INTRODUCTION

The 'VYAPAR-E' mobile application and related web-based platform (collectively, the "Platform") are owned and operated by VASIST PROVIDERE PRIVATE LIMITED, a company incorporated under the Companies Act, 2013, having its registered office at No. 368, 14th Cross, Upper Palace Orchards, Bengaluru – 560 080, Karnataka, India ("Company", "we", "us", or "our"). The Platform enables users to digitally purchase gold and silver ("Precious Metals") and request physical delivery of such Precious Metals through authorised delivery partners. The Platform also offers ancillary features, including price tracking and portfolio management (collectively, the "Services").

This Data Privacy and Protection Policy ("Privacy Policy") sets out, in a clear and concise manner, how we collect, use, process, store, share, and protect information obtained from or about you when you access or use the Platform. You are advised to read this Privacy Policy carefully.

This Privacy Policy applies to all users and visitors of the Platform. By accessing or using the Platform through any computer, mobile phone, tablet or any other device (collectively, "Device"), you acknowledge that you have read, understood, and consent to the practices described in this Privacy Policy.

For the purposes of this Privacy Policy, references to "you" and "your" shall mean any user, visitor or any service provider who accesses or uses the Platform.

PERSONAL DATA WE MIGHT COLLECT FROM YOU

We may collect the following personally identifiable information, including but not limited to:

To authenticate the account, we may use the phone number and email address ("Contact Details") provided by you. We reserve the right to send you SMS, mails and other communications regarding your account and any activities carried out by you on the Platform under your account.

In order to authenticate and process any purchases made by you, we may collect the following financial personally identifiable information, including but not limited to:

Important: If Aadhaar-based e-KYC/ biometric is used for authentication purposes, it will be conducted only through a UIDAI approved KUA partner and the Company shall not collect your Aadhar number.

The financial information collected is required in order to authenticate the purchase, process the purchase and ensure payment for the purchase.

For the avoidance of doubt, we will NEVER collect any confidential financial details you may provide on our Platform. All payment information barring the aforesaid (i.e. billing name, address and payment method) will be obtained and processed by our online payment gateway partner and by our banking partner.

We may also collect information pertaining to:

We do not knowingly collect any personal data from persons below the age of 18 years. If we become aware that our database includes information of a user who is below the age of 18 years, we will promptly erase such information. We would propose that a parent or legal guardian of such persons register on the Platform and access the offerings on the Platform on behalf of such persons.

PURPOSE AND METHOD OF PROCESSING

Your personal data is processed with the purpose of ensuring smooth and efficient purchases on our Platform. This includes collecting your personally identifiable information, financial information in order to:

In addition to this we may use or processes your personal data or information provided by you to:

We shall ensure to handle your personal data with utmost care. The data will be processed in a protected manner and shall be in compliance with any applicable laws/standards.

STORAGE, SECURITY AND RETENTION

All personal data collected from you is stored on secure and encrypted digital infrastructure operated by reliable and reputed cloud service providers.

Personal data collected from you is retained for as long as needed for operational, legal and regulatory purposes. The personal data collected can only be accessed by authorised personal and service providers who require the information for carrying out their obligations and other relevant, legitimate business purposes.

In the event Your account remains inactive for a period as set out under applicable law, Company may provide you 48 hours' prior notice before the expiry of such period. You may, before the expiry of this notice period, log in to your account, contact Company for fulfilment of a specified purpose, or exercise any of your rights in relation to the processing of such personal data. In the absence of such communication from You, we shall erase Your data or retain as per applicable law.

Any purchase made through the account shall remain safe and in order to reactivate it, you may contact our Grievance Redressal Officer and follow the reactivation process as given, which may include but is not limited to re - submission of KYC information. We may retain your personal and financial information as required by the applicable law. We may erase your data as provided for by the applicable law.

YOUR RIGHTS

You may request access to your personal data, ask for corrections to inaccurate information, or request erasure of data that is no longer required for lawful purposes. Where processing is based on your consent, you may withdraw such consent at any time without affecting prior lawful processing, including consent to share location. However, certain services may not be enabled without such information/consent. You may also request account closure, raise concerns regarding data handling, or seek further information about your data stored with us by contacting our Grievance Officer, whose contact details are provided hereinbelow. We may undertake reasonable verification to confirm your identity before fulfilling such requests.

You may, in accordance with applicable law and the Terms of Use of the Company, nominate one or more individuals to exercise your rights on your behalf. Such nomination shall be made at the time of creation of Your account in the Platform and shall be subject to the procedures and particulars required by the Company for validating such nomination.

DATA SHARING WITH SERVICE PROVIDERS

We may share your data with service providers in order to fulfil purchases that are made through the Platform. This may include data of users such as name contact details, billing address and strictly necessary bank account details in order to fulfil the purchase of the Precious Metals.

Service providers may use such data solely to process the purchase of Precious Metals, deliver the Precious Metals, communicate with you to ensure coordination of delivery and completing the purchase transaction. Service providers are contractually bound to maintain confidentially, refrain from unauthorised use, misuse, disclosure of information and protect the data from any breach. They shall also comply with all applicable data protection obligations while handling the information.

Service providers are directed to strictly refrain from using user data for any promotional or independent business purpose unrelated to the activities carried out on our Platform. Any misuse or unauthorised access by a service provider shall be treated as a breach of the service provider's contracts and may result in suspension, termination or legal action, including action as per the applicable law.

In case you face issues with misuse or unauthorized use of your data by service providers, we urge you to promptly inform us of the same in order to take strict action and ensure compliance is maintained with applicable laws.

Once you are redirected or choose to access any of the service provider website, platform, service, or application (including those integrated into or accessible through the Platform), your access, usage, and data shall be governed solely by the terms, conditions, and privacy policies of such third party. The Company does not endorse, control, or assume any responsibility or liability for the content, data handling practices, or policies of such third parties.

DATA SHARING WITH THIRD PARTIES

We may share your data with trusted third parties such as payment processors, bank gateways, cloud providers, communication service partners, verification agencies and other partners who enable functioning of the Platform.

We shall take all the required steps to ensure that the third parties protect the personal data from unauthorised access, disclosure, misuse or alteration and further, have in place technical and organisational measures to protect the personal data.

Personal data collected from you will not be shared with any third parties who engage in the services of online advertising, including personalized emails, targeted advertisements and emails and other related activities.

GRIEVANCE MECHANISM

If a data breach occurs, which affects your personal data, you will be notified immediately with the necessary details as well as recommended steps to be taken. Where required, we will also notify the competent authority and ensure to take corrective action in order to prevent further recurrence and reduce impact of the breach.

For any concerns, complaints or requests regarding your personal data, you may contact our Grievance Redressal Officer ("GRO"). The contact details of the GRO are provided below. You may also contact our GRO for any questions or clarifications regarding collection, use, retention or processing of your personal data.

Grievance Redressal Officer (Contact Details)

Name: [To be specified]
Email: [To be specified]
Phone: [To be specified]
Address: [To be specified]

PROCESSING OF PERSONAL DATA OF PERSONS WITH DISABILITIES

Where consent is required on behalf of a person with disability who is unable to provide legally valid consent, the Platform may obtain verifiable consent from a lawful guardian. In such cases, the guardian must demonstrate legal authority, which may include verification through:

Persons with disabilities may withdraw consent at any time. Upon withdrawal, access to Platform features may be limited or disabled in accordance with operational and legal requirements.

UPDATES TO THE PRIVACY POLICY

We may amend or update this Privacy Policy at any time. Any revisions will be reflected in the "Version Date" displayed above. We encourage you to review this Policy periodically to remain informed of any changes. We will notify you of any material changes required by law, but we advise periodically checking the App for updates. Your continued use of the Platform after a revised Privacy Policy has been posted will constitute your acknowledgement and acceptance of the updated terms.

GOVERNING LAW

This Policy is governed by Indian law. Any disputes arising from or connected to this Policy shall be adjudicated by a court having competent jurisdiction in India.