local laws/regulations in the territory where those activities occur including IT Act;

Sensitive Personal Data or Information will be collected for specified, legal and legitimate purposes and shall be used for the purpose for which it has been collected;

Sensitive Personal Data or Information will be relevant/necessary to/for the purposes for which it is collected and used;

Sensitive Personal Data or Information will be current and accurate with reasonable steps taken to rectify or delete inaccurate Sensitive Personal Data or Information;

Sensitive Personal Data or Information will be kept only as long as necessary for the purposes for which it was collected and processed; and

Appropriate measures will be taken to prevent unauthorized access or use, unlawful processing, and unauthorized or accidental loss, destruction, or damage to such Sensitive Personal Data or Information.

PURPOSES FOR COLLECTION, STORAGE AND/OR USE OF SENSITIVE PERSONAL DATA OR INFORMATION

The primary purposes for collection, storage and/or use of Sensitive Personal Data or Information is for:

our business processes, operations and management including but not limited to performance of the business, operation of the services, entering into or performing any contract, maintaining quality of the services, providing support to the products or services You have obtained from us, managing company assets;

processing Your order, corresponding with You, fulfilling Your transaction requests and delivering the programs, products, information, and services requested by You or other services related inquiries;

managing Client Contacts profiles including but not limited to the business relationship between the Clients and Client Contacts, administering and developing our business relationship with You, providing You with information, products or services that You request from us or which We feel may interest You, record keeping and other general administrative and services related processes;

ensuring the safety and protection of the rights or property of IRL or its business;

complying with applicable legal requirements including but not limited to governmental reporting, etc and fulfilling statutory/legal obligations as a service provider under applicable laws, adhering to judicial or administrative orders, compliance with laws;

contacting You via surveys to conduct research about Your opinion of current services or of potential new services that may be offered by us;

monitoring or recording of certain calls, chats and other interactions relating to the online transactions which may involve You calling us or us calling You and online chats for staff training or quality assurance purposes or to retain evidence of a particular transaction or interaction;

while conducting daily business/operations such Sensitive Personal Data or Information may be provided to affiliates and associate companies, employees/staff of IRL and Third Party’s for the purpose of processing such Sensitive Personal Data or Information for or on our behalf including but not limited to helping us to perform statistical analysis, send You email or postal mail, provide customer support/support services, arrange for deliveries of programs, products, information, and services etc;

direct marketing and promotional purposes;

operating Website, improving the content of our Website to offer You better products and/or services and to ensure that content from our Website is presented in the most effective manner for You; and

in connection with the business of IRL.

DATA COLLECTION DEVICES

In addition to Sensitive Personal Data or Information, We may use data collection devices such as “cookies” or other technology to obtain certain types of information when Your web browser accesses our Website. Cookies are small files containing a string of characters to identify Your browser. Cookies allow the Website to remember important data or information that will make Your visit to the Website more useful. Our Website may use cookies and other technology to store pertinent user information during a session to speed navigation and keep track of items and to collect anonymous traffic data that We may use to enhance our Website and for marketing and promotional purposes. You can reset Your browser to refuse cookies or warn You when they are being sent. Please note that by turning cookies off, You may not have access to all features available on our Website.

We also use logging systems on our internal network to register the use of your computer systems. This is done for the purpose of ensuring the performance, integrity and security of these systems. We have also contracted with third party’s to track and analyze anonymous usage and volume statistical information from our visitors and members for research purposes. Such information is shared externally only on an anonymous, aggregated basis. Such third parties use persistent cookies to help us to improve the visitor experience, to manage our Website content, and to track visitor behavior. All data or information collected by such third party on our behalf is used solely by or on behalf of IRL and is shared externally only on an anonymous, aggregated basis.

We will make best efforts to do so but do not warrant that any of the websites or any affiliate site(s) or network system linked to our Website is free of any operational errors nor do We warrant that our Website will be free of any virus, computer contaminant, worm, or other harmful components. Our Website contains links to other sites which are not owned or operated by IRL. IRL is not responsible and makes no guaranty for the privacy practices or the content of such websites. These links are provided only as a convenience to You. Neither, IRL nor any of its affiliates are responsible for the availability of such third party websites or their contents. IRL will not be liable for Your Sensitive Personal Data or Information transmitted over networks accessed by You of the sites or otherwise connected with Your use of the services. You understand, acknowledges and agree that neither IRL nor any of its affiliates are responsible or liable, directly or indirectly, for any damage or loss of any sort caused in connection with your use of or reliance on any content of any such site or services available through any such site.

You acknowledge that the services, content, site and/ or any software are provided on an “as is” and “as available” basis, without warranties of any kind, either express or implied, including, without limitation, implied warranties of merchantability, fitness for a particular purpose. Although IRL has taken adequate safeguard and in case of any breach IRL shall take action to remedy such breach. In addition to taking all the reasonable precautions as required under law, IRL expressly disclaims any and all warranties, express or implied, including, without limitation: (i) The services and/ or software will be free of all viruses and hacking. (ii) The software will work on all mobile phones, will be compatible with all mobile phone networks and/or will be available in all geographical areas. (iii) Any service will be uninterrupted, timely, secure or error-free for any reasons whatsoever including but not limited to overload / breakdown of receiving network, servers or applications; system failures out of the IRL’s control or due to heavy traffic on network”.

DISCLOSURES OR TRANSFER OF YOUR SENSITIVE PERSONAL DATA OR INFORMATION

If IRL wishes or is required to disclose the Sensitive Personal Data or Information collected from You to any Third Party, We will ask for Your prior Consent except when such disclosure has been agreed in the contract between IRL and You or it is necessary to comply with a legal obligation or it is to be shared with Government agencies or to be disclosed to any third party by an order under law. IRL will transfer, with Your Consent, the Sensitive Personal Data or Information to any other Third Party in India or overseas, that ensures the same level of data protection that is adhered to by IRL as setout herein for fulfilling any contractual obligation.

We will disclose or transfer Your Sensitive Personal Data or Information in accordance with this Policy and all applicable legal requirements. Your Sensitive Personal Data or Information will be disclosed or transferred, as may be required from time to time, as follows:

For Business Purposes: to (i) the appropriate employees/staff/persons in our offices; (ii) our affiliates and associate companies; (iii) from one office within IRL to another office in India or overseas in accordance with the IT Act; (iv) to any third party, in the event of a proposed or actual business transfer; and (v) in connection with our business and services provided by IRL.

To Third Party’s: working with us or on our behalf in different industries and categories of business. We will disclose, share, transfer Your Sensitive Personal Data or Information to any Third Party or provide Your Sensitive Personal Data or Information to any Third Party in connection with our business requirements or for the purposes indicated herein. Such Third Party’s are required to process Your Sensitive Personal Data or Information they receive from us in a lawful, safe and responsible manner in accordance with this Policy and the prevailing laws and take all appropriate security and confidentiality measures such that they do not use Your Sensitive Personal Data or Information for their own purposes or disclose Your Sensitive Personal Data or Information to others. Neither IRL nor any Third Party will publish Your Sensitive Personal Data or Information.

For Legal Requirement: to any court of law and/or government agencies/entity as may be required under law and/or statutory authority, Reserve Bank of India and Credit Information Bureau India Ltd (“CIBIL”) or in response to a legal process, for the purpose of verification of identity, or for prevention, detection, investigation including cyber incidents, prosecution, and punishment of offences and/or to any third party by an order under the applicable law or if We determine it is necessary or desirable to comply with any applicable law regulation, legal process or enforceable governmental request or to protect or defend our rights or property including compliance with accounting and tax rules and regulations or to investigate detect, prevent, or take action regarding illegal activities, suspected fraud, security or technical issues or situations involving potential threats to the physical safety of any person.

For Centralized Data Processing Activities: We have centralized certain aspects of our data processing and administration in order to allow us to better manage our business. Such centralization may result in the transfer of Your Sensitive Personal Data or Information: (i) from one country to another; (ii) to our employees/staff of the affiliates/associate companies of IRL in other locations etc. However, whenever Your Sensitive Personal Data or Information is transferred within IRL, it will be processed in accordance with the terms and conditions of this Policy.

REASONABLE SECURITY PRACTICES AND PROCEDURES AND AUDITS

We seek to ensure compliance with the requirements of the IT Act to ensure the protection and preservation of Your privacy, therefore We take appropriate security measures to protect Your Sensitive Personal Data or Information against unauthorized access, alteration, disclosure or destruction. We have a number of physical, electronic, and procedural safeguards/measures in place to actively protect the confidentiality, security, and integrity of Your Sensitive Personal Data or Information, including a comprehensively documented information security programme and a strict security policy that contains managerial, technical, operational and physical security control measures for protecting such data or information. We have implemented standard or code of best practices for data or information protection.

We limit access to Your Sensitive Personal Data or Information to members of our team/employees of IRL/Third Party’s who We believe reasonably need to come into contact with that information for the purpose of performing their duties. We have strict confidentiality obligations that apply to such members/employees of IRL/Third Party’s. Failure to meet these obligations may result in disciplinary and other actions, including dissolution of a contract, termination of employment and criminal prosecution.

We conduct training to authorized users regarding the lawful and intended purposes of processing Your Sensitive Personal Data or Information, the need to protect and keep information accurate and up-to-date and the need to maintain the confidentiality of the data or information to which such authorized users have access. Authorized users will comply with this Policy, and We will take appropriate disciplinary actions, in accordance with applicable laws, if Your Sensitive Personal Data or Information is accessed, processed, or used in any way that is inconsistent with the requirements of this Policy.

To further ensure enforcement of this Policy, The standard or code of best practices will be audited for compliance with this Policy and IT Act. For this purpose, We engage an independent auditor duly approved by the Central Government, to conduct the audit at least once a year or when We undertake significant upgradation of our process and computer resources and take such corrective action if necessary to address any issues or problems that such audit reveals.

RETENTION OF YOUR SENSITIVE PERSONAL DATA OR INFORMATION

We are aware of the importance of timely destruction of Sensitive Personal Data or Information. We ensure that Your Sensitive Personal Data or Information is not stored/retained for a longer period than necessary for the purpose for which it was collected, used or processed or as provided in our contracts except when there is a legal obligation to do so under any law. It is our practice to destroy Your Sensitive Personal Data or Information as soon as possible after it is no longer necessary for the purpose for which it was collected, used or processed save and except as stated hereinabove.

UPDATING OR REVIEWING YOUR SENSITIVE PERSONAL DATAORINFORMATION/ QUESTIONS OR COMPLAINTS

You may by a written request review the Sensitive Personal Data or Information provided by You. We will ensure that any Sensitive Personal Data or Information about You which is found to be inaccurate or deficient shall be corrected or amended as may be feasible.

You expressly state that Sensitive Personal Data or Information provided by You to us is correct and complete in all respects and does not contain any false, distorted, manipulated, fraudulent or misleading facts. We expressly disclaim any liability arising out of the said data or information provided by You to us. Further, You expressly agree that We are not responsible for the accuracy and authenticity of such data or information provided by You to us and You agree to indemnify IRL for all losses incurred by IRL due to any false, distorted, manipulated, defamatory, libelous, vulgar, obscene, fraudulent or misleading facts made by You to IRL.

Incase of any discrepancies or grievances with regard to the processing of Your Sensitive Personal Data or Information, please contact Mr. Shashank Singh / Mr. Dean Faria (the “Grievance Officer”) at +91(22) 67613600. Further on receipt of any concerns or complaints the Grievance Officer will employ all commercially reasonable efforts to address the same within one (1) month of receipt of same.

ENFORCEMENT RIGHTS

All IRL affiliates/group companies will ensure that this Policy is observed. All employees/staff of IRL and Third Parties who have access to Sensitive Personal Data or Information are required to comply with this Policy. In some countries, violations of data protection regulations may lead to penalties and/or claims for damages from the individuals who are adversely affected.

All Third Parties shall only process the Sensitive Personal Data or Information in accordance with IRL’s instructions or make decisions regarding such data or information as part of the delivery of their services. In either instance, IRL will select reliable Third Parties who undertake, by contract or other legally binding and permissible means, to put in place appropriate technical and organizational security measures to ensure an adequate level of protection of such data or information. IRL will require Third Parties to comply with this Policy or to guarantee the same levels of data protection that is adhered to by IRL when handling/processing such data or information. Such selected Third Parties will have access to such data or information solely for the purposes of performing the services specified in the applicable service contract and are legally and contractually bound to maintain the privacy of such data or information shared with them and will not disclose it further. If IRL concludes that a Third Party is not complying with these obligations, it will promptly take appropriate actions to remedy such non-compliance or implement necessary sanctions.

Additionally, our team members/employees/staff are bound by internal confidentiality policies. Any team member/employee/staff found to have violated this Policy or any other policies will be subject to disciplinary action, up to and including termination of employment including penalties under applicable laws.

All Third Party’s and our team members/employees/staff do hereby specifically agree that he/she/it shall, at all times, comply with the requirements of the IT Act, while collecting, receiving, possessing, using, processing, recording, storing, transferring, dealing, handling and disclosing Sensitive Personal Data or Information. The said Third Parties’ and team members/employees/staff do further unequivocally declare that in case he/she/it violates any provisions of the IT Act, he/she/it shall alone be responsible for all his/her/its acts, deeds and things and that he/she/it alone shall be liable for civil and criminal liability there under or under any other law for the time being in force.

MODIFICATIONS TO THE POLICY

IRL reserves the right to update, change or modify this Policy, from time to time, without prior notification. The policy shall come into effect from the date of such update, change or modification.

We will inform You regarding any such changes by updating this Policy and will post all changes to the Policy on relevant internal and external websites.

Effective with the implementation of this Policy, applicable IRL privacy guidelines or practices relating to the processing of Sensitive Personal Data or Information will be superseded by the terms of this Policy and modified accordingly. All parties to any such agreements will be notified of the effective date of implementation of the Policy.

If any of the terms or definitions used in this Policy are ambiguous, the definitions established under the IT Act shall apply.