THIS PRIVACY POLICY COMPLIES WITH THE REQUIREMENTS OF INDIAN LAW AND APPLIES TO PERSONS WHO ARE CITIZENS OF INDIA AND ARE RESIDENT IN INDIA OR ENTITIES WHICH ARE INCORPORATED IN INDIA. IF YOU ARE LOCATED IN ANY OTHER JURISDICTION AND DO NOT COMPLY WITH THE REQUIREMENTS SET OUT ABOVE. YOU MAY NOT SHARE PERSONAL INFORMATION OR USE THE SERVICES EXCEPT WITH THE PRIOR WRITTEN CONSENT OF THE COMPANY IN WRITING. This Privacy Policy (“Privacy Policy”) describes the use and processing of information by GROWSPACE DIGITAL ASSETS PVT LTD., a company incorporated under the laws of India with company registration number U74999RJ2022PTC079705 (“Company”) and also applies to its holding company, subsidiary company and group companies. This Privacy Policy applies to information Company collects when User use the website and other online products and services that link to this Privacy Policy. The Company is committed to ensuring that any use or sharing of your information with anyone shall be one only in accordance with the procedures described in this Privacy Policy. The capitalized terms used in this Privacy Policy, but not defined in this Privacy Policy, shall have the meaning given to such terms in the Terms of Services (defined hereinafter). Please read this Privacy Policy before using the site, the application or submitting any personal information. Where any person uses or accesses the Website of the Company or uses any products or services of the Company or otherwise provides any User Information (including information in relation to other persons) (“User”), the User consents to the collection and use of the information the User discloses on the Website or in the use of the services in accordance with this Privacy Policy, including but not limited to the User’s consent for collecting, using, sharing and disclosing information of the User as per this Privacy Policy. Please also note that the Privacy Policy will also apply to information of Users supplied by other Users. In case of information of Users supplied by other Users, the User providing the information confirms and warrants that the User has the authority to provide the necessary User Information. Other applicable terms This Privacy Policy is a part of and incorporated within, and is to be read along with the Terms of Service (the “Terms of Service”). Policy changes The Company may change and update this Privacy Policy from time to time. Such changes may be made without prior notice, but any changes will only apply to activities and information on a going forward and not retroactive basis, unless specified otherwise. The User are encouraged to review this Privacy Policy before accessing any services provided by the Company to make sure that the User understand how any personal information provided by the User will be used. Links to Third Party Websites The procedures and practices set forth in this Privacy Policy describe the use and disclosure of User Information collected by the Company. The application, website and/or other platforms of the Company, as available (“Products”) may contain links to other websites. Any personal information about the User collected which such User visits such websites is not governed by this Privacy Policy. The User is encouraged to exercise caution and review the privacy policies applicable to such websites before accessing them. The User acknowledges that the Company shall not be responsible for and has no control over the practices and content of any website accessed using the links contained on the Products. Competency to contract By agreeing to this Privacy Policy, a User (which such User is a natural Person) represents that the User is at least the age of majority i.e. 18 years, and is competent to contract. Additionally, where the User is registering on behalf of, and is the authorized representative of, a company, partnership or any other legal entity, such User has been duly authorized by such entity and is permitted under Applicable Laws to accept these Terms of Service. In case the User is a natural Person who is not of the age of majority or is not competent to contract, the User may not use the services of the Company, the Products or provide any information to the Company. Collection of information The Company collects two basic types of information from a User in conjunction with a User’s use of the Products i.e. personal information, which is any information that exclusively identifies a User (e.g., the User’s name, email address, telephone number, postal address amongst others) and non-personal information, which is information that does not exclusively identify a User but is related to you nonetheless such as, information about a User’s interests, demographics and use of the sites. The Company may also receive personal information regarding a User as shared by third parties who maybe our clients or otherwise avail service from the Company. Please note that in such instances the Company is acting on the instructions provided by such client or user and the Company does not separately verify the right of the client or user to provide User Information to the Company. In case you are not the intended recipient of the services and Products, you should contact the Company and at the earliest. Towards the provision of the services by the Company and the use of the Products, the Company shall in addition to the information described above, collect the following information from a User (“User Information”): Location Information about the location of the User’s device used to access the services from the Company. This is used for the provision of the services, pricing related information, for maintenance of records for audit purposes and other matters. Access information Passwords and other details required to access or use the services provided by the Company. Personal information Information about the name, email address, contact information and details of official documents. This is used for the provision of the services and for maintenance of records for audit purposes. Contacts Information of contacts and accounts information to detect references and accounts information to autofill data during a User’s requests for services. Other applications The User’s use of other software or applications which are linked or used in the provision of the services e.g. any third party sites though which a User may have accessed the services. Transaction information Transaction related information for transactions conducted by Users through the Services. Transaction information includes price, quantity, and any associated or supporting data related to the trade. Transaction information is used to provide the Services, facilitate the Transactions, provide support, and to operate, maintain and improve the Services. Billing Information To the extent permitted and required under applicable laws, billing and payment information of Users which may include a subscription number, an account number, credit card number, expiration date, billing zip code, bitcoin-related information, exchange market information, instructions for wire transfers. Automated collection Details of the User’s device, computer and device information, activity on the website, activity on the website and other similar information. The Company collects this information for analytics, improvement of the services and for review purposes. Others As may be explicitly required & requested from time to time. Usage of User Information User information will be used by the Company for the purposes which the Company considers necessary for achieving a seamless, efficient and safe experience, customized to a User’s needs and use the personal information to provide services to a User, enhance the operation of the Services and improve the Company’s marketing and promotional efforts. The processing of the User’s information is for the purposes of: to provide, maintain and enhance a User experience in relation to the application or the website; to provide and deliver the products and services requested by the User, process transaction, and send User related information including confirmations and invoices; to send technical notices, updates, security alerts, and support and administrative messages to the User; to take up and investigate any complaints/ claim/ disputes; to respond to your queries or feedback submitted by you; to monitor and analyze trends, usage, and activities in connection with the Services; to link or combine with information the Company receives from others to understand User’s needs and provide better service; to carry out any other purpose for which the information was collected; and to share the data such as back testing, user action and processed data for internal and external services with the third parties without User’s consent. Information collected by Cookies and other tracking technologies The Company and service provider shall use various technologies to collect information, including cookies and web beacons. Cookies are small data files typically stored on User’s computer’s hard drive or in device memory that help us improve our Services and User’s experience, see which areas and features of our Services are popular and count visits, manage the registration process for accounts, remember User’s site preferences, retain certain information to process orders for exchange transactions, and retain information to provide User with support. The Company also use cookies stored in emails to help us confirm User’s receipt of, and response to such emails. Web beacons are electronic images that may be used in Our Services or emails and help deliver cookies, count visits, and understand usage and campaign effectiveness. Information collected from cookies is used by us to evaluate the effectiveness of our site, analyse trends, see what difficulties our visitors may experience in accessing our site, and administer the platform. Storage of User Information User Information in the possession and control of the Company is stored in accordance with Applicable Laws. Storage and transfer of User Information is carried out in compliance with all Applicable Laws, including without limitation, the Information Technology Act, 2000 and the Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011. Please note that the Services have reasonable security measures, including as mentioned in Information Technology Act, 2000 in place to protect the loss or misuse of the User Information. Whenever a User’s changes or access the User’s account information, the Company offers the use of a secure server. However, the User acknowledges that transacting over the internet has inherent risks which can only be avoided by the User following reasonable security practices, such as not revealing account/login related information to any other person and informing the Company’s customer care team about any suspicious activity or where the User’s account has/may have been compromised. Please note that the Company does not guarantee that there will be no unintended disclosures of the User Information and data provided by a User on account of a data breach, unauthorized access, security failure etc. the Company cannot guarantee, give no warranties, and shall not be liable for breach of the security of User Information through the services of the Company due to malicious attacks, errors, commission or omissions not wilfully initiated by the Company and any transmission is at the risk of the User. Sharing and Disclosure of User Information User information shared with the Company shall not be shared or disclosed with any other user or third party except when the anonymous information is used for analysis and to make payment. The information can be disclosed if necessary in accordance with the applicable laws. User information shall be disclosed to external service providers such as payment providers, executors of the Services and/ or Google Analytics etc., to assist the Company in providing the Services or collating and analysing User information for making the Services more user-friendly. The payment and transaction details shall not be shared with other users or third parties under any circumstances. Retention of User Information The Company shall retain the personal information of the User as long as it serves the purpose(s) for which it was initially collected as stated in the Privacy Policy or subsequently authorized. The Company may continue processing User’s personal information for a period beyond such period only for the time and to the extent such processing reasonably serves the purposes of archiving, and subject to the protection of this Privacy Policy. After the expiry of this time period, the Company may either delete User’s personal information or retain it in a form such that it does not identify the User personally. Cryptographic Hashes User agrees and acknowledge that when User place the trading request on their Account in accordance with the Terms of Use, through the use of cryptographic hashes and keys, User take full responsibility for the risks involved. By using the Services, User automatically accept liability of any loss, damages or implications incurred or suffered. Communication policy When the User sets up an account or receives any request pursuant to the provision of the Services, the User is deemed to have opted in to receive emails and messages from the Company and its service providers in connection with the provision of the Services as well as any marketing and promotional agencies. While you may opt out of promotional messages, you cannot opt out of receiving certain administrative, financial, technical and legal information from the Company in connection with the services. Please refer to paragraph 8 above for the list of agencies with whom User Information is shared. Alteration of User Information In case the User requests any change or deletion of User Information of the User, or permanently delete the User’s, the User must contact the Company at investor@growspace.ai or contact the Data Protection and Grievance Officer. Do note that the Company is not obligated to alter or vary or delete any User Information which it is required to maintain under applicable laws or pursuant to contractual requirements of the Company. Cross border transfer and maintenance of User Information User Information may be required to be transferred or retained in locations other than the location of residence of the User. Such other countries may have differing (and potentially less stringent) laws relating to the degree of confidentiality and protection of the User Information. In case of any transfer of User Information, the Company will use best endeavors to put in place appropriate controls and safeguards to ensure that User Information is kept accurate, adequately protected, and processed only for specified and reasonable purposes in a manner that is fair, transparent and has a lawful basis, and is stored for no longer than is absolutely necessary. Data breach and disclosure notification In case of a data breach or an unauthorized disclosure of User Information which is likely to result in a high risk to the rights and freedoms of the User, unless the Company has appropriately mitigated the risk arising from such incident, the Company shall, within notify the affected Users of such breach with the details of the breach or incident, the consequences of such breach and the contact personnel of the Company in case of any queries by the User pertaining to such breach. In case any governmental or regulatory authority requires the Company to provide any User Information, unless specifically directors by the governmental or regulatory authority, the Company shall disclose to the User, the details of the request for the User Information. Contact details In case a User has any queries or any discrepancies / grievances with respect to the User Information provided by a User, please contact the Company’s Data Protection and Grievance Officer by writing at: Name: Ankit Rawat/Samder Singh Email: investor@growspace.ai Phone number: +91-87696-21346 Address: 161, Jaswant Nagar, Jaipur-302012, Rajasthan Updates to the Privacy Policy The Company reserves the right, at any time, to add to, change, update, or modify this Privacy Policy. The latest Privacy Policy will be available on this page.