1. BACKGROUND

1.1 This document (“PrivacyPolicy”) is an electronic record in terms of: (i) Information Technology Act, 2000; (ii) the rules framed there under 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.

1.2 This Privacy Policy is published in accordance with the provisions of 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.shiftimpact.co.in/ (“Website”).

1.3 The Website is owned, registered and operated by “Sattva Media and Consulting Private Limited” (“Company”), a company registered under the provisions of the Companies Act, 1956 (bearing CIN: U74300KA2009PTC049429) and having its registered office at 294/295, 2nd Floor, Amar Jyothi Layout, Domlur, Bengaluru, Karnataka – 560 071.

1.4 This Privacy Policy covers: (i) the type of information collected from the users through the Websiteincluding personal data or information; (ii) the purpose, means and modes of usage of such information; and (iii) how and to whom such information which has been collected will be disclosed.

1.5 For the purpose of this Privacy Policy, wherever the context so requires “you“, “your” or “user” shall mean any natural person who uses the Website.The term “we”, “us”, “our” shall mean the Company.

1.6 We reserve the right to make changes to this Privacy Policy at any time. Any such modifications will become effective immediately upon posting to the Websiteand your continued use of the Websiteconstitutes your agreement to such modifications. You agree to periodically review the current version of the Privacy Policy as posted on the Website. If you do not agree with the terms of this Privacy Policy, please do not use the Website.

2. INFORMATION THAT WE COLLECT

2.1. Information that is collected as you use the Website includes “Personal Information” as defined under Section 2(i) of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 (“SPI Rules”).

3. HOW WE USE THE INFORMATION

3.1. We will use the information that we collect for the following purposes:

(a) Name: We will use your name in order to customise all our communications sent to you.

(b) E-mail ID: Your E-mail address will be used to communicate all Website related messages, and to share our responses to any queries/clarifications that you may have regarding the SHIFT software/platform.

(c) Name of Organization: The name and nature of your organization will be used to better understand how the SHIFT software/platform will cater to your needs/requirements.

(d) Phone Number: Your phone number will be an alternative method to contact you for communicating any SHIFT software/platform-related messages.

(e) We retain any Personal Information that you may have provided to us, till such time we share our communications/responses to your queries/clarifications, and for areasonable time thereafter.

4. MARKETING COMMUNICATIONS

4.1. We will rely on your consent to process the personal data you provide in order for us to share marketing communications. If you no longer wish to receive such information, you have the right at any time to opt out of marketing emails and withdraw your consent at any time. The easiest way to opt out is to use the unsubscribe link that you will find at the bottom of each communication.

5. DISCLOSURE OF THE INFORMATION

5.1. The Company does not sell, trade, or rent or disclose your Personal Information to any third party. However, the Company cannot fully ensure that such information will not be disclosed to third parties. For example, we may be legally obligated to disclose information to the government or third parties under certain circumstances, wherein third parties may circumvent the Company’s security measures to unlawfully intercept or access transmissions or private communications, or an error may occur in the administration of the Website. In the unlikely event that the Company needs to investigate or resolve possible problems or inquiries, we may, and you authorize the Company to, disclose any information about you to government officials as permitted by Applicable Law.

For the purposes of this Privacy Policy document, “Applicable Law” shall mean, any statute, law, regulation, ordinance, rule, judgment, notification, rule of common law, order, decree, bye-law, government approval, directive, guideline, requirement or other governmental restriction, or any similar form of decision of, or determination by, or any interpretation, policy or administration, having the force of law of any of the foregoing, by any authority in India having jurisdiction over the matter in question, whether in effect as of the date of these Privacy Policy or thereafter.

5.2. We reserve the right to disclose any Personal Informationas required by Applicable Law and when we believe, at our sole discretion that disclosure is necessary to protect our rights, protect someone from injury and/or to comply with a judicial proceeding, court order, or legal process served on our Website.

5.3. If the Company becomes involved in a merger, acquisition, or any form of sale of some or all of its assets, personal information will be transferred to the new entity.

5.4. Notwithstanding the provisions of Applicable Law, we may disclose your Personal Information if: (a) we have received your consent for such disclosure; (b) when we believe in good faith that disclosure is necessary to protect our rights; (c) to protect your rights and safety; or (d) to investigate fraud or respond to a government, judicial or other legal requests.

6. COOKIE POLICY

6.1. The Website uses temporary cookies, which are files that your web browser puts on your system when you visit the Website, to store certain information. The information collected through these cookies is used by us for the technical administration of the Website, research and development.

6.2. We may use third party cookies to track visitor behaviouron our Website. However, such cookies shall not store any kind of personal information, nor shall such information be disclosed to any third party.

6.3. These cookies are intended to be automatically cleared or deleted when the user quits the browser application. You are encouraged to use the “clear cookies” functionality of your browser to ensure such clearing/deletion, since it is impossible for us to guarantee, predictor provide for the behaviour of your system.

6.4. The information we collect with cookies is not sold, rented, or shared with any third parties.

7. SECURITY PROCEDURES

7.1. We have implemented industry standard security policies, rules and technical measures, as required under Section 8 of the SPI Rules in order to protect any kind of personal sensitive information that we have under our control from unauthorized access. You should know, however, that the Company cannot fully eliminate such risks.

8. LIMITATION OF LIABILITY

8.1. Under no circumstances, including, but not limited to, negligence, shall we be liable for any direct, indirect, special, incidental or consequential damages, including, but not limited to, loss of data or profit, arising out of the use, or the inability to use the Website or any portion thereof, by any person, including employees and contracted personnel of the Company.

9. GOVERNING LAW AND JURISDICTION

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

10. GRIEVANCE OFFICER

10.1. The name and contact details of the Grievance Officer are provided below:

Name: Murthy Ponnan
E-mail ID: murthy.ponnan@sattva.co.in