We value your privacy and are committed to ensuring the security of your personal information. This Privacy Policy outlines how flipssi Limited and its affiliates (collectively referred to as "flipssi," "we," "our," or "us") collect, use, share, and manage your personal data through our website (www.flipssi.com), mobile application, and mobile site (collectively referred to as the "Platform").

This Privacy Policy is an electronic agreement established under the Information Technology Act, 2000 and its applicable rules and regulations, including the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, and the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021. No physical or digital signatures are required for this policy to be legally binding.

By accessing or using our Platform or services, you agree to the terms of this Privacy Policy, which forms a legally enforceable agreement. Please review this policy carefully, along with our Terms of Services.

By accessing our Platform, providing your information, or using our products or services, you explicitly agree to be bound by this Privacy Policy and our applicable Terms of Service. Your continued use of our platform/services constitutes your clear consent to the collection, use, sharing, and processing of your information as outlined in this policy. If you do not agree with these terms, please refrain from accessing or using our platform or services.

You acknowledge that the disclosure of your Personal Information is voluntary. If you choose not to provide the requested information during the registration process or when accessing our services, the registration may remain incomplete, and you may be unable to use our services.

If you are a corporate customer, a separate Non-Disclosure Agreement (NDA) may govern the confidentiality of information. This Privacy Policy does not affect or override any such agreements in place.

B. Application of Policy

This Privacy Policy applies to all websites, mobile sites, applications, and other services (collectively referred to as the "Services") provided by flipssi Limited and its affiliates (referred to as "flipssi," "we," "us," or "our") that link to this policy. It is binding on all users who access, visit, or use flipssi’s Services.

This policy applies equally to:

• Vendors
• Service providers
• Subcontractors
• Partners
• Agents
• Representatives
• Employees
• Third parties

We only collect and use personal data voluntarily provided by you. You can browse our platform without sharing personal information. However, to register or access specific services, you may need to provide certain personal details.

Additionally, this policy applies to:

• Contractors, suppliers, customers, users, vendors, and partners working on behalf of flipssi or using our Services.
• flipssi’s head office, branch offices, and other operational locations.
• All flipssi employees and officials.

We handle all identifiable personal data in compliance with this policy, even if the data is not explicitly covered under Privacy & Data Protection laws. Examples of the personal information we collect include:

• Names
• Addresses
• Mobile/Telephone numbers
• Email addresses
• Other information shared by users while accessing or using our Services

This Privacy Policy is a part of flipssi’s Terms of Service and governs the treatment of user information, including personally identifiable information, collected when you:

• Access the flipssi platform.
• Use flipssi’s Services.
• Use any software provided by flipssi.

This policy does not apply to third-party organizations we do not own, manage, or control, nor to individuals not employed or directly managed by flipssi.

C. Objectives of the Policy

flipssi collects and uses certain personal information from individuals, including customers, suppliers, vendors, business contacts, employees, and other third parties with whom we have a business relationship or may need to contact.

This policy outlines how flipssi:

• Collects, receives, stores, uses, and handles your personal information, including sensitive data.
• Ensures your personal information is available for your review.
• Complies with data protection laws and maintains best practices.
• Protects the rights of individuals, including employees, customers, suppliers, vendors, and business partners.
• Safeguards data from risks of breaches and unauthorized access.

Our goal is to ensure that all personal data is managed responsibly, in line with applicable legal requirements, while respecting your privacy rights.

D. Collection of Information

At flipssi, we collect and store various types of information from individuals and third parties while providing our services. This information may be generated, received, or maintained in multiple forms, including:

• Corporate records
• Financial records
• Legal documents
• Contracts
• Correspondence from third parties
• Employee records
• Invoices
• Completed application forms
• Contact lists
• Email communications and attachments
• Photos and other media

We collect information to offer and enhance our products and services. This information may be gathered online through our website (www.flipssi.com), mobile application, or mobile site, as well as offline through other interactions. Regardless of the collection method, we apply the same level of privacy protection to all personal data.

Ways We Collect Information

We may collect your Personal Information when you:

• Install, access, or use our services.
• Create an account on our platform.
• Request customer support or contact us.
• Conduct transactions, especially when required by law.
• Submit testimonials, ratings, or reviews.
• Provide any other personal information voluntarily.

Personal Information We Collect

During registration or service use, we may collect the following details:

• Personal Details: Name, residence address, workplace address, email address, date of birth, educational qualifications, marital status, and similar information.
• Payment Information: Credit card, debit card, or other payment instrument details.
• KYC Documents:
  • Individuals: Driving license, Aadhaar number, Voter ID, PAN card, GST, Passport, NREGA job card, or a National Population Register letter with address details.
  • Address Proof: Utility bills (electricity, telephone, mobile, gas, water) not older than two months, property tax receipts, or pension payment orders.
  • Foreign Nationals: Letter from a Foreign Embassy or Mission in India, as per RBI (Reserve Bank of India) guidelines.

For Businesses

Depending on the type of business entity, we may collect specific documents:

• Sole Proprietors:
  • Registration certificate
  • Shop and Establishment Act license
  • Sales and income tax returns
  • GST certificate
  • Importer Exporter Code (IEC)
  • Income Tax Return acknowledgment
  • Utility bills or other proof of business activity
• Legal Entities (Companies):
  • Certificate of Incorporation
  • Memorandum and Articles of Association
  • Permanent Account Number (PAN)
  • Board resolution and power of attorney documents
  • Documents relating to beneficial owners
• Partnership Firms:
  • Registration certificate
  • Partnership deed
  • PAN of the partnership firm
  • Beneficial owner, manager, and officer documents
• Trusts:
  • Registration certificate
  • Trust deed
  • PAN or Form No. 60
  • Beneficial owner and manager documents
• Unincorporated Associations or Bodies of Individuals:
  • Managing body resolution
  • PAN or Form No. 60
  • Documents relating to beneficial owners, managers, and officers

Video-Based Customer Identification

In compliance with RBI’s KYC policy, we may conduct a Video-Based Customer Identification Process (V-CIP) through third-party service providers or our internal team.

Purpose of Collecting Personal Information

We use the collected personal information for the following purposes:

• To personalize the content and improve your user experience.
• To fulfill service requests and process transactions.
• To communicate with you about our services using emails, SMS, or other channels.

We clearly indicate which fields are mandatory and which are optional during data collection. You always have the option not to provide certain information, although it may limit your access to specific services or features.

Other Sources of Data Collection

In addition to direct user interactions, flipssi collects data from external sources, including:

• Newspapers
• Visiting cards
• Pamphlets and advertisements
• Magazines and journals (both free and paid)
• Data collectors and agencies
• Free sign-up options available on our platform

Types of Information Collected by Flipssi

flipssi collects various types of information from different sources to provide and improve its services. Below is a detailed overview of the types of information we collect:

1. Users/Customers

   When you access or use our platform, we may collect the following personal information:

   • Personal Information: Name, address, phone number, email ID, age, personal description, and profile photograph.
   • Delivery Information: Delivery address and contact details.
   • Payment Information: Payment method, credit/debit card details, or other financial information.
   • Location Data: Your geographical location if enabled on your device.
   • Device Information: Device model, operating system, browser type, and other technical data.
   • IP Address: Internet Protocol (IP) address used to access our platform.
   • Contacts: Access to your address book for app users (with consent).
   • Communication Data: Emails, reviews, ratings, and feedback submitted to us.
   • Call Recordings: Voice recordings of customer service calls.
   • Usage Data: Login details, device log files, browsing behavior, and interactions with our platform.
2. Vendors/Sellers

   For vendors and sellers registered on our platform, we collect the following information:

   • Personal Information: Name, address, phone number, email ID, age, marital status, personal description, and profile photograph.
   • Payment Details: Bank details and financial transactions.
   • Location Data: Current geographical location if provided.
   • Device Information: Device specifications, IP address, and operating system.
   • Communication Data: Emails, reviews, feedback, and voice recordings of support calls.
   • Media Data: Photos, videos, and other content related to your business.
   • KYC Documents: Identification and address proofs such as Aadhaar card, PAN card, GST, Voter ID, Passport, Shop and Establishment Certificate, etc.
   • Business Details: Corporate information, business address, and financial details.
3. Automatic Information

   When you interact with our platform, we automatically collect certain information:

   • IP Address: Internet Protocol address of your device.
   • Login Data: Email address, password, and device log files.
   • Location Data: Location of your device or computer.
   • Interaction Data: Content viewed, searches performed, videos streamed, and pages visited.
   • Device Metrics: Performance metrics, error reports, and app usage data.
   • Technical Data: Network details, connectivity information, and troubleshooting logs.
   • Browsing Data: URLs visited, date and time stamps, page response times, and download errors.
   • Media Data: Images and videos accessed or uploaded on our platform.
   • Identifiers: Device identifiers, cookies, browsing history, and technical information.
4. Information from Other Sources

   We may receive additional information from third-party sources such as:

   • Delivery Information: Updated address and delivery details from carriers and third parties.
   • Account Information: Purchase or transaction data from merchants and partners.
   • Vendor Interactions: Communication details with vendors through our platform.
   • Search and Link Data: Search results and links from partner websites.
   • Device Data: Information from internet-connected devices.
5. Officials/Employees/Resellers

   We collect information from our employees, officials, and resellers for administrative purposes:

   • Personal Information: Name, address, phone number, email ID, age, profile photograph, and personal description.
   • Educational Information: Academic qualifications and certifications.
   • KYC Documents: Identification documents, including Aadhaar card, PAN card, and passport.
   • Payment Information: Salary and payment details.
   • Location Data: Geographical information if necessary.
   • Device Information: Device specifications, IP address, and log data.
   • Communication Data: Emails, reviews, and voice recordings of calls.
   • Login Data: Credentials and login history on our platform.
6. Third-Party Information

   We may collect the following information from third-party entities:

   • Corporate Information: Company details, including CIN, PAN, and GST numbers.
   • Financial Data: Financial records and payment details.
   • Location Data: Geographical location of third-party partners.
   • Device Information: Technical details from third-party applications or services.
   • Identity and Address Information: Official identification details from our partners and service providers.

This data helps us enhance our services, ensure compliance with legal obligations, and maintain platform security.

E. Information Not Collected by Flipssi

At flipssi, we do not collect sensitive personal data or information unless it is necessary to provide our services, fulfill specific purposes, or meet legal obligations. Users can freely browse and search on flipssi’s platform without providing any personal information. However, certain services may require personal information for access.

Information We Do Not Collect:

• Mobile Address Book: We do not collect email addresses, addresses, or other contact details from your mobile address book or contact list, except for names and mobile phone numbers when required.
• Location History: We do not store your historical location information. The only location data retained is the last known location when the flipssi platform is accessed and current location data is unavailable.
• Social Media Integration: flipssi integrates with the Facebook SDK and may send aggregate usage statistics to Facebook. Please note that Facebook’s use of this information is governed by its own data usage policies, which can be accessed at www.facebook.com/about/privacy.

Transparency During Data Collection

When collecting personal information, flipssi ensures you are clearly informed about:

• The fact that information is being collected.
• The purpose for which the information is being collected.
• The intended recipients of the information.
• The name and address of the collecting agency and the agency retaining the information.

Conditions for Data Collection

flipssi will only collect your personal information if:

• You provide valid, informed, and voluntary consent.
• The information is necessary for fulfilling a contract to which you are a party.
• Data processing is essential for compliance with legal obligations.
• Data processing is required to protect your interests.
• Processing is necessary for a task carried out in the public interest.

We are committed to maintaining transparency and ensuring your data is handled lawfully and responsibly.

F. Usage of Information

The information collected by flipssi is used primarily for the purpose for which it was gathered. Additionally, we use your data for the following purposes:

1. Providing and Enhancing Services
   • Deliver the requested products and services and communicate with you regarding your orders or service requests.
   • Provide a personalized experience by tailoring our platform’s content, product recommendations, and service offerings.
   • Analyze and improve the performance, usability, and effectiveness of our platform and services.
   • Ensure the proper operation and maintenance of our platform.
2. Customer Support and Communication
   • Respond to your reviews, comments, feedback, or inquiries.
   • Administer contests, sweepstakes, promotions, and surveys.
   • Communicate with you about our services and recommend products or features that may interest you.
3. Facilitating Transactions
   • If you search for a product or service without logging in, we may collect your mobile number and generate a lead for our vendors or service providers based on your choice or request.
   • If you are logged in, we may share your information (such as your name, mobile number, and email) with our vendors or service providers to fulfill your request.
4. Advertising and Marketing
   • Display interest-based advertisements for relevant products and services.
   • Contact you for promotional purposes, service updates, or customized offers.
5. Security and Fraud Prevention
   • Prevent, detect, and respond to fraud, unauthorized access, and misuse of our platform.
   • Protect the security of our users, flipssi, and others.
6. Legal and Compliance
   • Use your information in legal proceedings when necessary, including actions related to misuse of flipssi’s services.
   • Comply with legal obligations and requests from regulatory authorities. For example, we may collect seller information for identity verification and financial compliance.
7. Operational Needs

   Support our internal business functions, including:

   • Order fulfillment
   • Marketing analysis
   • Loss and fraud prevention
   • Authentication
   • Public safety management
8. Voice, Image, and Video Data
   • Process your voice input, images, and videos to respond to your requests, deliver services, and improve our platform.
   • Enhance the user experience by using data to understand, customize, and market our services.

By using our platform, you agree to the usage of your information as outlined above.

Use and Confidentiality of Personal Information

Your Personal Information will remain confidential and will be used solely for our research, marketing, and strategic analysis purposes, as well as other internal business functions. flipssi does not sell your Personal Information to third parties.

1. Information Sharing for Service Fulfillment
   • For Customers: If you are a customer using our services, your information may be shared with our subscribers or advertisers in response to your queries or requests. These subscribers or advertisers may contact you directly regarding the products or services you inquired about.
   • For Vendors/Sellers/Businesses: If you are a vendor or seller using our services, your information may be shared with our users, customers, subscribers, or advertisers who are interested in your offerings. By using our platform, you consent to this information sharing.
2. Use of Personal Information

   Your information may be used for the following purposes:

   • Order Management: Assist vendors, service providers, and business partners in processing and fulfilling your orders.
   • Customer Support: Enhance your customer experience and resolve disputes or troubleshoot issues.
   • Safety and Compliance: Promote a safe environment, prevent fraud, collect payments, and comply with legal requirements.
   • Promotions and Updates: Inform you about offers, products, and service updates.
   • Personalization: Customize your experience based on your preferences and usage patterns.
   • Market Analysis: Analyze user behavior for insights to improve our products and services.
   • Enforcement: Ensure compliance with our terms and conditions.
3. Consent for Access to Additional Information

   With your explicit consent, we may access the following:

   • SMS and Contacts: For certain services, such as verification or communication.
   • Location and Device Data: To enhance the user experience and provide localized services.
   • PAN, GST Number, or Government ID: To verify eligibility for specific products, issue GST invoices, or offer personalized services.

   Note: Your access to certain products or services may be limited if consent for these data access requests is not granted.

4. IP Address and Technical Data
   • We collect and analyze your IP address to diagnose server issues and administer our platform.
   • Your IP address may also be used for user identification and to gather demographic insights.
5. Surveys and Market Research

   Occasionally, we may invite you to participate in optional surveys conducted by us or authorized third-party agencies. These surveys may collect:

   • Personal and contact information
   • Date of birth and demographic data (e.g., location, age, income level)
   • Lifestyle preferences and interests
   • Purchasing behavior and history
   • Voice or video data (if applicable)

   Participation in surveys is voluntary, and the information collected will be used to customize and enhance your experience by tailoring content and recommendations according to your preferences.

By using our platform, you agree to the collection and use of your information as described in this policy.

Third-Party Functions and Data Use

flipssi collaborates with third-party companies and individuals to perform various functions, including:

• Data Analysis
• Marketing Assistance
• Search Result and Link Management (Including Paid Listings)
• Payment Processing
• Customer Service

These third parties have access to your Personal Information only to the extent necessary to perform their functions. They are prohibited from using this information for any other purposes and must comply with this Privacy Policy and applicable laws while processing your data.

Compliance with Legal Obligations

In certain situations, we may collect and use your Personal Information to comply with legal requirements. For example, we may gather details regarding a vendor or seller's place of establishment and bank account information for identity verification purposes.

Use of Your Personal Information

If you submit Personally Identifiable Information (PII) through the flipssi platform or flipssi Service, we use your information to:

• Operate, maintain, and provide platform features and services.
• Enable essential functionalities, particularly those requiring your mobile number for identification.

Your mobile number may be retained as part of your continued use of our services. Additionally, your name (as saved in other users’ contact lists) may be displayed to those users if they tag your mobile number to view your ratings within the app.

Tagging and Untagging Contacts

• Tagged Friends List: flipssi may tag your contacts as "friends" if they exist in your address book. Only users of flipssi who have rated an establishment will appear in your tagged friends list.
• Viewing Ratings: If a tagged contact has rated an establishment, their ratings will be visible to you. However, if they haven’t rated an establishment, their name may appear without any rating.
• Untagging Contacts: You have the option to untag any contact from your friends list. Once untagged:
  • Your ratings will no longer be visible to that contact.
  • Their ratings will also not be displayed to you.
• Ratings Visibility: Even if a contact registers later with flipssi, their ratings will only be visible to you if:
  • Your mobile number is present in their contact list.
  • They have not untagged you.

Please note that ratings are always visible to all users as a part of the public platform experience.

Use of Your Mobile Number

We do not use your mobile phone number or other PII for commercial or marketing messages without your explicit consent, unless as part of a specific feature or program for which you have the choice to opt-in or opt-out.

Cookies and Log Data

We may use cookies and log files for the following purposes:

• Auto-fill Information: Save your information to minimize the need to re-enter data during future visits.
• Personalization: Provide you with customized content and recommendations.
• Monitoring: Track viewed pages, platform activity, and engagement.
• Analytics: Analyze submissions, views, and interactions to enhance user experience.

This ensures a seamless and personalized experience on the flipssi platform.

G. Processing of Personal Information

flipssi processes Personal Data and Sensitive Personal Data under specific circumstances, as outlined below:

1. State Functions and Legal Compliance

   Personal or sensitive data may be processed if it is necessary for:

   • Performing functions of Parliament or a State Legislature.
   • Carrying out state-authorized activities to provide services or benefits to individuals.
   • Issuing certifications, licenses, or permits to individuals.
   • Complying with legal obligations under any law passed by Parliament or State Legislatures.
   • Enforcing court orders or tribunal judgments within India.
2. Emergency and Public Health Situations

   Personal or sensitive data may be processed without consent in situations involving:

   • Medical Emergencies posing a threat to life or health.
   • Providing medical treatment or health services during disease outbreaks, epidemics, or public health threats.
   • Ensuring safety or providing assistance during disasters or public disturbances.
3. Employment and Service-Related Processing

   Personal data may be processed when necessary for:

   • Recruitment or termination of employment.
   • Providing services or benefits requested by an individual.
   • Verifying an individual’s attendance.
   • Evaluating and assessing employee performance.
4. Reasonable Purposes for Processing

   Data may be processed for other reasonable purposes, including:

   • Fraud prevention and detection of unlawful activities.
   • Whistleblowing investigations.
   • Mergers and Acquisitions.
   • Enhancing network and information security.
   • Performing credit scoring.
   • Debt recovery.
   • Processing publicly available personal data.

   In these cases, flipssi ensures that data principal rights are protected.

5. Explicit Consent for Sensitive Data

   Processing sensitive personal data requires explicit consent from the data principal. Consent will be considered explicit if:

   • It is informed, meaning the individual is clearly notified of how the data will be used and any significant consequences.
   • It is clear, without relying on assumptions or inferred actions.
   • It is specific, allowing individuals to separately consent to different purposes, operations, and categories of sensitive data processing.
6. Processing of Children's Data
   • flipssi does not allow children under the age of 13 years to access the platform without parental guidance or supervision.
   • Age verification is performed based on the date of birth provided by the user.
   • If a child accesses the platform, it is assumed that they are doing so under parental supervision, and data may be processed accordingly.
   • flipssi ensures that any personal data collected from children is processed in a way that safeguards their rights and best interests.

H. Disclosure of Information

Users of the flipssi platform may view your ratings and submissions in a manner consistent with the platform's features. For instance, if you rate "ABC Restaurant" on flipssi, other users with your mobile number saved in their phone’s contact list and tagged as a friend in the flipssi app can see your rating using the platform's friends rating feature.

1. No Sale or Unauthorized Sharing of Personal Information
   • flipssi does not sell or share your Personally Identifiable Information (e.g., mobile phone number) with third-party companies for their commercial or marketing purposes without your consent.
   • However, in cases where specific programs or features require data sharing, you will have the option to opt-in or opt-out.
   • flipssi may share your data with third-party service providers only as necessary to enhance, maintain, or provide the platform’s services.
2. Data Sharing with Third Parties

   Your personal information may be disclosed to third parties, such as:

   Vendors, Sellers, Service Providers, Business Partners, and other stakeholders for:

   • Providing access to products and services.
   • Fulfilling your orders and requests.
   • Enhancing your experience.
   • Collecting payments.
   • Providing feedback on products.
   • Conducting surveys and market research.
   • Ensuring compliance with legal obligations.
   • Enforcing the Terms of Use.
   • Supporting marketing and advertising activities.
   • Analyzing data, managing credit risk, and enhancing customer support.

   These third-party entities are only allowed to use your personal information to perform the necessary tasks and are required to comply with legal data protection standards.

3. Sharing with Affiliates and Business Partners
   • flipssi may share your data with its affiliated companies, business partners, and associates.
   • The information exchange helps in operating, providing, improving, understanding, customizing, supporting, and marketing services.
   • This includes activities like improving infrastructure, ensuring service security, and preventing fraud or abuse.
4. Business Transfers
   • In cases of mergers, acquisitions, restructuring, or sale of assets, flipssi reserves the right to transfer personal information to any affiliated company, successor entity, or third party.
   • The information will be handled in accordance with the existing Privacy Policy.
5. Legal and Regulatory Disclosure

   flipssi may disclose personal information when legally required or in good faith, such as:

   • Compliance with Legal Processes: Responding to court orders, subpoenas, or government and law enforcement agency requests.
   • Policy Enforcement: Investigating and enforcing the platform’s Terms of Use and other applicable policies.
   • Fraud Detection and Prevention: Identifying, investigating, and preventing fraudulent activities, illegal activities, security threats, or technical issues.
   • Protection of Rights and Safety: Safeguarding the rights, property, and safety of flipssi, its users, and others.
6. Government and Law Enforcement Requests
   • flipssi may share data without obtaining your prior consent with government agencies when mandated under the law.
   • This includes sharing data for identity verification, fraud prevention, cyber incident investigations, and law enforcement purposes.

   Rest assured, all information will be shared and processed in strict compliance with applicable data protection laws.

I. Transfer of Information

flipssi will not transfer your sensitive personal data or information to third parties within India or outside the country, except in the following circumstances:

• To Fulfill Service Requests:
  • Your data may be transferred to third parties to fulfill your requests for products and services.
• To Fix Errors and Improve Services:
  • Information may be shared to identify and fix errors, enhance usability, and improve the effectiveness of flipssi services.
• For Fraud Prevention and Legal Functions:
  • Data may be transferred to prevent and detect fraud or abuse, ensuring the security of customers, flipssi, and others.
  • It may also be used for legal and public safety functions.
• For Contractual Obligations:
  • If the transfer is necessary for the performance of a lawful contract between flipssi and the data principal.
• With Consent:
  • When the data principal has provided explicit consent for the data transfer.

Data Protection Assurance

flipssi ensures that any third party receiving the data adheres to the same level of data protection as maintained by flipssi in accordance with this Privacy Policy.

Vendor Compliance

If flipssi uses vendors to collect or process personal information on its behalf, it ensures that these vendors comply with its data protection standards as outlined in this policy.

J. Retention of Your Information

flipssi will retain your personal information only for the purposes identified in the Terms of Service (TOS) and with your consent. Personal information will be stored for as long as necessary to fulfill business purposes as outlined in the TOS or as authorized by you.

We comply with applicable laws to ensure your data is not retained for longer than necessary for its original purpose or as required under any legal obligations. However, flipssi may retain your information in the following situations:

• To prevent fraud or future abuse.
• To comply with legal or regulatory requirements.
• For legitimate business purposes.
• In anonymized form for analytical and research purposes.

Data Destruction or De-identification

When your personal information is no longer needed for business purposes, flipssi follows strict procedures to either:

• Destroy the information securely to prevent unauthorized access.
• De-identify the data to ensure it is no longer personally identifiable.

Retention of Sensitive Data

For sensitive personal data, flipssi ensures that information is not retained longer than necessary for lawful use or as required by applicable laws. The company has established a data retention policy to manage the storage and deletion of sensitive data. Once the purpose of data collection is achieved, the information will be securely destroyed or anonymized.

Compliance and Auditing

flipssi conducts internal audits annually to ensure compliance with data retention, usage, and disposal policies. Personal information will be erased if its storage violates any data protection laws or if it is no longer necessary for the intended purposes.

Furthermore, flipssi reserves the right to retain personal information for legal and regulatory purposes as permitted by applicable laws.

K. Review of Your Information

flipssi provides a mechanism to help you review the personal information or sensitive data you have provided. You have the right to access, edit, rectify, modify, or delete any personal information that is inaccurate or incomplete. However, flipssi is not responsible for verifying the authenticity of the information supplied by you.

Accessing Your Information

You can request details about your personal information by submitting a written request to flipssi. Upon receiving your request, we will respond within 72 hours.

Your Rights

You have the right to:

• Access your personal information.
• Correct any errors, misleading details, or outdated information.
• Supplement incomplete information.
• Delete personal information, where applicable.

Process and Documentation

All requests to access or modify your personal data will be properly documented and tracked. flipssi will ensure the information is provided to you in a clear and simple format that is easy to understand.

If you have any concerns or require further assistance in managing your personal information, you can contact flipssi for support.

L. Your Consent (Opt-in & Opt-out)

By using the flipssi platform or providing your information, you consent to the collection, use, storage, disclosure, and processing of your information (including sensitive personal information) in accordance with this Privacy Policy.

If you provide personal information about others, you confirm that you have the necessary authority to share that information and allow flipssi to process it under this policy. By using the platform, you also consent to being contacted by flipssi (including its affiliates, partners, vendors, and service providers) via SMS, messaging apps, calls, or emails for purposes outlined in this Privacy Policy.

Managing Your Information

You can review, manage, or update your information using the platform's Settings tools. These options allow you to:

• Modify your personal information.
• Manage contact details, groups, and broadcast lists.
• Block specific users.
• Update notification preferences.

If you are a vendor, you can update your account and contact preferences using the Vendor’s Module.

flipssi retains previous personal information for record-keeping purposes, but you are free to update your data at any time.

Declining to Provide Information

You are not obligated to provide personally identifiable information. However, certain features and services may not be available if you decline to submit required information. If you disagree with the Privacy Policy or Terms of Service, you may delete your account and uninstall the flipssi app. Continued use of the service indicates your acceptance of this policy.

Consent Management

• Before Data Collection: flipssi provides the option to withhold consent before collecting personal or sensitive information.
• Withdrawal of Consent: You may withdraw your consent at any time using the available options on the platform. Upon withdrawal, flipssi may be unable to provide certain services that rely on your data.
• Documentation: Any changes to your preferences, consent, or withdrawal will be documented.

Additional Notifications

If your personal information is used for purposes not previously identified (e.g., marketing or advertisements), flipssi will:

• Notify you about the new purpose.
• Obtain your consent before proceeding.

flipssi also evaluates the privacy policies and consent management processes of third-party partners before sharing any personal data with them. If you have any concerns or inquiries about your consent or personal information, please contact flipssi through the available channels on the platform.

M. Consent to Push Notification

By using the flipssi platform, you agree that any reviews, ratings, comments, or other content you submit on the platform (including web, app, or phone) may be shared with your Tagged Friends who are also users of flipssi services. The visibility and sharing of such content will be at flipssi's discretion.

N. Third-Party Advertisers and Links to Other Sites

Currently, flipssi is an ad-free platform, and we intend to keep it that way. If we decide to introduce advertisements in the future, this section will be updated accordingly.

When you use services from flipssi's partners, you may be redirected to their websites or applications. Upon requesting your permission, flipssi may share your data to facilitate a seamless login using your flipssi credentials.

Please note that flipssi is not responsible for the privacy policies or practices of its partners. We recommend reviewing the privacy policies of partner sites or applications before sharing any personal information.

Additionally, if you make payments using our services, flipssi may receive relevant information such as payment confirmations and receipts from app stores or third-party payment processors.

O. Children's Information

flipssi does not knowingly collect or solicit personal information from children under the age of 13. The platform is only available to individuals who can legally form a binding contract under the Indian Contract Act, 1872.

If you are under 18 years of age, you must access and use the flipssi platform under the supervision of a parent, legal guardian, or a responsible adult.

P. Our Commitment to Information Security

The security of your Personal Information is important to us. You are responsible for maintaining the security of your device and account. In the event of any unauthorized use or a security breach, please notify us promptly. Your account information is protected using your password, so ensure it remains confidential.

flipssi uses commercially reasonable physical, managerial, technical, and procedural safeguards to protect your personal information. We adopt security practices and procedures as per applicable laws to ensure your information remains safe. This includes internal reviews of our data collection, storage, and processing methods, as well as using appropriate encryption and physical security measures to guard against unauthorized access. However, flipssi cannot guarantee complete security for information transmitted online. Any transmission of your data is at your own risk.

flipssi may share your information with third parties under a confidentiality agreement. This agreement restricts third parties from disclosing your information unless it is necessary for the agreed purpose. However, flipssi is not responsible for security breaches or the actions of third parties. You acknowledge that flipssi will not be liable for any loss or damage resulting from providing your information to third-party websites, even if accessed through our platform.

Q. Force Majeure Disclaimer

flipssi shall not be held responsible for any loss, damage, or misuse of your personal information caused by a Force Majeure Event. A Force Majeure Event includes, but is not limited to:

• Natural disasters like fire, flood, or earthquakes
• Civil unrest, strikes, or industrial actions
• Acts of terrorism or war
• Government actions
• Cyber-attacks or hacking incidents
• Computer crashes or system failures
• Power or connectivity failures

While we take reasonable measures to protect your information, you understand that internet transmission is not entirely secure. Therefore, flipssi cannot offer absolute assurance regarding data security.

Data Transmission and Payment Security

We work diligently to ensure the security of your data during transmission using encryption protocols and secure software. When handling payment card data, we comply with the Payment Card Industry Data Security Standard (PCI DSS) to protect financial information.

If you choose a payment gateway for a transaction, your financial details may be stored in compliance with PCI DSS standards and applicable laws.

Security Audits and Reviews

To ensure compliance with industry standards, flipssi conducts regular audits of its security practices and procedures. An independent auditor evaluates our systems annually to identify areas for improvement. Before accepting personal information from third-party sources, we thoroughly review their policies and data collection methods.

By using our platform, you acknowledge and accept the inherent risks associated with internet data transmission. You are also responsible for maintaining the confidentiality of your account login and password to further protect your information.

R. Transparency & Accountability Measures

Privacy by Design

flipssi implements robust privacy by design principles to ensure that our business practices and technical systems are built to protect your personal data from the outset. Our policies and measures include:

• Preventive Measures: Proactively identifying and preventing potential harm to your data.
• Technology Standards: Using commercially accepted or certified technologies for processing personal data.
• Balancing Interests: Supporting business innovation while safeguarding your privacy.
• End-to-End Protection: Ensuring privacy protection at all stages of data processing, from collection to deletion.
• Transparent Processing: Maintaining transparency by accounting for your rights and interests at every stage of data management.

Transparency

flipssi is committed to maintaining transparency about its data processing practices. We provide clear, accessible information on the following:

• Types of Data Collected: Categories of personal data we collect and how we collect them.
• Purpose of Data Processing: The reasons why we process your personal data.
• Exceptional Situations: Details on any exceptional data processing activities that may pose a risk of harm.
• Your Rights: Procedures to exercise your rights as a data principal.
• Filing Complaints: Information on how to lodge complaints with relevant authorities.
• Cross-Border Data Transfers: Details on international transfers of personal data, if applicable.

Security Safeguards

To protect your personal information, flipssi applies comprehensive security safeguards in accordance with the risks associated with data processing. Our security measures include:

• Data Protection Methods: Using techniques such as encryption and de-identification to protect sensitive data.
• Data Integrity Protection: Implementing controls to ensure your data remains accurate and complete.
• Access Prevention: Preventing unauthorized access, misuse, or destruction of data.
• Periodic Reviews: Conducting regular assessments and updates to strengthen our security measures.

Personal Data Breach Management

In the event of a data breach that may cause harm to you or other data principals, flipssi will promptly notify the relevant authorities. The notification will include:

• The nature of the breached data.
• The number of data principals affected.
• The possible consequences of the breach.
• The corrective measures being taken to resolve the issue.

Record-Keeping

flipssi maintains accurate records of:

• Significant activities in the data lifecycle, including data collection, transfer, and erasure.
• Periodic security reviews and their outcomes.
• Data protection impact assessments to ensure compliance with privacy laws.

Data Audits

To ensure compliance, flipssi conducts an annual audit of its privacy policies and data processing practices through an independent data auditor. The audit evaluates:

• The clarity and effectiveness of privacy notices.
• The transparency of data processing.
• The implementation of security safeguards.
• The handling of any data breaches and our response measures.

flipssi remains committed to continuous improvement to provide a secure and transparent data management environment.

S. Monitoring and Enforcement

Dispute Resolution & Recourse

flipssi has established a cyber-incident management program to address data protection and privacy-related incidents. The program includes a clear escalation process that involves executive management, legal counsel, and the board, depending on the severity of the incident.

Key components of our program include:

• A structured process to register, track, and resolve all incidents, complaints, or queries related to data breaches.
• Periodic review and monitoring of complaints to ensure timely resolution.
• Comprehensive documentation of incident reports and their resolutions.
• Clear escalation channels for unresolved complaints, ensuring they are handled effectively.
• Transparent communication of breach reporting procedures and escalation matrices to all data providers.

Employee Dispute Resolution & Escalation Process

Employees who have concerns regarding the processing of their personal information are encouraged to:

• Discuss the matter with their immediate reporting manager.
• If a resolution cannot be reached or the employee prefers not to escalate to their manager, they may contact the Grievance Officer.
• The Grievance Officer will ensure the matter is handled fairly and resolved promptly.

Customer & Third-Party Dispute Resolution & Escalation Process

If you, as a customer or third party, have any concerns or complaints regarding how flipssi processes your personal information, you may:

• Submit a written complaint to our Grievance Officer.
• Receive updates on the status and progress of your complaint.
• If the issue remains unresolved, disputes will be handled through arbitration in accordance with applicable laws.

T. Terms of Use, Policy & Revisions

By using flipssi services, you agree to our Privacy Policy and Terms of Use, including provisions regarding:

• Limitation of damages
• Resolution of disputes
• Application of Indian law

If you have concerns about your privacy or how your data is handled, please contact us with a detailed description, and we will work diligently to resolve the issue.

We may update our Privacy Policy to reflect changes in our business operations or legal requirements. Please check our website frequently for any revisions.

flipssi assures you that we will never make material changes to our privacy practices that reduce the protection of your data without obtaining your explicit consent.

U. Main Officer

In accordance with the Information Technology Act, 2000, and the rules and regulations established under it, the contact details of the Main Officer of flipssi are provided below:

If you have any queries, issues, concerns, or complaints regarding the collection or use of your personal information under this Privacy Policy, please feel free to reach out to us using the contact information above. Alternatively, you can write to us directly at info@flipssi.com.

Definitions

"Act"

Refers to the Information Technology Act, 2000 (21 of 2000).

"Automated Means"

Refers to any equipment capable of operating automatically in response to instructions for the purpose of processing data.

"Biometrics"

Technologies that measure and analyze human body characteristics such as fingerprints, eye retinas and irises, voice patterns, facial patterns, hand measurements, and DNA for authentication purposes.

"Body Corporate"

Refers to any company, including a firm, sole proprietorship, or other association of individuals engaged in commercial or professional activities.

"Child"

Refers to a data provider below the age of eighteen years.

"Cyber Incidents"

Refers to any actual or suspected adverse event related to cybersecurity that violates applicable security policies, resulting in unauthorized access, denial of service, disruption, unauthorized use of a computer resource, or unauthorized data changes.

"Cyber Security"

Refers to protecting information, devices, computer systems, and data from unauthorized access, use, disclosure, disruption, modification, or destruction.

"Data"

Refers to a representation of information, knowledge, facts, concepts, or instructions in a formalized form, intended for processing or storage in a computer system or network, in formats such as printouts, magnetic or optical storage media, or internal memory.

"Data Provider"

Refers to a natural person whose personal data is being processed.

"Data Protection & Security"

Anyone collecting personal and customer information must ensure fair and lawful processing for specific purposes, keeping the information accurate, relevant, and secure. Data should not be transferred outside the country without appropriate protection.

"Password"

Refers to a secret word, phrase, passcode, encryption key, or any secret authentication method used to access information.

"Personal Information"

Any information related to a natural person that can identify them, including name, address, mobile number, email ID, date of birth, or other identifiable information.

"Data Processor"

Refers to any individual, entity, company, or government body that processes personal data on behalf of a data fiduciary, excluding employees of the data fiduciary.

"Processing"

Any operation performed on personal data, including collection, recording, storage, organization, modification, retrieval, use, dissemination, erasure, or destruction.

"Reasonable Security Practices and Procedures"

Security protocols designed to protect data from unauthorized access, damage, misuse, or disclosure, as per agreements, applicable laws, or standards defined by the Central Government.

"Sensitive Personal Data or Information"

Refers to personal information including:

• Passwords
• Financial information (e.g., Bank Account, Credit/Debit Card details)
• Physical, physiological, or mental health conditions
• Sexual orientation
• Medical records and history
• Biometric information
• Any additional details related to the above provided for services or stored under lawful contracts

Note: Information that is publicly available or accessible under the Right to Information Act, 2005, or any other applicable law, is not considered sensitive personal data.

"Third Party"

Refers to any external entity, including contractors, interns, trainees, vendors, and users who have access to flipssi’s information assets or systems.