Introduction

Sumeru Digital Solutions Private Limited (Sumeru Digital), respects your privacy and
is committed to protecting the privacy and security of your personal data. This
Privacy Policy document contains types of information that is collected and recorded
by Sumeru Digital in a manner consistent with your rights and our obligations under
the applicable law. Our commitment to transparency and integrity is making sure you
understand what data we collect, how we use it and how it may be shared.

Please read this Privacy Policy carefully and ensure that you understand it. By
accessing our website, mobile application, or any other services we offer, you hereby
consent to our Privacy Policy. If you do not agree to this Policy, do not access or use these
sites and services. By continuing to use the sites and services, you are authorizing your
acceptance of the terms and conditions explained in this Policy.

Notice of Data Collection

We want you to know that we collect personal information actively and passively, and we
sometimes obtain information from third-party sources in the following manner:

Information you provide to us: You may provide us with personal data when you sign
up for our services, make a purchase, or contact us.
Information we collect automatically: We may automatically collect certain data
when you use our website or services. This may include usage data, device data, and
location data.
Information from third parties: In some cases, we may receive certain Personal Data
from you about a third party. For example, when you contact us, you may provide the
name and email address of a third party. If you submit any Personal Data about
another individual to us, you are responsible for making sure that you have the
authority to do so and to allow us to use their Personal Data in accordance with this
Privacy Policy.

Types of Data Collected

We also want you to know that we may collect the following types of data from you:

Personal Data: Name, address, email address, phone number, date of birth and any
other information that can be used to identify you.

Non-Personal Data: We may collect data that does not personally identify you, such
as demographic information, IP addresses, browser type, operating system, and other
usage data.

Use of Data

We use the Personal Data we collect to provide the Services to you, to improve our
Services and Site, and to protect our legal rights.

(a) In addition, we may use the Personal Data we collect for the following purposes:
(i) Register your account; (ii) Subscribe you to our newsletter; (iii) Process your job
application; (iv) Contact you regarding our products and services that we feel may be
of interest to you; (v) To provide you with our services and processing payments; (vi)
Communicate with you about our Site or Services or to inform you of any changes to
our Site or Services; (vii) Provide customer care and support; (viii) To maintain and
improve our Site and Services; (ix) To investigate, prevent, or take action regarding
illegal activities, suspected fraud, situations involving potential threats to the physical
safety of any person, or violations of our terms of use; (x) Defend our legal rights and
the rights of others; (xi) Efficiently maintain our business; and (xii) Comply with
applicable law.

b) All personal data is stored securely in a manner that reasonably protects it from
misuse and loss and from unauthorized access, modification or disclosure.

c) In some cases, the collection of data may be a statutory or contractual requirement.

d) Legal basis: We will ensure that your personal data is processed lawfully, fairly,
and transparently, without adversely affecting your rights. We will only process your
personal data if at least one of the following basis applies: (i) you have given consent
to the processing of your personal data for one or more specific purposes; (ii)
processing is necessary for the performance of a contract to which you are a party or
in order to take steps at the request of you prior to entering into a contract; (iii)
processing is necessary for compliance with a legal obligation to which we are
subject; (iv) processing is necessary to protect the vital interests of you or of another
natural person; (v) processing is necessary for the performance of a task carried out in
the public interest or in the exercise of official authority vested in the controller
and/or processing is necessary for the purposes of the legitimate interests pursued by
us or by a third party, except where such interests are overridden by the fundamental
rights and freedoms of the data subject which require protection of personal data.

e) Sensitive Information: Sensitive information as defined under the relevant national
data privacy laws, will be used by us only: (i) for the primary purpose for which it was obtained; and/or (ii) with your consent; or where required or authorized by
applicable law.

Data Sharing

We may share your data with the following third parties, and we ensure that the Data
will only be shared and used within the bounds of the law:
We may share the information that we collect about you in the following ways:

Service Providers: (i) We may share your data with third-party service providers who
assist us in providing our services, such as payment processors and marketing
providers; (ii) To service providers to prepare, deploy and analyze advertising
content.
Legal Compliance: We may share your data to comply with legal obligations or to
protect our rights or the rights of our users. In certain circumstances, we may be
legally required to share certain data held by us, which may include your personal
information, for example, where we are involved in legal proceedings, where we are
complying with the requirements of legislation, a court order, or a governmental
authority. We do not require any further consent from you in order to share your data
in such circumstances and will comply as required by any legally binding request that
is made of us.
Business Transfers: In the event of a merger, acquisition, or sale of assets, we may
transfer your data to the acquiring entity. Any such party with whom Sumeru Digital
merges or who acquires some of all of the assets of Sumeru Digital may not have the
same or similar privacy guidelines as set forth in this Privacy Policy and may use
personally identifiable information in a manner other than as set forth herein.
To any other person or entity where you consent to the disclosure.

Data Protection

We take appropriate measures to protect your personal data from unauthorized access,
alteration, disclosure, or destruction. We also require our service providers to take
appropriate security measures. However, no security measure or modality of data
transmission over the Internet is 100% secure. Although we strive to use
commercially acceptable means to protect your Personal Data, we cannot guarantee
absolute security.

Your Rights

We would like to make sure you are fully aware of all of your data protection rights.
Every user is entitled to the following rights under European Union’s General Data
Protection Regulations (GDPR) and California Consumer Privacy Act (CCPA)
regarding your personal data:
Although data stored on the Blockchain network may be immutable, but we are
committed to respecting your rights under the GDPR and CCPA and we will provide
you with the necessary information and assistance to exercise your rights to the fullest
extent possible. You have following rights:

Right to Correction: You have the right to request correction of any inaccurate
or incomplete personal data we hold about you.
Right to Object: You have the right to object to the processing of your
personal data in certain circumstances.
Right to Rectification: If you believe that your personal data stored on the
Blockchain network is inaccurate or incomplete, please contact us using the
details provided in Section Contact Information to request rectification.
Right to Restriction of Processing: In certain circumstances, you may have the
right to request the restriction of processing of your personal data on the
Blockchain network. Please contact us using the details provided in Section
Contact Information to exercise this right.
 Right to Deletion: You can ask us to delete your Personal Data if:
(i) We no longer need it for the purposes for which we collected it;
(ii) We have been using it with no valid legal basis;
(iii) We are obligated to erase it to comply with a legal obligation to which
we are subject;
(iv) We need your consent to use the information and you withdraw
consent;
(v) You object to us processing your Personal Data where our legal basis
for doing so is our legitimate interests and there are no overriding
legitimate grounds for the processing.
However, this right is not absolute. Even if you make a request for
deletion, we may need to retain certain information for legal or
administrative purposes, such as record keeping, maintenance of opt-
out requirements, defending or making legal claims, or detecting
fraudulent activities. If you do exercise a valid right to have your
Personal Data deleted, please keep in mind that deletion by third
parties to whom the information has been provided might not be
immediate and that the deleted information may persist in backup
copies for a reasonable period (but will not be available to others).

Data Minimization: We collect and process personal data in a manner that
ensures the data is adequate, relevant, and limited to what is necessary.
Make a Complaint: If you have any concerns about the processing of your
personal data, please make a complaint at [email protected] and

we will do our best to answer any question and resolve any
complaint to your satisfaction.
We also want you to know, that under CCPA, you have an important right of not
being discriminated:
 Right to Non-Discrimination: Sumeru Digital will never discriminate against
you for exercising any of your CCPA rights described in this Privacy Policy.
Unless permitted by the CCPA, we will not:
(i) Deny you services;
(ii) Charge you different prices or rates for services, including through
granting discounts or other benefits, or imposing penalties;
(iii) Provide you a different level or quality of services;
(iv) Suggest that you may receive a different price or rate for services or a
different level or quality of services;

If you make a request, we have one month to respond to you. If you would like to
exercise any of these rights, please contact us.

Cookie Policy

We use cookies on our website/application/service to make it work efficiently and
improve its performance. These cookies include essential cookies for the functioning
of the Service, analytics cookies for performance enhancement, and advertising
cookies to deliver relevant ads. Third-party service providers may also place cookies
through our Service. By using our Service, you consent to the use of cookies. You can
use to opt-out of our use of cookies and you can manage cookie preferences through
your browser settings. Please note that disabling cookies may impact the functionality
of the Service. For more information, Please see our Cookie policy.

Changes to this Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any
material changes by posting the new policy on our website. We encourage you to
review this Privacy Policy periodically. These changes are effective immediately,
after they are posted on this page.

Contact Us

Sumeru Digital shall periodically verify that related policies are accurate,
comprehensive for the information intended to be covered, prominently displayed,
implemented, and are in conformity with the principles of this Privacy Policy.
This Privacy Policy shall be reviewed annually and updated as necessary to comply
with the applicable regulations. Sumeru Digital shall post any revised Privacy Policy
on its website, or a similar website that replaces that website.
If you have additional questions or require more information about our Privacy
Policy, do not hesitate to contact us at [email protected]