General Information
The privacy policy of "Groopy Crowdfunding"(hereinafter referred to as groopy, We, or  the Data Controller(hereinafter referred to as the Privacy Policy) defines the terms of the processing of personal data using our website and/or services.

Details of your Data Controller:
We have a Data Protection team (hereinafter referred to as the DPT), to which you can contact to by data@groopy.in

Changes to the Privacy Policy:
We may change this Privacy Policy from time to time to reflect how we process your personal data. If significant changes are made, we will notify you via the website or other appropriate means of communication, such as e-mail, so that you can review these changes before continuing to use our website.

The terms and conditions of the Privacy Policy apply each time you access our content and/or service, regardless of which device (computer, mobile phone, tablet, TV, etc.) you use.

It is very important that you read the Privacy Policy carefully because every time you visit our website, every time you use our services or participate in our events, you agree to the terms and conditions described in this Privacy Policy. If you do not agree to these terms and conditions, please do not visit our website, do not use our content and/or services.

If the user of Platform is a legal entity, this Privacy Policy applies to the natural person whose data has been transferred to us by that legal entity. The User shall properly notify the data subjects (head, beneficiaries, representatives, collateral givers, guarantors, etc.) of the transfer of their data to Profitus and provide them with this Privacy Policy. In this Privacy Policy, the term YOU will apply to a natural person (talking about a legal entity ¨C to head, beneficiary, representative, collateral giver, surety, etc. of the user of Platform), whose data is managed by groopy.

Definitions in this Privacy Policy are used in accordance with the General Rules of Use of the groopy Platform (for investors and for project owners) as well as with the General Data Protection Regulation.

We confirm that your data will be collected and processed in accordance with the applicable legal requirements of the European Union and the Republic of Lithuania and the instructions of the supervisory institutions.

Persons under the age of 16 cannot provide any personal data through our website. If you are a person under the age of 16, you must obtain the consent of your parents or other legal guardians before submitting your personal information.

The domain name www.groopy.in (hereinafter referred to as "the said Website") is owned by Groopy Investment Management Pvt. Ltd.' a private limited company incorporated under the laws of India and having its registered office located in the State of Telangana (hereinafter referred to as "groopy"). For the purpose of this Privacy Policy' the term "You" or "User" shall mean any natural or legal person/entities including both Online and offline clients and the term "We"' "Us"' "Our" shall mean groopy and its affiliates and their service providers. groopy is committed to safeguarding the privacy of any person who access and uses the said Website that is owned and operated only by groopy.

We know that You care how information about You is used and shared and We appreciate Your trust in Us to do that carefully and sensibly. This policy gives details of the information We may collect from You or that You may provide while using/accessing the said Website and the manner in which such information is collected' used' processed' disclosed and maintained. By accessing the said Website and any of its pages' You are agreeing to the clauses specified read along with the terms of use of the said Website. By accessing and using the said Website' You accept and agree to be bound by and comply with (i) this Privacy Policy' and' (ii) the Terms of Use.

We urge the user to read and understand the policy carefully. If You do not agree with Our policies and Our practices in the way We treat Your information' You should immediately stop accessing and using the said Website. If You continue to use or access the said Website' it shall constitute Your agreement to this Privacy Policy and by accepting this Privacy Policy' You expressly consent to groopy use and disclosure of Your personal information in accordance with this privacy policy.

This policy shall apply to all information You provide on the said Website and all information that groopy collects on the Website including but not limited to any information You upload' emails that You exchange with Us and other Users and any information submitted by You to Us.

This policy applies to groopy as defined herein and help you to understand how we collect, use, store, process, transfer, share and otherwise deal with and protect all Your information when you visit Our Website. Note that this Privacy Policy is an electronic record in the form of electronic contract in terms of Indian Information Technology Act and rules made thereunder (as amended from time to time) and does not require any physical signature or seal. Please refer to the detailed outline of the policy.

Controller of Personal Information
groopy will be the controller of Your personal information provided by You or otherwise collected by Us. Your data controller is responsible for the collection' use' disclosure' retention' and protection of Your personal information in accordance with its privacy standards as well as any applicable laws.

Information Collected
groopy may for the purpose of rendering its services' collect personal information such as:

• Name' Gender' Residential / Correspondence Address' Telephone Number' Date of Birth' Marital Status' Email Address' IP address or Other Personal Information
• Bank account or other payment instrument details
• PAN' KYC' Signature and Photograph
• Any other detail necessary or ancillary for providing services
• Information provided by You on third party Websites and users information collected by groopy forms part of the aforementioned websites/web pages from Third party websites.
• groopy offers online platform for carrying out transactions that collect such personal data or information so as to process Your financial and/or non-financial transaction requests.

Storage of Your Information
Your Information will mostly be stored in electronic form however certain data may be stored in physical form. We may store' collect' use and process Your Information within India and/or outside India subject to compliance under applicable laws. We may enter into agreements with third parties (in or outside of India) to store or process Your Information and such third parties may have their own security measures to safeguard Your information with security standards as comparable with good industry practices.

Log File Information Collected and Stored Automatically
Whenever You visit/log into our Website just to browse' read pages or download information' We will automatically gather and store certain non-personal information about Your visit. The kind of information that is gathered automatically includes' but is not limited to' the type of browser You are using (e.g. Internet Explorer' Firefox' etc.)' the type of Operating System / Device like computer' mobile' laptop' tablet or any other internet enabled electronic device. You are using (e.g. Windows or Mac OS)' the domain name along with the IP address of Your Internet Service Provider' website navigation' marketing preferences' the date and time of Your visit and the pages on Our website when You use the said Website. Information regarding Your preferences and setting such as geographical location' time zone and language. We may collect process and store Your user ID associated with any social media account (such as you Facebook and Google accounts) that You use to sign into the Platform or connect with or use with the products or services. When You sign in to Your account with Your social media account information' or otherwise connect to Your social media account with the Product or Services' You agree to Our collection'storage' and use in accordance with this Privacy Policy' of the information that You make available to Us through the social media interface. This could include' without limitation' any information that You have made public through Your social media account' information that the social media service shares with Us' or information that is disclosed during the sign-in process. Please see Your social media provider's privacy policy and help centre for more information about how they share information when You choose to connect. This information cannot and does not identify You personally. We use this information purely for analytics and research purposes' in order to improve Our Website and to ensure the security of the Website.

Purpose of Collection' Storage' Processing of Your Information
groopy collects Your Information solely for the purpose of providing you the products or services that is connected with the function or activity of groopy which includes but not limited to the following ("Purpose"):

• To inform you about various products and services offered on Our Platform and provide customer support to You.
• To address Your queries and resolve Your concerns pertaining to any product or service that Your were looking for.
• To send You survey and marketing communications or facilitate various programs and initiatives launched either by Us or third party which We believe may be of interest to You.
• To facilitate Your usage of Platform (what features You like' etc.) and improve Our products or services' or any other content on the Platform (such as by personalizing content to Your interests)' process and complete Your transactions' and make special offers.
• To review Platform performance' diagnose technical problems and do data analysis to make Your experience better.
• To protect the integrity of Our Platform.
• To inform you about change in any term and condition of this Privacy Policy or Terms of Use of any Platform of groopy.
• To implement information security practices' to determine any security breaches' contaminant or computer virus' to investigate/prevent/take action against illegal activities and suspected fraud.
• To keep You informed about news' events and ideas regarding Your preferences and help You to improve Your knowledge and skills about the preferred content.
• To carry out Our obligations and enforce Our rights arising from any contracts entered into between You and Us.
• To allow you to participate in interactive features offered through Our Platform.
• To contact You about Our own and third-party products and services that may be of interest to You. If You do not want Us to use Your Information in this way' please check the relevant box located on the form on which We collect Your data and/or adjust Your user preferences in Your account profile.
• To produce and share aggregate insights and statistics that do not identify You.
• To enable us independently or in association with third party to show You tailored ads that are relevant to You.
• To enable us to display advertisements to our advertisers/service providers target audiences. Even though We do not disclose Your Personal Information for these purposes without Your consent' if you click on or otherwise interact with an advertisement' the advertiser may assume that You meet its target criteria.
• To help advertisers and other partners measure the effectiveness and distribution of their ads and services' and understand the types of people who use their services and how people interact with their websites' apps and services. In any other way We may describe when You provide the Information.
• For any other purpose at the sole discretion of groopy with Your consent.

Sharing of the Information

• Any service or product provided through Our Platform may be provided either by groopy or its vendor' dealer' OEM' channel partners and other third parties ("Other Entities") which are registered with groopy to render the services or provide products through Platform or otherwise. You acknowledge and agree that groopy may share' disclose' transfer or part with Your Information to Other Entities depending upon the type of Product or Service You are looking for or for one or more of the permissible purposes. groopy may also share Your personal information or non-personal information where it is required to share the same with such Other Entities for providing You the product or service and You provide groopy' Your unconditional consent to do the same.
• groopy may share statistical data and/or other non-personal information or details to facilitate various program or initiatives launched by groopy' third party service providers' partners or financial institutions' from time to time'
• We use other third parties such as a credit/debit card processing company' payment gateway' pre-paid cards etc. to enable You to make payments for buying products or availing services on Platform. When You sign up for these services' You may have the ability to save Your card details for future reference and faster future payments. In such case' We may share Your relevant Information as necessary for the third parties to provide such services' including Your name' residence and email address. The processing of payments or authorization is solely in accordance with these third parties policies' terms and conditions and We are not in any manner responsible or liable to You or any third party for any delay or failure at their end in processing the payments.
• The information so collected may be shared with Government of Semi-Government Body' Registrar and transfer Agents/ Collecting Banks/ KYC Registration Agencies (KRAs) / Custodian/ Central Depository Services (India) Limited (CDSL) etc. solely for the purpose of processing Your transaction requests or serving You better. The information so collected by groopy shall be shared by groopy with any Governmental and/or Judicial Agencies (eg. Police Authorities/investigating agencies like CBI' EOW etc.) or other authorized law enforcement agencies (LEAS) mandated under law to obtain Your Information for the purpose of verification of identity or for prevention' detection' investigation including but not limited to cyber incidents' prosecution' and punishment of offences etc
• We may process Your Information outside India ad relay on legally provided mechanisms to lawfully transfer Your Information across borders.
• We may share Your Information in any other circumstances where We have Your consent.
• groopy and/or its authorized agents shall not retain or store that information for longer than is required for the purposes' except in cases where the information may be used lawfully or is required under any other law for the time being in force. By agreeing to avail the service offered by groopy You have agreed to the collection and use of Your Sensitive Personal Data or Information by groopy. You may always choose to refuse or withdraw Your consent to share/disseminate Your Sensitive Personal Data or Information by contacting the customer care or if You would like Us to delete any Personal data or information provided by You' You may write to Us at info@groopy.co However' in such an event' You would no longer avail the services of groopy.

Updating or Reviewing Your Sensitive Personal Data or Information
You may upon written request to us review and rectify the sensitive personal data or information provided.

Reasonable Security Practices for Protecting Information
groopy uses commercially reasonable physical' managerial' and technical safeguards to preserve the integrity and security of Your personal information. groopy cannot' however' ensure or warrant the security of any information You transmit to groopy and You do so at Your own risk. Once we receive Your transmission of information' groopy makes commercially reasonable efforts to ensure the security of our systems. However' please note that this is not a guarantee that such information may not be accessed' disclosed' altered' or destroyed by breach of any of our physical' technical' or managerial safeguards. To protect Your privacy and security' groopy takes reasonable steps (such as requesting a unique password) to verify Your identity before granting You access to Your account. You are responsible for maintaining the secrecy of Your unique password and account information' and for controlling access to Your email communications from groopy' at all times. Notwithstanding anything contained in this Privacy Policy or elsewhere' groopy shall not be held responsible for any loss' damage or misuse of the User information or any other data' which You share with Us or which We have with Us if such loss or any damage caused to You because of Force Majeure events. You further acknowledge that any information (including Your personal information) transmitted to Us or from Your use of Website will therefore be at Your own risk.
It is clarified that Force Majeure events includes any event which is beyond the reasonable control of groopy which may include but not limited to sabotage' fire' flood' explosion' acts of God' civil commotion' strikes or industrial action of any kind' riots' insurrection' war' acts of government' computer hacking' unauthorised access to computer' computer system or computer network' computer crashes' breach of security and encryption

Access to Information
As per the terms and conditions of use' groopy has the right to restrict access of any User from the Website and the services offered therein ("Restricted User"). With respect to a Restricted User' groopy will delete any or all User Information given by the Restricted User. If groopy' by its sole discretion or due to a legal requirement' decides to retain the User Information for its records' then groopy will be responsible to safeguard that User Information to such extent as required under applicable law.

Links to Other Web Sites
Our website sometimes has links to other website(s) in the World Wide Web. The privacy policies of these website(s) are not under our control. Once You leave our servers' use of any information You provide is governed by the privacy policy of the operator of the site You are visiting. It is advisable to read their privacy policies for further information. Your browsing and interaction on any other Web site' including those that have links on our Website' is subject to that Website's policies. groopy shall not be liable for any loss' damage' claim' expenses or whatsoever suffered by You as a result of accessing these third party or other sites.

Children's information
We encourage parents and guardians to observe' participate in' and/or monitor and guide their online activity. groopy does not knowingly collect any Personal Identifiable Information from children under the age of 18. If You think that Your child have provided this kind of information on our website' we strongly encourage You to contact us immediately and we will do our best efforts to promptly remove such information from our records.

Changes to Our Privacy Policy
Please note that this policy may be changed or updated from time to time at its sole discretion for various reasons including' but not limited to' amendments in the relevant laws. If groopy changes its privacy policies and procedures' groopy will post those changes on groopy website to keep You/Users aware/updated of what information groopy collects' how groopy uses it and under what circumstances groopy may disclose/transmit it. Changes to this Privacy Policy are effective when they are posted on this page. groopy shall be under no obligation to notify the User about the changes. Please visit our website to keep Yourself updated of any changes to this policy and Your continued access and use of the said Website shall be deemed to be Your approval and acceptance of all changes to this Privacy Policy.

Cookies
Cookies are small files transferred to the hard drive of Your device that enable us to recognize Your browser and capture and remember certain information. They are also used to help us understand Your preferences based on previous or current activity on the Website' which allows us to improve our Website. We also use cookies to help us compile aggregated and anonymized data about the traffic on the Website so that we can offer better experiences and tools in the future. We may also use trusted third-party services that track this information on our behalf.

Authorization
You also acknowledge that all the information provided by You are out of Your free will and in compliance with applicable laws in Your territory. If We found that any of Your information is in non-compliance with the terms and conditions and Privacy policy' groopy reserves the right to remove Your non-compliant information from its systems. Further' depending on the seriousness of the non-compliance' we may choose to discontinue some or all of the services being provided to You by us.
In purview of the Telecom Regulatory Authority of India ("TRAI") guidelines' You hereby authorize groopy' and its affiliates/partners or otherwise who are accessing Your information by virtue of their association with groopy to communicate with You through whatsapp' telephone/mobile' Email' SMS or other modes of communication (now available or may be available in future) even if Your number/numbers(s) is/are registered in the National Do Not Call Registry (NDNC) or ndnc.net
You also accept that copy rights of the content in terms of copy or images on this Website belongs to groopy and replicating it in any form either by registered or unregistered channel partners or individuals for any form of communication will be considered violation of the Indian Copyright Act no. 14 of 1957.

Rights to control Your personal information

• Rectify Your information: We take all reasonable endeavors to update Our records with latest information as provided by You' however if you see any discrepancy in Your personal information' You may edit some of Your personal information or contact Us through Our Data Protection Officer/Grievance Officer to have Your information updated with Us.
• Object to' or Limit or Restrict the Use: You can ask Us to stop using or to limit Our use (in partial or full) Your Personal Information (past' existing or future).
• Deletion of Your information: You can ask Us to erase or delete (in partial or full) Your Personal Information (past' existing or future).
• Right to Access: You can ask Us for a copy of Your personal information.
• Right to Account Closure: If You choose to close Your Account' We will delete Your Personal Information or de-identify it so that it is anonymous and not attributed to your identity. We will retain Your Personal Information after You have closed Your account if reasonably necessary to comply with Our legal obligations (including law enforcement requests)' meet regulatory requirements' resolve disputes' maintain security' prevent fraud and abuse' enforce Our User Agreement' or fulfil You request to "unsubscribe" from further messages from Us. We will retain de-personalized information after Your account has been closed.
• Withdraw Consent/Opt-out: At any time' you can withdraw consent that You have provided to Us by going to Your account settings' if you have an account with us or otherwise you may request for Withdrawing you consent by writing an email to us at info@groopy.co. We will only collect and process personal information about You where We have lawful bases. Lawful bases include consent (where You have given consent)' contract (where processing is necessary for the performance of a contract with You (e.g. to deliver products or services you have requested)) and "legitimate interests". Where We rely on Your consent to process personal information' you have the right to withdraw or decline Your consent at any time and where we rely on legitimate interests' You have the right to object.
• You may also contact Us using the contact information as mentioned in this Privacy Policy' and We will consider Your request in accordance with applicable laws.

European Union (EU) privacy / data protection rights EU General Data Protection Regulation ("GDPR") (Chapter 3 - Article12-23) has provided the rights to the EU residents

Reach us
If you have any concern related to this Privacy Policy or collection' storage' retention or disclosure of Your Information under the terms of this Privacy Policy or Terms of Use or any other terms and conditions of groopy or its other business entities including any queries or grievances' You can contact to groopy through its Data Protection Officer/Grievance Redressal Officer at the below given details:
Email ID info@groopy.co
We will strive to address you feedback and concerns in a timely and effective manner
Please note that the details of the Data Protection Officer/Grievance Officer may be changed by Us from time to time by updating this Privacy Policy.

ACKNOWLEDGEMENT:
Please read this Privacy Policy carefully. Hence by visiting our Website platform or by using/ availing any of our services or products' You indicate that You understand' agree and consent to this Privacy Policy and You hereby give Your unconditional consent or agreement to groopy as provided under section 43A and section 72A of Indian Information Technology Act' 2000 for collection' use' storage' processing' sharing and transfer and disclosure of Your information.
You acknowledge that You have all legal rights and lawful authority to share the information with us and further acknowledge that by collecting' sharing' processing and transferring information provided by You' shall not cause any loss or wrongful gain to You or any other person.
If You do not agree with the terms of this Privacy Policy' please do not access/use our Website or avail any of our services or products available on our Website.