PRIVACY POLICY

Effective Date: 01.12.2025

Swaraaj Ecosystem Private Limited and/or its affiliates (“Company”, “we”, “us”, or “our”) respect your privacy and are committed to protecting it through this Privacy Policy (“Policy”).

This Policy explains:

The types of information we may collect from you when you access or use our website, mobile application, or any other online service (collectively referred to as the “Services”); and

Our practices for collecting, using, maintaining, protecting, and disclosing such information.

By accessing or using our Services, or by registering for an account with us, you agree to this Policy and consent to our collection, use, disclosure, and retention of your information as described herein.

We encourage you to review this Policy carefully. We may update this Policy periodically, and your continued use of our Services after any changes constitutes your acceptance of the revised Policy.

1. Applicability of the Policy

1.1 This Policy applies to information that the Company collects through its Services, including emails, text messages, and other electronic communications sent through or in connection with the Services.

1.2 This Policy does not apply to any information you provide to, or that is collected by, any third party that you interact with in connection with our Services. We encourage you to review the privacy policies of such third parties directly.

2. Collection of Information

2.1 General Overview

Some parts of our Services can be used without revealing personal information. However, certain features may require you to provide personal data. We also collect non-personal information, such as the web pages you visit, to improve our Services.

You are responsible for ensuring the accuracy of the personal information you provide, as inaccurate information may affect your use of the Services and our ability to communicate with you.

2.2 Types of Information Collected

We may collect the following categories of information:

Personal Information: Data that can identify you as an individual, such as your name, email address, contact number, date of birth, educational qualifications, occupation, marital status, income details, residential address, Aadhaar number, PAN, and similar identifiers.

Technical and Usage Information: Data about your internet connection, the devices you use to access our Services, and details of your interaction with our platform.

2.3 Sources of Information

We may collect information:

• Directly from you when you provide it;

• Automatically as you navigate through our Services (e.g., via cookies, analytics tools, or similar technologies); and/or

• From third-party sources, such as delivery partners or payment processors, to enhance accuracy and service quality.

2.4 Information You Provide

Account Information: When creating an account, we may collect details such as your name, email address, phone number, postal code, and password. You may also link social accounts (e.g., Google or Facebook), in which case we collect the information shared through those platforms.

Preferences: Your time zone, language, and other personal settings.

Content and Interactions: Information you share through our Services — such as reviews, photos, comments, order details, and communication with other users or sellers.

Searches and Activities: Search terms used, pages viewed, advertisements clicked, and features accessed.

Communications: Your communications with us, including support requests, survey responses, or participation in promotions or contests.

Transactional Information: Data required to process your transactions, including billing and payment details, which may be shared securely with PCI-compliant payment processors.

Public Posts: Any content you post publicly (reviews, ratings, comments, etc.) is shared at your own risk. We cannot control how others may use or share such content.

We use this information to personalize your experience, improve our Services, communicate with you, display relevant advertisements, and comply with our legal obligations.

2.5 Information Collected Automatically

Usage Data: Details of your interaction with our Services, such as access times, pages viewed, features used, and navigation paths.

Device Information: Information about your device and network (e.g., IP address, browser type, operating system, mobile network, and device identifiers).

Stored Files and Metadata: Access to certain files (e.g., photos, contacts, or media) may be requested with your permission for specific features.

Location Data: Real-time location information from your device, if you grant permission.

Mobile Device IDs: Unique identifiers (e.g., IDFA, GAID) may be used for analytics and advertising purposes.

Activity Logs: Details such as search queries, pages visited, time spent, clicks, and error logs.

Application Data: Information about other applications on your device may be collected (with your consent) to better personalize your experience and provide tailored recommendations.

3. Use of Information

We use the information we collect from and about you for various lawful purposes, including but not limited to the following:

3.1. Purchase and Delivery of Products and Services

To process and fulfill your orders, deliver products and services, manage payments, and communicate with you regarding your purchases, transactions, and promotional offers.

3.2. Providing, Troubleshooting, and Improving Services

To operate, maintain, and enhance the functionality, performance, and user experience of our Services, fix technical issues, and improve usability and effectiveness.

3.3. Recommendations and Personalization

To identify your preferences, recommend products, services, and features that may interest you, and personalize your overall experience. We may also share your preferences or activities with your network within the platform for marketing or promotional purposes, where permitted.

3.4. Legal Compliance

To comply with applicable laws and regulations, such as verifying the identity of sellers or collecting tax-related information.

3.5. Communication

To communicate with you via multiple channels (including email, phone, and chat) about your account, our Services, updates, and promotional messages.

3.6. Advertising

To display personalized or interest-based advertisements related to features, products, and services that may interest you. We do not use personally identifiable information for displaying interest-based ads.

3.7. Fraud Prevention and Credit Risk Management

To prevent, detect, and investigate fraud, abuse, or unauthorized access and to manage credit risks.

3.8. Contests and Promotions

To administer sweepstakes, contests, surveys, and similar promotional activities.

3.9. Contractual Obligations

To fulfill our contractual obligations and enforce rights under agreements with you, including for billing, collections, and dispute resolution.

3.10. Research and Analytics

To conduct internal research, generate reports, and analyze user behavior and service usage. We may use anonymized data for research, auditing, and service improvement to better understand user needs and preferences.

3.11. Other Purposes

To fulfill any other purpose disclosed at the time you provide the information, or any other purpose with your explicit consent.

4. Sharing of Information

We may disclose personal information that we collect or that you provide, as described in this Privacy Policy, in the following ways:

4.1. General Disclosures

a. Group Companies: To our holding company, subsidiaries, and affiliates under common ownership or control.

b. Service Partners: To contractors, advertisers, logistics partners, and other third-party vendors who support our business operations (e.g., payment processing, marketing, delivery) under confidentiality agreements.

c. Corporate Transactions: To buyers, successors, or assignees in the event of a merger, acquisition, restructuring, or sale of the Company’s assets.

d. Marketing Partners: To third parties to promote their products or services, where we believe such offers may be relevant to you.

All such third parties are contractually required to keep your information secure and to use it only for the purposes for which it is disclosed.

4.2. Purpose-Based Disclosures

To fulfill the purpose for which you provided the information.

For any other purpose disclosed by us at the time of collection.

For any other purpose with your consent.

4.3. Service Providers

We engage trusted vendors to assist with:

• Sending communications (emails, SMS, or push notifications).

• Payment collection and processing.

• Hosting databases and servers.

• Conducting surveys, marketing, and analytics.

• Organizing contests or promotional activities.

These vendors are provided with information only as necessary to perform their specific functions.

4.4. Legal Requirements

We may share your information when required by law or in good faith belief that such disclosure is necessary to:

• Comply with legal obligations, court orders, or government requests.

• Investigate or prevent potential illegal activity or security threats.

• Protect the rights, property, and safety of the Company, our employees, users, or the public.

4.5. Social Media

If you connect your account or interact with social media features (such as “Like” or “Share” buttons), those platforms may collect data about your interactions with our Services. Such interactions are governed by the privacy policies of the respective social media platforms.

4.6. Enforcement

We may disclose information to enforce our Terms of Use, including for billing and collection purposes or to prevent fraud or credit risks.

4.7. Consent-Based Disclosures

We may share your information in any other circumstance where you have given us explicit consent to do so.

5. Third-Party Links and Services

Our Services may contain links to third-party websites, plug-ins, or applications. Your interactions with these third parties may result in data collection or sharing.

We are not responsible for the privacy practices, content, or data handling of any external sites or services. We encourage you to review their respective privacy policies before providing any personal information.

6. Anonymous or De-Identified Data

We may anonymize or de-identify the data collected from you so that it no longer personally identifies you. Such information may be used for analytics, research, and improvement purposes without restriction and may be shared with third parties.

7. Cookies and Tracking Technologies

7.1. Use of Cookies

Cookies are small text files stored on your device that help recognize you and improve your user experience. We use cookies and similar technologies to:

• Enable certain features of our Services;

• Analyze traffic and usage patterns; and

• Deliver personalized content and advertisements.

You can control or disable cookies through your browser settings. However, disabling cookies may limit your ability to use certain features of our Services.

7.2. Third-Party Cookies

We may use cookies from third-party partners for marketing, analytics, and promotional purposes. The Company is not responsible for cookies placed by external websites or advertisers.

8. Security Precautions

We maintain reasonable administrative, physical, and technical safeguards to protect your personal data against unauthorized access, alteration, disclosure, or destruction.

While we strive to ensure data security, please note that no method of transmission over the Internet or electronic storage is completely secure. You are responsible for maintaining the confidentiality of your account credentials.

9. Permissible Age

Our Services are intended only for users aged 18 years or older, unless otherwise permitted by applicable law.

If you are under 18, you may use the Services only under the supervision of a parent or legal guardian. If we learn that we have inadvertently collected personal data from a minor, we will delete it promptly.

10. Data Retention

You may delete your account through your profile settings or by contacting our Grievance Officer.

We retain personal data for as long as necessary to fulfill the purposes outlined in this Policy or as required by law. After the retention period, we delete or anonymize your data unless it must be retained for legal, compliance, or analytical purposes.

11. Job Applicants

Information submitted through our Services for employment purposes will be used solely for evaluating your application and may be retained for future opportunities. Such data may be shared with affiliated entities or service providers assisting in recruitment.

12. Your Consent

By accessing or using our Services, you consent to our collection, use, storage, and disclosure of your personal information as described in this Policy.

If you provide information about others, you represent that you have the authority to do so and that they consent to such processing.

13. Changes to this Privacy Policy

We may update this Privacy Policy periodically to reflect changes in our practices, technologies, or legal requirements. The latest version will always be available on our website. Your continued use of our Services following any updates constitutes acceptance of the revised Policy.

14. Grievance Officer

In accordance with the Information Technology Act, 2000 and the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, the details of the Grievance Officer are as follows:

Name: Ankit Dagriya

Address:Office No. 1201 & 1202, 12th Floor, Colonnade Building, Above Kalki Showroom, Opp. ISCON BRTS Bus Stand, Iscon–Ambli Road, Ahmedabad – 380054

Email: legalsupport@Handmark.in

15. Contact Us

If you have any questions, concerns, or complaints regarding this Privacy Policy or the handling of your personal information, you may contact us using the details provided above in Clause 14.