Privacy Notice

This privacy notice (hereinafter, “Privacy Notice” or “Notice”) for Uforia Networks Private Limited (hereinafter, “Company”, “We”, “Us” or “Our”), trading as Uforia through the website accessible at https://www.tryuforia.com and the mobile/tablet applications made available through the Google Play Store, the Apple App Store, and similar other stores (hereinafter collectively, the “Platform”), describes Our policies and procedures on the collection, usage and disclosure of information in relation to the use of Our Platform.

Users, visitors and any other individual or entity engaging with the Platform directly or indirectly (hereinafter, “You”, “Your” and “User”) are advised to peruse this Privacy Notice prior to their usage of the Platform. This Notice transparently explains Our privacy practices and informs the User of their rights under applicable law. By using Our Platform, the User agrees to the collection, usage and disclosure of their personal information in accordance with this Notice. In case You do not agree with any of the terms included within this Privacy Notice, You are expressly prohibited from interacting with the Platform in any manner.

1. DEFINITIONS

Unless otherwise defined herein or the context otherwise requires, the capitalised terms used in this Notice shall have the meanings set out below:

1. a.

   “Consent” means a freely given, specific, informed and unambiguous indication of will.

2. b.

   “Cookies” are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.

3. c.

   “Data” means a representation of information, facts, concepts, opinions or instructions in a manner suitable for communication, interpretation or Processing (as defined hereinafter) by human beings or by automated means.

4. d.

   “Data Breach Incident” means an incident involving any unauthorised Processing of Personal Data (as defined hereinafter) or accidental disclosure, acquisition, sharing, use, alteration, destruction or loss of access to Personal Data that compromises the confidentiality, integrity or availability of Personal Data.

5. e.

   “Device” means any device that can access the Platform such as a computer, a cell phone or a digital tablet.

6. f.

   “Personal Data” means any Data about an individual who is identifiable by or in relation to such Data.

7. g.

   “Processing” in relation to Personal Data, means a wholly or partly automated operation or set of operations performed on digital Personal Data, and includes operations such as collection, recording, organisation, structuring, storage, adaptation, retrieval, use, alignment or combination, indexing, sharing, disclosure by transmission, dissemination or otherwise making available, restriction, erasure and destruction.

8. h.

   “Processor” refers to each of the entities or organisations involved in the Processing of Data on behalf of the Company, including third-party companies or individuals employed by the Company to facilitate the Platform, to provide the Platform on behalf of the Company, to perform services related to the Platform, or to assist the Company in analysing how the Platform is used.

9. i.

   “Sensitive Personal Data” means any Personal Data that demands additional protection under the applicable law.

10. j.

    “User Account” means a unique account created for the User to access the Platform or parts of the Platform.

2. SUMMARY OF KEY POINTS

This summary includes key points from Our Notice although it does not represent the entire Notice. Users are requested to consider this Section as a mere condensation of the actual Notice and are advised to peruse the entire Notice in addition to this Section. No part of this summary must be considered a replacement for any part of the Notice.

Collection of Personal Data: When You visit, use or navigate Our Platform, We may collect certain Personal Data depending on Your interaction with Our Company and Our Platform, Your choices and preferences, and the products or features You use. More information regarding Our policies on “Collection of Personal Data” is available under Section 3 of the Notice.

Processing Activities: We process Your Personal Data to provide, improve and administer Our Platform, to communicate with You, for security and fraud prevention, and to comply with the applicable law. Your Personal Data may also be processed for other purposes with Your Consent. Be that as it may, We do not process any of Your Personal Data without appropriate legal basis and lawful purpose. More information regarding Our policies on “Processing Activities” is available under Section 4 of the Notice.

Sharing and Disclosure of Your Personal Data: In Our business interests, We may share Your Personal Data in specific situations and with specific categories of third-parties. Again, under certain circumstances, We may be contractually bound or legally obligated to disclose Your Personal Data to third parties. More information regarding Our policies on “Sharing and Disclosure of Your Personal Data” is available under Section 5 of the Notice.

Data Security: Certain technical and organisational safeguards have been implemented by Us in order to protect Your Personal Data. However, in spite of adequate and reasonable safety procedures in effect, no electronic transmission over the internet or information storage technology can guarantee absolute protection. We thus cannot guarantee absolute protection against hackers, cybercriminals or other unauthorised third-parties from illegally collecting, accessing, stealing or otherwise modifying Your Personal Data. More information regarding Our policies on “Data Security” is available under Section 9 of the Notice.

Your Rights and Duties: Depending upon the applicable law, You may enjoy certain rights and are expected to perform certain duties. More information regarding “Your Rights and Duties” is available under Section 10 of the Notice.

Data Requests: The most convenient way to exercise any of the rights guaranteed to You is by contacting Us using the contact information provided within this Notice. We carefully consider all requests and act upon them in accordance with applicable law. More information regarding “Data Requests” is available under Section 11 of the Notice.

Children’s Personal Data: Our Platform is not intended to be used by any individual under the age of majority. More information regarding Our policies on Processing of “Children’s Personal Data” is available under Section 13 of the Notice.

3. COLLECTION OF PERSONAL DATA

3.1. Personal Data disclosed by You

We collect Personal Data that You voluntarily provide to Us when You register on the Platform, express an interest in obtaining information about Us or Our Platform, when You participate in or engage with activities on the Platform, or otherwise when You contact Us. The Personal Data that We collect depends on the context of Your interactions with Us and the Platform, the choices You make, and the products or features You use.

The categories of Personal Data We collect may include the following:

1. a.

   Basic Identifiers: Information that identifies an individual, such as name, username, etc.

2. b.

   Government Identifiers: Information assigned or issued by a government authority to uniquely identify an individual.

3. c.

   Contact Information: Information used to contact or communicate with an individual, such as email address, phone number, or postal address.

4. d.

   Biometric Data: Biological or behavioural characteristics used for identification or verification, such as facial scans, fingerprints, or voiceprints.

5. e.

   Demographic Data: Information relating to demographic characteristics, such as age, gender, nationality, language, or marital status.

6. f.

   Behavioural Data: Information relating to an individual’s habits, preferences, etc.

7. g.

   Location Data: Information relating to an individual’s geographic location, including approximate or precise location information derived from GPS, IP address, or device settings.

8. h.

   Payment Data: Financial and transaction-related information, such as payment method details, billing information, subscription records, and transaction history.

9. i.

   Communications Data: Information contained in or relating to communications exchanged through the Platform, including messages, support requests, and correspondence.

10. j.

    Professional / Employment Data: Information relating to an individual’s professional background, occupation, employer, work history, or professional qualifications.

11. k.

    Education Data: Information relating to an individual’s educational background, qualifications, institutions attended, certifications, or academic records.

12. l.

    User-Generated Content: Content voluntarily created, uploaded, shared, or published by an User, including text, photographs, videos, audio, comments, and other media.

13. m.

    Interaction Data: Information relating to an User’s interactions with other Users, content, advertisements, and Platform features, including likes, reactions, shares, and connections.

14. n.

    Preference Data: Information relating to an individual’s preferences, interests, choices, and personalisation selections.

3.2. Personal Data collected automatically

Certain Data is automatically collected upon Your visit, usage or navigation of Our Platform. This type of Data does not specifically identify You but may be capable of identifying You when supplemented by other information. This Data is primarily needed to maintain the security and operation of Our Platform, and for Our internal analytics and reporting purposes.

The categories of Personal Data collected automatically may include the following:

1. a.

   IP Address: Internet Protocol (IP) address and related network identifiers associated with a person’s device or internet connection.

2. b.

   Device Information: Technical information relating to the device used to access the Platform, such as device type, operating system, browser type, unique device identifiers, and hardware specifications.

3. c.

   Usage Data: Information relating to how Users access and use the Platform, including log data, session activity, feature usage, clickstream data, and access timestamps.

3.3. Personal Data collected from other sources

In order to enhance Our ability to provide relevant marketing, offers, and services to You and update Our records, We may obtain information about You from other sources, such as public databases, joint marketing partners, affiliate programs, Data providers, social media platforms, and from other third parties. This information includes mailing addresses, job titles, email addresses, phone numbers, intent Data (or User behaviour Data), Internet Protocol (IP) addresses, social media profiles, social media URLs, and custom profiles, for purposes of targeted advertising and event promotion.

If You interact with Us on a social media platform using Your social media account, We receive Personal Data about You such as Your name, email address, and gender. Any Personal Data that we collect from Your social media account depends on Your social media account's privacy settings.

4. PROCESSING ACTIVITIES

4.1. Purposes for Processing

We process Your Personal Data for a variety of reasons (“Lawful Purpose”), depending upon how You interact with Our Platform, including the following:

1. a.

   User Onboarding and Account Management. We may process Your Personal Data to create, authenticate, and administer User accounts; verify User eligibility (including age); enable secure access to the platform; and maintain account-related records necessary for service provision.

2. b.

   Feedback Acceptance, Customer Support and Grievance Redressal. Your Personal Data may be processed by Us to receive, manage, and respond to User queries, complaints, and grievances; resolve disputes between Users; provide customer support; and comply with applicable grievance redressal and consumer protection obligations.

3. c.

   User Profile Management and Enrichment. We process Your Personal Data to enable Users to create, update, verify and maintain their profiles; enhance User profiles with preferences and interests; and facilitate better User discovery, interaction, and personalisation of services.

4. d.

   Content Generation and Publication Enablement. Your Personal Data may be processed to enable Users to create, upload, publish, and share content (including text, images, videos, and other media); facilitate content distribution to relevant audiences; and support User engagement and expression on the Platform.

5. e.

   User-to-User Communication and Interaction Support. We may process Your Personal Data to enable communication and interaction between Users, including messaging, sharing of content, and engagement features (such as likes, comments, and reactions), and to support meaningful connections between Users.

6. f.

   Matching and Recommendation Algorithms. We may process Your Personal Data to analyse User preferences, behaviour, and interactions in order to generate personalised matches, recommendations, and content feeds; and to improve relevance, engagement, and overall User experience on the Platform.

7. g.

   Content Moderation and Safety. Your Personal Data may be processed to monitor, detect, prevent, and address harmful, abusive, fraudulent, or unlawful content and behaviour; enforce Platform policies; ensure User safety; maintain the integrity and trustworthiness of the Platform; and to prevent harm, respond to emergency situations, and protect the vital interests of individuals where necessary.

8. h.

   Location-Based Services. We may process Your Personal Data to provide location-based features, including proximity-based matching, discovery of nearby Users, and localised content; and to enhance relevance and safety of interactions based on User location.

9. i.

   Premium Features and Offerings. We process Your Personal Data to provide enhanced or paid features (such as increased visibility, advanced filters, or priority access); manage User entitlements; and deliver differentiated service offerings based on subscription or purchase.

10. j.

    Advertisement and Monetisation. Certain categories of Personal Data may be processed to deliver advertisements, sponsored content, and promotional materials; create an ad profile; measure ad performance; and generate revenue through targeted or contextual advertising and other monetisation strategies.

11. k.

    Analytics and Product Improvement. Personal Data may be processed to analyse User behaviour, usage patterns, and platform performance; conduct research and testing; improve features, functionality, and User experience; and support product development and innovation.

12. l.

    Notifications and Communications. Your Personal Data may be processed to send service-related notifications, alerts, and updates; deliver transactional and administrative communications; and, where applicable, send marketing communications in accordance with user preferences and applicable law.

13. m.

    Security and Fraud Prevention. Some categories of Personal Data are processed to ensure the security of the Platform; detect, prevent, and investigate unauthorised access, fraud, abuse, and other malicious activities; and protect Users, systems, and Data from security threats.

14. n.

    Legal and Compliance. Your Personal Data may be processed where We are obligated by any legal requirements, which may include, compliance to a judgement, decree or directive passed by a court of competent jurisdiction; cooperation with any law enforcement authorities or regulatory bodies with respect to investigations and reporting requirements; and in case of any litigation upon Us.

15. o.

    Fulfilment and Management of Credits, Subscriptions and Purchase Orders. Your Personal Data may be processed to manage subscriptions and credit-based features, process transactions, maintain billing records, and administer renewals, refunds and related financial operations.

4.2. Grounds and Basis for Processing

We only process Your Personal Data when We believe it is necessary and when We have a valid legal reason to do so under applicable law.

For Users in the European Union (EU) and the United Kingdom (UK)

Under the EU General Data Protection Regulations, Regulation (EU) 2016/679, the EU GDPR as applied in the United Kingdom, and the UK Data Protection Act, 2018 (c.12), we as the controller of Personal Data rely upon the following grounds (“Legal Basis”) for Processing:

1. a.

   Consent: With Your permission (or Consent), We may process Personal Data which You have voluntarily provided to Us for a specific purpose. For each category of such Personal Data, the Processing activities shall be restricted to the purposes mentioned within this Notice. You are entitled to withdraw or revoke Your Consent at any time.

2. b.

   Legitimate Interest: We may process Your Personal Data when We believe it is reasonably necessary for Us to achieve Our legitimate business interests and those interests do not outweigh Your interests, fundamental rights and freedom.

3. c.

   Contractual Obligation: We may process Your Personal Data when we believe it is necessary to fulfil Our contractual obligations to You, including providing any products or services through Our Platform, or at Your request prior to entering into a contract with You.

4. d.

   Legal Obligations: We may process Your Personal Data where We believe it is necessary to exercise or defend Our legal rights, adduce Your Personal Data as evidence for the purpose of any litigation in which We are involved, or for compliance with Our legal obligations, such as to comply to a judgement, decree or directive passed by any competent court of law or to cooperate with law enforcement authorities and regulatory bodies.

5. e.

   Vital Interests: We may process Your information where We believe it is necessary to protect Your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

For Users in India

Under the Indian Digital Personal Data Protection Act, 2023 (Act No. 22 of 2023), and the Information Technology Act, 2000 (Act No. 21 of 2000), including the rules framed thereunder, we, as the Data fiduciary, rely upon the following grounds (“Grounds”) for Processing:

1. a.

   Consent: With Your permission (or Consent), We may process Personal Data which You have voluntarily provided to Us for a specific purpose. For each category of such Personal Data, the Processing activities shall be restricted to the purposes mentioned within this Notice. You are entitled to withdraw or revoke Your Consent at any time.

2. b.

   Certain Legitimate Uses: We may process Your Personal Data for certain legitimate uses permitted under applicable law, including where You have voluntarily provided such Personal Data for a specified purpose and have not indicated that You do not consent to such Processing (“Voluntary Provision”), for compliance with any judgment or legal obligation (“Legal Obligation”), responding to medical emergencies (“Medical Emergency”), employment-related purposes (“Employment”), safeguarding against fraud or cyber incidents, ensuring network and information security, credit scoring, debt recovery, or any other legitimate use as may be permitted under applicable law.

For Users in Other Jurisdictions

The grounds for Processing Your Personal Data vary depending on the applicable laws of the relevant jurisdiction, and We only rely upon grounds that are lawfully recognised under such laws.

4.3. Summary of Processing Activities

The Lawful Purposes for Processing, the categories of Personal Data involved in each Processing activity, and the Grounds or Legal Basis for each jurisdiction are summarised through the table hereunder.

5. SHARING AND DISCLOSURE

5.1. Sharing of Personal Data

We may share Your Personal Data with third-parties in specific situations described in this Section and/or with the following categories of third parties:

1. a.

   Processors. We may share Your Personal Data with Our Data Processors that assist us in operating, maintaining, securing, and improving the Platform. We have established necessary contractual relations with such Processors which are designed to help safeguard Your Personal Data. In other words, in the absence of specific directions or instructions from Us, Our Processors cannot utilise Your Personal Data beyond their scope of engagement. Data Processors are restricted from sharing Your Personal Data with any other organisation in the absence of specific instructions from Us or without Our Consent. Furthermore, they commit to protect the Data they hold on Our behalf and to retain it for the period we instruct. The details and categories of such Processors and the purpose for such sharing are indicated through the table below:

1. b.

   Vendors, Consultants, and Other Third-Party Service Providers. We may share Your Personal Data with independent third-party vendors, service providers, contractors, or agents who perform necessary services for Us or on Our behalf and require access to such information. Such third-parties may process Your Personal Data independently in accordance with their own legal obligations and privacy practices. We strongly advise You to review their privacy policies.

1. c.

   Other Businesses in case of Business Transfer: We may share or transfer Your Personal Data in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.

2. d.

   Affiliates. We may share Your Personal Data with Our affiliates, in which case We will require those affiliates to honour Our privacy practices. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.

3. e.

   Business Partners and Collaborators. We may share Your Personal Data with Our collaborators to offer You certain products, services or promotions through the Platform.

4. f.

   Other Users. When You share Personal Data or otherwise interact in the public areas of Our Platform with other Users, such information may be viewed by all Users and may be publicly distributed outside of the Platform in perpetuity.

5. g.

   Any other third-party, with Your Consent. With Your specific Consent, We may share Your Personal Data with any other third-party for any other purpose. In such a situation, the details of such third-party along with the purpose for sharing shall be communicated to You in advance.

5.2. Disclosure of Personal Data

In certain situations, We might be obligated to disclose Your Personal Data to third-parties, by virtue of any contractual or legal obligations. Such situations include:

1. a.

   Business Transactions. If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. In such a situation, You shall be notified well in advance and prior to any actual transfer of Your Personal Data. It shall be noted that in such a situation, Your Personal Data shall be subject to and governed by different policies and practices. Your Consent to such new policies shall be refreshed.

2. b.

   Law Enforcement. Under certain circumstances, the Company may be required by law to disclose Your Personal Data upon valid requests from law enforcement authorities, regulatory bodies, courts of law or governmental agencies. We impart Our most sincere consideration to such requests and We only disclose Your Personal Data when such a request, upon Our analysis, is determined to be genuine, valid and absolutely mandated by the law. Although We are not obligated to, We may notify You of any disclosure in connection to Your Personal Data.

3. c.

   Other legal requirements. We may disclose Your Personal Data in the good faith belief that such disclosure is necessary to (a) comply with a legal obligation; (b) protect and defend the rights or property of the Company; (c) prevent or investigate potentially illegal activities in connection to the Platform; (d) protect the personal safety of the Users of the Platform; and (e) protect the Company against unjust liabilities.

6. THIRD-PARTY WEBSITES

Certain parts of Our Website and Our Platform may include links to third-party websites, online services, or mobile applications and/or contain advertisements from third parties which may link to other websites, services, or applications. Such third-parties are not affiliated to Us in any way, and thus, We do not assume any liability for any loss or damage caused by Your use of such third-party websites, services or applications.

The inclusion of a link towards a third-party website, service, or application does not imply an endorsement by Us. We cannot guarantee the safety and privacy of any Personal Data You provide to any third parties. Furthermore, We are not responsible for the privacy and security practices and policies of any third party, including other websites, services, or applications that may be linked to or from the Platform. Any Data collected by a third-party is not governed by this Notice. It is advisable for You to review and enquire upon the policies of such third parties prior to sharing any of Your Personal Data with them.

7. CROSS-BORDER DATA TRANSFERS

Our servers are located in the European Union. If You are accessing Our Platform from abroad, please be aware that Your Personal Data may be transferred to, stored, and processed by Us in Our facilities and by Our Data Processors, located in the European Union, United States, India, and other countries.

The Company takes reasonable steps to ensure that Your Data is treated securely and in accordance with this Notice by Our Data Processors. No transfer of Your Personal Data shall take place to an organisation or country that exhibits a lack of adequate controls or Data protection framework. We do not transfer Your Personal Data to any country or territory to which the transfer of Personal Data is restricted by the applicable law.

8. DATA RETENTION

We shall only retain Your Personal Data for as long as it is necessary to fulfil the purposes set out in this Notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). We may also retain Your Personal Data to resolve disputes, comply with the applicable law, or enforce Our legal agreements and policies.

When We have no ongoing legitimate business need to process Your Personal Data, we will either delete or anonymise such information, or, if that is not possible (for example, if Your Personal Data has been stored in backup archives), then We will securely store Your Personal Data and isolate it from any further Processing until deletion is possible.

Upon the deletion of Your User Account on Our Platform, most of Your Personal Data is automatically deleted within 30 (thirty) days, although some of them may be retained until 12 (twelve) months from the date of deletion of Your User Account for the purposes of fraud prevention, troubleshooting, investigations, enforcement of Our legal rights, and/or compliance with applicable law. Additionally, under certain circumstances, some specific categories of Your Personal Data may be retained even beyond the aforementioned time-frame, in order to manage risk and comply with legal obligations.

9. DATA SECURITY

We implement reasonable and appropriate technical and organisational safeguards designed to protect the security of any Personal Data We process. However, despite Our safeguards and best efforts to secure Your Personal Data, no electronic transmission over the internet or information storage technology can offer absolute security. We thus cannot guarantee absolute protection against hackers, cybercriminals or other unauthorised third-parties from illegally collecting, accessing, stealing or otherwise modifying Your Personal Data. In the event of any such Data Breach Incident involving Your Personal Data, We shall notify You about such an incident in the form and manner prescribed by applicable law.

Although We employ Our best efforts to protect Your Personal Data, transmission of Personal Data to and from Our Platform is at Your own risk. You are advised to access the Platform through a secure environment only.

10. YOUR RIGHTS AND DUTIES

10.1. Your Rights as an User

Users of Our Platform are guaranteed certain rights depending upon the applicable law of their jurisdiction.

For Users in the European Union (EU) and the United Kingdom (UK)

Under the EU General Data Protection Regulations, Regulation (EU) 2016/679, the EU GDPR as applied in the United Kingdom, and the UK Data Protection Act, 2018 (c.12), Users residing in the European Union and the United Kingdom are guaranteed the following rights:

1. a.

   Right to be Informed – the right to receive clear, transparent, and easily understandable information about how Personal Data is collected, used, stored, shared, and otherwise processed.

2. b.

   Right of Access – the right to obtain confirmation as to whether Personal Data is being processed and to access such Personal Data along with related information regarding the Processing.

3. c.

   Right to Rectification – the right to request correction or updating of inaccurate, incomplete, or outdated Personal Data.

4. d.

   Right to Erasure (or Right to be Forgotten) – the right to request deletion or removal of Personal Data in certain circumstances, including where the Data is no longer necessary for the purposes for which it was collected.

5. e.

   Right to Restriction of Processing – the right to request limitation or suspension of the Processing of Personal Data under certain conditions.

6. f.

   Right to Data Portability – the right to receive Personal Data in a structured, commonly used, and machine-readable format and to transmit such data to another controller where technically feasible.

7. g.

   Right to Object – the right to object to the Processing of Personal Data based on legitimate interests, public interest, direct marketing, profiling, or certain other lawful bases.

8. h.

   Right Not to be Subject to Automated Decision-Making – the right not to be subject to decisions based solely on automated Processing, including profiling, which produce legal or similarly significant effects, subject to applicable exceptions.

9. i.

   Right to Withdraw Consent – where Processing is based on Consent, the right to withdraw such Consent at any time without affecting the lawfulness of Processing carried out prior to withdrawal.

10. j.

    Right to Lodge a Complaint – the right to file a complaint with a competent supervisory authority or Data protection regulator if the User believes their rights have been violated.

For Users in India

Under the Indian Digital Personal Data Protection Act, 2023 (Act No. 22 of 2023), and the Information Technology Act, 2000 (Act No. 21 of 2000), including the rules framed thereunder, Users of Our Platform belonging to India are guaranteed the following rights:

1. a.

   Right to Access Information – the right to obtain information regarding the Personal Data being processed, including details relating to the Processing activities, categories of Personal Data processed, and identities of Data fiduciaries and Data Processors with whom such Personal Data has been shared.

2. b.

   Right to Correction and Erasure – the right to request correction, completion, updating, or erasure of Personal Data that is inaccurate, misleading, incomplete, or no longer necessary for the purpose for which it was processed, subject to applicable legal and contractual obligations.

3. c.

   Right to Withdraw Consent – the right to withdraw Consent previously granted for the Processing of Personal Data, at any time, with the understanding that such withdrawal shall not affect the lawfulness of Processing carried out prior to such withdrawal.

4. d.

   Right to Grievance Redressal – the right to have readily available means of grievance redressal and to seek resolution of concerns or complaints relating to the Processing of Personal Data.

5. e.

   Right to Nominate – the right to nominate another individual to exercise rights on behalf of the User in the event of death or incapacity, in accordance with applicable law.

6. f.

   Right to Be Informed – the right to receive clear and accessible information regarding the Processing of Personal Data, including the purposes of Processing, categories of Personal Data processed, methods of exercising rights, and mechanisms available for grievance redressal.

7. g.

   Right to Data Security and Protection – the right to expect reasonable security safeguards to be implemented to protect Personal Data against unauthorised access, disclosure, alteration, destruction, loss, or misuse, in accordance with applicable law and reasonable security practices.

For Users in Other Jurisdictions

For Users belonging to other jurisdictions, the rights are determined and granted with respect to the applicable local law.

10.2. Your Duties as an User

In Our attempts to maintain Our privacy practices and policies, We reasonably expect Users of the Platform to respect and perform the following duties:

1. a.

   Comply to the provisions of all applicable laws while exercising Your rights;

2. b.

   Ensure not to impersonate another person while providing Personal Data for a specified purpose;

3. c.

   Avoid the suppression of any material information while providing Your Personal Data for any document, unique identifier, proof of identity or proof of address issued by the Government or any of its instrumentalities;

4. d.

   Refrain from registering a false or frivolous grievance or complaint with Us or any supervisory government authority; and

5. e.

   Furnish only such information as is verifiably authentic, while exercising the right to correction or erasure.

11. DATA REQUESTS

The quickest and most convenient way to exercise any of Your rights guaranteed under the applicable law or as mentioned within this Notice is by:

1. a.

   Creating a submission on the “Data Requests” form available through the Platform; or

2. b.

   Contacting Us using the contact information provided under Section 16 of this Notice titled “Contact Us”.

We impart Our sincere consideration towards all access requests and act upon them in accordance with the applicable law.

12. DIRECT MARKETING

With Your Consent, We may use Your Personal Data to contact You with newsletters, marketing or promotional materials, and other information that may be of interest to You. You may withdraw such Consent and opt-out of receiving any, or all, of these communications from Us by following the unsubscribe link or instructions provided in any email We send or by contacting Us.

Upon withdrawal of Your Consent, although You will be removed from Our mailing and marketing lists, We may still continue to communicate with You, for example to send You service-related messages that are necessary for the administration, use and security of Your User Account, to respond to service requests, or for other non-marketing purposes.

13. CHILDREN’S PERSONAL DATA

Our Platform is not meant to be used or accessed by individuals below the age of majority in the jurisdiction they reside in (hereinafter, “Child” or “Children”). We do not knowingly or intentionally solicit any Personal Data from or market to Children. By using the Platform, You represent that You are not considered a minor in Your jurisdiction, or that You are the parent or legal guardian of such a Child and Consent to such Child dependent’s use of the Platform.

In case it comes to Our attention that Personal Data of a Child has been collected mistakenly or accidentally, We take adequate steps to deactivate the User Account and take reasonable measures to promptly delete such Personal Data from Our inventories and repositories. If You become aware of any Personal Data We may have collected from Children, We request you to kindly contact Us immediately.

14. UPDATES TO THIS NOTICE

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated and revised date and the updated version will be effective as soon as it is accessible. If We make any material changes to this Notice, We may notify You either by prominently posting a notice of such changes or by directly sending You a notification. We encourage You to review this Privacy Notice frequently to be informed of how We are protecting Your Personal Data.

15. GRIEVANCE REDRESSAL (INDIA)

In accordance to the Indian Information Technology Act, 2000 (Act No. 21 of 2000), the Digital Personal Data Protection Act, 2023 (Act No. 22 of 2023), and the Consumer Protection Act, 2019 (Act No. 35 of 2019), including the rules made thereunder, the name and contact details of the Nodal cum Grievance Officer are provided below:

Details of the Nodal cum Grievance Officer

Name: Mr. Athul Ben
Designation: Director
Address: No. 43 Residency Road, Shanthala Nagar, Ashok Na, Richmond Town, Bangalore, Bangalore North, Karnataka, India, 560025.
Email: gro@tryuforia.com
Phone Number: +91 7397730682

Any grievances, complaints or concerns regarding Our Data protection policies or practices shall be communicated to Our Nodal cum Grievance Officer.

Please note that the grievance redressal mechanism is an escalation channel. We request You to kindly exhaust the option to contact Our customer support by using the information provided under Section 16 herein before opting for the grievance redressal procedure. The grievance redressal mechanism shall only be utilised in relation to any complaints, grievances or concerns that You feel are not appropriately addressed by Our customer support team.

16. CONTACT US

In case You have any queries in relation to Our Platform, including this Privacy Notice, or if You wish to exercise any of Your rights, We encourage You to contact Us at the following details:

Support page: Profile → Settings → Help & Support
Phone number: +91 7397730682
Email: support@tryuforia.com
Postal Address: No. 43 Residency Road, Shanthala Nagar, Ashok Na, Richmond Town, Bangalore, Bangalore North, Karnataka, India, 560025.