PRIVACY POLICY

INTRODUCTION

Welcome to the Privacy Policy of IndiNXT. IndiNXT, having its registered office at Office No. 307, Tower 1, World Trade Center, Kharadi, Pune – 411014, Maharashtra, India (hereinafter referred to as "IndiNXT," "we," "us," or "our"), owns and manages its website(s) and related online platforms (collectively referred to as the "Platform" or "Website"). IndiNXT is engaged in the business of providing Unified Payments Interface (UPI) services through its advanced UPI Switch Platform, designed to cater to the evolving needs of digital banking by offering secure, seamless, and efficient payment solutions to its customers.

The term "User" or "Users" or "You" or "Your" means any individual or entity that uses, accesses, or browses the Website. At IndiNXT we are committed to safeguarding your personal information and ensuring your privacy. This Privacy Policy outlines how we collect, use, disclose, and protect your data when you interact with our website and use our services.

This document ("Privacy Policy") is an electronic record in terms of the (i) Information Technology Act, 2000; (ii) the rules framed thereunder as applicable; and (iii) the amended provisions pertaining to electronic records in various statutes as amended by the Information Technology Act, 2000. This electronic record is generated by a computer system and does not require any physical or digital signatures.

This Privacy Policy is published in accordance with the provisions of the Information Technology Act, 2000, and the rules made thereunder that require publishing the rules and regulations, privacy policy, and terms of use for access or usage of our Website https://www.indinxt.com/ (the "Website").

In order to provide you with access to use the website, we have to collect and otherwise process certain data about you. This Policy explains how we process and use personal data about you. We value your trust and strive to be transparent about our practices. By using our website or services, you agree to the collection and use of information in accordance with this policy, as may be amended from time to time by us at our discretion. You also agree and consent to us collecting, storing, processing, transferring, and sharing your personal information (including sensitive personal information) with third parties or service providers for the purposes set out in this Privacy Policy.

Please take a moment to review the details below to understand how we handle your information and what choices you have regarding your data, and give consent to the collection, use, disclosure, and/or retention of your personal information in accordance with the processing activities described under this policy.

BACKGROUND

This Privacy Policy applies to all individuals/entity who access or use the website or the end-users of the Website ("You"). We regularly review and update our Privacy Policy. It is important that the personal data that we hold about you is accurate. The Website may include links to third-party websites and applications ("Third Party Services"). Clicking on those links may allow third parties to collect and share data about you. We don't control these third-party Services, and we are not responsible for their privacy statements. When you leave the website or access third-party links through the Website, we encourage you to read the privacy policies of such third-party service providers.

YOUR INFORMATION BELONGS TO YOU

We carefully analyse what type of information we need to provide our services, and we try to limit the information we collect to only what we really need. Where possible, we destroy or anonymize this information when it's not relevant. In all of this work, our guiding principle is that your information belongs to you, and we aim to only use your information to your benefit.

COLLECTION OF PERSONAL INFORMATION

Type of Personal Information we collect

We collect certain categories of Personal Information directly from you, which you provide to us for the purpose of enabling and performing specific functions, including but not limited to:

• All users who access our website or services;
• Enquiring about our Services;
• Registration for our services on our website;
• upload your contacts, including access to mobile device contacts for certain services;
• communicate with us by phone, e-mail or otherwise;
• Any interaction, communication, or data exchange with IndiNXT.

As a result of the above-mentioned actions, you might share the following information with us:

• Identifying information such as your name, address, and phone numbers;
• Your Age;
• Your location information, including your mailing address;
• Identity information (such as PAN, Aadhaar, or other government-issued ID, where required).
• Employment, business, or professional details shared during consultancy engagements.
• Information provided through emails, forms, contracts, or other communications.

Information collected automatically and stored includes:

• the IP address, device's serial number (identifiers), browser type, operating system, access dates/time and unique identification number;
• email address and password;
• the location of your devices;
• phone numbers you used to call our customer service number;
• Information you voluntarily disclose that may reveal certain characteristics about you such as your racial or ethnic origin or sexual orientation;

THIS INFORMATION MAY INCLUDE, BUT IS NOT LIMITED TO, THE FOLLOWING

• Identification Information such as name, gender, current district, state or country location, contact information such as email address, mobile number;
• Details of the hardware and software that you are using to access the Websites such as your computer/device name, your operating system, browser type and version, application version, operator name, screen size, CPU speed, and connection speed;
• Usage Data, which includes information about how you use the Website, your activity on the Website, user taps and clicks, user interests, time spent on the Website, details about user journey, and page views.
• Additional Information relevant to your use of our websites and services, such as OTP for registration, where the relevant Service of the Website requires such information.
• We also collect, use, and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data under the law as it does not directly or indirectly reveal your identity. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data, which will be used in accordance with this Policy.

We take extra precautions to ensure that such personal information is kept secure and confidential, and we will only retain this information for as long as necessary for the purposes for which we collect it.

TO PROMOTE THE INDINXT BRAND, PRODUCTS, INITIATIVES, AND VALUES WITH MARKETING COMMUNICATIONS

IndiNXT has a strong legitimate interest in promoting its brand, products, initiatives and values. In order to further such goals, we process personal data about our business contacts, including existing and potential IndiNXT clients, third parties and intermediaries IndiNXT interact with in the course of doing business. IndiNXT may collect details about you including name, contact details and other information such as your job title, employer, areas of business interest and other business details. We may process such data using software or platforms which allow us to manage our client relationships. We collect such data directly or indirectly from you, or from third parties, such as business partners, data brokers, social networks, marketing companies, and publicly available sources such as social media sites where lawful to do so. In such cases, we will also comply with any additional restrictions imposed by the region in which your data was collected as well as the source of the data. IndiNXT may also collect data from our email and calendar systems concerning interactions between IndiNXT associates and contacts or third parties.

Your data is used by us in part for administering, managing and developing our business and services; such as identifying existing and potential client business needs, analysing and evaluating the strength of our interactions with certain business contacts, performing analytics including to produce metrics such as relationship maps for our business leadership and limited profiling for the purposes of helping us to develop and offer appropriate products and services to existing and potential clients. Analytics may be performed by us using algorithms which help us analyze and rank interactions with you depending on interaction frequency and duration. We may also send you marketing communications and surveys to carry out market research or provide information to you about us and our services which we have reason to believe would be of interest to you in your professional capacity.

When reaching out to you, we may do so through different channels, such as email, phone calls, post or any other means of communication such as through social media sites such as LinkedIn. We will only send electronic marketing communications to business contacts in a business-to-business context, where we have your prior consent or where it is otherwise lawful to do so in the jurisdiction you are located in. You can opt-out from receiving such communications at any time using the contact us form on https://www.indinxt.com/ or affiliate websites where you had given your personal data, writing to our Data Protection Officers or Head – Global Privacy Office (see section below) or by any other given method provided from time to time (for example: unsubscribe link included at the bottom of emails).

From time to time, we may use your name, quotes, pictures or videos to promote and amplify IndiNXT' brand and activities. In any such case, you will receive appropriate additional information about the usage of your personal data.

SUBSCRIPTIONS TO OUR PROMOTIONAL COMMUNICATIONS

If you sign up to receive marketing communications from IndiNXT, we may send these by email, post, telephone or any other means of communication. For information about managing your contact data, you may reach out to the contact details provided in the event privacy notice or in the emails you receive, or you may use the contact us form on the https://www.indinxt.com/ or affiliate websites where you had given your Personal data.

SOCIAL LISTENING

IndiNXT uses the services of a third party to monitor (primarily by keyword searches) and analyse statements, comments, opinions and similar interactions on social media channels about IndiNXT made by IndiNXT's customers, employees, followers, fans and others. IndiNXT has a legitimate interest to do so in order to identify and assess what is being said about our brand on social media, to understand sentiment, intent, mood, market trends and our stakeholders' needs, to improve our services and to protect our brand.

We may collect publicly accessible data from social media networks and websites, including

• user IDs
• social network profile names and information
• social network communications

HOW DO WE COLLECT PERSONAL DATA?

We use different methods to collect personal information from and about you, including through:

1. Direct Interaction: The personal information you provide when you:
   1. use our website or carry out other activities in connection with the Website or mobile application;
   2. Report a problem with the Website, give us feedback, or contact us.
2. Information we collect automatically: Each time you visit the Website, we automatically collect Technical Data about your equipment, browsing actions and patterns. We collect information using cookies and other similar technologies to help distinguish you from the other users of our website.
3. Information we receive about you from other sources: Sometimes you will have given your consent to other websites, services or third parties to provide information to us.
4. It could include information from the third parties that we work with to provide our products and services, such as delivery companies, technical support companies and advertising companies. Whenever we receive information about you from these third parties, we will only use it in such manner that is already communicated to you, as per this policy, and for defined purpose only.

WHAT IF YOU REFUSE TO SHARE YOUR INFORMATION?

Where we need to collect personal data under the terms of this policy and you fail to provide that data when requested, we may not be able to perform the contract (for example, to provide you full access with the Website). In this case, we may have to cancel or limit your access to the Website.

HOW DO WE USE YOUR PERSONAL INFORMATION?

We will only use your personal information when permitted by law. Most commonly, we will use your personal information where we need to provide you with access to the Website, or where we need to comply with a legal obligation. We may use your personal information outlined below, including but not limited to:

• To deliver updates and other relevant information.
• To deliver, operate, maintain, and enhance the consultancy and allied services offered by the Company.
• To perform obligations arising under agreements entered into with Users and to facilitate related business transactions.
• To establish and verify the identity of Users and to conduct due diligence measures, including Know Your Customer (KYC) and Anti-Money Laundering (AML) checks, where applicable.
• To understand how you use our website or services to enhance user experience.
• to help us identify you when you log into the Website and when you register an account with us and to map a specific profile with an authorized user;
• to personalize your browsing experience on the Website;
• for the performance of the contractual and legal obligations;
• to communicate with you;
• to provide and process service request initiated by you;
• Notification of any changes in the terms of use or privacy policy;
• To ensure compliance with applicable laws, statutes, regulations, legal processes, and lawful directives of governmental or judicial authorities.
• To prevent, detect, investigate, and address actual or suspected fraud, unauthorized access, data security incidents, or any other unlawful or prohibited activities.
• Resolution of any queries related to your use of Services.
• recommendations services, ad tech services, analytic services, including but not limited to click stream information, browser type, time and date, information about your interactions with advertisements and other content, including through the use of cookies, beacons, mobile ad identifiers, and similar technologies, in order to provide content, advertising, or functionality or to measure and analyse ad performance, on our Services or Websites and on third party websites.

We may further be required to share your personal information in certain exceptional circumstances, as follows;

• Required by the law, or in order to comply with the judicial proceedings, court order, or legal or regulatory proceedings.
• In connection with any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
• Necessary for the prevention or detection of crime, including exchanging information with the other companies or organizations for the purposes of the fraud protection.
• Necessary to protect the safety of our employees, our property, our company.

You agree and acknowledge that we may share data without your consent when it is required by law or by any court or government agency or authority to disclose such information. Such disclosures are made in good faith and belief that it is reasonably necessary to do so for enforcing this Policy or the Terms, or in order to comply with any applicable laws and regulations.

We may use and/or disclose your information with the Company-controlled businesses, affiliates, and other entities within our group companies.

You agree and acknowledge that by using our website and other features of the Website, you authorise us and our affiliates to contact you via email, phone, or otherwise. You ensure that you are aware of all the features of the Website.

YOUR RIGHTS OVER YOUR PERSONAL INFORMATION

We believe your rights over your information are crucial. Depending on how you use IndiNXT, you may have the right to request access to, correct, amend, delete, port, restrict or object to certain uses of your personal information. Please note that these rights apply only in certain circumstances and all these rights are limited by law.

If you are not satisfied with our responses to a request, you can contact us to resolve the issue.

• Right to Access: You can request to see the personal information a company holds about you. This means they should provide you with a copy of your data upon request.
• Right to Correct: If any of your personal information is inaccurate or incomplete, you can request corrections or updates to ensure it's accurate.
• Right to Deletion: You have the right to request the deletion of your personal data. This may not be absolute and could depend on the context or legal obligations, and contractual retention requirements.
• Right to Restrict Processing: You can ask a company to limit how it uses your personal data in certain situations. For instance, if you believe the data is inaccurate or you object to its use.
• Right to Object: You can object to the processing of your data for specific purposes, such as direct marketing or profiling.
• Right to Lodge a Complaint: If you believe your data is being mishandled or your rights are being violated, you can file a complaint with a relevant data protection authority or regulatory body.
• Right to Know the Purpose of Data Collection: You have the right to know why your data is being collected, how it will be used, and for how long it will be retained.

HOW DO WE PROTECT YOUR INFORMATION?

• We take commercially reasonable technical, physical, and organisational steps to safeguard any personal information you provide, to protect it from unauthorised access or alteration or misuse.
• We take reasonable security precautions, no transmission of information can ever be completely secure or error-free, and you should not expect that your information will remain private under all circumstances. We (the "Company") are not liable for any damages of any kind arising from the use of the Website, including, but not limited to, those incurred directly or indirectly, or any loss of data, use, goodwill, or other intangible losses.
• Our team works tirelessly to protect your information and to ensure the security and integrity of our website. We maintain physical, electronic, and procedural safeguards in connection with the collection, storage, processing, and disclosure of personal customer information. Our security procedures mean that we may occasionally request proof of identity before we disclose personal information to you.

WHAT CHOICE DO YOU HAVE?

• You can always choose not to provide certain information, but then you might not be able to take advantage of many of our services.
• If you do not want to receive e-mail or other communications from us, please adjust your Customer Communication Preferences.
• If you do not want to receive interest-based ads, please adjust your Advertising Preferences.
• The Help feature on most browsers and devices will tell you how to prevent your browser or device from accepting new cookies or other identifiers, how to have the browser notify you when you receive a new cookie or how to block cookies altogether. Because cookies and identifiers allow you to take advantage of some essential features of IndiNXT Services, we recommend that you leave them turned on.

COOKIES

Our website uses cookies and similar tracking technologies to enhance your browsing experience, analyse site usage, and serve targeted advertisements. To enable our systems to recognise your browser or device and to provide and improve IndiNXT Services, we use cookies and other identifiers.

ARE CHILDREN ALLOWED TO USE INDINXT SERVICES?

You must have attained the age of majority to be able to use or access our website. If you are a minor in your jurisdiction, your registration and use of our website must be under the supervision of an adult. As a parent or legal guardian, please do not allow your minors under your care to submit Personal Information to us. In the event that such Personal Information of a minor is disclosed to us, you hereby consent to the processing of the minor's Personal Information and accept and agree to be bound by this Privacy Policy and take responsibility for his or her actions.

However, if the Company is notified that the personal data of individuals below the age of majority has been collected by us, without user or parental consent, we shall take all necessary steps to delete such information from our servers. As a parent or legal guardian, you are encouraged to reach out to the Grievance Officer for redressal of any complaints in relation to the collection of children's data.

HOW LONG DO WE RETAIN YOUR INFORMATION?

We will retain your personal data only for as long as necessary to fulfil the purposes for which we have collected it. To determine the appropriate retention period, we consider the sensitivity of your personal information. For this reason, we process your personal information to determine whether we can achieve those purposes through other means and the applicable legal requirements. We will also retain and use your personal information to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our policies. If you stop using our services or if you delete your account with us, we will delete your information or store your information in an aggregated and anonymised format.

CHANGES OR UPDATES TO THE PRIVACY POLICY

ADVERTISING

Third-Party Advertiser: IndiNXT Service may include third-party advertising and links to other websites and apps. Third Party advertising partners may collect your information about you when you interact with their content and services.

Use of Third-Party Advertising Services: We provide information to the ad companies which allows them to serve you with more useful and relevant IndiNXT ads. We never share your name or other information that directly identifies you when we do this.

GOVERNING LAW AND JURISDICTION

This Privacy Policy shall be governed by and construed in accordance with the laws of India, without reference to conflict of laws principles. The courts in Pune shall have exclusive jurisdiction to determine any dispute arising in relation to, or under, the terms of this privacy policy. You agree to submit to the jurisdiction of the courts in Pune and agree to waive any and all objections to the exercise of jurisdiction over the parties by such courts.

GRIEVANCE OFFICER

The Name and the Contact details of the Grievance Officer are provided below:

Grievance Officers

Email ID: grievance@indiflyventures.com

HOW CAN YOU REACH US

If you want to make a request or complain about how we process your personal information. Please get in touch with IndiNXT Support or mail us.

IndiNXT Fintech Private Limited

Address: Office No. 412, Tower 2, World Trade Center (WTC), Kharadi, Pune, India - 411014

Attn: IndiNXT Support

Email Address: info@indinxt.com