Privacy Policy

Introduction
Please read this Privacy Policy carefully before using the "Website" and mobile applications ("App"). This Website and App are owned, registered and operated by “Platform Owner” ("we", "us" "our", “Emuron”). This Platform is a medium through which the Services of Platform Owner shall be streamed
directly to its Platform Users via App or Website. This App and the Website shall be together referred to as the “Platform”. By using this Platform, the Platform Users of the Website or App, hereinafter referred to as "User" or "you" or "your" or "yourself" “registered user” or “guest user” signify in your
agreement to be bound by these Terms & Conditions("Agreement"). The information if any collected through this Platform will be secured, safeguarded and shall be utilised for providing better and appropriate services to you and for lawful usage and purpose.

We process information relating to an identified or identifiable natural person in accordance with this Privacy Policy and in compliance with the relevant data protection regulation and laws. This Policy provides the necessary information regarding right and obligations for concerned parties, and
explains how, why and when we process such information.

Note
Our privacy policy is subject to change at any time without notice. Though every effort would be made to keep you informed of the changes, if any, to the policy, you are kindly advised to review the policy periodically.

By using our website application or downloading our mobile app you agree to be bound by the terms and conditions of this Privacy Policy. As this policy enables us to provide you a secure and wholesome experience, we will not be able to register you, if you are not in agreement with these
terms.

By mere use of the Platform, you expressly consent to our use and disclosure of your personal information in accordance with this Privacy Policy. This Privacy Policy is incorporated into and subject to the Terms of Use.

Scope and Definition
This policy shall govern the collection of data, use of Data and Handling ("usage") of the Personal Information ("PI") and the Sensitive Personal Data or Information ("SPDI") by the Platform Owner in accordance with the Rules.

"Personal Information" means any information that can be used to identify, locate, or contact an individual, alone or when combined with other personal or identifying information. For this purpose, Platform Owner collects the following Personally-Identifying Information ("PII") in a form from the
Users during their use of the Platform or the IoT/BSS Device:
● Name of the User
● E-mail address
● Address
● Credit card or debit card information which is required for payment purposes (excluding passwords, PIN numbers, (CVVs etc.)
● Billing and transaction details
● Any other information as required by Us for the purpose of the User’s use of the Platform or
the IoT/BSS device.

"Sensitive Personal Information" means such personal information which consists of information relating to:
● Password
● Financial information such as bank account or credit card or debit card or other payment instrument details


Any detail relating to the above clauses as provided to a body corporate for providing service; and any of the information received under above clauses by body corporate for processing, stored or processed under lawful contract or otherwise: Provided that, any information that is freely available or accessible in public domain or any other law for the time being in force shall not be regarded as sensitive personal data or information. By clicking the accept button below you hereby expressly give consent to use your PI and SPDI as more fully described herein below. Your consent to the
same shall be construed as a lawful contract between you and the Platform Owner in accordance with the Act and Rules.

"Third party website" A third party website is a website that is outside the domain of the actual Platform that you are in. It is important for you to know when you are leaving the original Platform to a third-party website for security reasons. The content of other websites, services, goods or
advertisements that may be linked to this Platform is not maintained or controlled by Platform Owner.

"Non-Personal Information" Platform Owner may also collect information other than Personal Information from You through the Platform when You visit and / or use the Platform. Such information may be stored in server logs. This Non-Personal Information would not assist Platform Owner to
identify you personally. This Non-Personal Information may include:
● Your geographic location.
● Details of Your telecom service provider or internet service provider.
● The type of browser (Internet Explorer, Firefox, Opera, Google Chrome etc.)
● The operating system of your system, device and the Website You last visited before visiting the Platform.
● The duration of your stay on the Platform is also stored in the session along with the date and time of your access, Non-Personal Information is collected through various ways such through the use of cookies. Platform Owner may store temporary or permanent 'cookies' on
your computer. You can erase or choose to block these cookies from your computer. You can configure your computer's browser to alert you when we attempt to send you a cookie with an option to accept or refuse the cookie. If you have turned cookies off, you may be prevented from using certain features of the Platform.
● Ads: Platform Owners may use third-party service providers to serve ads on behalf of Platform Owner across the internet and sometimes on the Platform. They may collect Non-Personal Information about Your visits to the Platform, and Your interaction with our products and Privacy Policy
services on the Platform. Please do note that Personal Information and Non-Personal Information may be treated differently as per this Privacy Policy.

You hereby represent to Platform Owner That
The Information you provide to Platform Owner from time to time is and shall be authentic, correct, current and updated and you have all the rights, permissions and consents as may be required to provide such Information to Platform Owner.

Providing the Information to Platform Owner and Platform Owner’s consequent storage, collection, usage, transfer, access or processing of the same shall not be in violation of any third-party agreement, laws, charter documents, judgments, orders and decrees.

Your Information will primarily be stored in electronic form however certain data can also be stored in physical form. We may store, collect, process and use your data in countries other than India but under compliance with applicable laws. We may enter into agreements with third parties (in or
outside of India) to store or process your information or data. These third parties may have their own security standards to safeguard your information or data and we will on commercially reasonable basis require such third parties to adopt reasonable security standards to safeguard your information / data.

Purpose for collecting, using, storing and processing your Information Platform Owner collects, uses, stores and processes your Information for any purpose as may be permissible under applicable laws (including where the applicable law provides for such collection, usage, storage, or processes in
accordance with the consent of the user) connected with a function or activity of each of Platform Owner’s entities and shall include the following:
● To facilitate your use of the Platform or other services of Platform Owner’s entities
● To respond to your inquiries or fulfill Your requests for information about the various products and services offered on the Platform.
● To provide you with information about products and services available on the Platform and to send you information, materials, and offers from Platform Owner.
● To send you important information regarding the Platform, changes in terms and conditions, user agreements, and policies and/or other administrative information.
● To send you surveys and marketing communications that Platform Owner believes may be of interest to you.
● To help you address your problems incurred on the Platform including addressing any technical problems.
● For proper administering of the Platform.
● To conduct internal reviews and data analysis for the Platform (e.g., to determine the number of visitors to specific pages within the Platform).
● To improve the services, content and advertising on the Platform.
● To facilitate various programmes and initiatives launched by Platform Owner or third-party service providers and business associates.
● To conducting academic research and surveys.
● To protect the integrity of the Platform.
● To respond to legal, judicial, quasi-judicial process and provide information to law enforcement agencies or in connection with an investigation on matters related to public safety, as permitted by law.
● To conduct analytical studies on various aspects including user behaviour, user preferences etc.
● To implement information security practices.
● To determine any security breaches, computer contaminant or computer virus.
● To investigate, prevent, or take action regarding illegal activities and suspected fraud.
● To undertake forensics of the concerned computer resource as a part of investigation or internal audit.

Legal basis for processing of Personal Information
We will normally collect Limited Personal Information from you only where it is needed to perform a
contract including minimum KYC requirement to on-board you, where the processing is in Our
legitimate interests and not overridden by your data protection interests or fundamental rights and
freedoms, or where We have your consent. In some cases, we may also have a legal obligation to
collect Personal Information from you. If We processes Personal Information with reliance on your
consent, you may withdraw your consent at any time.

Collection and use of Personal Information
We process Personal Information in India. If you are a resident of the European Economic Area and when your Personal Information is processed outside EEA, We, will ensure that the recipient of your Personal Information offers an adequate level of protection, for instance by entering into standard
contractual clauses for the transfer of Personal Information as approved by the European Commission (Article 46 General Data Privacy Regulation, 2016), or We will ask you for your prior consent to such international data transfers.

If there are any conflicts between this section and any other provision of this Privacy Policy, the policy or portion that is more protective of Personal Information shall control to the extent of such conflict.

Cookies
Cookies are files with a small amount of data that are commonly used as anonymous unique identifiers. These are sent to your browser from the websites that you visit and are stored on your device's internal memory.

However, the app may use third party code and libraries that use cookies to collect information and improve their services. You have the option to either accept or refuse these cookies and know when a cookie is being sent to your device. If you choose to refuse our cookies, you may not be able to
use some portions of this Service.

The information we collect with cookies is not sold, rented, or shared with any third parties, other than for internal development and maintenance of the Platform.

Links to Other Sites
It is clarified that you might see the links to website / advertisements / electronic communication service, which are provided by the third parties. If you click on a third-party link, you will be redirected to that site. Note that these external sites are not operated by Platform Owner. Any usage of such third-party website or availing any service or product through third party shall be at your risk and Platform Owner is not responsible for any loss / damage or otherwise. Therefore, we strongly advise you to review the Privacy Policy of these websites. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

Disclosure to Third Parties
Platform Owner shall be at liberty to disclose your information or part thereof to third party service providers who may facilitate the providing of services, on our behalf. These service providers have access to your data only to perform the tasks as stipulated by Platform Owner and are obligated not to disclose or use it for any other purpose. Platform Owner may also share personal information with third-party vendors, consultants, and other service providers who work for the Platform Owner, who are bound by contractual obligations to keep personal information confidential.

Data Protection
By participating or accepting any rights granted under this policy, each Participant consents to the collection and processing of personal data relating to the Participant. So that the Platform Owner and its Affiliates can fulfil their obligations and exercise their rights under the contract.

Under the Data Protection Laws, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. With your (client) permission, and where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email, telephone or post with information, news, and offers on our products and services. We will always work to protect your
rights fully and comply with our obligations under the Data Protection Laws.

Data Breach
In case of data breach the responsibility of the data loss does not lies with the Patform Owner. We have the right to use the data to improve upon the our current product offering which is can be necessary for our performance of a contract with you. If the user provides us consent to delete data
for a particular time period then we will address the same by truncation of all data for the specific time period.

Data Backup
The users wil have Immediate data access of all active IoT/BSS devices for the last 3 months and 9 months of archival data. Data before 12 months is not available to the user but the same can be made available on case to case basis. Archival data is maintained on a separate AWS service of S3 bucket. We also maintain a separate log of all data for the last 1 week and in case of a data loss, the same can be made available on request.

Governing Law and Dispute Resolution
In case of any dispute Privacy Policy shall be governed by and constructed in accordance with the applicable laws of India without reference to conflict of laws principles. Courts in New Delhi, India shall have the exclusive jurisdiction to determine any disputes arising in relation to, or under, this
Privacy Policy.

Amendment
Platform Owner reserves the right to add, revise, amend, modify or delete any part of this Policy (in part or in full) at its discretion. The updated version of this Policy in force will be posted on the Platform from time to time. In the event of any change in the Act or the Rules or in case of any requirement arising under any of the applicable law, this Policy shall be deemed to be amended or modified to the extent necessary to comply with such amendment to the Act or the Rules or to meet any requirement under the applicable laws.

Data Access
The user who's the Personal Information and/or Sensitive Personal Data or Information is collected, received, possessed, processed, stored, transferred, dealt or handled may inquire as to the nature of data stored or processed by the Platform Owner. The person will be provided reasonable access to
the person's Personal Information and Sensitive Personal Data or Information held by the Platform Owner. If any data is inaccurate or incomplete, such person may request that the data be amended or modified or updated.

Security Procedures
We have implemented industry standard security policies, rules and technical measures, to protect any kind of personal sensitive information that we have under our control from unauthorized access, improper use or disclosure, unauthorized modification and unlawful destruction or accidental loss.
Following are some of technical measures taken for security:
● The server is hosted in Mumbai region and since most of our users are also from India, we stricly monitor the server access form outside India, and if a repeated unauthorized access is found then the server automatically blacklists the IP.
● Except the ports used from devices and users, all other ports are blocked.
● Server Socket Layer runs 24/7 and we renew it every 3 months. Also, the 3rd party trying to acess the server should be SSL protected then only it will be able to communicate with our server.
● All APIs are on REST architecture and no user can send SQL through form thereby providing protection against SQL vulnerability.

Contact Us
In the event You have any complaints or concerns with respect to the Platform or our services or if You have any questions about this Privacy Policy, please write us at support@emuron.com.

Grievance Redressal
For any grievances related with collection and use of Personal & Sensitive Personal Information please contact:

Grievance Officer email address: support@emuron.com.

Note:
● Please include the following subject line in the email – "Attention: Grievance Officer"
● We will strive to address your feedback and concerns in a timely and effective manner.