1. OVERVIEW

Swa Consultancy Pvt Ltd (hereinafter referred to as “the Company” or “our” or “we” or “us”) respect your privacy and are committed to protecting your personal data. This Privacy Notice (“Privacy Notice”) describes how we collect, store, use, disclose and process your personal data and tells you about your privacy rights.

PLEASE READ THIS PRIVACY NOTICE IN DETAIL BEFORE YOU START USING THE SERVICES.

1.1 Binding Nature

Our websites, applications and services (collectively the “Services”) are not intended for children, and we do not knowingly collect data relating to children as part of our Services. Under Indian laws, a child is a person under 18 years of age. By consenting to and accepting our Privacy Notice, you will be deemed to have the capacity to enter into a legally binding contract in accordance with applicable law in the jurisdiction from which you are accessing our Services. You will consequently be deemed to have read, understood and agreed to the practices and procedures outlined in this Privacy Notice.

1.2 Changes To The Privacy Notice

We review and update this Privacy Notice from time to time. When we do, we will note the date of the version on the Privacy Notice and post it on this website. You can tell when we last updated this Privacy Notice by checking the “Last Updated” date at the top of this Privacy Notice. You also may obtain historical versions of this Privacy Notice by contacting us.

1.3 Third-Party Links

Our website and mobile application may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. This Privacy Notice does not apply to information that is collected by any third-party website or service that you may access through our Services.

2. WHAT DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that individual can be identified. It does not include data where the identity has been removed (anonymous data). The Company may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes name, username or similar identifier, title, designation, organization name
• Contact Data includes email address and telephone/mobile numbers;
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the Services;
• Profile Data includes your username and password, your interests, preferences, feedback and survey responses;
• Usage Data includes information about how you use our website, applications and Services;
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

The Company also collects, uses and shares aggregated data such as statistical or demographic data. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific feature within our Services.

3. WHY WE COLLECT YOUR DATA

We process your personal data for the following purposes:

• For monitoring the security of our Services
• To send you updates related to your account, respond to your inquiries and provide you support.
• To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.
• To make suggestions and recommendations to you about Services that may be of interest to you.
• To inform you of offers, discounts and other schemes made available by us or through us by other parties.
• To analyse user behaviour for understanding demographics, preferences and trends to help improve our Services and take informed business decisions.
• For fulfilling our obligations under applicable laws and regulations or as required under a judgement or order issued under any law for the time being in force.

4. HOW WE COLLECT YOUR DATA

4.1 Direct Interactions

We collect your personal data directly from you when you correspond with us, register on or visit our website, or attend an event organized by us.

4.2 Cookies

As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. For more information on the cookies collected on our website, please visit our Cookie Notice.

4.3 Grounds of Processing

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in any of the following circumstances:

• Where you have provided your consent to use such personal data.
• Where you have voluntarily provided the personal data for a specified purpose
• For fulfilling a legal obligation
• Pursuant to any other legitimate uses prescribed under the applicable data privacy law.

5. WHO DO WE DISCLOSE YOUR DATA TO

We may have to share your personal data with the parties set out below for the purposes set out in the table above.

• Third party service providers from whom we avail services for carrying out our business activities.
• Professional advisors, government/regulatory authorities and other parties as required under the applicable law.
• Other entities within the Swa Consultancy Pvt Ltd.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Notice.

Unless otherwise prohibited under the applicable law, your personal data may be transferred to, and processed outside the country in which you reside. However, please be assured that we require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions unless the applicable law permits otherwise.

6. HOW WE PROTECT YOUR DATA

The Company has put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They are only permitted to process your personal data on our instructions and are subject to a duty of confidentiality.

You are responsible for maintaining the security of your account credentials and other authentication involved in obtaining access to password-protected or secure areas of the Services. The Company will treat access to the Services through your account credentials as having been authorized by you. We shall bear no liability in respect of such unauthorized use of your account. Unauthorized access to password-protected or secure areas is prohibited and may lead to prosecution under the applicable laws. We may suspend your use of all or part of the Services without notice if we suspect or detect any breach of security. If you believe that information you provided to us is no longer secure, please notify us immediately using the contact information provided below.

7. HOW LONG WE RETAIN YOUR DATA

We retain the personal data collected or otherwise processed by us, (i) for as long as necessary to fulfill the purposes for which you provided the information, (ii) for the purposes of satisfying any legal/regulatory, accounting, or reporting obligations, (iii) to resolve disputes, and (iv) for such other purposes as are permitted under applicable law.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements that may require or permit retention for a longer duration.

8. WHAT ARE YOUR RIGHTS & DUTIES

8.1 Your Legal Rights

The rights available to you with respect to your personal data may differ based on your geographic location. You may contact us for more information on the specific rights available to you. Following are some of the rights prescribed under various laws:

• Right to Access. You may request a summary of your personal data available in our records, the identities of other parties that we have shared your personal data with and any other information that may be prescribed under the applicable law.
• Right to Correct or Erase. You may request us to correct, complete, update or erase your personal data from our records.
• Right to Withdraw Consent. Where we have taken your consent to process your personal data, you have the right to withdraw such consent. However, in certain cases we may not be able to continue providing you with access to our Platform or certain parts of it, if we cannot process the personal data essential for enabling the provision of such Platform. We will inform you if that is the case.
• Right to Object. If you are a resident of the EU or the UK, you may also have the right to object to the processing of your personal data if you believe it impacts your fundamental rights and freedoms
• Right of Grievance Redressal. Under the Digital Personal Data Protection Act, 2023 of India (“DPDPA”), you have the right to register a grievance with us with respect to the processing of your personal data.
• Right to Nominate. The DPDPA also gives you the right to nominate any other individual to exercise your rights under the DPDPA in the event of your incapacity or death.

Please note that some of the above rights may be subject to certain exemptions under the applicable data protection law.

If you wish to exercise any of the above rights, you may contact us at contact@swaconsultancy.com. You also have the right to lodge a complaint with the relevant data protection authority in your country, if you believe we have violated any of your rights.

8.2 Your Duty To Inform Us Of Changes

It is important that the personal data we hold about you is accurate and current. Whenever there is a change, you must promptly make the changes by logging into your account on the mobile application or website. We will rely on the information made available by you to us.

Cookies notice

This Cookie Notice applies to the websites and applications linked to www.swaconsultancy.com (“Websites”) and operated by (Swa Consultancy Pvt Ltd) (“we”, “our”, “us”). This Cookie Notice explains how we use cookies and similar technologies when you visit our websites and/or use our web applications. It explains what these technologies are and why we use them, as well as your rights to control our use of them.

1. What are cookies?

“Cookies” are small text files stored by your web browser when you use websites. Cookies arewidely used by website owners in order to make their websites work, or to work more efficiently, as well as to provide reporting information.

Where required by applicable law, we will obtain your consent before we place any cookies on your device that are not strictly necessary for the functioning of our Websites.

Cookies set by the website owner (in this case, Swa Consultancy) are called “first party Cookies”. Cookies set by parties other than the website owner are called “third party Cookies”. Third party Cookies enable third party features or functionality to be provided on or through the website (e.g. like advertising, interactive content and analytics). The parties that set these third-party Cookies can recognize your computer both when it visits the website in question and also when it visits certain other websites.

2. What Cookies do we use?

We use first party and third-party Cookies for several reasons as given below.

1. “Strictly Necessary” Cookies are necessary to enable the basic features of this site to function, such as allowing images to load, or allowing you to select your cookie preferences.
2. “Functional” Cookies allow us to analyze your use of the site to evaluate and improve its performance. They may also be used to provide a better customer experience on this site, such as by remembering your content preferences, optimizing video performance, or providing us information about how our site is used. If you do not allow these Cookies then some or all of these services may not function properly.
3. “Advertising” Cookies, which are third party Cookies set through our Websites by our advertising partners. These companies may use information about your visits to this and other websites in order to provide relevant advertisements about our businesses, goods and services that you may be interested in. They may also employ technology that is used to measure the effectiveness of advertisements. They do not directly store personal information but are based on uniquely identifying your browser and internet device. If you do not allow these Cookies, you will still experience advertising but it will be less targeted to you.

3. Technologies similar to Cookies

Cookies are not the only way to recognize or track visitors to a website. We may use other, similar technologies from time to time for authenticating you, keeping track of information that you have provided to us, remembering your preferences and running analytics of site visits. When you are using our application offline, we may store information related to how you used that website on your device and then transfer it to our servers the next time you connect online to our service. However, all information collected by us, using any of the tracking methods, will be processed in accordance with this Cookie Notice and our Privacy Policy [link] as applicable.

4. Web beacons

Web beacons (sometimes called “tracking pixels” or “clear gifs”) are tiny graphics files that contain a unique identifier that enable us to recognize when someone has visited our Websites or opened an e-mail that we have sent them. This allows us, for example, to monitor the traffic patterns of users from one page within our Websites to another, to deliver or communicate with Cookies, to understand whether you have come to our Websites from an online advertisement displayed on a third-party website, to improve site performance, and to measure the success of e-mail marketing campaigns. If you do not wish to enable such tracking, please do not download any images in such emails, or alternatively please unsubscribe from our mailing lists by updating your choices on our preference page or by following the link at the bottom of each email. In many instances, these technologies are also reliant on Cookies to function properly, and so declining performance Cookies will impair their functioning.

In this Cookie Notice, references to “Cookies” are to Cookies and to the similar tracking technologies referred to above.

5. How can you control Cookies?

You have the right to decide whether to accept or reject Cookies. When you visit our Website, you will see a cookie banner providing the option to accept or manage your cookie preferences, except for Strictly Necessary Cookies

You may:

• Set or change your cookie preferences using our [Cookie Settings] link.
• Block or delete cookies via your browser settings. However, this may impact the functionality of the Website.

Additionally, most advertising networks offer you a way to opt out of targeted advertising. These opt out tools are provided by third parties and Swa Consultancy does not control or operate these programs or the choices that third parties provide through these tools.

PLEASE NOTE THAT THIS COOKIE NOTICE DOES NOT ADDRESS THE PRIVACY OR INFORMATION PRACTICES OF ANY THIRD PARTY.

6. How often do we update this Cookie Notice?

We may update this Cookie Notice from time to time in order to reflect, for example, changes to the Cookies we use or for other operational, legal or regulatory reasons. Please therefore re-visit this Cookie Notice regularly to stay informed about our use of Cookies and related technologies.

7. Where can you get further information?

If you have any questions about our use of Cookies or other technologies, please contact us at contact@swaconsultancy.com

You may also refer to our Privacy Notice to know more about your rights in relation to personal information we collect or otherwise process Cookies.