Privacy Policy

1.1 Company & Commitment

We, Krypsm Private Limited, a company registered under the laws of India, with office located at 1st Floor, M Dange Caterers, In front of Neelam Mess, LIT Road, Ram Nagar, Nagpur, Maharashtra – 440010, India (hereinafter referred to as the “Company”, “Krypsm”, “We”, “Us” or “Our”) are committed to protecting privacy of Our users and grant importance to the confidentiality of user data provided over the internet.

1.2 Legal Framework & Electronic Record

This privacy policy ("Privacy Policy") is an electronic record in the form of an electronic contract formed under the Information Technology Act, 2000 and is published in accordance with the relevant provisions of Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021 and the Information Technology (Reasonable Security Practices & Procedures & Sensitive Personal Data or Information) Rules, 2011 (hereinafter referred to as the "SPDI Rules") which collectively mandate organizations to publish a privacy policy to provide for relevant information pertaining to collection, use, storage, transfer/disclosure of Personal Information (as defined hereinafter). This Privacy Policy does not require any physical, electronic or digital signature and is a legally binding document between the User and Us.

1.3 Applicability & Platform Definition

The Privacy Policy together with other relevant terms available on Our Platform including the terms and conditions published on the Platform ("Terms") and other agreements between the user and the Company (as may be applicable) is applicable to the Users of the Platform (hereinafter also referred to as "You", "Your", "Yourself"). It is clarified that a reference to the term 'Platform' in this Privacy Policy shall mean collectively Our website located at https://www.krypsm.com and the associated mobile application(s) where We provide Services (as defined herein).

1.4 Scope of Policy & Agreement

This Privacy Policy governs and sets forth the understanding in relation to the collection, usage, processing, storage, and disclosure of information that You may provide to Us electronically in connection with Your use or access of any of the services and facilities made available by Us on the Platform (the "Services"). The User acknowledges that this Privacy Policy, Terms and such other policies as may be framed by Us from time to time (as available at Our Platform) together form Our collective agreement ("Agreement") with the User in relation to Your use of the Platform and the Services.

1.5 Information Collection Overview

Krypsm collects various types of information from Users (collectively, the "Information Collected" as further defined hereinafter) such as Personal Information including Sensitive Personal Information (as defined hereinafter) and User Data (as defined hereinafter) from the User during and as a result of Your use of the Platform, including at the time of setting up of Your virtual User account with Us, at the time You successfully register on the Platform ("Account") or You browse and access Our Platform and Services. We collect and process the Information Collected in the aforementioned manner subject to the Privacy Policy and User's consent for the purposes mentioned in this Privacy Policy.

1.6 User Consent & Indemnity

By visiting or using Our Platform and/or Services in any manner, You acknowledge and accept the practices and policies outlined in this Privacy Policy and hereby consent to Our collection and processing of Information Collected (as elaborated hereinafter) in accordance with the terms herein and the Agreement. You further acknowledge and accept that You are lawfully authorized to provide Your information to Us and have the legal capacity to do so and to give Your legal consent for the collection and processing of such information by Us. You further agree that such collection and processing of Your Information Collected in accordance with this Privacy Policy shall not cause any loss to any other person. You acknowledge that anything done, caused to be done, whether expressly or impliedly in contravention of this Privacy Policy may render You liable for legal action. We shall not be held liable in any manner whatsoever if there is any error or deficiency by Us in Our business transaction with You due to any information You provide Us which is incorrect or provided in a manner contrary to this Privacy Policy or due to any withdrawal of Your consent. You acknowledge and agree to indemnify and hold Us and/or Our employees, consultants, directors, representatives and/or associates, etc. harmless from any complaints, legal proceedings or claims filed or initiated by any third party against Us due to any breach by You of the terms of this Privacy Policy through any act or omission attributable to You.

1.7 Business Purpose & Usage Stance

The Information Collected (including Your Personal Information and Sensitive Personal Information, as may be applicable) is collected and processed by Us strictly in line with Our business purposes and to provide You with useful features, including for provision and enhancement of Services, the operation of the Platform and to respond to Your requests/queries in an efficient manner. If You do not agree to such use of Your information, please do not use this Platform and/or Services provided by Us. If You proceed to use this Platform and/or Services provided by Us, You hereby consent to Our collection and processing of Your Information Collected in the manner described in this Privacy Policy.

1.8 Definition of Personal Information

For the purpose of this Privacy Policy, any reference to the term "Personal Information" shall mean the Personal Information or data of a User available with Us in electronic form (as elaborated below) and includes information through which a User is capable of being identified, whether directly or indirectly (in combination with other information available or likely to be available with Us in electronic form). Personal Information will not include anonymized information that has been appropriately processed to make it non-identifiable in order to irreversibly prevent its identification.

1.9 Definition of Sensitive Personal Information

Further, for the purpose of this Privacy Policy, any reference to the term "Sensitive Personal Information" shall refer to the specific Personal Information of a User (as available with Us in electronic form) which qualifies as "sensitive personal information and data" in terms of the SPDI Rules. For reference, per the SPDI Rules, "sensitive personal information and data" includes Personal Information which falls in the following categories: Passwords; Financial information such as bank account or credit card or debit card or other payment details; Physical, psychological and mental health conditions; Sexual orientation; Medical records and history; Biometric information. Users should note that We may collect and process certain Sensitive Personal Information (as elaborated below) of Users of the Platform, with consent from relevant Users and for certain purposes (as elaborated below) in relation to and for the purpose of the Services in accordance with the Agreement.

1.10 User Eligibility & Adult Residency

It is clarified that reference(s) to the terms "User(s)", "You", "Your", "Yourself" herein shall mean an adult individual (above the age of eighteen years) resident in India, who has validly signed up/registered on the Platform for availing any of the Services provided by the Platform and/or has access to/use the features and functionalities of the Platform and who in connection with the Platform and the Services may access or avail, share, transact, view, display, download or upload any of the Information Collected on the Platform.

1.11 Protection of Minors

For the avoidance of doubt, subject to the Terms, Krypsm does not provide Services to any individuals below the age of eighteen years ("Minors"). Krypsm shall never knowingly seek Personal Information (including Sensitive Personal Information) from a person who has not attained the age of majority under applicable laws. If You are a parent or guardian having lawful custody of a Minor and are aware that the Minor in Your care has provided Us with any such information, without Your knowledge and consent, We request You to contact Our Grievance Officer in the manner provided in this Privacy Policy. If We become aware that We have collected any Personal Information from Minors in contravention of terms herein, We will take appropriate steps to remove that information from Our servers and/or to deactivate the relevant Account (if any) associated with such persons as soon as reasonably practicable.

1.12 Business Partners

It is clarified that reference(s) to "Business Partner(s)" in this Privacy Policy shall mean the natural and legal person(s) with which Krypsm has a business arrangement or collaboration under a definitive agreement, in relation to the functioning of the Platform and its Services, such as for facilitating, providing and/or delivering certain functionalities on the Platform including any features or aspects of any Services provided to User(s) on the Platform, as further elaborated in the Terms. Principally, Our Business Partners include Our qualified identity verification and Know-Your Customer (KYC) compliance partner one, Signzy Technologies & Services Inc ("Signzy") and Zigram Data Technologies Private Limited, (Zigram) for AML, along with registered payment processing partners, security and information technology vendors.

1.13 AML Policy Reference

It is clarified further that references to "AML Policy" in this Privacy Policy shall mean the consolidated Anti-Money Laundering ("AML") / Know Your Customer ("KYC") / Combating Financing of Terrorism (CFT) Policy maintained by Krypsm with respect to the Services.

1.14 Additional Terms Reference

For further information concerning Krypsm and Our Services, Users are encouraged to refer to the Terms published on the Platform.

2.1 Jurisdiction & Cross-Border Processing

Users should note that the Information Collected including Personal Information shared with the Company shall be primarily processed in India but may be processed in such other jurisdictions where a third-party engaged by the Company or its Business Partner(s) (as defined in the Terms) may process the data on the Company’s behalf in accordance with applicable laws. You acknowledge and accept that data protection regulations in India or such other jurisdictions mentioned above may differ from those of Your country of residence. However, We will on a commercially reasonable basis require Our Business Partners and any other third-parties We engage and license to process the Information Collected that they adopt reasonable security standards to safeguard Your information/data in accordance with this Privacy Policy equivalent to the security standards maintained by Us under applicable laws.

2.2 Explicit User Consent

By agreeing to this Privacy Policy, You provide the Company with Your explicit consent to collect, share and process Your Information Collected for the purpose(s) defined in this Privacy Policy. In case You have any concerns in the processing of Your Personal Information (including Your Sensitive Personal Information), please reach out to Our Grievance Officer in the manner specified in Section 10 of this Privacy Policy.

3.1 Collection Modes

In the course of providing Services to You through the Platform and through Your use of the Platform, You acknowledge and accept that We may collect User Data, Personal Information, Sensitive Personal Information and other types of information listed herein below (collectively, the "Information Collected") from the User in the following ways: (i) as information supplied by User via the Platform; (ii) as information automatically tracked during Users navigation on the Platform; and/or (iii) as communicated directly to Us via e-mail or other electronic mode. You consent to Our collection and processing of that information.

3.2 Personal Information

We may collect Personal Information such as Your name, date of birth, contact information (such as Your mobile phone number and e-mail or both) and other identity and KYC details (including in relation to Your Aadhaar, PAN or other official Government ID Document or live photo etc.) at the time of Your registration on the Platform or at any time during the process You avail the Services. This type of information is primarily used for the purpose of creation of Your User account ("Account") with Us for the Services, to assess Your eligibility for the services and to provide You with the Services on the Platform. We principally use such information for KYC purposes to verify Your identity in accordance with applicable KYC and AML laws and regulations in India.

We may further collect Personal Information such as select contact data, or files or SMS messages (such as OTPs) (to the extent required for the Services) as available on Your device, during the provision of Services, upon taking Your prior consent to access such data. We collect such information strictly to facilitate the provision of the Services (such as by verifying messages on Your device), for related KYC purposes and to enhance Your experience on the Platform. This type of information is primarily processed for the purpose of offering You the Services through Our Business Partner(s) as well as to assess Your eligibility for the Services, to maintain security and operation of Our Platform along with Our analytics, risk assessment and reporting purposes.

3.3 Sensitive Personal Information

Users should note that the Personal Information which We access and process about You, in collaboration with Our Business Partners, on the Platform for the purpose of the Services may include certain Sensitive Personal Information. Principally, please note that We along with Our Business Partners (including Signzy and Zigram) may collect and process identity and KYC details such as Your Aadhaar card and/or other official identification document(s) ("ID") along with associated data (such as User's legal name, date of birth, expiry date of Your provided ID and details of issuing country/authority of said ID) for the purpose of KYC or identity verification as well as AML compliance screening at the time You apply for Our Services in line with applicable laws in India. Access to some Sensitive Personal Information may be also provided to Us by relevant Business Partners (engaged for AML and KYC screening) together with the results of the AML/sanctions and KYC screening conducted by Our Business Partners by processing such information (which may include information about Your PEP status, AML screening timestamp, screening reference ID etc). Krypsm may access and process the aforementioned information for the purpose of processing Your request for any of the Services made available on the Platform and delivering Services in accordance with terms herein.

We may also collect and process Your occupation and salary details, including but not limited to proof of income, current employment status and any further information as may be reasonably required for verification and client due diligence procedures as prescribed under applicable laws in India. In addition, We may collect and process Your financial information (such as bank account details) to enable payment requests at the time You apply for Our Services on the Platform or initiate transactions in connection with the Services, delivering Our Services, managing Your Account, in line with applicable laws in India. It is clarified that Your Sensitive Personal Information is processed by Us solely and strictly to verify Your identity and accuracy of any subscriptions associated with Your Account, and to determine Your eligibility for availing Services (including by verifying that Your ID is not expired and Your information is updated) and for offering such Services. We also process such information for the purpose of carrying out legal compliance (including without limitation mandatory AML compliance, sanctions screening and reporting processes) along with Our administrative, risk assessment, monitoring and reporting purposes (such as by maintaining an internal risk-score for users, tracking suspicious transactions, screening for safety etc.). You agree and acknowledge that We may access, store and retain such Personal Information (including Sensitive Personal information) in line with requirements under applicable laws and regulations in India and process this for the aforementioned purposes.

We do not collect or process Your Sensitive Personal Information except as expressly provided herein. Please note that applicable Business Partners (if any) that the Company engages for payment processing services or payment aggregator services may also collect and process certain Personal Information (including Sensitive Personal Information such as payments information) that You choose to provide for the purpose of facilitating payment transactions initiated by User in connection with the Services on the Platform. Users should note that such information (as You may provide to any relevant Business Partners) will be processed by Our Business Partners subject to third-party terms and policies independently maintained by them, which will be applicable to the User in addition to these Terms and Privacy Policy. In providing such information, User understands, acknowledges and agrees to be bound by such applicable terms and policies maintained by Our Business Partners.

3.4 Retention Principles

It is clarified that Your Personal Information is not retained or stored by Us except to the extent expressly specified in this Policy and only as required for Our business operation or compliance with applicable laws. We retain only the relevant portion of Personal Information of Users as is necessary for Us to carry out Our business operation, including to facilitate the Services and fulfill the purposes set out herein, in accordance with applicable laws and this Privacy Policy. For further information regarding how We store and secure Your information, please refer to Section 7 of the Privacy Policy.

3.5 User Data & Technical Identifiers

We may collect information and technical data about Your hardware devices with Your permission automatically when You access or register on the Platform. For example, when You utilize Our Platform, We may collect technical data and information about the type of mobile device/computer/laptop You use, the browser You use, Your IP address and Your geographic region/location. We may also collect select information about Your activity on the Platform such as information relating to Your Account (such as its creation date and status – verified/pending/restricted) and Your usage of Our Platform (including wallet and blockchain identifiers, wallet address, transaction hashes if initiated/permitted) as well as information about how You interact with the Platform (collectively, "User Data"). We may combine this User Data with other information, including Personal Information We have collected about You for maintenance and/or recovery of Your Account, in order to provide or enhance the Services and to offer features and functionalities on the Platform, including to fetch wallet information (relating to Your balances or tokens) and to maintain record of all transactions from/to Your wallet through Our Platform.

3.6 Communications

We collect communications exchanged between You and the Company and related information (such as contact details associated with such communication) as well as any forms, files, data or information or documents You send to Company or share on the Platform in connection with the Services in accordance with the Terms. Further, if the User communicates with Us, for example, via e-mail, registers with Us or provides feedback or grievances to Us in accordance with the Terms, any information provided in such communication by User may be collected by Us for the purpose of responding to the User, resolving Your queries and rendering Services and/or offering use of the Platform. We collect and process information that You upload to, or choose to share through, Our Services and/or Platform strictly for the purpose of offering Services in accordance with the Terms.

3.7 Non-Disclosure & Security Stance

We use the Information Collected (including the Personal Information and the Sensitive Personal Information) for the Platform and Services in the manner mentioned in the Privacy Policy. Except for the disclosures mentioned to be made in the Privacy Policy, We do not disclose or share Your Personal Information and Sensitive Personal Information in any manner. We do not publicly publish Your Sensitive Personal Information in any way.

3.8 User Responsibility & Authenticity

You acknowledge and accept that We are not responsible for the authenticity of any Information Collected, including the Personal Information and Sensitive Personal Information that You provide to Us. You are solely and exclusively responsible for providing Us with information about Yourself that is true, authentic, and correct in all aspects and particulars. If You provide inaccurate or false information to Us, You shall be liable to indemnify and hold harmless the Company (and its officers, directors, contractors or agents and any third party relying on the information provided by You) in the event You are in breach of this Privacy Policy.

3.9 Correction, Update and Amendment of Information Collected

You shall have the sole responsibility to intimate Us and request correction of inaccurate Personal Information maintained by the Company about You. You may intimate Us in this regard by reaching out to Our support team via the following email address: [email protected]. Upon receipt of a verifiable request from You, We will use commercially reasonable efforts to correct the inaccurate Personal Information taking into account the nature of the information and the purposes of the processing and in accordance with applicable laws and regulations.

4.1 Data Server Transmission

While We have implemented commercially reasonable physical, managerial, operational and technical security measures (as detailed herein below) to protect against the loss, misuse and alteration and to preserve the security of the Personal Information (including Sensitive Personal Information) in Our care, the User acknowledges and accepts that Information Collected on the Platform may be transmitted to third-party data servers for the purposes mentioned herein below and processed subject to the terms and policies of such data server.

4.2 Transmission to Business Partners & Authorities

We transmit certain Information Collected, including select Personal Information, with Our Business Partners in the manner and for the purposes elaborated hereinafter in Section 5. Principally, We and Our Business Partners may share and process User’s KYC and other identification details to the extent required to facilitate transactions on the Platform or maintain Your subscription for Our Services. Where required, We may share Personal Information (including Sensitive Personal Information such as financial details with law enforcement agencies and financial regulators) in accordance with terms herein.

4.3 Parity of Security Safeguards

You acknowledge and accept that We may disclose Your information as We may deem necessary by sharing such information with Our Business Partners who are responsible for fulfilling facilities and payments requested by Users in connection with Services on the Platform, in the manner elaborated herein. It is clarified that any transfer or disclosure of Your Personal Information to other third parties in the manner mentioned herein will only be done by Krypsm upon ensuring the relevant third party receiving such information has implemented an equivalent or higher level of security practices as We have in the manner mentioned herein in accordance with statutory requirements.

4.4 Lawful Disclosures & Statutory Mandates

Other than as specifically stated in this Privacy Policy, We will only disclose Your Personal Information in the event it is required to do so by applicable law, rule, regulation, law enforcement agency, governmental official, legal authority or similar requirements applicable to Us or if We, per Our sole discretion, deem it necessary in order to protect Our rights or the rights, property or personal safety of others; respond to claims, to prevent harm to persons or property, to fight fraud and credit risk, or to enforce or apply the Privacy Policy or Agreement, as and when deemed necessary. All transfers or disclosure of Your information pursuant to this Privacy Policy and the Agreement will be undertaken for lawful purposes only.

5.1 Purposes of Processing

We may use and process the Information Collected including Your Personal Information, Sensitive Personal Information and User Data along with other information as shared and allowed to be stored by You along with the information as available in or linked with Your Account (such as Your transaction history) to facilitate Your use of Our Services and to enable You to complete Your transactions on the Platform expeditiously. In particular, We (and Our Business Partners including third-party data processors, vendors and hosting partners who may be engaged and authorized by Us and acting on Our behalf) may collect, store and process Information Collected for the following reason(s):

• To register the User, create Your Account and send verification message(s) or email(s);
• For promotional activity, such as promotional messages, notices and/or offering of periodic rewards or offers;
• To render the Services and facilitate associated functionalities and transactions for User(s) through Our Business Partners;
• To operate and improve Our coaching and educational facility, the "Krypsm Coach" as part of the Services on the Platform, including for tracking course progress, learning history, and performance assessment;
• To send confirmations and exchange communication regarding Services, in collaboration with Our Business Partner, including via SMS or other messaging service as may be applicable including sending any updates or changes thereto;
• To allow Our customer service to contact You, if necessary;
• To request for feedback or reviews of Our Platform and/or Services or any other improvements thereto;
• To validate/authenticate Your Account and to prevent any misuse;
• To analyze data about Our Users' activity on Our Platform;
• To help diagnose problems with Our data server, and to administer Our Platform;
• For responding to the judicial process and providing information to law enforcement agencies or any government agency in connection with a query/investigation on matters as permitted by law;
• To allow third parties to contact with You in relation to Services availed/requested by You on Our Platform (for the purposes defined in this Privacy Policy or the Terms) or through third party links;
• To identify security breaches and attacks, investigating, preventing and taking action on illegal or suspected fraud or money laundering activities and conducting forensic audits as part of internal or external audit or investigation by Us or government agencies located within India or outside jurisdictions;
• For sharing, disclosing and transfer of data in case of any major event such as merger, acquisition, sale or transfer of assets in case of any force majeure event to any third party with prior intimation to You;
• For data processing, statistical or risk analysis and for analytics and review for improvement of the Services;
• For maintaining records and documentation in compliance with applicable laws;
• For designing and marketing Our Services and the Company’s business;
• To resolve disputes; troubleshoot problems; help promote a safe service; collect payment; measure consumer interest in Our products and services or detect and protect Us against error, fraud and other criminal activity; enforce Our Terms and the Agreement; and as otherwise described to You at the time of collection as part of the Agreement.

5.2 Operational, Customization & Legal Reasons

Further, We may use, store and process the Information Collected for the following reason(s):

• For fulfillment of the Services, including to make the Services of this Platform customized; to provide Services tailored to individual requirements; to understand Your needs and provide You with improved Services;
• To maintain any registered Accounts that You may hold with Us and to provide You with updates or notifications of changes to Your Account;
• For Our internal record keeping requirements including collection of anonymized details about visitors to Our Platform to compile aggregate statistics or produce internal reports;
• To communicate with You and to share with You additional and/or upcoming information regarding the Services offered by Us on the Platform;
• To better understand how the Users access and use Our Services; and
• For any purposes related to the above or where We have a legal right or duty to use, process or store Your Personal Information (including for abuse, crime and fraud prevention and related purposes);

5.3 Corporate Restructuring & Insolvency

We may disclose Your Personal Information as part of any merger, sale of the Company assets or acquisition, as well as in the event of insolvency, bankruptcy or receivership upon prior written intimation to You.

5.4 Third-Party Links & External Platforms

Our Platform may contain links to third party websites or applications. The User agrees and understands that these website(s) and application(s) are not under Our control and subject to additional and separate terms and policies. The User acknowledges and accepts that once the User leaves Our servers, use of any information provided by the User will be governed by the privacy policy and terms of the operator of these website(s) and application(s).

6.1 Sharing Authorization

Subject to the Privacy Policy, You acknowledge and accept that Your Information Collected shall be disclosed, transferred and shared with the parties mentioned below who are responsible for fulfilling components of any Services requested by Users on the Platform in accordance with the Privacy Policy. You further acknowledge and accept that while making use of Our Platform with the Company, You authorize Us to share Your Information Collected with the said parties in the manner described herein.

6.2 Sharing with Business Partners

We may share Your Personal Information (including Sensitive Personal Information) with Our Business Partners for purpose(s) defined under this Privacy Policy, including in Section 4 and 5, in the course of Your transactions and use of Services on the Platform. Except for Our Business Partners, We do not disclose or transfer Your Personal Information to any third parties without Your prior consent except in limited and specific circumstances where such disclosure is mandatory, as elaborated herein.

6.3 Contractual Safeguards & Purpose Limitation

Where relevant for fulfillment of Services, and for the purposes described in Section 4 and 5, We may share Your Personal Information (including Sensitive Personal Information) with Our Business Partners, who are contractually bound to safeguard the confidentiality and security of such information in accordance with applicable laws and this Privacy Policy. We may share Your Personal Information as well as Your non-personal information (such as Your User Data) with Business Partners that We work with for facilitating the Services as well as other associated business activities/facilities/transactions including but not limited to KYC verification, payments, communication, consumer support, marketing, data and information storage, transmission, security, analytics, audit, investigation, forensics, fraud detection, risk assessment in the manner permitted under law on a need-to-know basis.

6.4 Mandatory Legal Disclosures

We re-iterate that other than what is specifically stated in this Privacy Policy, We will only share Your Personal Information (including Sensitive Personal Information) in the event it is required to do so by applicable law, rule, regulation, law enforcement agency, governmental official, legal authority or similar requirements applicable to the Company or where Company, in its sole discretion, deems it necessary in order to protect its rights or the rights of others, to prevent harm to persons or property, to fight fraud and credit risk, or to enforce or apply the Privacy Policy and Agreement, as and when deemed necessary under applicable laws. We may share Your Personal Information if required to do so by law or in the good faith belief that such disclosure is reasonably necessary to respond to court orders, or for other legal process. We may share Your Personal Information with government or judicial or other competent legal bodies (such as law enforcement agencies) in the good faith belief that such disclosure is reasonably necessary to enforce Our Agreement, respond to claims or orders or notices or other lawful requisitions or for other compliance with applicable laws and regulations. Such transfer or disclosure shall be for lawful purposes and made subject to applicable laws in India.

6.5 Independent Data Fiduciaries

We do not share Your Personal Information (including Sensitive Personal Information) with Business Partners for any other purposes except as may be necessary for the fulfillment of their part of Services or as mentioned in this Privacy Policy. However, User accepts and acknowledges that Personal Information may be collected directly from User and processed by Our Business Partners to render verification, KYC, AML screening, payment and transactions services in connection with Our Services. You agree and acknowledge that in respect of any information as You may provide to relevant Business Partners (such as KYC or identity verification partners) shall be processed by them as independent data fiduciaries, and such processing may also be subject to separate terms and privacy policies. If You choose to avail any services offered by said parties, the services or facilities so availed will be governed by the terms and conditions and the privacy policy of the respective party providing such services.

6.6 Corporate Events

We may disclose Your Personal Information (including Sensitive Personal Information) subject to lawful contract and applicable statutory requirements such as for the purpose of or as part of any merger, sale of the Company assets or acquisition, as well as in the event of insolvency, bankruptcy or receivership upon prior written intimation to You.

6.7 Customer Support and Marketing Partners

In the interests of improving personalization and service efficiency, We may, under controlled and secure circumstances, share Your Personal Information with select customer support and marketing Business Partners. This will enable Us to provide You with information which might interest You in relation to the Services; or help Us address Your questions and requests in relation to Your use of the Platform.

6.8 Transfer of Customer Information on Asset Sale

If the Company’s assets are acquired, Users should note that Our customer information (including Your Personal Information) may also be transferred to the acquirer depending upon the nature of such acquisition in accordance with this Privacy Policy. In relation, as part of business expansion/development/restructuring or for any other reason whatsoever, if We decide to sell/transfer/assign Our business, any part thereof, then as part of such restructuring exercise Our customer information (including the Information Collected herein) shall be transferred accordingly in accordance with this Privacy Policy.

6.9 No Sale of Personal Data

We do not sell User’s Personal Information to any advertisers or any third party. We may, however, use User’s Personal Information to display relevant advertisements on the Platform, based on Your preferences.

7.1 Retention Purpose & Legal Mandates

Subject to the Privacy Policy, We retain and store certain Personal Information We collect from Users strictly as is necessary for the business purposes which are elaborated herein. We will typically retain or store Your Information Collected only so long as is required for provision or facilitation of Services or to maintain Your Account with Us. We may retain the Information Collected for a longer duration where prescribed under statute or by a statutory authority, for the purpose of undertaking compliance under applicable laws.

7.2 Security Infrastructure & Standards

The security of Your Personal Information is important to Us. Such Personal Information collected on Our Platform is securely transmitted to Our internal computer servers and to the AWS servers to ensure secure storage of data and is securely stored with Us and Our relevant Business Partner (subject to applicable services policies of such Business Partner). The database is stored on servers secured behind a firewall; access to the servers is password-protected and is strictly limited. We implement commercially reasonable physical, managerial, operational and technical security measures to protect the loss, misuse and alteration of the Personal Information in Our possession. We take necessary precautions to protect Your Personal Information both online and off-line and implement reasonable security practices and measures that are commensurate with respect to the information being collected and the nature of Our business in accordance with legal and industry standards and the applicable laws.

7.3 User Security Best Practices & Breach Notification

Although We make best possible efforts to store Your Personal Information in a secure operating environment that is not open to the public, the User acknowledges and agrees that there is no such thing as complete security, and We cannot guarantee safety or security of Your information as events beyond Our control can also occur, both during transmission of Your information and once We receive it. If We become aware that there has been any unintended disclosure of Your Personal Information in a manner not in accordance with this Privacy Policy, We will use reasonable efforts to notify such User of the nature and extent of such disclosure as soon as reasonably possible and as permitted by law. We encourage the User to follow certain security measures on their part, including: if using a computer in a public location, to always log out and close the website browser when You complete Your online session; keep Your Account details and passwords private; frequently change Your password; and avoid using the same password for multiple online accounts.

7.4 Tenure of Storage and Retention of Information Collected

We retain Your Information Collected for as long as is reasonably necessary to fulfill the purposes listed in this Privacy Policy so as to provide You with access to Our Services and Platform. You acknowledge, accept and understand that Krypsm will retain Your Personal Information on its servers for as long as is reasonably necessary for the purposes listed in this Privacy Policy.

7.5 Statutory 5-Year Retention Under AML/KYC Regulations

We will typically retain Your Personal Information only until such time as You maintain Your Account on the Platform and will securely delete Your Information Collected once You terminate Your Account with Us. Please note, however, that We may retain Your Personal Information (including Your Sensitive Personal Information) for longer periods of time, only where necessary, such as for instance where We are required to do so in accordance with any legal, regulatory, tax or accounting requirements. Principally, subject to terms herein, We retain Your Personal Information (such as select KYC, identity and contact information and records) for 5 (five) years from the date of termination of Your Account and certain User Data and Sensitive Personal Information (such as financial information, transaction records etc.) for 5 (five) years from the date of initiated transaction strictly for AML and KYC purposes as part of due diligence requirements under applicable laws in accordance with this Privacy Policy and Our AML Policy.

7.6 Third-Party Storage Servers

The User acknowledges and understands that the third-party storage servers utilized by Us are subject to additional and separate terms and policies of their operators which may be applicable to the User. You acknowledge and agree that We may retain Your Personal Information in the manner mentioned in this Privacy Policy for the purpose of the Services and in accordance with any legal, regulatory, tax or accounting requirements.

8.1 Grievance Redressal & Consent Withdrawal Impact

Users are encouraged to communicate any grievances regarding User’s Personal Information (including Sensitive Personal Information) to Our Grievance Officer in writing by using the applicable contact details set out at Section 10 of this Privacy Policy. In case the User opts to decline to provide consent or withdraw any consent granted to Us in respect of collection or processing of the User’s Personal Information (including Sensitive Personal Information) or request deletion of any of the Information Collected, the User acknowledges and agrees that such action may interfere with or render it impossible for Us to continue offering You the Services (or to offer You any additional Services) and We may be forced to limit, suspend or terminate Your access to the Platform and/or the Services.

8.2 User Representation & Indemnity

User hereby agrees and acknowledges that We shall not be held liable in any manner whatsoever if We are unable to perform Our Services or if there is a deficiency in the Services provided by Us due to any Information Collected which You provide to Us which is incorrect (in whole or in part) or due to any withdrawal of consent. User acknowledges and agrees to indemnify and hold Us and/or Our employees, consultants, directors, representatives and/or associates, etc. harmless from any complaints, legal proceedings or claims filed or initiated by any third party against Us due to any breach by the User of the terms of this Privacy Policy.

8.3 Marketing & Promotional Communications Opt-Out

We provide Users with the opportunity to opt-out of receiving non-essential (promotional, marketing related) communications from Us (on behalf of Our Business Partners, and from Us in general) after setting up an account by sending an email to the following email address: [email protected]. To the extent We use Your Personal Information to market to You, We will provide You the ability to opt-out of such uses. In case You choose to do so, then Your access to the Platform may be limited, or We might not be able to provide the Services to You.

8.4 Grievance Officer Escalation

We re-iterate that in case You have any concerns in the collection and processing of Your Personal Information or any relative consent or permission You have granted Us in this regard, please reach out to Our Grievance Officer in the manner provided in this Privacy Policy.

9.1 Right to Modify & Notice

You acknowledge and accept that the Company may update this Privacy Policy at any time, with or without advance notice. In the event there are changes in the way Company treats User’s Personal Information (including Sensitive Personal Information) or in the terms of Privacy Policy itself, Company will display a notice on the Platform or send Users an email, as provided for above, so that You may review the changed terms prior to continuing to use the Services.

9.2 Objection, Account Deactivation & Continued Use

If You object to any of the changes to Our Privacy Policy, and You no longer wish to avail the services, You may contact Us at [email protected] to deactivate Your Account or may contact Us in the manner specified in Section 10 herein for any other grievances or issues related to the collection of Your Personal Information under this Privacy Policy. Unless stated otherwise, Our current Privacy Policy applies to all information that the Company has about You and is associated to Your Account with Us. If a User uses the Platform, after a notice of changes published on the Platform, such User hereby consents to the changed terms.