PRIVACY POLICY

Your usage of the features or functionalities on Our Platform implies Your acceptance to the terms and conditions outlined in the Terms of Use and this Policy. By providing Your explicit consent and by availing the Services, You acknowledge that You have been duly informed about the Information being collected, the purpose for usage and processing of such Information.

In furtherance of the above, please note that, in addition to rights available under applicable laws, You have the right to grievance redressal, and the right to withdraw Your consent in a manner as laid down hereunder.

You also have the option of making a complaint to the Board in a manner as laid down under applicable law. For the purposes of this Policy, 'Board' shall mean the Data Protection Board established by the Central Government in accordance with the Digital Personal Data Protection Act, 2023 ("DPDP Act, 2023") and rules made thereunder.

If You are accessing or using the Platform and Services from any location outside India, You do so at Your own risk and will be solely liable for compliance with any local laws, as may be applicable.

Sharing Your Information (as defined below) is entirely voluntary. You need not register with Us, however, if You do not register with Us, You may not have access to Our Platform and the Services provided by Us.

Further, if You register with Us, and upon Your request We will remove/block Your Information from Our database. However, Your Information may remain stored in archive on Our servers even after You temporarily disable Your account. You may lose access to Our Platform and Services pursuant to the cancellation of Your registration or upon permanent termination of Your account.

Your account may be disabled for a temporary period either upon request or at the discretion of the Company. Please note that disablement of Your account or Services is not a withdrawal of Your consent to process and store Your Information. The Information provided by You may still be available on the Platform during the disablement period until and unless You explicitly withdraw Your consent. In the event that You choose to permanently terminate Your account or do not revive Your account during the disablement period, You will permanently lose access to Your account and any and all information thereof. Further, We delete Your account and all information relating to You or Your account in perpetuity.

The information provided by You shall be used to provide, enhance and improve the Service for You and all users, including for the following purposes:

• Providing safe, efficient, smooth and customised experience on the Platform;
• For account creation and processes;
• To provide You with Services on Your request;
• To maintain and manage a secure and confidential database;
• To understand, improve and analyse Your usage and interaction with Our Platform;
• Enforcing our Terms of Use, and mitigating and protecting You from fraud and other criminal activities;
• For internal operations such as troubleshooting, data analysis, research, testing, monitoring and service improvement of a Platform;
• To communicate with You and send You important notices relating to the Platform, products, Services, payment reminders, account-related alerts, security alerts, and updates to this Policy or Our Terms & Conditions of Use, through verified contact details provided by You, via phone calls, SMS, email, WhatsApp, in-Platform notifications, or any other digital communication channels as may be introduced from time to time;
• To send marketing and promotional communications, including without limitation communications tailored to specific user groups or demographics, which may be delivered in different formats or languages including Hinglish or any other language/dialect deemed suitable for better engagement, covering new features, special offers, and other information We believe may interest You;
• To allow Our authorised representatives, including sales personnel and customer support representatives, to contact You directly for promotional, feedback, service-related, or product-related purposes, through manual or automated calling/communication systems, in compliance with applicable laws. Such communications may be made through phone calls, SMS, email, WhatsApp, in-Platform notifications, or any other digital communication channels;
• For general marketing and promotional purposes, including targeted advertising and audience segmentation;
• To build, analyse, train, and enhance data models including, without limitation, analytical and machine-learning models, Artificial Intelligence (AI) models ("Models"), to gain insights into user behaviour for improving Services and for marketing and promotional activities;
• To comply with applicable laws, regulations, and governmental reporting requirements;
• For security purposes, including fraud detection, account verification, and to investigate or prevent illegal activities;
• Deal with enquiries and complaints made by or about You relating to Our Platform;
• Verify compliance with the terms and conditions governing the use of Our Platform.

In light of the aforementioned, You acknowledge and agree that You have knowledge that Your Information is being collected and the purpose of such collection and its usage, including without limitations, the above-mentioned methods of using the Information.

All Information collected on Our Platform is securely stored within Our controlled database. The database is stored on servers secured behind security controls such as firewalls. Access to the servers is password-protected and is strictly limited to authorised personnel only. You are advised to refrain from posting Your Information anywhere other than as specifically required by eBullion and in the manner instructed by Us through the Platform. eBullion will never ask for Your password through unsolicited phone calls, emails or other forms of communication.

Further, please do not provide or make available any other person's data or information available to Us, without the prior express consent of such persons. If such information is made available to Us by You, it will be deemed that You have the authority and consent to provide Us with such information for Our use in accordance with this Policy.

We may use Your tracking information such as IP addresses, and/or device ID to help identify You and to gather broad demographic information, and make further services available to You. We will not sell, license or trade Your personal information. We will not share Your personal information with others unless they are acting under Our instructions or We are required to do so as per the applicable law.

In some cases, We may also have a legal obligation to collect certain additional Information from You or may otherwise need such additional Information to protect Your vital interests or those of another person.

By using Our Platform and Services, You declare that:

• You understand and have the knowledge that Information is being collected.
• You understand and have the knowledge of the purpose for which Your Information is being collected, utilised and displayed on the Platform, if applicable.
• You understand and have the knowledge of the intended recipients of the Information.
• You understand that You have the option not to provide the data or Information sought to be collected by Us.
• You understand that You have an option (while availing Our Services or accessing the Platform or otherwise) to withdraw Your consent given earlier to Us and You understand and accept that such withdrawal of Your consent shall be sent in writing and in such an event We shall have the right, at Our discretion, to remove access to the Platform and not provide the Services for which the information was derived/collected.
• You have read and understood this Policy and all other policies governing the usage of the Platform.
• By agreeing to the terms of this Policy, You, as a User, hereby give Your explicit consent and agree to Our processing of Your Information for the purposes given herein.

We store Information in secured cloud-based servers. We may store and process Your Information on a server located outside the country where You live. The Information You provide, subject to disclosure in accordance with this Policy, shall be maintained in a safe and secure manner.

Please do not hesitate to contact Us at support@ebullion.in if You have any questions related to the storage of Your Information.

The act of providing Aadhaar is voluntary in nature, which will be required for completing Your account opening procedure on-line. DigiLocker is a part of the National e-Governance Division under the Ministry of Electronics & Information Technology (MeitY), Government of India.

The Digital Aadhaar issued within DigiLocker is the same as the eAadhaar issued by UIDAI (https://eaadhaar.uidai.gov.in). DigiLocker has partnered with UIDAI to make it available automatically to its users when they link their DigiLocker account with Aadhaar. This act of issuing an eAadhaar within DigiLocker and subsequently DigiLocker sharing the information limited to the above points, is similar to a physical KYC. We only receive information limited to the above points for the purposes of completing KYC of clients online. Based on your consent, we receive and store information limited to (1) The last four digits of the Aadhaar; (2) Full Name; (3) Date of Birth; (4) Gender; (5) Address; and (6) your Photo.

By providing your consent, you authorise eBullion to receive, store, and use this Aadhaar information for the purposes of completing KYC, account verification, and compliance with applicable laws. eBullion will not use your Aadhaar information for any other purpose without your explicit consent.

You hereby represent and warrant to eBullion that:

1. The Information that You provide to eBullion from time to time is and shall at all times be true, correct, complete, accurate and not misleading in any respect whatsoever.
2. You have all the rights, permissions, authorisations and consents as may be required to provide Information to eBullion.
3. The Information provided by You to eBullion is and shall not be in conflict with or in violation or default of (a) any third party agreement to which you are a party, (b) laws applicable to You, (c) the constitutional documents of the entity that you are authorised to represent on the Platform, or (d) any judgments, orders or decrees which apply to You.
4. You acknowledge that eBullion relies on the accuracy and completeness of the Information provided by you for KYC, account management, compliance, and other lawful purposes, and that any false, misleading, or incomplete information may result in suspension or termination of Your account.

Your Information will primarily be stored in electronic form. However, certain Information may also be stored in physical form. We may enter into agreements with third parties to store or process your Information. These third parties may have their own security standards to safeguard your Information and we will on a commercially reasonable basis require such third parties to adopt adequate security measures consistent with industry standards and applicable laws to safeguard your Information.

If You change your mind after opting-in to provide us with or make Information available to us, You may withdraw Your consent for the continued collection, use or disclosure of Your Information, at any time, by deleting Your registration with Us on all Platforms.

However, even after deletion of your account, We will retain Your Information in accordance with applicable law, for a period no longer than is required for the purpose for which it was collected or as required under any applicable law. However, We may retain Information related to you longer, if We believe in good faith that such retention of your Information may be necessary to prevent any fraud, illegal activity or future abuse or for other legitimate purposes, including defending ourselves in legal proceedings or enquiries or investigations or claims, or for other legitimate business purposes, including dispute resolution and audit requirements.

We hereby represent that We do not sell or involve Ourselves in businesses related to selling any information. The exceptions are listed as follows:

Business Transfers

Your Information may be shared in the diligence process with counterparties and others assisting with the transaction and transferred to a potential acquirer, successor, or assignee as part of any proposed merger, acquisition, debt financing, sale of assets, or similar transaction, or in the event of insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of Our business assets.

Service Requirements

The employees, business associates and any other third parties of the Company shall be provided information as provided by You for the fulfilment of the Services. We may use the Information as provided by You internally, for the purposes of Our internal training, data analytics, research, analysis, to troubleshoot, to identify trends, usage, activity patterns and areas for integration and improvement of Services and other business-related purposes, subject to not directly disclosing any of Your Information.

Requirement under Applicable Law

The Information may be disclosed to any person, if such disclosure is required for a lawful purpose connected with a function or activity of Platform. This may include but is not limited to: (i) satisfying any Applicable Law, regulation, legal process, or governmental request; (ii) enforcing this Policy, including investigation of potential violations hereof; (iii) detecting, preventing, or otherwise addressing fraud, security, or technical issues; (iv) responding to Your requests; or (v) protecting Our rights, property or safety of Our users and the public.

• Remind Us of who You are in order to deliver to You a better and more personalized service;
• Recognize Your access privileges to Our Platform;
• Track the information You enter on Our Platform for some of Our promotions;
• Help diagnose problems with Our server; and
• Administer Our Platform.

We store your Information in India. The hosting facilities for our website is situated in India.

Only the persons authorized by eBullion will have access to your Information. By accepting this Policy, You grant complete and unconditional consent to eBullion for using such Information and sharing the Information with persons or entities affiliated or associated with eBullion, including their respective employees, directors, officers, consultants, contractors, agents, and/or representatives, insofar as reasonably necessary for the purposes as set out in this Policy and for compliance with applicable laws. It is clarified that all of Our rights and obligations under this Policy are freely assignable by us to any of Our affiliates, in connection with a merger, acquisition, restructuring, or sale of assets, or by operation of law or otherwise, and We may transfer Your Information to any of our affiliates, successor entities, or the new owner.

We may also share Your Information with third parties to (a) provide You access to Our products and Services, (b) assist or facilitate the fulfilment of the sale or purchase requests, (c) assist or facilitate payment on the Platform, (d) assist in providing banking and storage facilities for the products purchased by You, (e) enhance your experience on the Platform, (f) conduct surveys, (g) facilitate our marketing activities, (h) assist in feedback and customer support, (i) analyse data, (j) ensure the security of our Platform, (k) assist with technical operations such as maintaining software, databases and back-up, (l) undertake the know-your customer requirement processes; and (m) undertake, assist or facilitate such other activities related to our products and Services. We will ensure that third parties with whom Your Information has been shared undertakes to ensure at least the same level of data protection as being provided by Us under this Policy. We will however not be responsible or liable for any action or inaction of such third parties in relation to the use or misuse of Your Information for any reason whatsoever. We may also disclose your Information to Our insurers and other professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or to defend ourselves in legal or administrative proceedings.

The Platform may provide links to websites of certain third-party service providers such as payment gateways, other payment transaction processors or data backup service providers, whose services are integrated with Our Services or access to third-party websites or other digital properties, including social networking websites. Please note that such third-party service providers or other digital properties are governed by their respective terms of use and privacy policies. For these service providers and other digital properties, we recommend that you read their privacy policies so You can understand the manner in which Your Information will be accessed, processed and handled by these providers. In particular, remember that certain providers or other digital properties may be located in or have facilities that are located in a different jurisdiction than either You or Us. So, if you elect to proceed with a transaction that involves the services of a third-party service provider, then Your Information may become subject to the laws of the jurisdiction(s) in which that service provider is or its facilities are located. Once You leave our Platform or are redirected to a third-party website or application, You are no longer governed by this Policy or our Terms and Conditions of Use. Further, We do not make any warranties and expressly disclaim all warranties express or implied, including without limitation, those of merchantability and fitness for a particular purpose, title or non-infringement with respect to any information or services or products that are available or advertised or sold through these third-party websites.

We reserve the right, at our sole discretion, to change, revise and modify any or all portions of this Policy at any time, with an intimation to You. You are requested to please review the Policy periodically, to remain aware of any changes. Changes and clarifications will take effect immediately upon their posting on the Website. If we make changes to this Policy, We will notify You that it has been updated.

Any such changes to the Policy will be notified to Your registered email address with Us. We recommend that You shall update Your details with Your active and correct email address with Us for smooth communication. We will not be liable in case the registered email is inactive, incorrect or not updated for any claims regarding and not limited to communication gaps, liabilities and legal claims with regard to this Policy.

Any continued use of the Services shall signify your acceptance of such new or updated Policy, as the case may be. In the event of a merger, acquisition, restructuring, or sale of assets, Your Information may be transferred to the new owners, affiliates, or successor entities so that We may continue to provide services to You. We encourage you to periodically check this Policy for updates. Your decision to continue using the Platform after changes are posted constitutes Your acknowledgment and acceptance of the revised Privacy Policy.

We aim to protect Your Information against unauthorised access, unlawful alteration, disclosure, or destruction. When You register and/or create Your account on Our Platform, We store your Credentials in an encrypted format. We also aim to maintain its security, integrity, and privacy. To protect data and to aid in preventing unauthorised access, We put in place the necessary physical, electronic, and managerial safeguards in addition to safeguards as laid down under Applicable Laws. As no method of data transmission or protection is 100% safe, We cannot guarantee perfect security.

Password protection is a crucial component of the security of Your Information. You must take care not to reveal Your account login information to any other parties and must keep Your login information, including Your password, private. You are ultimately in charge of protecting the confidentiality of Your account login details, even though We will use our best efforts to ensure the highest level of security for Your Information. If You suspect that someone else knows Your password, or You discover unauthorised use of Your account, or You become aware of any other security lapses, kindly let Us know right away.

We restrict access to Information to those: (i) Third Parties who We need to fulfil their obligations under this Policy, the Terms of Use and any other agreements concluded with Us; (ii) who have received the necessary and ongoing training on how to process, handle, and care for Information; (iii) who store and/or process the Information in an encrypted format; and (iv) who are subject to confidentiality obligations as required by Applicable Law.

We retain Your Information, until it is no longer necessary to fulfil the purpose it is being used for, or as required by Applicable Law, or until You specifically withdraw your consent, or ask Us to delete such Information. After completion of the purpose for processing Your Information, We will either delete, aggregate such Information, or anonymize it, or, if this is not possible (for example, because Your Information has been stored in backup archives), then We will securely store Your Information and isolate it from any further processing until deletion is possible.

While you are registered with our Platform and anytime within 3 (three) months of you deleting your account on our Platform, you may contact our Grievance and Compliance Officer for any complaints or concerns pertaining to breach of Policy:

We reserve the right to terminate accounts of minors, as understood pursuant to the laws of India ("Minor"), who are using Our Services, if We believe that the environment around Our Platform is not safe for a Minor, at Our discretion. Please do not submit any Information through the Services and/or Our Platform if You are a Minor, as You will not be allowed to utilise the Services or the Platform. Please get in touch with Us if You think a Minor may have provided Us with Information through the Services, and We will do Our best to remove that data from Our records.

Any Information that We collect other than the Information collected through the Services is not covered by this Policy. Any Unsolicited Information that You send to Us by any unauthorised method is not covered by this Policy. This includes, but is not limited to, information submitted informally (collectively, "Unsolicited Information") or posted in any public parts of the Platform. All Unsolicited Information will be regarded as non-confidential, and We may be allowed to distribute, disclose, and utilise it without any restriction or credit.

Further, in the below circumstances, We may process your data in accordance with the DPDP Act, 2023 for a lawful purpose without requiring your consent:

• If the processing of Information is for the purpose mentioned in this Policy or Terms of Use, for which You have voluntarily provided the Information to the Company, and in respect of such information You have not indicated to Us that You do not consent to the use of Your Information;
• When We process and/or disclose the Information in special circumstances such as compliance with court orders, requests/order from legal authorities or law enforcement agencies requiring such disclosure;
• Pursuant to Section 17 of the DPDP Act, 2023, processing necessary for enforcing any legal right or claim; processing in the interest of prevention, detection, investigation or prosecution of any offence; or processing of individuals not situated within the territory of India pursuant to a contract entered by Us with any Person situated outside India.

When You visit the Website, one or more cookies will be sent to the computer/smartphone or other devices being used by You. Cookies are small files or texts used to store information on browsers. Cookies are used to store and receive identifiers and other information on computers, phones and other devices. Other technologies, including data that we store on Your web browser or device, identifiers associated with Your device and other software, are used for similar purposes. Cookies enable us to offer Services to You and to understand the information that we receive about You, including information about your use of other websites and apps, whether or not You are registered or logged-in.

We may use Google Analytics and/or a similar service provider or technology to analyse the use of one or more of the Platforms. Google Analytics and other such similar tools gather information about the use of the relevant Platform by means of cookies. The information gathered relating to the Platforms is used to create reports about the use of Our Platforms. For more information, please review such service provider's privacy policy available at their respective websites. To opt out of such services please refer to opt-out options on their website. E.g., click on https://tools.google.com/dlpage/gaoptout for Google Analytics opt out.

The cookies are either used to improve the quality of the Platform or for storing Your preferences as a user, improving search results and tracking user trends. You have the option of disabling cookies via your browser preferences. Most browsers and devices allow You to prevent them from accepting new cookies or alert You when cookies are being sent or disable cookies altogether. Each browser and device is different, so check the 'help' menu of Your browser or device to learn how to change Your cookie preferences or read the additional information about the controls offered by popular browsers at the links below:

• Google Chrome: https://support.google.com/chrome/answer/95647
• Internet Explorer: support.microsoft.com/…/delete-and-manage-cookies
• Firefox: support.mozilla.org/…/enhanced-tracking-protection
• Safari: support.apple.com/…/sfri11471/mac
• Opera: blogs.opera.com/…/how-to-manage-cookies-in-opera
• Microsoft Edge: support.microsoft.com/…/microsoft-edge-browsing-data

However, if You disable cookies on your browser, some or all features of the Platform may not function effectively and your use of such features will be limited to such extent.

Your Responsibility for the Information You Provide

By accessing the Platforms, You may be required to create a username, password and/or provide Us with other personally identifiable information. Any Information shared by you with Us on any Platform must be kept confidential by You and must not be disclosed to, or shared with, anyone.

The Policy shall be governed and construed in accordance with the laws of India. In the event of any disputes or claims arising out of or in connection with this Policy, including its interpretation, validity, performance, breach, or termination ("Dispute") the Parties shall first endeavor to resolve such Dispute amicably through mutual discussions within thirty (30) days from the date on which the Dispute is notified by one Party to the other and if the Dispute is not resolved amicably within the aforesaid period, such Dispute shall be finally settled by way of arbitration in accordance with the provisions of the Arbitration and Conciliation Act, 1996, including any statutory modifications or re-enactments thereof, for the time being in force.

The arbitration shall be conducted as follows:

1. The arbitration proceedings shall be conducted by a sole arbitrator to be mutually appointed by both Parties.
2. In the event the Parties are unable to agree on the appointment of an arbitrator within thirty (30) days from the notice of invocation of arbitration, the arbitrator shall be appointed in accordance with the provisions of the Arbitration and Conciliation Act, 1996.
3. The seat and venue of arbitration shall be Mumbai, Maharashtra, India.
4. The language of the arbitration proceedings shall be English.
5. The arbitral award shall be final and binding on the Parties and shall be enforceable in accordance with applicable law.

Subject to the foregoing, the courts at Mumbai, Maharashtra, India shall have exclusive jurisdiction over all matters arising out of or in connection with this Policy, including any applications to enforce or challenge an arbitral award. Each Party hereby irrevocably submits to the jurisdiction of such courts and waives any objection to the laying of venue or to the claim that such forum is inconvenient.

We shall not be liable for any loss or damage sustained by reason of any disclosure (inadvertent or otherwise) of any information concerning the account and/or omission or inaccuracy with respect to any information so disclosed and used whether or not in pursuance of a legal process or otherwise.

If You have any concerns or are dissatisfied with how We handle Your Information or Our privacy practices, You have the right to seek redress under the provisions of the DPDP Act, 2023.

In the event that your grievance remains unresolved after contacting Us or You are not satisfied with Our response, You may escalate the matter by submitting a complaint to the Board established under the Act.

To file a complaint with the Board, you can follow these steps:

1. Prepare Your complaint and clearly outline the details of Your grievance, including: (i) Your name and contact information; and (ii) A description of the privacy concern or the specific aspect of Our practices You are dissatisfied with. Include details of any prior communication with Us regarding the issue.
2. To access the complaint portal, visit the official website of the Board where complaints can be submitted online.
3. Follow the instructions on the portal of the Board to submit Your grievance. Attach supporting documents, if any, to substantiate Your claim.
4. After submission, You will receive an acknowledgment with a unique complaint reference number. You may use this reference number to track the status of Your complaint.

For further information on the complaint process or to access the official portal of the Board, please visit the website of the Data Protection Board of India or contact them directly as per the details provided on their platform.

You fully accept and agree that Your Information may be processed in India (or any other local or foreign jurisdiction as per Our requirements) if You are using Our Services. Laws governing privacy and data security may differ from or be less strict than those in force in Your jurisdiction.

We value openness and are dedicated to upholding all Our User's privacy rights. Each User of Our Services has the following rights:

• The Right to Access You have the right to request copies and/or obtain access to Your Information, including: (a) a summary of the Information being processed by Us and the processing activities undertaken; (b) the identities of all other data fiduciaries and data processors with whom the Information has been shared, along with a description of the Information so shared; and (c) any other information related to Your personal data and its processing, as prescribed under applicable laws.
• The Right to Rectification In the event of any inaccurate or incomplete Information, You have the right to rectification, completion, or updating of the Information, as the case may be.
• The Right to Erasure Subject to certain conditions or for compliance with any law for the time being in force, upon Your request, We shall erase any Information as provided by You.
• The Right to Withdraw You have the right to withdraw Your consent to processing of Your data at any time. Please be advised that the same may result in the restriction of the complete Services and access to Our Platform.
• The Right to Notification You have the right to be notified regarding any rectification or erasure of Information or restriction of processing unless this proves impossible or involves disproportionate effort.
• The Right to Opt-in You have the right to give explicit consent for the processing of Your Information or the right to withdraw Your consent at any time.
• The Right to Nominate You have the right to nominate any other individual, who shall, in the event of Your death or incapacity, exercise Your rights in accordance with the law.
• The Right to Grievance Redressal You shall have the right to have readily available means of grievance redressal provided by the Company regarding the performance of Our obligations in relation to the Information or the exercise of Your rights under applicable law.

If You choose to exercise any of the above rights, We will respond within seven (7) days. Please send any requests to support@ebullion.in.

In accordance with the Information Technology Act, 2000 read with the rules made thereunder and the DPDP Act, 2023 read with rules made thereunder, and in accordance with the Applicable Laws of the country from which You access and use the Platform, You may contact the Grievance and Compliance Officer for any queries, concerns, or complaints relating to the Platform or this Policy at the email address specified below:

BY AGREEING TO THE TERMS OF THIS POLICY, YOU AGREE TO OUR PROCESSING OF YOUR INFORMATION FOR THE PURPOSES GIVEN HEREIN.