Personal Data Protection and Privacy Policy Powerweave Heuristic Investment Technologies Private Limited

This Personal Data Protection and Privacy Policy (this “Policy”) relates to the collection, receipt, possession, storage, disclosure, dealing and handling of your information including your personal data and information and your sensitive personal data and information. You must carefully review and understand the contents of this Policy before you provide your consent to us to agree to and be bound by the terms and conditions of this Policy. If you do not agree to the terms and conditions of this policy, and/or if you withdraw the consent that you may provide, at any time, then we reserve our rights not to provide a license of our software to you and/or to discontinue the provision of the license, as the case may be, and the related services, if any. If you provide consent thorugh our website or otherwise, you would be bound to have accepted all the terms and conditions contained in this Policy. We reserve our rigts to modify and amend this Policy by sending you an e-mail notifying you of the same and you shall be bound to have accepted the modification or amendment, if you do not respond stating otherwise within 24 hours of receiving the said e-mail. Collection of Personal Data and Information and Sensitive Personal Data and Information: In connection with the software license that may be granted to you pursuant to the End User Software License Agreement, the terms and conditions of which you accept through our website (https://www.phi1.io/), or through any other method or device, as we may make available in the future, we would collect your personal data and information and sensitive personal data and information such as: (i) name, age and gender, (ii) residential and/or office address, (iii) passwords for use on our website, (iv) financial information i.e. bank account, credit card, debit card and/or other payment instrument details.

Please note that our website may use cookies and google analytics to collect information and data regarding your demographics including location, and your behaviour and activity on our website. Purpose of Collection and Usage of Information Collected: The purpose of collection and usage of the information collected by us is to: (i) to verify that we are dealing with a genuine customer (ii) for conducting our own due diligence with regard to the security of our receivables of the fees, (iii) protection of our intellectual property rights in the software (iv) protection of our confidential information, (v) our ability to effectively enforce the terms and conditions of the software license agreement between us, including recoveries of any pending amounts that may be or become due and pending under the said agreement, (vi) to have adequate information for disclosure to any government agencies mandated under the law to obtain such information from us for the purposes of verifying your identity or for the prevention, detection, investigation, prosecution and punishment of offences and/or pursuant to any order under the law, (vii) to analyse and understand customer behaviour, (viii) to improve the quality of our products and services, (ix) to offer new and/or related products and services to you whether of our company or of any third person’s or entity’s, (x) to provide technical support and/or perform our obligations under the End User Software License Agreement between us, and (xi) for billing and payment collection purposes, (xii) for providing news letters and news alerts regarding our existing and anynew products and/or services, (xiii) for sending certain push notifications, (xiv) for communicating with you on e-mails and telephone and other modes of communication. Disclosure of Information Collected: In addition to what is stated above with regard to disclosure of the information collected from you, we may also disclose the said information for other business development purposes. The information that we collect will be disclosed to our employees, shareholders, and directors, and may also be disclosed to our consultants, sub-contractors and/or vendors, legal advisors, accountants, company secretaries, auditors, as we may deem necessary.

Retention of Information: We shall retain the information you provide until such time as is required for the purpose for which the information is being collected or is required by law in force from time to time.

Review of the Information: You may review all the information that you may be provide and we collect upon written request to us. Upon receipt of such request, we shall within a reasonable time share with you such information collected by us. If you find that any such information is inaccurate or deficient, please intimate the same to us in writing and we shall correct or amend the same as may be feasible with a reasonable time. However, please not that we are not liable for the authenticity of any information provided by you and you yourselves will be liable for any incorrect information that you may provide.

Option not to provide the Information: Please note that it is your option whether or not to provide the above information. As stated above, you also have the option to withdraw any consent that you may have given to us earlier provided that such withdrawal is sent by you in writing to us. Further as stated above, if you do not provide your consent or withdraw your consent in the future then we have the option not to provide the software license and/or any good or services to you for which the above information was sought.

Security of the Information:We use technical and organizational safeguards to protect your personal data and we also work with select third parties to have adequate data security processes. We use Transport Layer Security (“TLS”) encryption technology in order to protect certain information that you submit. This type of technology protects you from having your information intercepted by anyone while it is being transmitted. While on a secure page, such as our order form, the "lock" icon in the browser window is displayed, confirming that a secure, encrypted connection has been established with our website. We work hard to ensure that our website is secure. We also use other safeguards, such as firewalls, authentication systems (i.e, passwords and personal identification numbers), and access control mechanisms to control unauthorized access to systems and data. Where you chose to create an account, you are responsible for doing everything reasonable to keep your access details secret. You must not share such details with anyone else. We also do our best to protect your information offline. The servers that store personal data are located in a secure environment in a locked facility. We are constantly improving the ways we secure the data we collect, store and process, including physical security measures that help us counter unauthorized access to our systems. However, electronic storage or transmission of data can never be 100% secure. Therefore, absolute security cannot be guaranteed, but we undertake all reasonable care to secure the data. Transfer of the Information: We may transfer the information we collect from you, to any body corporate or to any person in India and/or outside India provided such a body corporate or person ensures the same level of protection that is adhered to by us. Further, in addition to any legal obligation, we would transfer the information only where it is necessary for the performance of the contract between us including in connection with any business or corporate transaction, such as a joint venture, a merger, an acquisition, a strategic alliance, etc. We may also transfer such information in the course of a business transaction. Data Breach: While we have taken all reasonable steps to protect the information, we collect from you, in the unfortunate event that there is any data breach for any reason whatsoever, then our maximum liability for any act or omission attributable to us shall be limited to Rs.500/- and we shall in no manner whatsoever be liable to compensate you further under any theory of law including tort. Further, in order to prevent any data breaches, apart from the steps we have taken, you agree that you would take all reasonable steps to protect your own personal information including passwords Any and all disputes between us with regard to the terms and conditions of this policy shall be submitted to arbitration on the same terms as are provided in the End User Software License Agreement between us, and the arbitration provisions and all other applicable clauses of the said Agreement are deemed to be incorporated herein by reference, and you agree to be bound by the such clauses thereof.

Grievance Officer: If you have any grievance with regard to processing of your information then you may contact Mr. Aviral Bajpai via email on aviral.bajpai@powerweave.com followed by a letter in writing and sent to our registered office address which is Powerweave House, Plot Number 27, Road Number 11, MIDC, Marol, Andheri (E), Mumbai 400-093. The Grievance Officer shall make reasonable efforts to redress your grievance within one month from the date of written receipt of your grievance.