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PRIVACY POLICY

Last Updated: 10th October, 2026

THIS PRIVACY POLICY OF THE PLATFORM (“POLICY”) IS AN ELECTRONIC RECORD IN TERMS OF THE INFORMATION TECHNOLOGY ACT, 2000 AND THE RULES MADE THEREUNDER. THIS ELECTRONIC RECORD IS GENERATED BY A COMPUTER SYSTEM AND DOES NOT REQUIRE ANY PHYSICAL OR DIGITAL SIGNATURES.

THIS DOCUMENT IS PUBLISHED IN ACCORDANCE WITH RULE 3(1) OF THE INFORMATION TECHNOLOGY (INTERMEDIARY GUIDELINES AND DIGITAL MEDIA ETHICS CODE) RULES, 2021, READ WITH THE INFORMATION TECHNOLOGY ACT, 2000, WHICH REQUIRE THE PUBLICATION OF THE RULES AND REGULATIONS, PRIVACY POLICY, AND TERMS OF USE FOR ACCESS TO OR USE OF THE PLATFORM.

Welcome to MyProcureHub!

This Policy applies to the MyProcureHub platform, including the website at https://www.myprocurehub.com, its domains, sub-domains, mobile application and all products, features and services offered thereon (“Platform”).

The Platform is owned and operated by Brilliance Innovation Private Limited, a company incorporated under the laws of the Republic of India (hereinafter referred to as the “Company”, “we”, “us”, or “our”).

The Company is committed to respecting your online privacy and recognises your need for appropriate protection and management of any information you share with the Company on and through the Platform. This Policy explains how we collect, use, share, store and otherwise process information in relation to the Services (as defined in the Platform Terms) made available on the Platform. In the event of any inconsistency between this Policy and the Platform Terms or the applicable User Terms, this Policy shall prevail in respect of the collection, use, storage, disclosure and other processing of personal data, and the Platform Terms or the applicable User Terms, as the case may be, shall prevail in respect of all other matters.

This Policy is being framed in view of the Information Technology Act, 2000 and the rules made thereunder, the Digital Personal Data Protection Act, 2023 (“DPDP Act”) and the rules made thereunder.

This Policy shall be deemed to be incorporated into the Platform Terms and Conditions (“Platform Terms”) and where applicable, the Buyer Terms and Conditions and the Seller Terms and Conditions (collectively, the “User Terms”) and shall be read in addition to them.

BY COMPLETING REGISTRATION, CLICKING “ACCEPT” OR “I AGREE”, OR BY OTHERWISE ACCESSING OR USING THE PLATFORM IN ANY MANNER, YOU UNCONDITIONALLY ACCEPT AND AGREE TO BE BOUND BY THIS POLICY. IF YOU DO NOT AGREE TO THIS POLICY, YOU MUST IMMEDIATELY CEASE ALL ACCESS TO AND USE OF THE PLATFORM. BY ACCEPTING THIS POLICY, YOU UNDERSTAND AND AGREE TO THE COLLECTION, USE, SHARING AND PROCESSING OF PERSONAL DATA AS DESCRIBED HEREIN.

If you are unwilling or unable to be legally bound by this Policy, please do not use the Platform. You cannot accept this Policy if: (a) you are not lawfully entitled to use the Platform; or (b) you are not of legal age to form a binding agreement with the Company in accordance with Applicable Law.

Unless otherwise defined in this Policy, all capitalised terms used herein shall have the same meaning assigned to them in the Platform Terms and where applicable, the Buyer Terms and Conditions and the Seller Terms and Conditions. In the event of any inconsistency between a definition in this Policy and a definition of the same term in the Platform Terms or the User Terms, the definition in this Policy shall prevail for the purposes of this Policy.

Please read this Policy carefully.

1. SCOPE OF THIS POLICY

1.1. By accessing or using the Platform or otherwise giving us your information, you undertake that you have the capacity to enter into a legally binding contract vide this Policy, which constitutes a legally binding document between you and the Company under Applicable Law, in particular the Indian Contract Act, 1872 and the DPDP Act. If you accept this Policy on behalf of an organisation or other legal entity, you represent and warrant that you have full authority to bind such organisation or legal entity to the terms of this Policy.

1.2. This Policy applies to all Information (defined below) collected through or in connection with the Platform, and to all Users, whether accessing or using the Platform as a Buyer, as a Seller, or otherwise, and to all persons authorised by a User to access or use its Account.

1.3. This Policy does not apply to any Underlying Transaction concluded directly between a Buyer and a Seller, to any information exchanged between them otherwise than through the Platform, to the processing of any Information by a User after its disclosure through the Platform, to any third-party website or service linked from the Platform, or to any information collected by the Company otherwise than through the Platform. Where a User determines the purposes and means of processing the personal data of another User or of any individual, including in connection with an Underlying Transaction or any dealing outside the Platform, that User acts as an independent data fiduciary in its own right and is solely responsible for its own compliance with Applicable Law, including the DPDP. The Company bears no responsibility for such processing.

1.4. This Policy seeks to ensure that any personal data handled by the Company is managed in an ethical and compliant manner.

1.5. This Policy describes the types of Information the Company collects, why and how the Company uses such Information, the circumstances in which such Information may be shared and with whom, the period for which such Information is retained, and the choices and rights available to you in relation to the Company’s handling of such Information. This Policy also describes the measures adopted by the Company to protect the security of such Information and how you may contact the Company in relation to its privacy practices.

2. MINOR

2.1. For the purposes of this Policy, a “minor” means an individual who has not attained the age of eighteen (18) years (being a “child” for the purposes of DPDP Act. The Company does not intend to attract a minor to enter into a binding legal contract and does not intentionally or knowingly collect Information from any minor. The Company encourages parents and guardians to be involved in the online activities of minors to ensure that no Information is collected from a minor without their prior consent. The Company does not undertake any tracking or behavioural monitoring of minors and does not direct any advertising towards minors.

2.2. The Platform is intended solely for use by business entities and organisations acting through their authorised representatives, each of whom must have attained the age of eighteen (18) years. By registering an Account or otherwise accessing or using the Platform, you represent and warrant that neither you nor any person you authorise to access or use the Account is a minor.

2.3. If the Company becomes aware that any personal information relating to a minor has been collected through the Platform, the Company shall, as soon as reasonably practicable, cease processing such Information and shall delete the same, and at its discretion, may suspend or terminate the relevant Account, without any liability to the User and without any obligation to refund any fees paid.

3. TYPES OF INFORMATION COLLECTED BY THE COMPANY

This Clause describes the type of Information the Company collects through the Platform, grouped into categories for clarity. The Information collected depends on the manner in which you access and use the Platform and the capacity in which you do so.

3.1. Personal Information: “Personal Information” means any data about an individual who is identifiable by or in relation to such data, that is collected, received, accessed, stored, or otherwise processed in connection with the Platform and its Services. Personal Information may include, where applicable, contact information, demographic information, professional or business information, profile information, identity and verification information and location information.

3.2. Registration and Identity Information: Information we collect at the time of registration and thereafter in order to sign in and maintain your Account and to identify the User. This includes the name of the organisation, entity type and constitution, its addresses, the name, designation, email address and mobile number, alternate contact details and details of persons authorised to act on behalf of the organisation, and the profile attributes displayed on the Platform such as industry, organisation size, location and budget range.

3.3. Verification and KYC Information: Information collected for the purposes of identity confirmation, credential verification, due diligence and prevention of fraud or misuse. This includes PAN, GSTIN and other tax registrations, CIN, licenses, registrations, approvals, certifications and authorisations relating to the goods or services offered, including authorisations evidencing the Seller’s entitlement to offer the relevant goods or services (such as manufacturer, authorised distributor, channel partner, reseller or cloud service provider authorisations), KYC documents and officially valid documents furnished in respect of the organisation or its authorised representatives.

3.4. Account and Authentication Information: Information collected to enable secure access to and administration of your Account. This includes your registered email address and mobile number, one-time passwords and other authentication credentials, records of log-in, log-out and authentication events, access permissions assigned to persons using the Account, and records of authentication of an award through the applicable authentication mechanism made available on the Platform.

3.5. Procurement Information: Information generated or submitted in the course of your participation in a Procurement Process on the Platform. This includes Requirements posted, together with specifications, quantities, delivery locations, timelines, budget parameters, payment terms, evaluation criteria and eligibility conditions, Bids submitted, together with pricing, commercial terms, technical proposals, supporting documentation and any revisions or withdrawals, records of participation in tenders, bidding processes and reverse auctions including timestamps, shortlisting and award decisions, Award Confirmation Certificates and the particulars recorded therein including the identity of the Buyer and the selected Seller, the awarded line items, quantities and value, the applicable Platform Fee and the audit trail identifier, Private Marketplace records including invitations issued, participants and eligibility criteria applied, and communications exchanged between Users through the Platform in connection with a Requirement, Bid or Transaction.

3.6. Profile, Rating and Score Information: Information relating to your conduct and performance on the Platform which is used to generate profile scores, ratings, rankings and related outputs. This includes Reviews submitted by you and Reviews received in respect of you, aggregate ratings, profile scores and any adjustment made to them, records of withdrawal or cancellation of Requirements, failure to proceed with or honour an awarded Transaction, breaches of the Platform Terms or the User Terms, payment history in respect of amounts due to the Company, and rankings, visibility levels and matching outcomes generated by the Platform.

3.7. Billing and Payment Information: Information collected in connection with amounts payable by you to the Company. This includes billing entity name and address, Goods and Services Tax Identification Number, invoice and payment records, subscription plan and billing history, transaction reference numbers, and payment instrument or payment gateway tokens processed through the Company’s authorised payment service providers. The Company does not collect, receive, hold or facilitate any payment made between a Buyer and a Seller in respect of an Underlying Transaction.

3.8. Communication Information: Information shared, recorded or generated during your interactions with the Company. This includes correspondence with the Company by email, telephone, chat or through the Platform, support and service requests, communications and chat messages exchanged between Users through the messaging or chat functionality made available on the Platform in connection with a Requirement, Bid or Transaction, grievances, complaints and reports submitted under the Platform Terms or the User Terms, responses to surveys, feedback and questionnaires, and notices and other communications issued by the Company to you.

3.9. Technical and Usage Information: Information collected automatically when you access or use the Platform, whether directly or through third-party analytics service providers. This includes IP address, browser type and version, operating system, device type, hardware model, unique device identifiers, device location, preferred language, referring and exit pages, server, access, activity, transaction and error logs of various nature, cookies and similar technologies, session duration, pages viewed and the order in which they were viewed, search queries, number of clicks, and other data indicating the mode and manner of your use of the Platform.

3.10. Non-Personal Information: Information which does not, in itself, identify an individual or an organisation. This includes aggregated statistics relating to the number of visitors to the Platform, aggregate traffic and usage patterns, and information voluntarily submitted by you in response to a questionnaire or survey conducted by the Company.

3.11. Personal Information, Registration and Identity Information, Verification and KYC Information, Account and Authentication Information, Procurement Information, Profile, Rating and Score Information, Billing and Payment Information, Communication Information, Technical and Usage Information and Non-Personal Information shall hereinafter collectively be referred to as “Information”. The Company limits the collection of Information to that which is necessary for its intended purpose.

3.12. For the purposes of this Policy, the categories of Information described above shall include not only the specific items listed, but also any associated, incidental, supplementary, derivative or related information that may reasonably be collected, generated, stored, processed or disclosed in connection with the purposes described in this Policy, compliance with Applicable Law, or performance of contractual obligations. The examples provided under each category are illustrative and not exhaustive.

4. CONSENT

4.1. By accepting the Platform Terms and, where applicable, the User Terms and this Policy, by creating or registering an Account, by accessing or otherwise using the Platform, or by voluntarily providing your Information, you expressly consent (where such consent is required under Applicable Law) to the collection, use, storage, disclosure and processing of your Information by the Company in accordance with this Policy and the applicable provisions of DPDP Act and other Applicable Law. Such acceptance constitutes a valid and binding agreement between you and the Company in relation to the processing of your Information.

4.2. By registering on the Platform and accepting this Policy, you consent to receiving communications from the Company through SMS, WhatsApp, email, in-app notifications, push notifications (where enabled) and telephone calls, using your registered contact details. Such communications may include without limitation account registration and verification messages, one-time passwords and authentication and login alerts, notifications relating to Requirements, Bids, shortlisting, awards and the generation of Award Confirmation Certificates, Private Marketplace invitations, invoices and Platform Fee and payment reminders, customer support responses, responses to grievances and complaints, service-related and security announcements, Platform updates, promotional or marketing communications. You may opt out of receiving marketing communications at any time, using the unsubscribe facility provided in each such communication or by writing to the Company at its published contact details. Communications that are administrative, transactional, security-related or otherwise necessary for the provision of the Platform and its Services may not be available to be opted out of.

4.3. The Company shall continue to retain such of your Information as it is required or permitted to retain under Applicable Law, notwithstanding the withdrawal of your consent or the closure of your Account.

4.4. If you provide the Company with personal data relating to any individual other than yourself, you confirm that (a) such personal data is accurate and up to date; (b) such individual is aware that you have provided their personal data to the Company; and (c) such individual has consented to both the disclosure and the processing of their personal data in accordance with this Policy and Applicable Law. You agree to indemnify and hold the Company harmless against any claim, demand, loss, liability, penalty or cost arising out of or in connection with a breach of the confirmations in this Clause, including any claim brought by such individual or any proceeding initiated by the Data Protection Board of India.

4.5. You hereby acknowledge and agree that all Information is provided by you to the Company voluntarily and the Information provided by you is not subject to any undue influence.

5. COLLECTION OF INFORMATION

5.1. The Company may collect Information directly from you when you (a) register an Account or update your Account or profile details; (b) furnish documents or credentials for verification; (c) post a Requirement, submit a Bid, participate in a Procurement Process or authenticate an award; (d) participate in a Private Marketplace; (e) submit a Review, report, complaint or grievance; (f) subscribe to or use any paid or premium feature; (g) correspond with the Company or respond to a survey or feedback request; or (h) otherwise access or use the Platform.

5.2. The Company may collect Technical and Usage Information automatically when you access or use the Platform, including through cookies and similar technologies as described in this Policy and through third-party analytics service providers engaged by it.

5.3. The Company may collect Information relating to you from sources other than you, including from verification service providers and document verification agencies engaged by it, from publicly available registries and databases maintained by government departments, regulators or other authorised agencies, from publicly available online sources, social media and other public platforms, for the purpose of verifying the Information furnished by you, and from other Users who submit a Review, report, complaint or grievance concerning you.

5.4. The Company may generate Information relating to you in the course of operating the Platform, including audit trails and records of Platform activity, Award Confirmation Certificates and audit trail identifiers, and profile scores, ratings, rankings, benchmarks and risk indicators generated through AI Features.

5.5. Where you access the Platform through a mobile application, the Company may request access to the files, photographs or camera on your device in order to enable you to upload documents to the Platform. Such access shall be sought only with your authorisation and shall be used solely for the purposes described in this Policy. You may withdraw or manage such access at any time through your device settings, in which case certain features requiring such access may not function.

5.6. Information collected by the Company from a particular browser or device may be used with another computer or device that is linked to the browser or device on which such Information was collected.

5.7. You may choose not to provide certain Information; however, such choice may prevent you from registering an Account, participating in a Procurement Process or accessing certain Services.

6. PURPOSE AND USE OF INFORMATION

6.1. The Company uses the Information collected by it to: (a) register, administer and maintain your Account and verify your identity; (b) provide, operate, maintain and improve the Platform and the Services; (c) conduct and administer Procurement Processes, including the publication of Requirements, submission and evaluation of Bids, shortlisting, award and generation of Award Confirmation Certificates; (d) facilitate the disclosure of identity and other information between a Buyer and a Seller; (e) generate profile scores, ratings, rankings, benchmarks and risk indicators, and operate AI Features; (f) raise and recover invoices in respect of Platform Fees, subscription fees and premium-feature fees; (g) communicate with you in relation to your Account, a Procurement Process, a Transaction or an invoice, and respond to your enquiries, complaints and grievances; (h) maintain electronic records and audit trails of Platform activity; (i) maintain the security and integrity of the Platform and detect, prevent and investigate fraud, collusion, bid-rigging, unauthorised access, circumvention of the Platform and other misuse; (j) enforce the Platform Terms, the applicable User Terms and this Policy and establish, exercise or defend legal claims; (k) comply with Applicable Law and respond to any order or lawful requirement of a court, tribunal, regulator or other competent authority; (l) conduct internal research, analytics and audits to develop and improve the Platform and the Services and (m) carry out data analytics to understand usage and improve the Platform and the Services; and (n) undertake marketing, cross-selling and up-selling of products, services and features.

6.2. The Company may create aggregated, de-identified or anonymised data from the Information, from which you are no longer identifiable, and may use such data for analytics, benchmarking, reporting, research and service improvement.

7. AI FEATURES AND THIRD-PARTY TECHNOLOGY PROVIDERS

7.1. The Company may process your Information through AI Features, including through models, infrastructure or services provided by third-party technology providers. Such providers act as data processors and process your Information only on the instructions of the Company, under a valid contract, for the purposes specified by the Company, and subject to obligations of confidentiality and data security.

7.2. The Company shall not permit your Information to be used by a third-party technology provider for the training or improvement of that provider's own models except with your consent.

8. IDENTITY, ANONYMITY AND DISCLOSURE BETWEEN USERS

8.1. Certain Procurement Processes may be conducted on an anonymous or partially anonymised basis, in which case a Seller may be shown only limited profile attributes of the Buyer prior to an award and a Buyer may be shown only limited information concerning the Seller.

8.2. You consent to the Platform disclosing your identity and other Information to another User (a) in the case of a Seller, at the shortlist, award or such other stage as may be specified on the Platform; (b) in the case of a Buyer, to the selected Seller following an award; (c) where you participate in a Private Marketplace, to the extent necessary to operate that environment; and (d) where another User uses a paid feature which permits access to such information.

8.3. The anonymity features of the Platform operate only to limit the information displayed to other Users. They do not anonymise your Information in the hands of the Company, which continues to hold and process it in identifiable form in accordance with this Policy.

8.4. Your profile, together with the profile scores, ratings, rankings and Reviews relating to you, may be displayed to other Users of the Platform. Where you exercise your right of erasure in respect of a Review, the Company may anonymise it rather than delete it, save where deletion is required under Applicable Law.

9. THIRD-PARTY SERVICE PROVIDERS

9.1. The Company engages third-party service providers to operate the Platform, including cloud hosting, authentication and OTP providers, verification agencies, KYC agencies, data analytics providers, marketing service providers, payment gateways, communication and messaging providers, social media and other platforms, customer support tools, analytics providers, cyber security providers, and AI and technology providers. Such providers may access your Information only to the extent necessary to perform their functions, process it only on the instructions of the Company under a valid contract, and are not permitted to use it for any other purpose, save as required under Applicable Law.

9.2. Payments to the Company are processed through third-party payment gateways operating under their own privacy policies. The Company does not store complete payment card details on its systems.

9.3. The Platform may contain links to third-party websites or services which the Company does not control or endorse. Any Information you provide on those websites or services is governed by the privacy policies of the relevant third parties and not by this Policy.

10. YOUR RIGHTS IN RESPECT OF YOUR PERSONAL INFORMATION

10.1. Subject to applicable law, including DPDP Act and the rules made thereunder, you are entitled to exercise the following rights in respect of the Personal Information that the Company holds concerning you:

10.1.1. Right of Access: You may request confirmation as to whether the Company processes your Personal Information and, where it does, a summary of the Personal Information held by the Company and the purposes for which such Personal Information is processed.

10.1.2. Right of Correction and Updating: You may request that the Company correct, complete, or update any Personal Information held by it that is inaccurate, incomplete, or no longer current.

10.1.3. Right of Erasure: You may request the deletion of your Personal Information where the Company no longer has a lawful basis to retain or process such Personal Information, subject to the Company’s legitimate business interests and its obligations under applicable law, including record retention requirements. You acknowledge and agree that certain Information, in particular Procurement Information such as Requirements, Bids, Award Confirmation Certificates, transaction history and the associated audit trails, may be retained by the Company notwithstanding a request for erasure or the withdrawal of consent, where retention is necessary to preserve the integrity of the Platform's records, to protect the rights of other Users, for dispute resolution, or to comply with Applicable Law.

10.1.4. Right to Withdraw Consent: Where the Company’s processing of your Personal Information is based on your consent, you may withdraw such consent at any time by providing written notice to the Company at the contact details specified in this Policy. Withdrawal of consent shall not affect the lawfulness of any processing undertaken prior to such withdrawal. You acknowledge that, following such withdrawal, the Company may be unable to provide certain features of the Platform or may be required to suspend or terminate your account where the processing of such Personal Information is necessary for the provision of the Platform.

10.1.5. Right to Nominate: You may nominate another individual to exercise the rights available under this Clause 10 on your behalf in the event of your death or incapacity, in the manner prescribed under the DPDP Act.

10.1.6. Right to Grievance Redressal: You are entitled to readily available means of grievance redressal in relation to the processing of your Personal Information, as more particularly described in this Policy.

10.2. To exercise any of the rights set out in this Clause, you may submit a written request to the Grievance Officer at the contact details specified in this Policy. The Company shall respond to such requests within the period prescribed under applicable law and may require you to verify your identity before acting upon any request. The Company may refuse or limit a request where compliance would: (a) contravene applicable law or a lawful order of a court or competent authority; (b) prejudice the rights or freedoms of another individual; (c) require the disclosure of another person’s Personal Information; or (d) conflict with the Company’s legal obligations or its right to establish, exercise or defend a legal claim.

10.3. The Company shall make reasonable efforts to correct, update, or delete your Personal Information upon receipt of a valid request and in accordance with applicable law. However, the Company cannot modify, correct, or delete Information that has already been shared with or is independently processed by third parties, including payment service providers or other Users with whom you have chosen to share Information through the Platform. Any request relating to Information held independently by such third parties may need to be addressed directly to them in accordance with their respective privacy policies.

10.4. Nothing contained in this Clause shall require the Company to delete, modify, or cease processing Personal Information that it is required or permitted to retain under applicable law, or that is necessary for the establishment, exercise, or defence of legal claims, prevention of fraud, enforcement of the User Terms or other agreements, resolution of disputes, or compliance with regulatory or contractual obligations.

10.5. You may opt out of receiving marketing or promotional communications at any time by: (a) using the unsubscribe option included in such communications, where available; (b) submitting a written request to the Company at the contact details specified in Clause 19 of this Policy; or (c) contacting the Grievance Officer. The Company shall process any valid opt-out request within a reasonable period. For the avoidance of doubt, opting out of marketing communications shall not affect your receipt of administrative, transactional, security-related, legal, account, payment, or other service-related communications that are necessary for the operation of the Platform or the provision of its Services.

11. DATA RETENTION

11.1. The Company retains Personal Information only for as long as is necessary to fulfil the purposes for which it was collected, including the provision of the Platform and its Services, management of User accounts, dispute resolution, compliance with legal and regulatory obligations, enforcement of the User Terms, or for such longer period as may be required or permitted under applicable law, regulation, court order, or the Company’s legitimate business interests. In determining the appropriate retention period, the Company has regard to the nature and sensitivity of the Information, the purposes for which it is processed, and any applicable legal or regulatory retention requirement.

11.2. Information that does not constitute Personal Information, including Non-Personal Information, Usage Information, aggregated data, and de-identified information, may be retained for such period as the Company considers reasonably necessary for operational, analytical, security, research, product improvement, audit, or other legitimate business purposes, subject to applicable law.

11.3. When your Personal Information is no longer required for the purposes set out in this Policy, or upon closure of your account or a valid withdrawal of your consent, the Company will delete or de-identify such Personal Information within a reasonable period, unless its retention is required or permitted under applicable law, including for the establishment, exercise, or defence of legal claims, the prevention of fraud, or compliance with a legal or regulatory obligation. Where deletion is not immediately feasible, for example where Information is held in secure backups, the Company will securely store and isolate such Information from further processing until deletion is possible.

12. SECURITY OF INFORMATION

12.1. The Company implements appropriate physical, technical, organisational, and administrative safeguards designed to protect the confidentiality, integrity, and security of your Information against accidental or unlawful destruction, loss, alteration, unauthorised access, disclosure, or misuse. Such measures are designed having regard to the nature of the Information processed, the risks involved, and applicable legal requirements.

12.2. The Company considers the security of your Information to be of paramount importance and adopts reasonable security practices and procedures consistent with applicable law and recognised industry standards. Access to Personal Information is restricted to authorised personnel and service providers who require such access for legitimate business purposes and are subject to appropriate confidentiality obligations. While the Company uses commercially reasonable measures to safeguard your Information, no method of transmission over the internet or method of electronic storage is completely secure. Accordingly, the Company cannot guarantee the absolute security of your Information and any transmission of Information to or through the Platform is at your own risk. The Company periodically reviews and updates its security measures to address evolving technological, operational, and regulatory requirements.

12.3. You are responsible for maintaining the confidentiality of your account credentials and for ensuring the security of the devices through which you access the Platform. The Company shall not be liable for any loss, unauthorised access, or misuse of Information resulting from your failure to safeguard your login credentials or devices, or arising from circumstances beyond the Company’s reasonable control, including acts of government, cyberattacks, malware, hacking, unauthorised access to computer systems, failures of telecommunications or internet services, power failures, or other Force Majeure Events.

13. CROSS-BORDER DATA TRANSFERS

13.1. The Company primarily stores and processes your Information on cloud infrastructure located in India. However, in certain circumstances, Your Information may be processed, accessed, or stored by the Company or its authorised service providers or technology partners whose infrastructure or personnel may be located outside India, where such processing is necessary for the operation, maintenance, security, or delivery of the Platform and its Services.

13.2. Where Personal Information is transferred outside India, the Company shall take reasonable steps to ensure that such transfers are carried out in accordance with the DPDP Act, the rules framed thereunder, and other applicable laws.

14. COOKIES

14.1. To enhance your experience with the Platform, many of the web and application pages use “cookies”, pixel tags, and clear GIFs on certain pages of the Platform. Cookies are text files the Company places in your computer’s or mobile’s browser to maintain your log-in and session details. The Company uses three types of cookies: necessary session cookies (including username, email ID, and user access information), which enable the Company to recognise you and make it easier for you to return to the Platform and interact with the Company’s Services without signing in again; preference cookies (including search and browsing history), which are stored for the maximum duration permitted by law; and statistics cookies (including Usage Information such as unique request ID and statistical data), which are stored for 24 hours or the maximum duration permitted by law (collectively referred to as the “Cookies”).

14.2. Cookies, by themselves, do not tell the Company your email address or other personally identifiable information unless you choose to provide this information to the Company by, for example, registering on the Platform or availing the Services provided on the Platform. Cookies are designed to hold a marginal amount of data specific to a particular user and Platform and can be accessed either by the web server or the user device. However, once you choose to furnish the Platform with personally identifiable information, this information may be linked to the data stored in the Cookies. The Company uses Cookies to understand site usage and to improve the content and offerings on the Platform. For example, the Company may use Cookies to personalise your experience on the Platform (such as to recognise you by name when you return) and to offer you products, programs, or services. Cookies may be placed on the Platform by third parties as well, the use of which the Company does not control, and such third-party Cookies are governed by the respective third parties’ privacy policies.

14.3. Cookies are retained in your browser unless specifically deleted, depending on the type of Cookies. If you decline non-essential Cookies, you may be unable to use certain features of the Platform and you may be required to re-enter your password frequently. Necessary Cookies are essential for the operation of the Platform and are placed when you access it; preference and statistics Cookies, and any other non-essential Cookies, are placed only where you have consented through the cookie banner or your browser settings. You may withdraw your consent at any time by adjusting your browser settings or the cookie banner, which may also enable you to review and erase Cookies.

14.4. You can manage browser Cookies through your browser settings. The “Help” feature on most browsers will tell you how to prevent your browser from accepting new Cookies, how to have the browser notify you when you receive Cookies, how to disable Cookies, and when Cookies will expire. If you disable all Cookies on your browser, neither the Company nor third parties will transfer Cookies to your browser. If you do this, however, you may have to manually adjust some preferences every time you visit the Platform, and some features and Services may not work.

15. LIMITATION OF LIABILITY

15.1. TO THE FULLEST EXTENT PERMITTED BY APPLICABLE LAW, THE COMPANY SHALL NOT BE LIABLE TO YOU FOR ANY LOSS OF PROFITS, ANTICIPATED SAVINGS, GOODWILL, REPUTATION, BUSINESS OPPORTUNITY, OR FOR ANY INDIRECT, INCIDENTAL, SPECIAL, EXEMPLARY, PUNITIVE, OR CONSEQUENTIAL LOSS OR DAMAGE ARISING OUT OF OR IN CONNECTION WITH THIS POLICY OR THE PROCESSING OF YOUR INFORMATION, INCLUDING ANY LOSS ARISING FROM A DATA BREACH OR SECURITY INCIDENT, EXCEPT TO THE EXTENT SUCH LOSS IS DIRECTLY ATTRIBUTABLE TO THE COMPANY’S GROSS NEGLIGENCE, WILFUL MISCONDUCT, OR ANY LIABILITY THAT CANNOT BE EXCLUDED UNDER APPLICABLE LAW.

15.2. The Company shall not be responsible for any loss, damage, unauthorised access to, or misuse of your Information arising from: (a) a Force Majeure Event; (b) your acts or omissions or those of any person authorised by you to access or use your account; (c) your failure to maintain the confidentiality and security of your account credentials, devices, or systems used to access the Platform; (d) any Information that you voluntarily disclose or share with other Users of the Platform; or (e) the acts or omissions of any third party or any circumstance beyond the Company’s reasonable control.

16. CHANGES TO THIS POLICY

The Company reserves the right to amend, update, or modify this Policy at any time to reflect changes in applicable law, regulatory requirements, technology, business practices, or the Services offered through the Platform. Any revised version of this Policy shall become effective from the date it is published on the Platform, unless otherwise specified. You are encouraged to review this Policy periodically. Your continued access to or use of the Platform after the revised Policy becomes effective shall constitute your acceptance of such changes.

17. GOVERNING LAW AND DISPUTE RESOLUTION

17.1. This Privacy Policy and any disputes arising out of or related to it shall be governed by and construed in accordance with the laws of India, without regard to conflict-of-law principles.

17.2. Subject to Clause 17.3, the courts at Mumbai, Maharashtra, India shall have exclusive jurisdiction over all matters arising in connection with this Privacy Policy. The User irrevocably submits to the jurisdiction of such courts.

17.3. Any dispute, controversy, or claim arising out of or in connection with this Privacy Policy, including any question regarding their existence, validity, or termination, shall be referred to and finally resolved by arbitration under the Arbitration and Conciliation Act, 1996. The arbitration shall be conducted by a sole arbitrator appointed by mutual agreement of the parties. Failing agreement on the appointment of the sole arbitrator within thirty (30) days of one party receiving a written request from the other to refer the dispute to arbitration, the arbitrator shall be appointed in accordance with the provisions of the Arbitration and Conciliation Act, 1996. The seat and venue of arbitration shall be Mumbai, Maharashtra, India, and the language of the arbitration shall be English. The arbitral award shall be final and binding on the parties. Nothing in this Clause shall prevent either party from seeking interim or injunctive relief from a court of competent jurisdiction.

17.4. Nothing in this Clause shall affect your right to register a grievance with the Grievance Officer or to make a complaint to the Data Protection Board of India in accordance with Applicable Law.

18. GRIEVANCE REDRESSAL MECHANISM

18.1. In accordance with the Information Technology Act, 2000 and rules made thereunder along with the DPDP Act, you have the right to readily available means of grievance redressal in relation to your Information collected by the Platform. Therefore, the Company respects your rights and hereby furnishes the name and contact details of the Grievance Officer, as provided below:

Grievance Officer:

Name: Mr. Ketan Mirchandani

Address: Unit No. 1802, Marathon Emblem, Mulund Goregaon Link Road, Mulund West, Mumbai -400080

Email: support@myprocurehub.com

Mob No.: +91 72087 27123

18.2. In the event that your grievance is not resolved to your satisfaction by the Company’s Grievance Officer, you have the right, under the DPDP Act, to refer the matter to the Data Protection Board of India in accordance with the rules and procedures prescribed under the DPDP Act.

19. CONTACT DETAILS

If you have any questions or concerns about this Policy, you may contact the Company at support@myprocurehub.com.

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