Introduction

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Vananam Ventures Private Limited and Vananam Rewards Private Limited are dedicated to safeguarding your privacy when using our website and goods. In order to collect, utilise, and transmit Personal Data and Sensitive Personal Data for information we have about you, Vananam Ventures Private Limited and Vananam Rewards Private Limited have established this Privacy Policy ("Policy"). This Policy outlines the requirements to ensure compliance with the relevant data privacy laws and regulations.

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Vananam Ventures Private Limited and Vananam Rewards Private Limited (together referred to as "we," "us," or "our") manage this website. When you use our mobile application (the "App"), our website (the "Site"), and other online products and services that link to this Policy (collectively, the "Service"), we may gather information about you. This privacy policy (the "Policy") explains how we may collect, use, and disclose information about our users. In this policy, we refer to users as "User," "you," or "your," as well as "Potential Customers" to refer to people who are looking at our website or contacting us for more information about our services, "Customer Company" to refer to our corporate client, and "Employee User" to refer to specific employees of a Customer Company who use the App, the Site, and the Service through their employer.

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Your permission for our collection, use, and sharing of your personal information as set forth in this Policy is implied by your use of the Service. Being a global organisation, we respect the privacy of data subjects and are committed to complying with all applicable data privacy laws and legislation, including but not limited to the EU General Data Protection Regulation 2016/679 and the California Consumer Privacy Act/California Privacy Rights. Protecting the privacy rights of data subjects and safeguarding their Personal Data is now treated as a basic right of an individual and a legal requirement in many parts of the world, including under the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 and other privacy laws that may be relevant insofar as they affect Vananam Ventures Private Limited and Vananam Rewards Private Limited's data processing and business operations (collectively, the "Data Privacy Laws").

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We take your privacy seriously. If you have any questions about this Policy or about privacy at either entity, please contact us at [email address].

This privacy statement explains how we collect information, why we do it, what we do with it, and with whom we share it.

• How to access and update such information.
• The decisions you can make regarding how we gather, utilise, and distribute your information.
• How we safeguard the data we maintain about you.
• Without our express written consent, no party may aggregate or scrape any content, data, or other information from the website to be displayed alongside content from other websites or on a secondary site.
• If you access our Services through a third-party site, you may also be required to read and accept that site's terms of service and privacy policy.

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Definitions

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The following definitions provide details on some of the terms used in the Policy.

Personal Data

Personal data is any information about a Data Subject that can be connected or reasonably linked to a specific natural person. This could be anyone who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location information, an online identifier, or one or more factors specific to that natural person's physical, physiological, economic, cultural, or social identity.

Sensitive Personal Data

Described as any information revealing an identified or identifiable natural person's racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, or the processing of genetic information, biometric information for the purpose of uniquely identifying a natural person, data regarding health, or information concerning an individual's sex life or sexual orientation, and data relating to offences or criminal convictions.

In relation to residents of California, in addition to the aforementioned, the term also encompasses citizenship, national origin or ancestry, sexual orientation, sex (including gender, gender identity, and gender expression), pregnancy, childbirth, and medical conditions associated with the same, age, physical or mental disability, veteran status, and sex.

Process, Processes, Processed, or Processing

Any action, or series of actions, carried out on an individual's or an organisation's personal data, sensitive personal data, or sets of those data, whether or not automatically, such as gathering, organising, structuring, storing, retrieving, consulting, using, disclosing by transmission, disseminating, or otherwise making available, alignment or combination, restriction, erasure or destruction.

Consent

Any freely given, specific, informed, and unambiguous indication of the Data Subject's wishes by which the Processing of their Personal Data, Personal Information, and/or Sensitive Personal Data signifies agreement to the processing of their Personal Data, Personal Information, and/or Sensitive Personal Data through a statement or by a clear affirmative action.

Data Subject

Refers to a specific natural person, i.e., a named or distinguishable natural person to whom the personal data relates. A legal representative (parent or guardian) would represent the data subject in cases involving minors or people with mental impairments.

The term "Data Subject" used in this Policy refers to Vananam Ventures Private Limited and Vananam Rewards Private Limited's current and former employees, potential recruits, current, prospective, and former customers' personnel, current and former partners' and vendors' workers, website visitors, and subcontractors.

Vananam Ventures Private Limited and Vananam Rewards Private Limited do not collect Personal Data, Personal Information, or Sensitive Personal Information from Data Subjects who are under the age of 18. For the purpose of CCPA/CPRA, Data Subject shall include California residents.

Data Controller

This phrase refers to a person or entity that (alone, jointly, or in common) decides the reasons why and how any personal data will be processed. References to the Data Controller in this Policy shall, if applicable, include Vananam Ventures Private Limited and Vananam Rewards Private Limited and their respective affiliates.

Data Processor

A data processor is a person or business that handles personal data on the data controller's behalf and at the latter's directions.

Third Party

In relation to Personal Data, Personal Information, or Sensitive Personal Data, means any person other than the Data Subject, the Data Controller, or any Data Processor or other person authorised to process data for the Data Controller.

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‍Personal Information we collect and process and how we use it

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Information That We Obtain from the Client Company

We obtain the following details via our sign-up form from Customer Companies that express interest in our service: full name, email address, company name, and phone number. We gather this data through a landing page that a customer company with an interest can visit by filling out forms on various directory services listed by our third-party provider.

Personal Data We Collect from Employee Users

We collect human resource ("HR") information, and other information about Employee Users, from the Customer Company, and at the Customer Company's option, such as: full name, email address, phone number or any other information that may be required from time to time. This data is provided by the Customer Company's HR department directly or indirectly by allowing Vananam Ventures Private Limited and Vananam Rewards Private Limited to connect to customer systems such as HRMS or single sign-on systems, and is loaded and maintained in our system to allow for analytics.

We get employee opinions from Employee Users when they vote on surveys, participate in text discussions with peers, or otherwise interact with peers on the App, Site, or System. Votes and comments made by employees are associated with their authors. We use certain tracking information when a user visits our site. For tracking information, we make use of Google Analytics.

The following tracking information is collected: email address, device ID, and IP address. We collect your email address, IP addresses, and device information directly through inclusion of their SDK or pixel, or any other information which may be required from time to time. Tracking information is collected via the Site and our web applications, as well as via our iOS and Android implementations.

Payment Information

Your postal and email addresses may be included in the billing and financial information we gather if a third party is not paying for the service on your behalf. This information is needed to process your charges for Vananam Ventures Private Limited and Vananam Rewards Private Limited's services that require payment. When your transaction is handled by a different company, Vananam Ventures Private Limited and Vananam Rewards Private Limited may also obtain the invoicing and payment information you supply. Our Terms of Service outline the rules and conditions that apply to our fees and billing procedures. Please be aware that there might be additional rules if you open an account with a third-party payment processor.

Technical and Usage Information

We gather two types of usage data when you access our websites or use our services:

1. Specific technical information about your computer system or mobile device, such as your IP address and mobile device ID.
2. Usage statistics regarding your interactions with the Service. This data is often gathered and analysed via tracking technologies such as browser cookies, mobile device software development kits, server log files, or web log files (collectively referred to as "Log Files"). Your user ID number(s) are associated with some of the cookies that the Service stores on your computer.

Cookies and Automated Information Collection

We gather certain technical information when you use the Service in order to:

1. Analyse how our sites and services are used.
2. Give you a more customised experience.
3. Control reviews.
4. Provide the service.

You can limit the kinds of cookies you allow, or have your web browser warn you when someone tries to place one on your computer.

Other Sources

We may collect or receive information from other sources including third-party information providers. This information will be used to supplement your profile, primarily to help you and your contacts connect. It will be combined with other information we collect.

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How we use the information we collect

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In general, we collect, store, and use your information to provide you with a safe, smooth, efficient, and customised experience. For example, we may use information collected from you in any one or more of the following ways:

• Provide, maintain, and improve our Service.
• Provide and deliver the services that the Customer Company requests and configures, process transactions, and send you related information, including confirmations.
• Investigate system issues that impact our ability to provide the Service to users.
• Send you technical notices, updates, confirmations, security alerts, and support and administrative messages.
• Respond to your comments, questions, and requests and provide customer service.
• Communicate with Customer Companies about products, services, offers, promotions, rewards, and events offered by us and others, and provide news and information we think will be of interest to you.
• Monitor and analyse trends, usage, and activities in connection with our Service and improve and personalise the Service.
• Personalise and improve the Service, content, or features that match user profiles or interests.
• Link or combine with information we get from others to help understand your needs and provide you with better service.
• Connect you with other users in your contacts.

Vananam Ventures Private Limited and Vananam Rewards Private Limited will not sell, rent, or share Personal Data with third parties outside of our companies without your consent, except in the following ways.

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Law Enforcement and Internal Operations

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Third – parties

1. To respond to claims asserted against us or to comply with the legal process (for example, discovery requests, subpoenas, or warrants).
2. To enforce or administer our policies and agreements with users.
3. For fraud prevention, risk assessment, investigation, customer support, product development, and de-bugging purposes.
4. To protect the rights, property, or safety of our companies, our users, or members of the general public.
5. We will use commercially reasonable efforts to notify users about law enforcement or court-ordered requests for data unless otherwise prohibited by law.
6. Nothing in this Privacy Policy is intended to limit any legal defences or objections that you may have to any third-party request to compel disclosure of your information.

We occasionally hire other firms and individuals to execute operations or services on our behalf, such as software maintenance, data hosting, email message delivery, and so on. We are compelled to disclose your Personal Data with third parties in order for them to execute their functions. We take the appropriate precautions to guarantee that these third parties take your privacy as seriously as we do, such as engaging into Data Processing Addendum(s), EU Model Clauses, and/or ensuring these third-parties have EU-US and Swiss-US Privacy Shield certification.

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Data Recipients, Transfer, and Disclosure of Personal Information

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Vananam Ventures Private Limited and Vananam Rewards Private Limited do not share your Personal Information with third parties for their direct marketing purposes.

If required by law, or if we have a good-faith belief that using or disclosing your Personal Information is necessary to defend our rights, ensure your safety or the safety of others, carry out an investigation of potential fraud, or otherwise comply with the law, court order, or legal process, we retain the right to do so.

Business Transfer

In the case of a merger, acquisition, reorganisation, sale of assets, or bankruptcy, Vananam Ventures Private Limited and Vananam Rewards Private Limited may sell, transfer, or otherwise distribute all of their assets, including your personal information. In such cases, Vananam Ventures Private Limited and Vananam Rewards Private Limited will make commercially reasonable attempts to warn their users if their personal information is to be shared, transferred, and/or subject to a new privacy policy.

Third Parties

We occasionally engage other firms and individuals to execute operations or services on our behalf, such as software maintenance, data hosting, email message delivery, and so on. We may be required to disclose your Personal Data with third parties in order for them to execute their functions. We take appropriate precautions to guarantee that these third parties take your privacy as seriously as we do, such as entering into Data Processing Addendums, EU Model Clauses, and/or ensuring these third parties hold EU-US and Swiss-US Privacy Shield certification.

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How Is My Data Protected?

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To protect your personal information from unauthorised access, deletion, or alteration, we have implemented appropriate administrative, technological, and physical security measures, including:

• SSL encryption (HTTPS) while dealing with personal data. Personal data is encrypted in transit and at rest using HTTPS/SSL/TLS.
• Our database is encrypted, and everything sent over SFTP is protected using PGP.
• Password security for your account.
• Changing the verification codes that some parties use to gain access.
• Data is stored on safe, encrypted servers.
• Limiting staff access to Personal Data, which is safeguarded by password logs and two-factor authentication.
• Non-disclosure agreements with vendors.
• Consistent privacy and security training for employees.

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Retention and Disposal of Personal Data or Personal Information

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1. User data: 7 years from the date of termination of contract.
2. Employee data: 8 years as per the Indian Companies Act.
3. Financial data: 8 years as per the Indian Companies Act.
4. Audit logs: 1 year.
5. Other records: 3 years.

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Children's Personal Information

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We do not knowingly collect any personal data from minors under the age of 16. Please do not submit any personal information through our websites or services if you are under the age of 16.

In order to help implement this Policy, we encourage parents and other responsible adults to monitor how their children use the internet and to teach them not to submit any personal data to the websites or services without their consent. Please contact us at [email address] if you have reason to suspect that a child under the age of 16 has supplied personal information to us through the websites or services, and we will make commercially reasonable steps to have that information removed.

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Your Rights in Relation to Your Information

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• Access: You have the right to access information about the personal data we hold about you.
• Right to be informed about the data that we collect, process, and store.
• Right to object to processing: You have the right to object to processing of your personal data.
• Rectification: You have the right to request rectification of inaccurate personal data held about you.
• Erasure: To the extent permitted by applicable data protection laws, you have the right to request erasure of personal data held about you.
• Request to restrict processing: This enables you to request that the processing of your personal data be restricted in certain circumstances.
• Rights in relation to automated decision-making, including profiling.
• Portability: You have the right to obtain your personal data in order to reuse it.
• To exercise any of these rights, please email us at [email address].

You have the right to request certain information about our collection and use of your Personal Data over the past 12 months. We will provide you with the following information:

1. The categories of Personal Data that we have collected about you.
2. The categories of sources from which that Personal Data was collected.
3. The business or commercial purpose for collecting or selling your Personal Data.
4. The categories of third parties with whom we have shared your Personal Data.
5. The specific pieces of Personal Data that we have collected about you.

If we have disclosed your Personal Data for a business purpose over the past 12 months, we will identify the categories of Personal Data shared with each category of third-party recipient as per CCPA/CPRA.

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Exercising Your Rights

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To exercise the rights outlined above, you must submit a request to us that: (1) provides enough detail for us to confirm that you are the person about whom we have obtained Personal Data, and (2) clearly expresses your request so that we can comprehend, consider, and respond to it. Every request that satisfies both of these requirements is regarded as a "Valid Request." Requests that do not meet these requirements may not receive a response. We will only utilise the Personal Data you submit in a Valid Request to authenticate you and complete your request.

You may submit a Valid Request by emailing [email address].

You may also authorise an agent (an "Authorised Agent") to exercise your rights on your behalf. To do this, you must provide your Authorised Agent with written permission, and we may request a copy of this written permission from your Authorised Agent when they make a request to exercise your rights on your behalf.

We will not discriminate against you for exercising your rights under the CCPA/CPRA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights. However, we may offer different tiers of our services as allowed by applicable data privacy laws (including the CCPA/CPRA) with varying prices, rates, or levels of quality related to the value of Personal Data that we receive from you.

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Complaints and Grievances

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Any complaints or grievances received about our use of Personal Data, Personal Information, or Sensitive Personal Data, and any communications regarding enforcement of your privacy rights, should be directed promptly to our Data Protection Officer.

Contact: Data Protection Officer

Email: support@therewardstore.com

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Updates to Our Policy

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Vananam Ventures Private Limited and Vananam Rewards Private Limited may amend or update this Privacy Policy. We will provide you with notice of amendments to this Privacy Policy, as appropriate, and update the "Last updated" date at the top of this Privacy Policy. Please review our Privacy Policy from time to time.