Kavalry Technologies Private Limited, including its subsidiaries, affiliates, associate/group companies and licensors (collectively“TopMate” , “Company”, “we”, or “our”) welcomes you, irrespective of whether you are a mere visitor or a member/subscriber (the “Customer”, “Subscriber”, “User”, “User”, “you” or “your”) to our platform https://www.topmate.io (“Platform”). We take your privacy and data protection seriously. When you browse through the Platform and/or avail our services provided through the Platform (“Services”), you agree to be bound by this privacy policy (“Privacy Policy”). We ensure compliance with Applicable Laws by periodically updating this Privacy Policy. Hence, you are strongly advised to read this policy carefully from time to time. In addition to our Terms of Service, this Privacy Policy (the “Policy”) explains the types of information collected by TopMate when you use the Platform (as defined in Terms of Service that references this Policy), how we collect, use, share and store such information collected and also explains the rationale for collection of such information, the privacy rights and choices you have regarding your information submitted to us when you use the Services. TopMate LLC - a company incorporated in the State of Delaware, USA, and is a subsidiary of TopMate. Similarly, use of the terms “you”, “yours” and/or “User(s)” refer to all shall refer to all visitors of the Platform and the Creator(s) (as defined under our Terms of Service). The Services are governed by this Policy, Terms of Service, and any other rules, policies or guidelines published on the Platform as applicable to you. Please read this Policy carefully prior to accessing our Platform and using the Services. By accessing and using the Platform, providing your Personal Data (defined below), or by otherwise signing your agreement when the option is presented to you, you consent to the collection, use, disclosure, sharing and storing of information described in this Policy, Terms of Service and any other rules, policies or guidelines published on the Platform as applicable to you (collectively referred to as the**“Platform Terms”**), and TopMate disclaims all the liabilities arising therefrom. If you have inadvertently submitted any Personal Data to TopMate prior to reading this Policy, or you do not agree with the way your Personal Data is collected, stored, or used, then you may access, modify and/or delete your Personal Data in accordance with this Policy (refer to the sections about Your Choices and Your Rights). If any information you have provided or uploaded on the Platform violates the Platform Terms, TopMate may be required to delete such information upon informing you of the same where possible and revoke your access to the Platform if required. Capitalized terms used but not defined in this Policy can be found in our Terms of Service. If you have any questions about this Policy, please contact us at support@topmate.io. A. Applicability: This Policy applies to all users of the Platform, including without limitation, (i) visitors of the Platform, (ii) the Creators (as defined in the Terms of Service), (iii) the Authorized Users (as defined in the Terms of Service), and (iv) Creator's End-Users (as defined in the Terms of Service). Acceptance of the Platform Terms and any other specific terms by the Creator in association with their use of the Platform, shall be deemed as acceptance of such terms by all of Creator's Page Users*(as defined in the Terms of Service)*. Creators are solely responsible for publishing any terms and conditions, privacy policies and any other terms and conditions or policies that shall be applicable for their Page Users in accordance with the Platform Terms and applicable laws, including Data Protection Laws (as defined in the 'Personal Data' section below). B. Access: You may be allowed to access and view the Platform as a guest/visitor and without creating an account on the Platform or providing any Personal Data; TopMate does not validate or takes no responsibility towards information, if any, provided by you as a guest/visitor, except as otherwise required under any law, regulation, or an order of competent authority. To have access to all the features and benefits on our Platform, you are required to first create an account on our Platform. To create an account, you are required to provide certain Personal Data as may be mandatorily required during the time of registration. All other information requested on the registration page, including the ability to receive promotional offers from TopMate, is optional. TopMate may, in future, include other optional requests for information from you to help TopMate customize the Platform to deliver personalized information to you. TopMate may keep records of telephone calls or emails received from or made by you for making enquiries, feedback, or other purposes for the purpose of rendering Services effectively and efficiently. C. Processors and Controllers: TopMate is the 'Controller' (as defined in the Data Processing Addendum ('DPA')) of the information, including Personal Data that it directly collects from you and processes in connection with the use of the Platform and the provision of the Services on the Platform (“User Data”). The kind of information we collect in connection with such use is detailed below. It is hereby clarified that User Data specifically excludes Creator Data (defined below). When it comes to the Content on Creator's Page (as defined in the Terms of Service), any information, materials, media, applications, data, services, subject-matter, including Personal Data, or solutions created and/or uploaded by a Creator on their Page, Page Users' Data (as defined in Personal Data section below) (“Creator Data”), the respective Creators are the 'Controllers' (as defined in the DPA) of such Creator Data. In this case, TopMate only acts as a 'Processor' (as defined in the DPA) and processes the Creator Data on behalf of the Creator. We clarify that the Page User(s) Data processed and stored by the Creator outside the purview of the Platform shall be the sole responsibility of the Creator. You as a Creator acknowledge and agree that you are responsible for complying with all applicable laws and regulations related to the protection of information, including Personal Data for which you are the Controller or the Processor, as applicable. You are also responsible for providing an appropriate privacy notice and cookies policy to your Page Users that detail, among other things, the processing activities and security measures undertaken by you in respect of your Page Users' Data (as defined below) within and beyond the scope of this Platform in accordance with applicable laws. D. Use of the Platform by Minors/Children: As stated in our Terms of Service, to register on the Platform you must meet the 'Age Requirements' (as defined in our Terms of Service). If you are a “Minor” or “Child” i.e., an individual who does not meet the Age Requirements, then you may not register on the Platform. We do not knowingly collect any Personal Data from a Child. If you are a Parent and you are aware that your Child has provided us with any Personal Data without your consent, please contact us at support@topmate.io. If we become aware that we have collected Personal Data from a Child, we will take steps to remove such information from our servers. Furthermore, as stated above, our Platform is not directed at Minors/Children, and we urge you to follow and apply the same in respect of your Page Users. However, in your use of the Services, if you fail to include the necessary age-related disclosures, or knowingly make available services/content targeted at Minors/Children, then it shall be your sole responsibility to comply with all applicable laws relating to the privacy rights of children, including the Children's Online Privacy Protection Rule (COPPA). TopMate shall not be liable for your non-compliance of the applicable laws, including the Data Protection Laws. E. Personal Data: For the purpose of the Platform Terms - “Personal Data” shall mean the information which identifies a user, including first and last name, identification number, email address, age, gender, location, photograph and/or phone number and any other information categorized as 'personal data' under the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, General Data Protection Regulation (GDPR) and / or the California Consumer Privacy Act (CCPA) or other equivalent / similar legislations (“Data Protection Laws”) and in context of this Policy. “Sensitive Personal Data” shall mean and include (i) passwords and financial data (except the truncated last four digits of credit/debit card), (ii) health data, (iii) official identifier (such as biometric data, aadhar number, social security number, driver's licence, passport, etc.,), (iv) information about sexual life, sexual identifier, race, ethnicity, political or religious belief or affiliation, (v) account details and passwords, or (vi) other data/information categorized as 'sensitive personal data' or 'special categories of data' under the applicable Data Protection Laws and in context of this Policy. “Page User(s) Data” shall mean and include End-User(s) Data and Authorized User(s) Data. “End-User(s) Data” shall mean and include any Personal Data and/or Sensitive Personal Data that a Creator collects from their End-User(s) through the Creator's Page. “Authorized User(s) Data” shall mean and include any Personal Data and/or Sensitive Personal Data that a Creator collects from their Authorized User(s) through the Creator's Page. We request you to not provide TopMate with any Personal Data unless specifically requested by us. In the event you share with TopMate any Personal Data without us having specifically requested for the same, then we bear no liability in respect of such Personal Data provided by you. Further, we do not collect, process, or store or facilitate storing of any Sensitive Personal Data. Accordingly, you shall not use the Services to collect, process, or store any Sensitive Personal Data, including personal health information, banking, and credit card information; and if you do use the Platform and/or the Services to collect, store or otherwise process any Sensitive Personal Data, then you do so at your own risk and you are responsible for ensuring compliance with all applicable laws. F. Information we collect: We only collect information about you if we have a reason to do so — for example, to provide our Services on the Platform, to communicate with you, or to make our Services better. It is hereby clarified that we do not directly collect any information, including any Personal Data, from your Authorized Users and End-Users. We only process the End-Users' Personal Data as collected by you through your Page, in accordance with your instructions under the DPA. Further, we do not contact or solicit your Authorized Users and/or End-Users directly and any correspondence with the End-Users will strictly be through you and in relation to the Platform, its access or any technical issue they may want resolved in connection with the Platform. We collect this information from the following sources: Information we collect from You: Basic account information: In order to access certain features of the Platform, you will need to create an account and register with us. We ask for basic information which may include your name, an email address, state of residence country, and password, along with a username and phone/mobile number. Public profile information: If you create an account with us, we also collect the information that you provide for your public profile on the Platform viz., your username is part of that public profile, along with any other information you may put into your public profile, like an 'About Me' description; we may also give you an option to upload your photo and include links of your social media & YouTube channels, websites, blogs, etc. your public profile information is, as the word suggests, 'public', so please keep that in mind when deciding what information you would like to include. The above information is collected so you can personalize your new account, provide you access to the Platform, and we can send you notifications, updates, or other essential information. Information when you communicate with us: When you write to us with a question or to ask for help either for yourself or for your Page Users, we will keep that correspondence, and the email address, for future reference; this may also include any phone/ mobile numbers or any of your Page Users' Personal Data, if you have provided us the same as part of your communication either in writing (emails included), over a phone call or otherwise. When you browse pages on our Platform, we will track that for statistical purposes which may be to improve the Platform and/or the Services. You may also provide us your Personal Data or other information when you respond to surveys, enter any form of events, webinars, etc., hosted by TopMate, either on the Platform or otherwise, or when you otherwise communicate with us via form, e-form, email, phone, or otherwise, we store a copy of our communications (including any call recordings or emails, if any, as permitted by applicable law). Information we collect automatically: Device and Log information: When you access our Platform, we collect information that web browsers, mobile devices, and servers typically make available, including the browser type, IP address, unique device identifiers, language preference, referring site, the date and time of access, operating system, and mobile network information. We collect log information when you use our Platform — for example, when you create or make changes to your profile page or account on the Platform. Usage information: We collect information about your usage of our Platform. We also collect information about what happens when you use our Platform (e.g., page views, support document searches, features enabled for your account, interactions with other parts of our Services) along with information about your Supported Device (e.g., screen size, name of cellular network, and mobile device manufacturer). We use this information to provide our Platform to you, get insights on how people use our Platform so that we can make our Platform better, and understand and make predictions about User retention. Location information: We may determine the approximate location of your Supported Device from your Internet Protocol (IP) address. We may collect and use this information to calculate how many people visit from certain geographic regions or to improve our Platform Services. Information from cookies & other technologies: We may collect information about you through the use of cookies and other similar technologies. A cookie is a string of information that a website stores on a visitor's computer, and that the visitor's browser provides to the website each time the visitor returns. For more information on our use of cookies and similar technologies, please refer to our Cookie Policy. Further, we may also collect information about your End-Users through the use of cookies and other similar technologies, however, we will not collect any Personal Data through such cookies and other similar technologies. Information we collect from other sources: We might receive and collect information about you from other sources in the course of their services to us, such as information received from Third-Party Platforms (as defined in our Terms of Service), information relating your purchase of the Subscription on our Platform through Third-Party Service Providers (as defined in our Terms of Service) or we may receive information about you from a social media site or a Google service if you connect to the Services through that site or if you use the Google sign-in. G. Basis for Collection and Processing of your Personal Data: Basis for collection: We collect and process your Personal Data based on the following legal parameters depending upon the nature of Personal Data and the purposes for which it is processed: Consent: We rely on your consent to process your Personal Data in certain situations. If we require your consent to collect and process certain Personal Data, as per the requirements under the applicable Data Protection Laws, your consent is sought at the time of collection of your Personal Data and such processing will be performed where consent is secured. Compliance with a legal obligation: Your Personal Data may be processed by us, to the extent that such processing is necessary to comply with a legal obligation. Processing of your Personal Data: We may process your Personal Data in connection with any of the purposes and uses set out in this Policy on one or more of the following legal grounds: Because it is necessary to perform the Services you have requested or to comply with your instructions or other contractual obligations between you and us; To comply with our legal obligations as well as to keep records of our compliance processes; Because our legitimate interests, or those of a third-party recipient of your Personal Data, make the processing necessary, provided those interests are not overridden by your interests or fundamental rights and freedoms; Because you have chosen to publish or display your Personal Data on a public area of the Platform, such as a comment area; Because it is necessary to protect your vital interests; Because it is necessary in the public interest; or Because you have expressly given us your consent to process your Personal Data in a particular manner. We do not use Personal Data for making any automated decisions affecting or creating profiles other than what is described in this Policy. Where the processing of your Personal Data is based on your consent, you have the right to withdraw your consent at any point in time in accordance with this Policy. Please note that should the withdrawal of consent result in us not being able to continue offering our Services to you, we reserve the right to withdraw or cease from offering our Services to you upon your consent withdrawal. You may withdraw consent by contacting us with a written request to the contact details provided in the 'Grievances' section below. Upon receipt of your request to withdraw your consent, the consequences of withdrawal may be communicated to you. Upon your agreement to the same, your request for withdrawal will be processed. H. How we Use and Share the Information Collected We use/process your information in the following manner: To provide Services on our Platform: We use your information as collected by us to allow you to access the Platform and the Services offered therein, including without limitation to set-up and maintain your account, provide customer service, fulfil purchases through the Platform, verify User information and to resolve any glitches with our Platform. The legal basis for this processing is consent or, where applicable, our legitimate interests in the proper administration of our Platform, and/or the performance of a contract between you and us. To improve our Platform and maintain safety: We use your information to improve and customize the Platform and Services offered by us, including providing automatic updates to newer versions of our Platform and creating new features based on the Platform usage analysis. Further, we also use your information to prevent, detect, investigate, and take measures against criminal activity, fraud, misuse of or damage to our Platform or network, and other threats and violations to TopMate's or a third party's rights and property, or the safety of TopMate, its users, or others. The legal basis for this processing is consent or, where applicable, our legitimate interests in the proper administration of our Platform, and/or the performance of a contract between you and us. To market our Platform and communicate with You: We will use your information to develop a more targeted marketing of our Platform, to communicate with you about our offers, new products, services or even receive your feedback on the Platform. The legal basis for this processing is consent or, where applicable, our legitimate interests in the proper administration of our Platform, and/or the performance of a contract between you and us. To establish, exercise, or defend legal claims: We may process any Personal Data identified in this Policy when necessary for establishing, exercising, or defending legal claims, whether in court, administrative, or other proceedings. The legal basis for this processing is our legitimate interest in the protection and assertion of our legal rights, your legal rights, and the legal rights of others. To manage risk and obtain professional advice: We may process any of the Personal Data identified in this Policy to manage risk or obtain professional advice. The legal basis for this processing is our legitimate interest in the proper protection of our business and Platform. Consent: We may otherwise use your information with your consent or at your direction. To Better Understand Our Users: We may use information we gather to determine which areas of the Services are most frequently visited to understand how to enhance the Services. We share the information collected as per terms of this Policy only in the manner specified hereinbelow. We do not sell or otherwise disclose Personal Data we collect about you for monetary or other valuable consideration. Further, only authorized representatives of TopMate and on a need-to-know basis use any information received from you and as consented by you. In the event of any identified unauthorized use or disclosure of information or upon your complaint as stated under the 'Grievances' section below, we will investigate any such complaint and take the appropriate action as per the applicable Data Protection Laws. You are responsible for protecting your Page Users Data that you collect, and for processing that information in accordance with applicable privacy laws including the Data Protection Laws. Information shared with Creator's End-Users of the Platform: When a Creator creates an account and makes available Content on the Platform, the Content on Creator's Page will be viewable by their End-Users. Please note that all information shared by you, whether as part of your public profile or Content, in Public Forums, or other public portions of the Creator's Page, is deemed as public information. Since the same is publicly available, we cannot control how others treat it; so please keep that in mind when deciding what information, you choose to include, and refrain from sharing your Sensitive Personal Data and those of others. Other ways we may share Information: Affiliates and Subsidiaries: We may disclose information about you to our affiliates, subsidiaries and other businesses under the same control and ownership, and their respective officers, directors, employees, accountants, attorneys, or agents, who need the information to help us provide the Services or process the information on our behalf or as stated in our Terms of Service. We require our affiliate, subsidiaries and other businesses under the same control and ownership to follow this Privacy Policy for any Personal Data that we share with them. Third-party vendors/service providers including integrated services on the Platform: We may share information about you with third-party vendors or service providers (including consultants, payment processors, and other service providers and integrated services) who need the information to provide their support services to us or you, or to provide their services to you on our behalf either directly or through the Platform. These services may include providing customer support, performing business and sales analysis, supporting our website functionality, facilitating payment processing, and supporting contests, surveys, and other features offered on our Platform. Such third-party vendors are not allowed to use the information for any purpose other than what it was provided for, and they are required to process and use the information in accordance with this Privacy Policy. Legal Disclosures: We may disclose information about you in response to a court order, or other governmental request. Without limitation to the foregoing, we reserve the right to disclose such information where we believe in good faith that such disclosure is necessary to: