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Privacy Policy

We, Sawara Solutions Pvt Ltd, a company duly registered under the Companies Act, 1956, bearing CIN-U72900KA2021PTC143734., having registered place of business at #118, Kacharakanahalli, St Thomas Town Near Jyothi School, Hennur Main Road Bengaluru 560084, India., our subsidiaries, affiliates, successors and assigns (collectively, “Promilo”, “we”, “us” or “our”) acknowledge and respect the importance of protecting your privacy. Pursuant to the same, we have adopted the principles set forth in this Privacy Policy (this “Policy”) to govern our use and disclosure of your personal information in the website www.promilo.com and the Android and iOS compatible mobile application, namely “Promilo” [ hereinafter collectively referred to as the “ Platform”]

The foregoing Policy specifically governs the usage of information collected by us from our users of the Platform and/or any other services provided by us on the Platform, which can be accessed thereof. This Policy should not be read in isolation and is to be read in conjunction and together with the Terms of Use available on the Platform.

Your viewing or browsing of our content or your use of our services offered on our Platform is construed to mean that you explicitly consent to our collection, storage, processing of your Personal Information or Sensitive Personal Information or Information in accordance with this Privacy Policy and you consent to the Terms and Conditions of this Privacy Policy. You hereby agree to be bound by the terms of this Privacy Policy.

1) Collection of Information from Users

We receive process and store information about you, such as:

a) Your e-mail address, name, address, postal code, birth date, preferences, gender details, and telephone number.

b) In this regard, we may also record conversations and archive correspondence between users and the representatives of the Platform (including the additional information, if any) in relation to the services for quality control or training purposes.

c) In connection with any communication or transaction and payment services or any other services that you may avail using the Platform, any information, including but not limited to, bank account numbers, billing and delivery information, credit/debit card numbers and expiration dates and tracking information from cheques or money orders ("Account Information") may be collected by such Payment Aggregator only to the extent permitted/mandated by applicable laws, among other things, to facilitate the sale and purchase as well as the settlement of purchase price of the products or services transacted on or procured through the Platform. Promilo Platform on a standalone basis does not store any payment related information pertaining to Users.

d) Certain other information like your choice to provide further information pertaining to preferences, account settings, reviews, ratings, or any other information provided to us through our service, or elsewhere.

e) Users may also choose to delete or deactivate their accounts on the Platform. We will evaluate such requests on a case-to-case basis and take the requisite action as per applicable law.

f) In this regard, please note that information sought to be deleted may remain with us in archival records for the purpose of compliance of statutory enactments, or for any other lawful purpose. Therefore, users are requested to carefully evaluate what types of information they would like to provide to us at the time of registration.

2) Information Collected Automatically:

The following information is collected about you, your use of our service, the devices used to access our service and it includes the following:

a) Your activity on our Platform, which would include your search history within the Platform, your search inputs within the Platform, services or products viewed over the Platform, profile visits within the Platform;

b) Your interactions with our customer support via various support channels like e-mails, messages, calls;

c) Information collected by other technologies, also including but not limited to advertisement data;

d) Device IDs and other unique identifiers like IP address, browser type, version, network service provider details;

e) Device and software characteristics including types and configurations, connection information, statistics on page views, URLs with time stamp;

f) Service support and payment/ subscription transaction history.

3) Use of Information Collected by Us

In order to offer you enhanced use of the features of our Platform, We use your information for the following activities :

a) Process your registration, and provide you with your login account details;

b) Process your orders and payments in respect of our services;

c) Provide an efficient medium to facilitate communication and business growth between Users using the Promilo Platform. Users shall be able to strategize, identify their business growth, approach third parties with business proposals and also utilize various parameters available on the Platform to maximize the commerciality of their businesses, based on certain algorithms arrived after utilization of information/ data collected by us to the extent mentioned herein.

d) providing User with customer service and responding to User(s) queries, feedback, claims or disputes;

e) To offer you certain types of services, free trials, and other applicable offers based on your eligibility;

f) To offer you relevant contextual advertisements wherever applicable; g) To connect with you via emails/ phone calls for feedbacks regarding the Platform ; h) To record the phone calls for quality purposes and future references with intent to enhance customer experience on the Platform.

4) Sharing and Disclosure of Information

a) While the Platform is the recipient of your Personal Information or Sensitive Personal Information, we may allow access of this information to various third parties with whom Promilo, has direct legal and confidentiality binding and such data shall stay with them only for limited purpose and period for the processing and storage of information, provision of account to you, provision of customer support, content development and delivery, and other purposes as identified in the Use of Information Collected By Us section to this Policy. To the extent possible and practicable, We shall on a best effort basis enter in to confidentiality arrangements with such third parties.

b) We may also from time to time engage various service providers to perform services on behalf of us enabling us to provide you services better. Such services may include, communications, advertising, infrastructure and IT, payment gateways processing payments, customer support, data analytics, conduct customer surveys, geo tagging/ location based content.

c) Promilo shall on a best effort basis ensure that such service providers adhere to a similar standard of data protection and security that we have agreed to under this Privacy Policy. However, at no point of time shall we be responsible for the privacy practices of such third party entities.

d) Promilo and our service providers may be required to disclose and otherwise use your personal and other information where we or our service providers reasonably believe that there exists the need to disclose to

i. Meet or satisfy any applicable law, regulation, governmental request, or, legal process;

ii. Enforce the agreed Terms of Use;

iii. Address and investigate any illegal activities, which may also include financial frauds, any security or technical issues;

iv. Protect itself against any harm, misuse, of the property or safety of its users and the public, as required or permitted by law.

5) Interaction with third party Platforms

You may be using other third party platforms, to access our services, which may have policies pertaining to privacy which may be different from ours. While you may use mobile devices, gaming systems, smart TVs and other such enabling devices to access our services, it is noteworthy that these have independent privacy policies, Terms of use, which we recommend you read very carefully.

6) Data Security

We understand that we must safeguard your personal information available with us. We use and employ reasonable technical, organizational, logical, physical, administrative measures to protect your personal information against any unauthorized access, modification, or, use.

7) Your Rights and Your Preferences

a) At all times, you have the right to access your personal information, or update, or correct the personal information we hold about you. This can be easily done by you through the “Profile” section; available at the Platform which empowers you with multiple information about your account, which may relate to your contact information, payment information, and several other relevant information about your account. To access this section, and make the relevant changes, you must be logged into your Account

b) Where you have any questions, or wish to make additional requests, you may write to our support team. We strive to respond to any requests made with the specific exercise of data protection rights available under various applicable data protection laws. We retain information as required or permitted by the applicable laws or regulations, including to retain your choices and preferences, for billing purposes, and to meet and fulfill other requirements as specified in this Privacy Policy. Reasonable measures are made to destroy or to remove identifiers in a secure manner when it is no longer required to be retained with us.

c) If you no longer wish to receive certain communications from us via e-mail, messages, you can unsubscribe to the same by clicking on the unsubscribe option in the e-mail communication received from us. Please note that you cannot however, unsubscribe to service related correspondence made by us to you, such as messages regarding your transactions, subscriptions. You can also choose not to receive any push notifications, as may be enabled on your devices; this can be done through your device settings.

8) Children

You must be 18 years of age or older to subscribe to our services. In jurisdictions, where the age of majority is older than 18, in such case, you must satisfy such requirement to become a member.

9) Cookies and Advertising

a) A "cookie" is a small amount of data that is sent to User’s browser and stored on User’s device. If User does not deactivate or erase the cookie, each time User uses the same device to access the Platform, our services will be notified of User visit to the Platform and in turn Promilo may have knowledge of User visit and the pattern of User’s usage.

b) We and our service providers use cookies and other technologies, such as web beacons, as well as several advertising identifiers for several purposes. This is done to understand the users better and offer you with tailored marketing and advertising services. If you do not consent to the use of cookies, use of similar technologies by us, you may at any time adjust your browser settings and delete or disable such cookies. However, this may result in the absence of tailored or user interest based advertisements.

10) Changes in Privacy Policy

We may update this Privacy Policy from time to time. Your continued use of our Platform constitutes your acceptance of our Terms of Use and this Privacy Policy. We encourage and request you to review this section periodically to review any changes made. If you do not wish to accept any changes made to this Privacy Policy, you may cancel your use of our services.

11) Grievance Officer

In accordance with Information Technology Act 2000 and rules made there under, the name and contact details of the Grievance Officer are provided below:

Name of the officer appointed as Grievance Officer:

Mr. Michael Jude Saladanha - (Advocate)

Complete Office Address: #118 Kacharakanachali, St Thomas Town, Near Jyothi School, Hennur Main Road, Bengaluru, KA- 560084

Official E-mail Address: grievance@promilo.com