Privacy Policy

1. Acceptance of Privacy Policy

Last modified on 12th of July 2022.

1.1 By accessing and using our Services, you signify acceptance to the terms of this Privacy Policy. Where we require your consent to process your personal information, we will ask for your consent to process your personal information, we will ask for your consent to the collection, use, and disclosure of your personal information as described further below. We may provide additional “just-in-time” disclosures or information about the data processing practices of specific Services.

1.2 These notices may supplement or clarify our privacy practices or may provide you with additional choices about how we process your data.

1.3 If you do not agree with or you are not comfortable with any aspect of this privacy policy, you should immediately discontinue access or use of our services.

2. Changes to our Privacy Policy

If there are any changes made to the privacy policy, we will communicate about the changes through the email address provided by you.

3. Our Services

3.1 There are many different ways you can use our services through the Avalanchio Technology Private Ltd’s properties, including websites, mobile applications and social media pages that reference this Privacy Policy (“Online Channels”); offline collection in connection with sales, marketing, partner and supplier engagement (“Offline Channels”); and third-party sources, including ad networks and lead brokers (collectively, the “Channels”).

3.2 This Privacy Policy does not apply to personal information obtained through our Careers website, which is subject to the Candidate Privacy Notice available here, or to products and services that post separate privacy policies.

3.3 When you share information with us, for example by creating a Website Account, we can make those services even better – to show you more relevant search results and ads, to help you connect with the right services or to make sharing other products quicker and easier. As you use our services, we want you to be clear how we’re using information and the ways in which you can protect your privacy.

Our Privacy Policy explains:

A. What information we collect and why we collect it.

B. How we use that information.

C. With whom we share it.

D. The choices we offer, including how to access and update information.

E. The measures we take to safeguard the information.

F. How you can contact us regarding privacy policy practices.

3.4 We’ve tried to keep it as simple as possible, but if you’re not familiar with terms like cookies, IP addresses, pixel tags and browsers, then read about these key terms first. Your privacy matters to Avalanchio Pvt. Ltd. so whether you are new to us or a long time user, please do take the time to get to know our practices – and if you have any questions contact us.

3.5 The Online Channels may provide links to other third-party websites and features, or contain third-party cookies, that are not owned or controlled by Avalanchio. Please review the privacy policies of these third parties to familiarize yourself with their practices.

4. Personal Information We Obtain

4.1 Personal information is typically data that identifies an individual or relates to an identifiable individual. This includes information you provide to us, information which is collected about you automatically, and information we obtain from third parties. The definition of personal information depends on the applicable law based on your physical location. Only the definition that applies to your location will apply to you under this Privacy Policy.

4.2 We may obtain personal information through the Channels. The types of personal information we may obtain include:

A .Personal Identification Information: Full name, date of birth, nationality, gender, signature, utility bills, photographs, phone number, postal address, fax number and/or email for you or for others (e.g., principals in your business);

B. Transaction Information: information used to create your online account (such as username, password and security question and answer);

C. Formal Identification Information: biographical and demographic information (such as date of birth, age, gender, job title/position, marital status and dependent, spousal and other family information);

D. Institutional Information: Employer Identification number(or comparable number issued by a government), proof of legal formation(e.g. Articles of Incorporation), personal identification for all material beneficial owners, purchase and customer service history;

E .Financial Information: Bank account information such as payment information including name, billing address and payment card details (i.e., card number, expiration date and security code); bank account information; financial statements; income; and credit score);

F. Location Information: (such as data derived from your IP address, country and zip code) and the precise geolocation of your mobile device where we have provided notice and choice, as appropriate;

G. Transaction Information: contact information you provide about friends or other people you would like us to contact; audio, electronic, or visual information; inferences about you, including about your preferences;

H. Clickstream Information: information about your online activities (such as information about your devices, browsing actions and usage patterns), including across the Online Channels and third-party websites, that we obtain through the use of cookies, web beacons and similar technologies (see our Cookie Consent Tool); and

I. Correspondence: Other personal information contained in content you submit to us (such as through our “Contact Us” feature).

4.3 In addition, in connection with our insurance and financial services products, we may obtain Government issued identity document such as Passport, Driver’s License, National Identity Card, State ID Card, Tax ID numbers, passport number, driver’s license details, national identity card details, visa information and/or and any other information deemed necessary to comply with our legal obligations under financial or anti-money laundering laws.

4.4 We use third-party web analytics services in connection with the Online Channels, including Google Analytics, Adobe Analytics and Marketo, which use cookies and similar technologies to collect data (such as IP addresses) to evaluate use of and interaction with the Online Channels.

4.5 You may learn about Google’s advertising features, including Google Analytics’ currently available opt-out mechanisms, here. To learn more about these and other analytics services and how to opt out, please view our Cookie Consent Tool here.

4.6 Please note that providing personal information to us is voluntary on your part. If you choose not to provide us certain information, we may not be able to offer you certain products and services, and you may not be able to access certain features of the Online Channels.

5. Information We Collect From You Automatically

5.1 To the extent permitted under the applicable law, we may collect certain types of information automatically, such as whenever you interact with the sites or use the services. This automatically helps us address customer support issues, improve the performance of our Sites and applications, provide you with a streamlined and personalized experience, and protect your account from fraud by detecting unauthorized access. Information collected automatically includes:

A. Online Identifiers: Geo location/tracking details, browser fingerprint, operating system, browser name, version, and/or personal IP addresses.

B. Usage Data: Authentication data, security questions, click-stream, public social networking posts, and other data collected via cookies and similar technologies.

5.2 We may automatically receive and record the following information on our server logs:

A. How you can came to us and use the Services; B. Device type and unique device identification numbers; C. Device event information(such as crashes, system activity and hardware settings browse type, browse language, the date and time of your request and referral URL); D. Broad geographic location( e.g. country or city level location): and E. Other technical data collected through cookies, pixel tags and other similar technologies that uniquely identify your browser.

5.3 We may also use identifiers to recognize you when you access our Sites via an external link, such as a link appearing on a third party site.

6. Information you provide to us 6.1 Verification 6.2 Access

7. How We Use Cookies

7.1. Cookies and Similar Technologies, like most companies, Avalanchio uses cookies and similar technologies (“cookies”) on our websites to personalize and enhance your experience on our sites.

7.2. Cookies contain small amounts of information which are downloaded to your device when you visit our website. Cookies are sent back to our website to allow us to recognize your device.

7.3. Essential Cookies allow us to recognize your device to help you navigate efficiently to obtain the information and services you have requested.

7.4. Analytical and Customization Cookies allow our site to remember your preferences such as language selection, and help you to view information that is most relevant to your interests; these cookies also help us to maintain and improve our websites by providing information on how visitors find and use the sites, and how well the sites are performing.

7.5. Advertising Cookies may be used in some cases to make advertising messages more relevant to you.

8. Sharing Tools

8.1. To enhance your experience on our websites, we sometimes embed content and sharing tools from other third-party sites, such as “like” buttons from social networking sites; these third-party sites may also place and access cookies on your device. Avalanchio does not control the placement or access of these third-party cookies. The third parties can be found in our Cookie Consent Tool. Please review the privacy policies of these third parties to familiarize yourself with their practices.

9. How We Use Personal Information

9.1. We may use the personal information we obtain to:

A. provide and administer our products and services;

B. process and fulfill orders and keep you informed about the status of your order;

C. communicate about and administer our products, services, events, programs and promotions (such as by sending alerts, promotional materials, newsletters and other marketing communications);

D. conduct and facilitate surveys, sweepstakes, contests, focus groups and market research initiatives;

E. perform data analytics (such as market research, trend analysis, financial analysis and customer segmentation);

F. engage in ad retargeting and evaluate the effectiveness of our marketing efforts (including through our participation in ad networks);

G. provide customer support; process, evaluate and respond to requests, inquiries and applications;

H. create, administer and communicate with you about your account (including any purchases and payments); administer and register participants in our courses;

I. provide investor services; conduct marketing and sales activities (including generating leads, pursuing marketing prospects, performing market research, determining and managing the effectiveness of our advertising and marketing campaigns and managing our brand);

J. operate, evaluate and improve our business (such as by administering, enhancing and improving our products and services;

K. developing new products, services and Online Channels; managing our communications and customer relationships; and performing accounting, auditing, billing, reconciliation and collection activities);

L.verify your identity and protect against and prevent fraud and other unlawful activity, unauthorized transactions, claims and other liabilities, and manage risk exposure and quality;

M. conduct investigations and comply with and enforce applicable legal requirements, relevant industry standards, contractual obligations and our policies and terms (such as this Privacy Policy and other Online Channels terms of use); and

N. maintain and enhance the safety and security of our products, services, Online Channels, network services, information resources and employees.

9.2. We may combine personal information we obtain through Online Channels with information we obtain through Offline Channels, as well as other information, for the purposes described above. We may anonymize or aggregate personal information and use it for the purposes described above and for other purposes to the extent permitted by applicable law. We also may use personal information for additional purposes that we identify at the time of collection. We will obtain your consent for these additional uses to the extent required by applicable law.

9.3. Where required by applicable law, we will obtain your consent for the processing of your personal information for direct marketing purposes.

9.4. The legal basis for Avalanchio processing your personal information as described above will typically be one of the following:

A.Your consent;

B.Performance of a contract with you or a relevant party;

C.Our legitimate business interests; or

D.Compliance with our legal obligations.

10. Personal Information Sharing

10.1. We do not sell or otherwise disclose personal information about you except as described here or at the time of collection. A.We may share personal information with service providers we have retained to perform services on our behalf (such as payment processing, order fulfillment, customer support and data analytics). These service providers are contractually required to safeguard the information provided to them and are restricted from using or disclosing such information except as necessary to perform services on our behalf or to comply with legal requirements.

B. We may disclose personal information about you (1) if we are required or permitted to do so by applicable law or legal process (such as a court order or subpoena), (2) to law enforcement authorities or other government officials to comply with a legitimate legal request, (3) when we believe disclosure is necessary to prevent physical harm or financial loss, (4) to establish, exercise or defend our legal rights, (5) in connection with an investigation of suspected or actual fraud or illegal activity or (6) otherwise with your consent.

C. We reserve the right to transfer to relevant third-parties any information we have about you in the event of a potential or actual sale or transfer of all or a portion of our business or assets (including in the event of a merger, acquisition, joint venture, reorganization, divestiture, dissolution or liquidation) or other business combination. In such a case, we will require the relevant third parties to provide comparable levels of protection as the Avalanchio provides with respect to the information we share. We only share information in the following circumstances: Network Infrastructure, Cloud storage, Payment processing, Security, Document repository services, Customer support, Internet (e.g. ISPs), Data analytics, Information Technology, Marketing.

11. Cross Border Data Transfers

We may transfer the personal information we collect through the Channels to, and store such data in, other countries, including the U.S., which may have different data protection laws than the country in which the information was provided. If we do so, we will transfer the personal information to facilitate global operations only for the purposes described in this Privacy Policy. To the extent required by applicable law, when we transfer your personal information to recipients in other countries, we will take measures to protect that information. By communicating electronically with Us, you acknowledge and agree to your personal information being processed in this way.

12. Children’s Personal Information

Our Services are not directed at children under the age of eighteen (18) and we do not knowingly collect personal information from children under the age of eighteen (18). If we become aware that we have inadvertently received personal information from a Visitor under the age of eighteen (18), we will delete the information from our records.

13. Your Privacy Rights

13.1. Access and portability- You may request that we provide you a copy of your personal information held by us. this information will be provided without undue personal information held by us. This will be provided without undue delay subject to a potential fee associated with gathering of the information (as permitted by law), unless such provision adversely affects the rights and freedoms of others. in certain circumstances, you may request to receive your personal information in a structured, commonly used and machine- readable format, and to have us transfer your personal information directly to another data controller.

13.2. Ratification- You may ask for ratification of incomplete or inaccurate personal information.

13.3. Erasure- You may request to erase your personal information, subject to the applicable law.

13.4. Consent- You may withdraw your consent for sharing the information mentioned in this policy at any point.

13.5. Restriction- You may restrict the processing of the information mentioned herein.

13.6. Automated Individual decision-making, including profiling. We rely on automated tools to help determine whether a transaction or a customer account presents a fraud or legal risk. In some jurisdictions, you have the right not to be subject to a decision based solely on automated processing of your personal information, including profiling, which produces legal or similarly significant effects on you, save for the exceptions applicable under relevant data protection laws.

14. How We Protect Personal Information Transmission

We maintain administrative, technical and physical safeguards, consistent with legal requirements where the personal information was obtained, designed to protect against unlawful or unauthorized destruction, loss, alteration, use or disclosure of, or access to, the personal information provided to us through the Channels.

15. Retention of Personal Information

To the extent permitted by applicable law, we retain personal information we obtain about you as long as (1) it is needed for the purposes for which we obtained it, in accordance with the provisions of this Privacy Policy or (2) we have another lawful basis, stated in this Privacy Policy or at the point of collection, for retaining that information beyond the period for which it is necessary to serve the original purpose for obtaining the personal information.

16. CCPA and GDPR

16.1. We may process your personal data for specific processing purposes based on your prior consent, for legitimate business interest. Where we refer to GDPR Article 6.1 (f) to process your personal data, to efficiently manage and perform its business operations, to maintain and operate intelligent and sustainable business processes in a group structure optimized for the division of labor and in the best interest of our employees, customers, partners, and shareholders, to operate sustainable business relationships with Avalanchio Technologies Private Ltd customers and partners including you (each of which as further set out below), serve you with the best possible user experience when using Avalanchio Technologies Private Ltd’s web services, comply with extraterritorial laws and regulations, or assert or defend itself against legal claims.

16.2. We believe that our interest in pursuing these business purposes is legitimate and thereby not outweighed by your personal rights and interest to refrain from processing. In any of these cases, we duly factor into our balancing test: the business purpose reasonably pursued by Avalanchio Technologies Private Ltd in the given case,the categories, amount and sensitivity of personal data that is necessarily being processed,the level of protection of your personal data which is ensured by means of our general data protection policies, guidelines, and processes, and the rights you have in relation to the processing activity. If you wish to obtain further information on this approach, please contact webmaster privacy@avalanchio.com Avalanchio Technologies Private Ltd.com.

16.3. Pursue business relationships with customers, partners, and others when pursuing business relationships with customers, partners and others, Avalanchio Technologies Private Ltd and local Avalanchio Technologies Private Ltd group entities may be processing personal data based on:

GDPR Article 6.1 (b) if necessary, to fulfill (pre-)contractual obligations with you,

GDPR Article 6.1 (c) if necessary, to fulfill legal requirements applicable to Avalanchio Technologies Private Ltd,

GDPR Article 6.1 (f) if the contract or pre-contractual relation relates to a company or other legal body and if Avalanchio Technologies Private Ltd processes your personal data as Customer Contact to fulfill (pre-) contractual obligations with your employer (legitimate interest to efficiently perform or manage Avalanchio Technologies Private Ltd’s business operation)

GDPR Article 6.1 (f) if necessary, to maintain our business relationships with you, ensure your satisfaction as a user or customer representative, and provide you with information about other Avalanchio Technologies Private Ltd products and services as indicated by your interest or demand (legitimate interest to operate sustainable business relationship with Avalanchio Technologies Private Ltd customers and partners), or a legal permission under other national laws equivalent to any of the above, when applicable. Ensure compliance with laws and regulation when ensuring compliance with applicable laws and regulations, Avalanchio Technologies Private Ltd and local Avalanchio Technologies Private Ltd group entities may process your Personal data based on

GDPR Article 6.1 (c) if necessary, to fulfill legal requirements under European Union or EU Member State law to which Avalanchio Technologies Private Ltd is subject,

GDPR Article 6.1 (f) if necessary, to fulfill laws and regulations extraterritorial to the EU (legitimate interest to comply with extraterritorial laws and regulations), or the equivalent articles under other national laws, when applicable. Operate Avalanchio Technologies Private Ltd internet pages, web offering, or other online events when operating its internet pages, web-offerings or other online events (“web-services”) and depending on the respective operating purpose, Avalanchio Technologies Private Ltd or the local Avalanchio Technologies Private Ltd group entity is processing your personal data on the basis of the following legal permissions:

GDPR Article 6.1 (b) and (f) to provide the web services and functions, create and administer your online account, updating, securing, troubleshooting the service, providing support, improving, and developing the web service, answering and fulfilling your requests or instructions, (legitimate interest to efficiently perform or manage Avalanchio Technologies Private Ltds business operation)

GDPR Article 6.1 (c) and (f) to manage and ensure the security of our web services and prevent and detect security threats, fraud or other criminal or malicious activities and as reasonably necessary to enforce the web services terms, to establish or preserve a legal claim or defense, to prevent fraud or other illegal activities, including attacks on our information technology systems (legitimate interest to efficiently perform or manage Avalanchio Technologies Private Ltd’s business operation and assert or defend itself against legal claims)

GDPR Article 6.1 (a) if it is necessary that we ask you for your consent to process your personal data or equivalent legal permissions under other relevant national laws, when applicable. Cookies and similar tools when tracking and evaluating the usage behavior of users of our web services by means of cookies or similar technologies, Avalanchio Technologies Private Ltd is processing your personal data on the basis of the following legal permissions:

GDPR Article 6.1 (a) if it is necessary that we ask you for your consent to process your personal data,

GDPR Article 6.1 (b) if necessary to fulfill (pre-)contractual obligations with you,

GDPR Article 6.1 (f) if necessary to fulfill (pre-)contractual obligations with the company or other legal body you represent as a customer contact (legitimate interest to efficiently perform or manage Avalanchio Technologies Private Ltd’s business operation), or equivalent legal permissions under other relevant national laws, when applicable. Collection of data from third parties, including publicly available sources when collecting personal data about you from third parties, the legal basis for the collection by Avalanchio Technologies Private Ltd. GDPR Article 6.1 (a) if it is necessary that we or the third party transferring your personal data to Avalanchio Technologies Private Ltd has asked you for your consent to process your personal data,

GDPR Article 6.1 (b) if necessary to fulfill (pre-)contractual obligations with you,

GDPR Article 6.1 (c) if necessary to fulfill legal requirements under European Union or EU Member State law to which Avalanchio Technologies Private Ltd is subject,

GDPR Article 6.1 (f) if necessary to fulfill laws and regulations extraterritorial to the EU (legitimate interest to comply with extraterritorial laws and regulations) or to maintain our business relationships with you, ensure your satisfaction as a user or customer representative, and provide you with information about other Avalanchio Technologies Private Ltd products and services as indicated by your interest or demand (legitimate interest to operate sustainable business relationship with Avalanchio Technologies Private Ltd customers and partners) or equivalent legal permissions under other relevant national laws, when applicable. Offering Avalanchio Technologies Private Ltd products and services When engaging in marketing activities, Avalanchio Technologies Private Ltd is processing your personal data on the basis of the following legal permissions:

GDPR Article 6.1 (a) if your consent is required by law for Avalanchio Technologies Private Ltd to process your data for this purpose,

GDPR Article 6.1 (f) if necessary to fulfill (pre-)contractual obligations with the company or other legal body you represent as a customer contact (legitimate interest to efficiently perform or manage Avalanchio Technologies Private Ltd’s business operation), to maintain our business relationships with you or your employer, to ensure your satisfaction as a user or customer contact, to map the relevant group internal structures and bundle relevant business activities at central sources within the Avalanchio Technologies Private Ltd Group to operate them uniformly and to provide you with information about other Avalanchio Technologies Private Ltd products and services as indicated by your interest or demand, which may also comprise the combination about you from different sources (profiling) (legitimate interest to maintain and operate intelligent and sustainable business processes in a group structure optimized for the division of labor and in the best interest of our employees, customers, partners, and shareholders and to operate sustainable business relationship with Avalanchio Technologies Private Ltd customers and partners). Avalanchio Technologies Private Ltd may provide you with this information to your postal address to pursue our legitimate interest to address customers, prospects and targets for the purpose of advertising our products and services, to your email address for the purpose of direct marketing of similar products or services provided that we (i) received your email address in connection with the purchase of our products or services, (ii) you did not object to the use of your email address for direct advertising and (iii) and we inform you in every approach that you may object to our use of your email address for marketing purposes at any time, and by other electronic means (e.g. telephone, MMS) to the extent permitted under applicable law, generally either explicit or presumed consent, or equivalent legal permissions under other relevant national laws, when applicable.

16.4.How does Avalanchio Technologies Private Ltd justify international data transfers? As a global group of companies, Avalanchio Technologies Private Ltd has group affiliates and uses third party service providers also in countries outside the European Economic Area (the “EEA”). Avalanchio Technologies Private Ltd may transfer your personal data to countries outside the EEA as part of Avalanchio Technologies Private Ltd’s international business operations. If we transfer personal data from a country in the EU or the EEA to a country outside the EEA and for which the EU Commission has not issued an adequacy decision, Avalanchio Technologies Private Ltd uses the EU standard contractual clauses to contractually require the data importer to ensure a level of data protection consistent with the one in the EEA to protect your personal data. You may obtain a copy (redacted to remove commercial or irrelevant information) of such standard contractual clauses by sending a request to privacy@avalanchio.com Avalanchio Technologies Private Ltd.com. You may also obtain more information from the European Commission on the international dimension of data protection here.

16.5. Where Avalanchio Technologies Private Ltd is subject to certain privacy requirements in the United States, the following also applies: U.S. Children’s Privacy. Avalanchio Technologies Private Ltd does not knowingly collect the personal data of children under the age of 13. If you are a parent or guardian and believe Avalanchio Technologies Private Ltd collected information about a child, please contact Avalanchio Technologies Private Ltd as described in this Privacy Statement. Avalanchio Technologies Private Ltd will take steps to delete the information as soon as possible. Given that Avalanchio Technologies Private Ltd websites and online services are not directed to users under 16 years of age and in accordance with the disclosure requirements of the CCPA, Avalanchio Technologies Private Ltd does not sell the personal data of any minors under 16 years of age.

16.6. Where Avalanchio Technologies Private Ltd is subject to certain privacy requirements in the United States. We do Not Track. Your browser may allow you to set a “Do not track” preference. Unless otherwise stated, our sites do not honor “Do not track” requests. However, you may elect not to accept cookies by changing the designated settings on your web browser or, where available, by referring to our Cookie Statement. Cookies are small text files placed on your computer while visiting certain sites on the Internet used to identify your computer. If you do not accept cookies, you may not be able to use certain functions and features of our site. This site does not allow third parties to gather information about you over time and across sites.

16.7. You have the right: to request from Avalanchio Technologies Private Ltd access to your personal data that Avalanchio Technologies Private Ltd collects, uses, or discloses about you;to request that Avalanchio Technologies Private Ltd delete personal data about you; to opt-out of the use or disclosure of your sensitive personal information; to non-discriminatory treatment for exercise of any of your data protection rights;

16.8. If you request access to your personal data, for such information to be portable, if possible, in a readily usable format that allows you to transmit this information to another recipient without hindrance

16.9. In accordance with the disclosure requirements under the California Consumer Privacy Act (“CCPA”), Avalanchio Technologies Private Ltd does not and will not sell your personal data or otherwise permit the use of your information for any kind of cross-context behavioral advertising. In accordance with the verification process set forth in the CCPA, Avalanchio Technologies Private Ltd will require a more stringent verification process for deletion requests, or for personal data that is considered sensitive or valuable, to minimize the harm that might be posed to you by unauthorized access or deletion of your personal data. If Avalanchio Technologies Private Ltd must request additional information from you outside of information that is already maintained by Avalanchio Technologies Private Ltd, Avalanchio Technologies Private Ltd will only use it to verify your identity so you can exercise your data protection rights, or for security and fraud-prevention purposes.

16.10. This policy guarantees the contractually agreed and legally prescribed data security measures. It will take all necessary measures to safeguard the data and the security of the processing, in particular taking into account the state of the art, as well as to reduce possible adverse consequences for the affected parties.

16.11. Measures to be taken include, in particular, measures to protect the confidentiality, integrity, availability and resilience of systems and measures to ensure continuity of processing after incidents. In order to ensure an appropriate level of processing security at all times, we will regularly evaluate the measures implemented and make any necessary adjustments.

17. How to Contact Us

If you have any questions or comments about this Privacy Policy or if you would like us to update information we have about you or your preferences, please contact us by visiting our Feedback & Inquiries Form or write to us at:

info@avalanchio.com

Attention: Customer Success, Avalanchio Technologies Private Ltd 677, 1st Floor, 27th Main, 13th Cross, HSR Layout, 1 Sector, Bangalore, Karnataka, 560102, India