1. Policy Version :

Policy Name Privacy Policy
Version No 1.0
Contact Person

Data Protection Officer (Grievance

Officer): LegalDepartment

Last Review Date N.A.

Version No Date Description
1.0 7th June 2024 Privacy Policy released

This document is an electronic record in terms of the Information Technology Act, 2000 of India (hereinafter referred to as the “IT Act”, which term shall be deemed to include any amended versions or replacements thereof and any Rules framed thereunder) and the amended provisions pertaining to electronic records in various statutes as amended by the IT Act. This electronic record is generated by a computer system which does not require any physical or digital signatures and is being published in accordance with the IT Act that requires publishing of rules & regulations, privacy policy and terms of use for access or usage of websites and applications for mobile and handheld devices.

Terms capitalized herein but not defined shall have the same meaning as given in the Master Subscription Agreement (“MSA”) we have with you, if any, or in the Terms of Use contained in the Platform.

Your use of the Platform and the Products / Services listed on or provided through the Platform constitutes your agreement to be subjected to this Privacy Policy, which shall, together with our Terms of Use and the MSA between you and ETPL (if any), govern the relationship between ETPL and you in relation to the Platform, Products & Services.

If you disagree with any part of this Policy, or to your information being collected, transferred, stored or used in ways detailed herein below, please do not use the Platform, or the Products & Services.

Nothing contained herein shall be construed to contradict or override anything contained in our MSA with you or the Terms of Use, but in case a conflict arises, the provisions of the MSA or the Terms of Use, as applicable, shall prevail, unless mandated otherwise by an applicable law. The interpretation of ETPL in this matter shall be final and binding.

Scope of this Privacy Policy

This Privacy Policy applies to all the Platform and mobile applications that link to it (the “Platform”). It also applies to all the Products & Services provided by us through the

Platform. This Privacy Policy may not apply to any of the Platform, mobile applications, products or services that have a separate privacy policy.

Categories of Data Collected, Processed, Stored, Transferred or otherwise handled by ETPL

Data collected, processed, stored, transferred or otherwise handled by ETPL fall primarily into two categories:

Category I – Information ETPL collects from and about you, and controls. Category II – Information that ETPL processes on your behalf.

2. Category I – Information ETPL collects from and about you, and controls :

What information ETPL collects:

We collect information about you only if we need the information for some legitimate purpose. ETPL will have information about you only if (a) you have provided the information yourself, (b) ETPL has automatically collected the information, or (c) ETPL has obtained the information from a third party. Below we describe the various scenarios that fall under each of those three categories and the information collected in each one.

Information that you provide us:
  1. Account creation: When you onboard in EVE platform to access one or more of our Products / Services, we ask for information like your name, contact number, email address, company name and country to complete the onboarding process. You'll also be required to choose a unique username and a password for accessing the created account. You may also provide us with more information such as your photo, time zone and language.

  2. Payment processing: Payments for purchases must be made in advance by you through payment modes made available to you, internet banking, Cheque /NEFT / RTGS / IMPS. Your use of the payment gateway shall be subject to the terms and conditions of the payment gateway service provider and your bank.

  3. Testimonials: When you authorize us to post testimonials about our Products & Services on the website, we may include your name and other personal information in the testimonial. You will be given an opportunity to review and approve the testimonial before we post it. If you wish to update or delete your testimonial, you can email us at support@eve24hrs.com and as well as tag with relationship manager email ID with the same.

  4. Interactions with ETPL : We may record, analyze and use your interactions with us, including email, telephone, and chat conversations with our sales and customer support professionals, for improving our interactions with you and other customers.

Information that we collect automatically:
  1. Information from browsers, devices and servers: When you visit the Platform, we collect information that web browsers, mobile devices and servers make available, such as the internet protocol address, browser type, language preference, time zone, referring URL, date and time of access, operating system, mobile device manufacturer and mobile network information. We include these in our log files to understand more about visitors to the Platform.

  2. Information from cookies and tracking technologies: We use temporary and permanent cookies to identify users of our Products & Services and to enhance user experience. We embed unique identifiers in our downloadable Products to track usage of the Products. We also use cookies, beacons, tags, scripts, and other similar technologies to identify visitors, track website navigation, gather demographic information about visitors & users, understand email campaign effectiveness and for targeted visitor and user engagement by tracking your activities on the Platform. We mostly use first-party cookies and do not use third- party cookies or other third-party tracking technologies on the Platform for non- essential or intrusive tracking.

  3. Information from application logs and mobile analytics: We collect information about your use of our Products & Services from application logs and in-house usage analytics tools, and use it to understand how your use and needs can improve our Products & Services. This information includes clicks, scrolls, features accessed, access time and frequency, errors generated, performance data, storage utilized, user settings and configurations, and devices used to access and their locations.

Information that we collect from third parties:
  1. Referrals: If someone has referred any of our Products or Services to you through any of our referral programs, that person may have provided us your name, email address and other personal information. You may write to us at support@eve24hrs.com and as well as tag with relationship manager email ID with the same to request that we remove your information from our database. If you provide us information about another person, or if another person gives us your information, we will only use that information for the specific reason for which it was provided to us.

  2. Information from our Reselling Partners & Service Providers: If you contact any of our Reselling Partners, or otherwise express interest in any of our products or services to them, the concerned Reselling Partner may pass on your name, email address, company name and other information to ETPL. If you register for or attend an event that is sponsored by ETPL, the event organizer may share your information with us. ETPL may also receive information about you from review

sites if you comment on any review of our Products & Services, and from other third-party service providers that we engage for marketing our Products & Services.

  1. Information from Social Networking Sites (SNS) and other publicly available sources: When you provide feedback or reviews about our Products, interact, or engage with us on marketplaces, review sites or SNS such as Facebook, X (formerly Twitter), LinkedIn, Instagram etc. through posts, comments, questions and other interactions, we may collect such publicly available information, including profile information, to allow us to connect with you, improve our Products, better understand user reactions and issues, or to reproduce and publish your feedback on the Platform. We must tell you that once collected, this information may remain with us even if you delete it from these sites. ETPL may also add and update information about you, from other publicly available sources.

Further Purposes for using such collected information:

In addition to the purposes mentioned above, we may use the above information to:

  1. communicate with you (such as through email) about Products & Services you have purchased, changes to our Terms of Use or this Privacy Policy, or other important notices;

  2. keep you posted on new Products & Services, upcoming events, offers, promotions and other information that we think will be of interest to you;

  3. ask you to participate in surveys, or to solicit feedback on our Products & Services;

  4. set up and maintain your account, and to do all other things required for providing the Services, such as maintenance of the Products, enabling collaboration, providing website and mail hosting, providing cloud storage and backing up and restoring your data;

  5. understand how users use our Products & Services, to monitor and prevent problems, and to improve our Products & Services;

  6. provide customer support, and to analyze and improve our interactions with customers;

  7. detect and prevent fraudulent transactions & other illegal activities, report spam, and protect the rights and interests of ETPL, ETPL’s users, third parties and the public;

  8. update, expand and analyze our records, identify new customers, and apprising you of Products & Services that may be of interest to you;

  9. analyze trends, administer the Platform, and track visitor navigations on the Platform to understand what visitors are looking for and to better help them;

  10. monitor and improve marketing campaigns and make suggestions relevant to the user.

Legal bases for collecting and using information:
  1. Legal processing bases applicable to ETPL: Most of our information collection and processing activities are typically based on (i) contractual necessity, (ii) one

or more legitimate interests of ETPL or a third party that are not overridden by your data protection interests, or (iii) your consent. Sometimes, we may be legally required to collect your information, or may need your personal information to protect your vital interests or those of another person.

  1. Withdrawal of consent: Where we rely on your consent as the legal basis, you have the right to withdraw your consent at any time, but this will not affect any processing that has already taken place.

  2. Legitimate interests notice: Where we rely on legitimate interests as the legal basis and those legitimate interests are not specified above, we will clearly explain to you what those legitimate interests are at the time that we collect your information.

Your choice in information use:
  1. Optout of non-essential communications: You may opt out of receiving newsletters and other non-essential electronic communications by using the ‘unsubscribe’ function included in all such messages. However, you will continue to receive essential notices and emails such as account notification emails (password change, renewal reminders, etc.), security incident alerts, security and privacy update notifications, and essential transactional and payment related emails.

  2. Disable cookies: You can disable browser cookies before visiting the Platform. However, if you do so, you may not be able to use certain features of the websites properly.

  3. Optional information: You can choose not to provide optional profile information such as your photo. You can also delete or change your optional profile information. You can always choose not to fill in non-mandatory fields when you submit any form linked to the Platform.

Who we share your information with:

We do not sell any personal information. ETPL shares your information only in the ways that are described in this Privacy Policy, and only with parties who have a legitimate business need to access the information. ETPL ensures that any party who has access to your information, adopts appropriate confidentiality and security measures no less stringent than as described in this Privacy Policy or in any applicable law. The following parties may, without limitation, have access to your information:

  1. Employees and independent contractors: Employees and independent contractors of relevant ETPL group entities have access to the information covered in Category I on a need-to-know basis. We require all our employees and independent contractors to strictly follow this Privacy Policy for personal information that we share with them.

  2. Third-party service providers: We may need to share your personal and aggregated or de-identified information with third-party service providers that we

engage, such as marketing and advertising partners, event organizers, web analytics providers and payment processors. These service providers are authorized to use your personal information only as necessary to provide these services to us.

  1. Reselling Partners: We may share your personal information with our authorized Reselling Partners in your region, solely for the purpose of contacting you about the Products & Services you have purchased. We will give you an option to opt out of continuing to work with that Reselling Partner.

  2. Other cases: Other scenarios in which we may share the same information covered under Parts I and II are described in Category III hereunder.

Your rights with respect to information we hold about you as a controller:

You have the following rights with respect to information that ETPL holds about you:

  1. Right to access : You have the right to access (and obtain a copy of, if required) the categories of personal information that we hold about you, including the information's source, purpose and period of processing, and the persons with whom the information is shared.

  2. Right to rectification: You have the right to update the information we hold about you or to rectify any inaccuracies. Based on the purpose for which we use your information, you can instruct us to add supplemental information about you in our database.

  3. Right to erasure: You have the right to request that we delete your personal information in certain circumstances, such as when it is no longer necessary for the purpose for which it was originally collected.

  4. Right to restriction of processing: You may also have the right to request to restrict the use of your information in certain circumstances, such as when you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

  5. Right to object: You have the right to object to the use of your information in certain circumstances, such as the use of your personal information for direct marketing.

  6. Right to complain: You have the right to complain to the appropriate supervisory authority if you have any grievance against the way we collect, use or share your information.

Retention of information:

We retain your personal information for as long as it is required for the purposes stated in this Privacy Policy. Sometimes, we may retain your information for longer periods as permitted or required by law, such as to maintain suppression lists, prevent abuse, if required in connection with a legal claim or proceeding, to enforce our agreements, for tax, accounting, or to comply with other legal obligations. When we no longer have a legitimate need to process your information, we will delete or anonymize your

information from our active databases. We will also securely store the information and isolate it from further processing on backup discs until deletion is possible.

3. Category II – Information that ETPL processes on your behalf

Information entrusted to ETPL and purpose:

  1. Information provided in connection with Products & Services: You may entrust information that you or your organization (“you”) control, to ETPL in connection with use of our Products & Services or for requesting technical support for our Products. This includes information regarding your customers and your employees (if you are a controller) or data that you hold and use on behalf of another person for a specific purpose, such as a customer to whom you provide services (if you are a processor). The data may either be stored on our servers when you use our services, or transferred or shared to us as part of a request for technical support or other services.

  2. Information from mobile devices: When you elect to allow it, some of our mobile applications have access to the camera, microphone, Location, call history, contact information, photo library, files and other information stored on your mobile device. Our applications require such access to provide their Services. Similarly, when you elect to provide access, location-based information is also collected for purposes including, but not limited to, locating nearby contacts or setting location- based reminders. This information will be exclusively shared with our mapping providers and will be used only for mapping user locations. You may disable the mobile applications' access to this information at any time by editing the settings on your mobile device. The data stored on your mobile device and their location information to which the mobile applications have access will be used in the context of the mobile application, and transferred to and associated with your account in the corresponding Services (in which case the data will be stored on our servers) or Products (in which case the data will remain with you unless you share it with us).

  3. Service Data: All the information entrusted to ETPL by you is hereinafter collectively referred to as “Service Data”.

Ownership and control of your Service Data:

We recognize that you own your Service Data. We provide you complete control of your Service Data by providing you the ability to (i) access your Service Data, (ii) share your Service Data through supported third-party integrations, and (iii) request export or deletion of your Service Data.

How we use Service Data:

We process your Service Data when you provide us instructions through the various modules of our Products & Services. For example, when you generate a payslip using our HRMS module information such as the name, designation and salary details of your employee will be used to generate the payslip; and when you use our FOS service for tracking your field sales agents, the locations of the agents on your payroll will be used for generating relevant reports.

Push notifications:

If you have enabled notification on our desktop and mobile applications, we will push notifications through a push notification provider such as Apple Push Notification Service, Google Cloud Messaging or Windows Push Notification Services. You can manage your push notification preferences or deactivate these notifications by turning off notifications in the application or device settings.

Who we share Service Data with:
  1. ETPL group and third party sub-processors: In order to provide Services and technical support for our Products, ETPL may engage other group entities and/or third parties, with whom the Service Data is shared for the purposes of enabling the Product & providing Services.

  2. Employees and independent contractors: We may provide access to your Service Data to our employees and individuals who are independent contractors of the ETPL group entities involved in providing the Services (collectively our “Employees”) so that they can (i) identify, analyze and resolve errors, (ii) manually verify emails reported as spam to improve spam detection, or (iii) manually verify scanned images that you submit to us to verify the accuracy of optical character recognition. We ensure that access by our Employees to your Service Data is restricted to specific individuals, and is logged and audited. Our Employees will also have access to data that you knowingly share with us for technical support or to import data into our Products / Services. We communicate our privacy and security guidelines to our Employees and strictly enforce privacy safeguards within the ETPL group.

  3. Collaborators and other users: Some of our Products / Services allow you to collaborate with other users or third parties. Initiating collaboration may enable other collaborators to view some or all of your profile information. For example, when you edit a document that you have shared with other persons for collaboration, your name and profile picture will be displayed next to your edits to allow your collaborators to know that you made those edits.

  4. Third-party integrations you have enabled: Most of our Products & Services support integrations with third-party Products & Services. If you choose to enable any third-party integrations, you may be allowing the third party to access your Service Data and personal information about you. We encourage you to review the privacy practices of the third-party services and products before you enable integrations with them.

  5. Other cases: Other scenarios in which we may share information that are common to information covered under Categories I & II are described under the section General Provisions.

Retention of information:

We hold the data in your account as long as you choose to use our Products & Services. Once you terminate your ETPL user account, your data will eventually get deleted from active database after a certain period of time clean-up that occurs. The data deleted from active database will be deleted from backups after a certain period of time as well. To know more about the timelines for retention & deletion of your data post termination of your relationship with us, please write to us at support@eve24hrs.com and as well as tag with relationship manager email ID with the same.

4. General Provisions Children’s personal information:

Our Products & Services are not directed to individuals under 18. ETPL does not knowingly collect personal information from children who are under 18 years of age for its own purposes. If we become aware that a child under 18 has provided us with personal information, we will take steps to delete such information. If you believe that a child under 18 years has provided personal information to us, please write to support@eve24hrs.com and as well as tag with relationship manager email ID with the same and as well as tag with relationship manager email ID with the same with the details, and we will take the necessary steps to delete the information we hold about that child. Further, our Products must not be used to collect data about individuals who may be children. If you process information relating to children, you acknowledge and agree that you will (i) obtain written permission from ETPL by writing to us at support@eve24hrs.com and as well as tag with relationship manager email ID with the same and as well as tag with relationship manager email ID with the same (ii) be responsible for complying with the applicable laws and regulations related to protection of such personal information and (iii) indemnify us from any and all liability arising out of such data processing relating to children.

5. How secure is your information?

At ETPL, we take data security very seriously. We have taken steps to implement appropriate administrative, technical & physical safeguards to prevent unauthorized access, use, modification, disclosure or destruction of the information you entrust to us. If you have any concerns regarding the security of your data, we encourage you to write to us at support@eve24hrs.com and as well as tag with relationship manager email ID with the same with any questions.

6. Data Protection Officer

Our Data Protection Officer (DPO) will oversee our management of your personal information in accordance with this Privacy Policy and the Digital Personal Data Protection Act, 2023 (the “DPDPA”).

7. Locations and international transfers:

We share your personal information and Service Data within the ETPL group and with third parties engaged by ETPL group for the purposes described above. By accessing or using our Products & Services or otherwise providing personal information or Service Data to us, you understand and agree that your personal information or Service Data may be processed in, transferred to and stored in countries outside India, where ETPL or its service providers / affiliates operate. Such transfers are subject to appropriate data protection agreements such as a group company agreement that is based on EU Commission’s Model Contractual Clauses for data processing activities to which GDPR applies. You can write to us at support@eve24hrs.com and as well as tag with relationship manager email ID with the same for obtaining a copy of the agreements on the basis of which we transfer your data within ETPL group and with the third parties engaged by us.

8. Do Not Track (DNT) requests:

Some internet browsers have enabled 'Do Not Track' (DNT) features, which send out a signal (called the DNT signal) to the websites that you visit indicating that you don't wish to be tracked. Currently, there is no standard that governs what websites can or should do when they receive these signals. For now, we do not take action in response to these signals.

9. Blogs and forums:

We offer publicly accessible blogs and forums on the Platform. Please be aware that any information you provide on these blogs and forums may be used to contact you with unsolicited messages. We urge you to be cautious in disclosing personal information in our blogs and forums. ETPL is not responsible for the personal information you elect to disclose publicly. Your posts and certain profile information may remain even after you terminate your account with ETPL. To request the removal of your information from our blogs and forums, you can contact us at support@eve24hrs.com and as well as tag with relationship manager email ID with the same.

10. Disclosures in compliance with legal obligations:

We may be required by law to preserve or disclose your personal information and Service Data to comply with any applicable law, regulation, legal process or governmental request, including to meet national security requirements.

11. Enforcement of our rights:

We may disclose personal information and Service Data to a third party if we believe that such disclosure is necessary for preventing fraud, spam filtering, investigating any suspected illegal activity, enforcing our agreements or policies, or protecting the safety of our users.

12. Business Transfers:

In the event that ETPL undergoes a change in Control, we will ensure that the acquiring entity is legally bound to honor our commitments to you. We will notify you via email or through a prominent notice on our website of any change in ownership or in the uses of your personal information and Service Data. We will also notify you about any choices you may have regarding your personal information and Service Data.

13. Compliance with this Privacy Policy

We make every effort, including periodic reviews, to ensure that personal information you provide is used in conformity with this Privacy Policy. If you have any concerns about our adherence to this Privacy Policy or the way your personal information is used, feel free to write to us at support@eve24hrs.com and as well as tag with relationship manager email ID with the same. We'll contact you, and if required, coordinate with the appropriate regulatory authorities to effectively address your concerns.

14. Notification of changes:

We may modify the Privacy Policy at any time. If we make significant changes to the Privacy Policy that affect your rights, we will notify you of the same through a service announcement or by sending an email to your primary email address. You will be provided with at a certain period of time advance notice of the upcoming changes. However, if you have not verified / maintained your updated email address with us, you may miss important notifications that we send through email. If you think that the updated Privacy Policy affects your rights with respect to your use of our Products or Services, you may terminate your MSA by providing us with a written notice in a certain period of time. Your continued use of the Platform, any Product or Service after the effective date of changes to the Privacy Policy will be deemed to be your agreement to the modified Privacy Policy. You may not receive notifications of minor changes to the Privacy Policy. If you are concerned about how your personal information is used, you should check this page regularly for updates.