Privacy Policy

This privacy policy ("Privacy Policy" or "Policy") sets out Neokred's practices in relation to the personal data that is collected on, though, or in relation to the cookie management solution, and/or consent management solution ("Offerings"), developed and offered by Neokred Technologies Private Limited ("Neokred", "us", "we" or "our").

At Neokred, we are committed to protecting your personal data and respecting your privacy. This Policy explains how we process and treat personal data when you use the Offerings and explains the rights that are available to you.

By using the Offerings, you confirm that you have read, accepted and consented to the terms of this Policy.

1. BACKGROUND AND KEY INFORMATION

(a) How this Policy applies:

In this Policy, our clients are referred to as "Clients". We process the personal data of individuals through the Offerings strictly on behalf of our Client's instructions. We will be considered data processors of our Clients with respect to any processing undertaken on behalf of our Clients in connection with the Offerings. Client process personal data in an independent capacity, and have their own privacy policies that we recommend you review.

In certain instances, we may process personal data in an independent capacity.

The terms "you", "yours", and "users" across this Policy collectively refer to end users of the Offerings.

By using the Offerings, you agree and consent to the collection, use, storage, disclosure, and sharing of your personal data as described and collected by us in accordance with this Policy.

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(b) Review and Updates:

We regularly review and update our Privacy Policy, and we request that you regularly review this Policy. It is also important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

2. DATA THAT WE COLLECT

(a) We collect different types of data, some of which is personally identifiable. We do this to ensure that the Offerings operate effectively and to provide users with a smooth functional experience. We have grouped the data collected as follows:

(i) User Data or Identity Data

Such as your name, username, or similar identifier.

(ii) Contact Data

Such as your email address and telephone numbers.

(iii) Demographic Data

Which includes your zip code and age.

(iv) Usage Data

Which includes how the Offerings are being used, for how long it is used, and when they are used.

(v) Technical Data

Including IP addresses, browser types and versions, time zone settings and locations, operating systems, and other technology on the devices you use to access the Offerings.

(b) We do not knowingly collect or process data of children, or any data about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, or any information about criminal convictions and offences.

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(c) What happens if you refuse to provide your personal data?

Where we need to collect personal data under applicable law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

3. HOW DO WE COLLECT DATA?

We use different methods to collect data from and about you including:

(a) Direct Interactions

We collect data directly from you if and when you provide it to us.

(b) Information through Clients

We may receive information about you from or through our Clients.

(c) Automatic technologies or interactions

As you use, interact with, and navigate the Offerings, we will automatically collect data about your usage patterns. We collect this data by using server logs and other similar technologies.

4. HOW DO WE USE YOUR PERSONAL DATA?

(a) We will only use your personal data when applicable law allows us to. Most commonly, we will use your personal data where we need to perform the contract we are about to enter into or have entered into with our Clients, where it is necessary for our legitimate interests (or those of a third party), or where we need to comply with a legal obligation. We use your personal data for the following purposes:

(i) To carry out our obligations arising from the relationship between us and our Clients, and/or to provide you with relevant information and services.

(ii) To manage our relationship with you, which will include notifying you about changes to this Policy or asking you to leave a review or take a survey.

(iii) To administer and protect our business and the Offerings (including troubleshooting, data analysis, testing, system maintenance, support, reporting, and hosting of data).

(iv) To use data analytics to enhance security and make improvements to the Offerings, Client relationships, and your experiences.

(v) To enforce our contract executed with the Clients, and other legal terms and policies.

(vi) To comply with applicable legal requirements, such as government regulations and industry standards, contracts, and law enforcement requests.

(b) Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by applicable law.

5. DISCLOSURES OF YOUR PERSONAL DATA

(a) We may share your personal data with the parties set out below for the purposes set out in Section 4 above.

(i) External third parties, such as:

• Service providers, including those that provide IT, system administration and cloud storage services
• Professional advisers, including lawyers, bankers, auditors, and insurers, who provide consultancy, banking, legal, insurance, and accounting services
• Regulators and other authorities

(ii) Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the manner set out in this Policy.

(b) We require all third parties to respect the security of your personal data and to treat it in accordance with applicable law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. COOKIES

(a) Cookies are small data files that are stored on your device. We use cookies and other tracking technologies to distinguish you from other clients and to remember your preferences. This helps us provide you with a good experience when you use the Offerings and also allows us to improve the Offerings.

(b) We identify you by way of using cookies. The cookies shall not provide access to data in your device, such as email addresses or any other data that can be traced to you personally. The data collected by way of cookies will allow us to provide you with a tailored and user-friendly experience. The cookies shall enable you to access certain features of the Offerings. Most devices can be set to notify you when you receive a cookie or prevent cookies from being sent. If you prevent cookies from being sent, it may limit the functionality that we can provide when you access our Offerings.

(c) Additionally, you may encounter cookies or other similar technologies on certain aspects of the Offering that are placed by third parties. We do not control the use of cookies by such third parties.

7. CROSS-BORDER TRANSFERS OF PERSONAL DATA

The personal data that we process may be transferred to or stored in countries other than where you are based. This may happen if any of our servers are from time to time located in a country other than the country you are based in. Where applicable law permits such transfer, we rely on consent to transfer such data.

8. DATA SECURITY

(a) We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

(b) We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

9. DATA RETENTION

(a) We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation with respect to our relationship with you.

(b) In some circumstances, we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

10. YOUR LEGAL RIGHTS

(a) Under certain circumstances and subject to applicable laws, you may have certain rights in respect of your personal data, such as the right to review and correct your personal data or revoke or deny consent.

(b) If you wish to exercise any of the rights set out above, please write an email to the Grievance Officer, whose details are mentioned in Section 11 of this Policy.

11. GRIEVANCE OFFICER

If you have any questions about this Policy, how we process or handle your personal data, or otherwise, you may reach out to us with your queries, grievances, feedback, and comments at rohitbadri@neokred.tech or contact our grievance officer, whose contact details are provided below:

Name: Rohit Badri
Email: rohitbadri@neokred.tech

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