Last updated: October 31, 2023

Welcome to SalarySe’s privacy policy (“Privacy Policy” or “Policy”).

This Policy outlines Critical Path Technologies Private Limited’s and its affiliates’ (“SalarySe”, “we”, “us”, or “our”) practices in relation to the storage, use, processing, and disclosure of personal data that you have chosen to share with us or that we collect about you (including, for example, when you contact us through the information available on our website www.salaryse.com (“Website”). This Policy explains how we process and use your personal data.

At SalarySe, we are committed to protecting your personal data and respecting your privacy. In order to provide you with access to and use of the Website, we have to collect and otherwise process certain data about you. This Policy explains how we process and use personal data about you.

By interacting with us, submitting information to us, or using the Website, you confirm that you have read this Policy and consent to the collection, use, disclosure, and/or retention of your personal information in accordance with the processing activities described under this Policy.

1. BACKGROUND AND KEY INFORMATION

(a) How this Policy applies:

This Policy applies to all individuals who access or use the Website (“you”).

By accessing or using the Website, you consent to the collection, storage, usage, and disclosure of your personal data, as described in and collected by us in accordance with this Policy.

(b) Third-Party Services:

The Website may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party services and are not responsible for their privacy statements. When you leave the Website, we encourage you to read the privacy policy of such third-party service providers.

2. PERSONAL DATA THAT WE COLLECT

(a) We collect different types of personal data about you in various ways, which we have grouped together as follows. The information that we collect may include:

(i) [Identity Data, such as your name, username, and any similar identifier. (ii) Contact Data, such as your address, email addresses, and telephone numbers.

(iii) Technical Data, which includes your IP address, device ID, device type or other identifier, browser information including browser type and version, browser language preference, time zone setting and location, browser plug-in types and versions, web browser application details, corresponding location details, date and time stamp, operating system, and other technology on the devices you use to access the Website.

(iv) Usage Data, which includes information about how you use the Website and your activity within the sites, time spent using the Website, referring URL, and page views.

(v) Marketing and Communications Data, which includes your preferences in receiving marketing from us and our third parties and your communication preferences.]

(b) We also collect, use, and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data under law as it does not directly or indirectly reveal your identity. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Policy.

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may not be able to provide you access to our Website.

3. HOW DO WE COLLECT PERSONAL DATA?

We use different methods to collect your data, including through:

(a) Direct Interactions. You provide us your personal data when you interact with us. This includes personal data you provide when you request marketing to be sent to you, create an account on our Website, subscribe to our newsletters, interact with the Website chat assistant, or when you give us feedback or contact us.

(b) Automated technologies or interactions. As you interact with the Website, we will automatically collect technical data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies, server logs, and other similar technologies. We may also receive technical data about you if you visit other websites that employ our cookies.

4. HOW DO WE USE YOUR PERSONAL DATA?

(a) We will only use your personal data when the law allows us to. Most commonly, we will use your personal data where we need to provide you access to the Website. We use your personal data for the following purposes:

(i) To personalize your experience: Your information helps us to better respond to your individual needs.

(ii) To improve our services: We continually strive to improve our service offerings based on the information and feedback we receive from you.

(iii) To send periodic emails, including marketing emails: The email address you provide may be used to send you marketing emails, information, and updates, in addition to receiving occasional company news and updates related to us or our business. (iv) To comply with legal obligations.

(v) To provide you financial services: Your information helps us determine your eligibility for credit-based financial services being provided via SalarySe’s partners

5. COOKIES

(a) Cookies are small files that a site or its service provider transfers to your computer’s hard drive through your web browser (if you allow) that enables the sites or service provider’s systems to recognise your browser and capture and remember certain information.

(b) We use cookies to help us understand and save your preferences for future visits and compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future. We may contact third-party service providers to assist us in better understanding our site visitors. These service providers are not permitted to use the information collected on our behalf except to help us conduct and improve our business.

(c) Additionally, you may encounter cookies or other similar devices on certain pages of the Website that are placed by third parties. We do not control the use of cookies by third parties. If you send us personal correspondence, such as emails, or letters, or if other users or third parties send us correspondence about your activities or postings on the Website, we may collect such information within a file specific to you.

6. DISCLOSURES OF YOUR PERSONAL DATA

(a) You agree and acknowledge that any and all information pertaining to you, whether or not you directly provide it to us (via the Website or otherwise), including but not limited to personal correspondence such as emails, instructions from you, etc., may be collected,

compiled, and shared by us in order to render the Website to you. This may include but not be limited to third-party service providers, storage providers, data analytics providers, consultants, lawyers, and auditors.

(b) You agree and acknowledge that we may share data where we are required by law, any court, a government agency, or authority to disclose such information. Such disclosures are made in good faith and belief that it is reasonably necessary to do so for enforcing this Policy or in order to comply with any applicable laws and regulations.

7. TRANSFERS OF YOUR PERSONAL DATA

(a) We comply with applicable laws in respect of storage and transfers of personal data. As a part of your use of the Website, the information, and personal data you provide to us may be transferred to and stored in countries other than the country you are based in. This may happen if any of our servers are from time to time located in a country other than the one you are based in, or one of our service providers is located in a country other than the one you are based in.

(b) By submitting your information and personal data to us, you agree to the transfer, storage, and processing of such information and personal data in the manner described above.

8. DATA SECURITY

We have implemented appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed without authorisation, altered, or disclosed, and are fully compliant with the standards laid down under applicable laws.

9. DATA RETENTION

(a) We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a legal obligation to retain such data in respect of our relationship with you.

(b) In some circumstances, we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

10. BUSINESS TRANSITIONS

In the event we go through a business transition, including but not limited to a merger, acquisition by another organisation, or sale of all or a portion of our assets, your personal data might be among the assets transferred.

11. USER GENERATED INFORMATION

(a) We invite Website users to submit feedback and suggestions, make service requests, and submit details of grievances on the Website. Please note that such content may be available to visitors to our Website.

(b) We cannot prevent such Information from being used in a manner that is contrary to this Policy, applicable laws, or your personal privacy, and we disclaim all liability (express or implied) in this regard. Further, you agree to comply with all applicable laws in relation to the content uploaded or otherwise shared and received by you on our Website. You understand and acknowledge that you will be solely responsible for any information published or shared by you on or through our Website that violates applicable laws.

12. UPDATES TO THIS POLICY

(a) We may occasionally update this Policy. If we make changes to this Policy, we will notify you of the changes through the Website or through other means, such as email. To the extent permitted under applicable law, by using our Website after such notice, you consent to updates made to this Policy.

(b) We encourage you to periodically review this Policy for the latest information on our privacy practices. We will also make prior versions of our privacy policies available for review.

13. GRIEVANCE OFFICER

If you have any questions about this Policy, how we process or handle your personal data, or otherwise, you may reach out to us, with your queries, grievances, feedback, and comments at support[at]salaryse.com