COINOME PRIVACY POLICY

Last Revised on 19 Aug 2017

The website www.coinome.com and the Coinome mobile app (collectively referred to as “Website”) is owned and operated by Hatio Innovations Private Limited (“Company” or “Coinome”), a company incorporated under the Companies Act, 2013, having its registered office at Shah Industrial Estate, Andheri (W), Mumbai – 400053.

Introduction

1. Your use (both as unregistered user and registered user) of this Website is subject to the terms of this privacy policy (“Privacy Policy”) and the Terms of Use of Website

2. By using this Website, and/or by registering with us, you signify that you have carefully read, understood and agree to be bound by this Privacy Policy. If you disagree with any of the terms of or any part of this Privacy Policy, you must refrain from using this Website.

3. This Privacy Policy may be altered, edited, amended, modified, reviewed, revised or substituted by the Company at any time with or without prior notice and users are requested to read the Privacy Policy before using or accessing the Website. Please check this page regularly to ensure you are familiar with the latest version of the Privacy Policy.

Collection of Information

1. For the purpose of this Privacy Policy, the term ‘User Information’ includes the user’s personal information that can be used to uniquely identify or contact a single person collected by the Company to provide specific services to the user through the Website. The User Information collected by the company inter alia include the following:

   • Traffic Data. The Company tracks certain information about the user when he/she visits the Website. The information that is tracked includes information such as: (a) IP addresses; (b) domain servers; (c) types of computers system accessing the Website; (d) types of web browsers used to access the Website; (e) referring source which may have sent you to the Website’s URL; and (e) other information associated with the interaction of your browser and the Website.

   • Personal Information. In order for you to use certain features of the Website, such as creating an account on the Website for placing orders, you would be required to register with us, which requires you to provide certain personal information such as your e-mail address, phone number, name, date of birth etc., and certain sensitive personal data or information such as passwords, credit card details, debit card details, bank account information etc.

   • Transactional Data. All transactional data, such as intra Website searches, additions to wish list, orders placed, orders cancelled, payment modes chosen, number of visits, etc., is collected and used to ensure a better service.

   • Cookies Data. Cookies are small files that the Website transfers to your computers’ hard drive through your web browser (if you allow it) that enables the Website to recognize your browser and capture and remember certain information. We use cookies to help us understand and save your preferences for future visits and compile statistical data about the Website traffic and Website interaction so that we can offer better Website experiences and tools in the future. If you prefer, you can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies via your browser settings. Like most websites, if you turn your cookies off, some of our services may not function properly.

   • Web Analytics. The Company may use third party web analytics services to track and analyze your interaction with the Website, such as mouse clicks, mouse movements, scrolling activity as well as any text that you choose to type into the Website. The Company uses this information to enhance your experience.

2. The Company may also obtain information, including personal information, from third parties and sources other than the Website, such as advertisers or other users who import your email address to their address book. We may also, at your discretion, receive information from third party services that provide a mechanism to expose information you have provided to such third party through use of an application program interface (API), such as Facebook, Twitter, Google etc. If we combine or associate information from other sources with User Information that we collect through the Website, we will treat the combined information as User Information for the purposes of this Privacy Policy.

3. The Company may have access to certain financial information which you may have provided at the time of making payments on the Website. The information includes your bank account details, payment method (valid credit card number, type, expiration date or other financial information). The said information is collected and stored by our third party payment processing company (the “Payment Processor”), which may in turn provide us with a secured portion of your financial information in order to complete transactions made through the Website. You acknowledge that the use and storage of your financial information is governed by the Payment Processor’s applicable terms of service and privacy policy.

4. The user has an option not to provide the aforesaid User Information if he/she wishes not to avail the specific service on the Website, for which the User Information is required.

5. Further, the Company will collect the User Information from the user at the time of creation of a user account or when the user is browsing the Website or while transacting an online purchase of the Company’s service through the Website or while posting comments (in form of texts, images, videos, audios etc.), uploading contents or participating in any offers or contests or availing special gifts or communicating with customer support by phone, email or otherwise.

Use of Your Information

1. The Company will use your contact information primarily to contact you when necessary, including to inform you of your transactions status, contest alerts, feedback surveys, latest offers or at any other instance as the Company may deem fit. The Company may also use your demographic data, your traffic data, to customize and tailor your experience on the Website. You agree that the Company may use your Personal Information (as defined under the Information Technology Act and the rules made thereunder) or Sensitive Personal Data or Information (as defined under the Information Technology Act and the rules made thereunder) in such manner as may be required to serve you better or as the Company deems fit.

2. The Company will share the User Information with its affiliates or group entities for marketing, support or such other services as the Company deems fit.

3. By accessing the Website you signify that you have carefully read, understood and agree to be bound by and consent to the collection, use, transfer, retention, alteration, deletion of your information as provided in this Privacy Policy and/or the Terms of Use of Website of the Company.

Confidentiality and Security

1. Except as otherwise provided in this Privacy Policy and the Terms of Use of Website , the Company will keep your User Information private and will not share it with third parties, unless the Company believes in good faith that disclosure of your User Information or any other information collected about you is necessary to:

   • comply with a court order or other legal process;

   • protect the rights, property or safety of the Company or another party;

   • enforce our Terms of Use of Website ; or

   • respond to claims that any posting or other content violates the rights of third parties.

2. The Company does not have, and will not accept, any obligations of confidentiality with respect to any communications other than those expressly stated in this Privacy Policy and Terms of Use of the Website.

3. The Company will take reasonable steps to ensure that the User Information is accurate, complete, up-to-date and stored in a secure environment protected against unauthorized access. The Company has in place security controls and is making best efforts to use the latest and most secure technology for protecting your User Information. Please note, no method of transmission over the Internet or method of electronic storage is 100% secure. In case of any concerns with the confidentiality and security of your User Information please contact our privacy officer at support@coinome.com. For reasons outside of our control, security risks may still arise and the Company hereby disclaims any responsibility for damages arising out of such a security breach or failure.

4. The Company will retain your User Information for as long as your account is active or as needed to provide you services and as required under and in accordance with applicable data retention laws.

Applicable Laws

You agree that this Privacy Policy and any security measures that the Company may take to secure Personal Information (as defined under the Information Technology Act and the rules made thereunder) or Sensitive Personal Data or Information (as defined under the Information Technology Act and the rules made thereunder) on the Website constitutes reasonable security practices and procedures under section 43A of the Information Technology Act, 2000 and accordingly, the rules of the Central Government in this regard shall not apply.

Miscellaneous

1. External Links. While accessing the Website you will come across external links to other websites. Although the Website only looks to include quality, safe and relevant external links, you are required to exercise caution before clicking any external web links provided on the Website. The Company disclaims all liability against any loss suffered by you from accessing those external links. Your use of such external links would be governed by the terms of use and the privacy policy of such external websites.

2. Sharing of information. No officer or employee of the Company will, at any time, request a user to share his/her personal information or sensitive personal data or information through social media platforms or emails or telephone or any other mode of communication. You are requested to not disclose your Coinome account details with any person. The Company will not be liable for any loss/damage suffered by you due to mis-appropriation of your account resulting from you sharing you Coinome account details. You would be solely responsible and liable for such losses/damages.

Grievance Officer

Email: grievances@coinome.com

Time: Mon - Friday (9:00 A.M. - 6:00 P.M.)

Contacting Us

If there are any questions regarding this privacy policy you may contact the Company using the information below.

Hatio Innovations Private Limited

Shah Industrial Estate, Andheri (W),

Mumbai – 400053

Email: policies@coinome.com

THE PRIVACY POLICY IS PUBLISHED IN ACCORDANCE WITH THE PROVISIONS OF RULE 3(1) OF THE INFORMATION TECHNOLOGY (INTERMEDIARIES GUIDELINES) RULES, 2011. THE PRIVACY POLICY IS AN ‘ELECTRONIC RECORD’ AS CONTEMPLATED UNDER SECTION 2(T) OF THE INFORMATION TECHNOLOGY ACT, 2000 AND THE RULES THEREUNDER. THE PRIVACY POLICY BEING AN ELECTRONIC RECORD IS GENERATED BY A COMPUTER SYSTEM AND DO NOT REQUIRE ANY PHYSICAL OR DIGITAL SIGNATURES.