PRIVACY POLICY – BW INFRA SUPPLIES PRIVATE LIMITED

THIS PRIVACY POLICY IS AN ELECTRONIC RECORD IN THE FORM OF AN ELECTRONIC CONTRACT FORMED UNDER THE INFORMATION TECHNOLOGY ACT, 2000 AND THE RULES MADE THEREUNDER AND THE AMENDED PROVISIONS PERTAINING TO ELECTRONIC DOCUMENTS / RECORDS IN VARIOUS STATUTES AS AMENDED BY THE INFORMATION TECHNOLOGY ACT, 2000. THIS PRIVACY POLICY DOES NOT REQUIRE ANY PHYSICAL, ELECTRONIC OR DIGITAL SIGNATURE.

INTRODUCTION

BW Infra Supplies Private Limited (hereinafter “BWISPL”) recognizes the importance of privacy of its users and also of maintaining confidentiality of the information provided by its users as a responsible data controller and data processor.

This Privacy Policy provides for the practices for handling and securing user's Personal Information (defined hereunder) by BWISPL and its subsidiaries and affiliates.

This Privacy Policy is applicable to any person (‘User’) who uses BWISPL’s customer interface channel i.e., SpeedyCem and agree to be bound by the terms and conditions of this Privacy Policy. You expressly consent to our use and disclosure of Personal Information provided by you in accordance with this Privacy Policy. If you disagree with this Privacy Policy please do not use or access SpeedyCem. This Privacy Policy is incorporated into and subject to the Terms of Use.

This policy DOES NOT apply to information that you provide to, or that is collected by, any third-party. BWISPL encourages you to consult directly with such third parties about their privacy practices. This Privacy Policy is an integral part of your Terms and Conditions with BWISPL and all capitalized terms used, but not otherwise defined herein, shall have the respective meanings as ascribed to them in the Terms of Use. To enforce or apply Our Terms and Conditions and other agreements, including for billing and collection purposes.

By using SpeedyCem and/ or by providing your information, You consent to the collection and use of the information you disclose on the SpeedyCem in accordance with this Privacy Policy, including but not limited to Your consent for sharing your information as per this privacy policy. If you disclose any personal information relating to other people to us, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

TYPE OF INFORMATION WE COLLECT AND ITS LEGAL BASIS

The information as detailed below is collected in order to provide the services chosen by you and to fulfil our legal obligations as well as our obligations towards third parties.

Your "Personal Information"(“PI”) is the information that can be associated with a specific person and could be used to identify that specific person whether from that data, or from the data and other information that we have or is likely to have access to. We do not consider personal information to include information that has been made anonymous or aggregated so that it can no longer be used to identify a specific person, whether in combination with other information or otherwise.

We collect information:

• directly from you when you provide it to us;

• at first hand from your phonebook; and/or

• automatically as you navigate through our Services (information collected automatically may include usage details, IP addresses and information collected through cookies, web beacons and other tracking technologies).

Registration on the SpeedyCem: Information which you provide while subscribing to or registering on the SpeedyCem, including but not limited to information about your personal identity such as name, gender, age etc., your contact details such as your email address, postal addresses, telephone (mobile or otherwise) and/or fax numbers and any other information relating to your income and/or lifestyle; billing information payment history etc. (as shared by you).

Other information: We may also collect some other information and documents including but not limited to: • Transactional history (other than banking details) about your e-commerce activities, buying behaviour.

• Your usernames, passwords, email addresses and other security-related information used by you in relation to our Services.

• Data either created by you or by a third party and which you wish to store on our servers such as image files, documents etc.

• Data available in public domain or received from any third party including social media channels, including but not limited to personal or non-personal information from your linked social media channels (like name, email address, friend list, profile pictures or any other information that is permitted to be received as per your account settings) as a part of your account information.

• Information pertaining to any other person for who you make a purchase through your registered BWISPL account. In such case, you must confirm and represent that each of the other person for whom a purchase has been made, has agreed to have the information shared by you disclosed to us and further be shared by us with the concerned service provider(s).

USE OF DEMOGRAPHIC/PROFILE DATA/YOUR INFROMATION

The Personal Information collected may be used in the following manner:

While making a purchase
While making a purchase, we may use Personal Information including, payment details which include cardholder name, credit/debit card number (in encrypted form) with expiration date, banking details, wallet details etc. as shared and allowed to be stored by you.

We may also use your Personal Information for several reasons including but not limited to:

• Process and respond to your queries

• Understand our users (what they do on our Services, what features they like, how they use them, etc.), improve the content and features of our Services (such as by personalizing content to your interests), process and complete your transactions, and make special offers.

• Administer our Services and diagnose technical problems.

• Send you communications that you have requested or that may be of interest to you by way of emails, or courier, or registered post, or telephone calls, or any other mode of communication. We may also share your preferences or the Services availed by you with your network followers on BWISPL for marketing and other promotional activities of our Services.

• Send you questions from other users that you may be able to answer if you have registered with BWISPL.

• Enable us to show you ads that are relevant to you.

• Generate and review reports and data about, and to conduct research on, our user base and Service usage patterns.

• Administer contests and sweepstakes.

• Provide you with customer support.

• Provide you with policies about your account.

• Carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.

• Notify you about changes to our Services.

• Allow you to participate in interactive features offered through our Services.

• In any other way we may describe when you provide the information.

• Confirm your orders with the sellers;

• Keep you informed of the transaction status;

• Send order confirmations either via sms or WhatsApp or any other messaging service;

• Send any updates or changes to your order(s);

• Allow our customer service to contact you, if necessary.

• Customize the content of our SpeedyCem;

• Request for reviews of products or services or any other improvements;

• Send verification message(s) or email(s);

• Validate/authenticate your account and to prevent any misuse or abuse;

• Contact you on your birthday/anniversary to offer a special gift or offer; or

• For any other purpose with your consent.

We use Personal Information to provide the services you request. To the extent we use your Personal Information to market to you, we will provide you the ability to opt-out of such uses. We use your Personal Information in handling and fulfilling orders, enhancing customer experience, resolve disputes; troubleshoot problems; help promote a safe service; collect money; measure consumer interest in our products or services(if applicable), inform you about online and offline offers, products, and updates; customize and enhance your experience; detect and protect us against error, fraud and other criminal activity; enforce our terms and conditions; and as otherwise described to you at the time of collection.

• In our efforts to continuously improve our product offerings, we collect and analyse demographic and profile data about our users' activity on our SpeedyCem.

• We identify and use your IP address to help diagnose problems with our server, and to administer our SpeedyCem. Your IP address is also used to help identify you and to gather broad demographic information.

• We will occasionally ask you to complete optional online surveys. These surveys may ask you for Personal Information, contact information, date of birth, demographic information (like PIN Code, age, or income level), attributes such as your interests, household or lifestyle information, your purchasing behaviour or history, preferences, and other such information that you may choose to provide. We use this data to tailor your experience at our SpeedyCem, providing you with content that we think you might be interested in and to display content according to your preferences.

Cookies:

BWISPL uses cookies to personalize your experience on the SpeedyCem and the advertisements that maybe displayed. BWISPL’s use of cookies is similar to that of any other reputable online companies.

Cookies are small pieces of information that are stored by your browser on your device's hard drive. Cookies allow us to serve you better and more efficiently. Cookies also allow ease of access, by logging you in without having to type your login name each time (only your password is needed); we may also use such cookies to display any advertisement(s) to you while you are on the SpeedyCem or to send you offers (or similar emails – provided you have not opted out of receiving such emails) focusing on destinations which may be of your interest.

Most web browsers automatically accept cookies. Of course, by changing the options on your web browser or using certain software programs, you can control how and whether cookies will be accepted by your browser. BWISPL supports your right to block any unwanted Internet activity, especially that of unscrupulous websites. However, blocking BWISPL cookies may disable certain features on the SpeedyCem, and may hinder an otherwise seamless experience to purchase or use certain services available on the SpeedyCem.

Automatic Logging of Session Data:

• Each time you access the SpeedyCem your session data gets logged. Session data may consist of various aspects like the IP address, operating system and type of browser software being used and the activities conducted by the User while on the SpeedyCem. We collect session data because it helps us analyse User’s choices, browsing pattern including the frequency of visits and duration for which a User is logged on. It also helps us diagnose problems with our servers and lets us better administer our systems. The aforesaid information cannot identify any User personally. However, it may be possible to determine a User's Internet Service Provider (ISP), and the approximate geographic location of User's point of connectivity through the above session data.

• We may also use your information to contact you about our own and third-party goods and services that may be of interest to you. If you do not want us to use your information in this way, please check the relevant box located on the form on which we collect your data and/or adjust your user preferences in your account profile.

• We may use the information we have collected from you to enable us to display advertisements to our advertisers'/service providers' target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

WITH WHOM YOUR PERSONAL INFORMATION IS SHARED

Companies in the same group:

In the interests of improving personalization and service efficiency, we may, under controlled and secure circumstances, share your Personal Information with our affiliate or associate entities. This will enable us to provide you with information about various products which might interest you; or help us address your questions and requests in relation to your orders.

If the assets of BWISPL are acquired, our customer information may also be transferred to the acquirer depending upon the nature of such acquisition. In addition, 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, any of our subsidiaries or any business units, then as part of such restructuring exercise customer information including the Personal Information collected herein shall be transferred accordingly.

Business Partners and Third-Party Vendors

You hereby unconditionally agree and permit that BWISPL may transfer, share, disclose or part with all or any of Your Information, within and outside of the Republic of India to various BWISPL entities and to third party service providers / partners / banks and financial institutions for one or more of the Purposes or as may be required by applicable law. In such case we will contractually oblige the receiving parties of the Information to ensure the same level of data protection that is adhered to by BWISPL under applicable law.

You acknowledge and agree that, to the extent permissible under applicable laws, it is adequate that when BWISPL transfers Your Information to any other entity within or outside the country of residence, BWISPL will place contractual obligations on the transferee which will oblige the transferee to adhere to the provisions of this Privacy Policy.

You unconditionally agree and permit BWISPL to access and read your SMS to autofill or prepopulate ‘OTP’ while making a transaction and to validate your mobile number as may be applicable.

BWISPL may share statistical data and other details (other than Your Personal Information) without your express or implied consent to facilitate various programmes or initiatives launched by BWISPL, its affiliates, agents, third party service providers, partners or banks & financial institutions, from time to time.

We may transfer/disclose/share Information (other than Your Personal Information) to those parties who support our business, such as providing technical infrastructure services, analysing how our services are used, measuring the effectiveness of advertisements, providing customer / buyer services, facilitating payments, or conducting academic research and surveys. These affiliates and third-party service providers shall adhere to confidentiality obligations consistent with this Privacy Policy. Notwithstanding the above, we use other third parties such as a credit/debit card processing BWISPL, payment gateway, pre-paid cards etc. to enable You to make payments for buying products or availing services on BWISPL. When You sign up for these services, You may have the ability to save Your card details and/or UPI details for future reference and faster future payments. In such case, We may share Your relevant Personal Information as necessary for the third parties to provide such services, including your name, residence and email address. The processing of payments or authorization is solely in accordance with these third parties’ policies, terms and conditions and we are not in any manner responsible or liable to You or any third party for any delay or failure at their end in processing the payments.

BWISPL may also share Personal Information if BWISPL believe it is necessary in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of various terms and conditions or our policies.

DISCLOSURE OF INFORMATION

In addition to the circumstances described above, BWISPL may disclose User's Personal Information if required to do so:
• by law, required by any enforcement authority for investigation, by court order or in reference to any legal process;

• to conduct our business;

• for regulatory, internal compliance and audit exercise(s);

• to secure our systems; or

• to enforce or protect our rights or properties of BWISPL or any or all of its affiliates, associates, employees, directors or officers or when we have reason to believe that disclosing Personal Information of User(s) is necessary to identify, contact or bring legal action against someone who may be causing interference with our rights or properties, whether intentionally or otherwise, or when anyone else could be harmed by such activities.

Such disclosure and storage may take place without your knowledge. In that case, we shall not be liable to you or any third party for any damages howsoever arising from such disclosure and storage.

• Service Providers: We may share your information with outside vendors that we use for a variety of purposes, such as to send you communications via emails, messages or tele-call to inform you about our products that may be of interest to you, push notifications to your mobile device on our behalf, provide voice recognition services to process your spoken queries and questions, help us analyze use of our Services, and process and collect payments. Some of our products, services and databases are hosted by third party hosting services providers. We also may use vendors for other projects, such as conducting surveys or organizing sweepstakes for us. We may share information about you with these vendors only to enable them to perform their services.

• Legal Purposes: We may share your information when we believe in good faith that such sharing is reasonably necessary in order to investigate, prevent, or take action regarding possible illegal activities or to comply with legal process. We may also share your information to investigate and address threats or potential threats to the physical safety of any person, to investigate and address violations of this Privacy Policy or the Terms of Service, or to investigate and address violations of the rights of third parties and/or to protect the rights, property and safety of BWISPL, our employees, users, or the public. This may involve the sharing of your information with law enforcement, government agencies, courts, and/or other organizations on account of legal request such as subpoena, court order or government demand to comply with the law.

• Social Networks: If you interact with social media features on our Services, such as the Facebook Like button, or use your social media credentials to log-in or post content, these features may collect information about your use of the Services, as well as post information about your activities on the social media service. Your interactions with social media companies are governed by their privacy policies.

Payment Card Information:

• To use certain of our Services, we may require credit or debit card account information. By submitting your credit or debit card account information through our Services, you expressly consent to the sharing of your information with third-party payment processors, and other third-party service providers (including but not limited to vendors who provide fraud detection services to us and other third parties), and you further agree to the following terms.

• When you initially provide your credit or debit card account information through our Services in order to use our Services, we provide your credit or debit card account information to our third-party payment service providers. As explained in our Terms and Conditions, these third parties may store your credit or debit card account information as per RBI guidelines so you can use our Services in the future.

• For information about the security of your credit or debit card account information, see the "Security" section below.

HOW CAN YOU OPT-OUT OF RECEIVING OUR PROMOTIONAL E-MAILS?

You will occasionally receive e-mail updates from us about order information and other noteworthy items. We hope you will find these updates interesting and informative. If you wish not to receive them, please click on the "unsubscribe" link or follow the instructions in each e-mail message.

HOW WE PROTECT YOUR PERSONAL INFORMATION

All payments on the SpeedyCem are secured. This means all Personal Information you provide is transmitted using TLS (Transport Layer Security) encryption. TSL is a proven coding system that lets your browser automatically encrypt, or scramble, data before you send it to us. SpeedyCem has stringent security measures in place to protect the loss, misuse, and alteration of the information under our control. Whenever you change or access your account information, we offer the use of a secure server. Once your information is in our possession, we adhere to strict security guidelines, protecting it against unauthorized access.

It is important for you to protect against unauthorised access to your password and to your computer. Be sure to sign off when you finish using a shared computer.

THIRD PARTY LINKS

Our SpeedyCem links to other websites that may collect personally identifiable information about you. BWISPL is not responsible for the privacy practices or the content of those linked websites.

WITHDRAWAL OF CONSENT AND PERMISSION

You may withdraw your consent to submit any or all Personal Information or decline to provide any permissions on as covered above at any time. In case, you choose to do so then your access to the SpeedyCem may be limited, or we might not be able to provide the services to you. You may withdraw your consent by sending an email to tech@speedycem.co.in .

Data Retention and account Termination

You can close your account by visiting your profile settings page on our SpeedyCem. We will remove your public posts from view and/or dissociate them from your account profile, but we may retain information about you for the purposes authorized under this Privacy Policy unless prohibited by law. Thereafter, we will either delete your personal information or de-identify it so that it is anonymous and not attributed to your identity. For example, we may retain information to prevent, investigate, or identify possible wrongdoing in connection with the Service or to comply with legal obligations.

YOUR RIGHT QUA PERSONAL INFORMATION

You may access your Personal Information from your User account with BWISPL. You may also correct your personal information or delete such information (except some mandatory fields) from your User account directly. If you don’t have such a User account, then you write to Tech@Speedycem.Co.In .

HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION

BWISPL will retain your Personal Information on its servers for as long as is reasonably necessary for the purposes listed in this policy. In some circumstances we may retain your Personal Information for longer periods of time, for instance where we are required to do so in accordance with any legal, regulatory, tax or accounting requirements.

Where your personal data is no longer required, we will ensure it is either securely deleted or stored in a way which means it will no longer be used by the business.

CHANGES TO BWISPL

We reserve the rights to revise the Privacy Policy from time to time to suit various legal, business and customer requirement. You are required to be aware of any changes and review this policy periodically.

Use of information we collect is subject to the Privacy Policy in effect at the time such information is used. If we make any material changes to this Privacy Policy, we will post the changes here. Please review the changes carefully. Your continued use of the Services following the posting of changes to this Privacy Policy will constitute your consent and acceptance of those changes.

Grievance Officer:
In accordance with Information Technology Act 2000 and rules made thereunder, the name and contact details of the Grievance Officer is specified below:

Email: Tech@Speedycem.Co.In

You may always submit concerns regarding this Privacy Policy via email to us at Tech@Speedycem.Co.In . BWISPL shall endeavour to respond to all reasonable concerns and inquires.