PRIVACY POLICY

Arka Capital Advisors Pvt. Ltd., an entity incorporated under the laws of India, owns and operates the mobile application ‘I Am - Playbook to Happiness’ mobile application (“Platform”), referred to as "We", “our”, and “Us”. This privacy policy (“Privacy Policy”) governs the receipt, collection, processing, storage, usage, transfer, and disclosure of personal data (“Personal Data”) of users (“You”, “Your”, and/or “User/s”) through the Platform. We process Personal Data of Users in our capacity as a “body corporate” as the term is defined under Section 43-A of the Information Technology Act, 2000 and as “data fiduciary” as the term is defined under the Digital Personal Data Protection Act, 2023.

By engaging with Us and using our services, You agree to the data collection and processing practices and policies set forth in this Privacy Policy. You hereby acknowledge that You have expressly consented to our collection, use, processing, storing, disclosure and/ or transfer of Your Personal Data in the manner as described hereinunder and for the specified purposes. If you do not agree to any part of this Privacy Policy, please inform us and we will take actions accordingly.

If you wish to view the Privacy Policy in another language, then please reach out to us and we will arrange for the same. In the event of any discrepancy or conflict between the English version of the Privacy Policy and versions in other languages, the English version will prevail over the other translated versions.

Please note that this Privacy Policy does not apply to websites maintained by other companies or organizations with which We partner with and/or link, and We are not responsible for any Personal Data You submit to third parties via the Platform. Please ensure that You read the privacy policy of such third parties before submitting Your details. Please further note that our Platform is hosted on Amazon Web Services’ (“AWS”) cloud platform and therefore We urge You to review AWS’ privacy policy, which is available at https://aws.amazon.com/privacy/.

1. Modes of collection of Personal Data

1. Information You provide us: We will collect Personal Data that You choose to provide Us, for registration purposes and in relation to the services provided by Us. For example, for account creation, marketing communications, sending notifications to You, etc.
2. Automatically collected information: When We provide You with our services, We collect activity information, such as Your device’s IP address, at what time Your device used the Platform, etc. In this regard, We may utilise cookies, pixel tags, web beacons, etc., as further specified in our “Cookie Policy” in Section 3 of the Privacy Policy.

2. Nature of Personal Data collected and their respective purposes

3. Cookie Policy

1. We may use cookies, pixel tags, web beacons, and similar files or technologies to collect and store information with respect to Your use of our Platform. This information is collected automatically when You navigate our Platform. A cookie is a small text file that is stored on Your mobile application that enables Us to recognize You, when You visit our Platform, store Your preferences and settings, track Your use of Our Platform, and assist with security and administrative functions as well as monitor Your navigation and search patters on our Platform.
2. Users have the option to accept or disable cookies at any time through the mobile application, however this may affect the functioning of our Platform.

4. Access of Platform by minors

1. The Platform is not targeted towards minors. However, the Platform will be available on Android Play Store and Apple Store for download, and therefore, the Platform may be accessed by persons under the age of 18, i.e., minors. In the event, any minor attempts to access the Platform (basis the date of birth inputted by them), then we will seek parental consent by requiring the parent to write to app@arkaleadership.com with their consent and the government issued identity card of the minor as well as the parent, prior to providing access of the Platform to minors. We will be collecting government issued identity card only for this purpose.
2. If You believe that a child under the age of 18, has accessed the Platform without parental consent and provided Us with their Personal Data, please contact us at app@arkaleadership.com.

5. Disclosure and/ or transfer of Your Personal Data with third parties:

We will not share the Personal Data we have collected from You, except as described below:

1. We may share and/ or transfer Your Personal Data with a third-party service provider, on a need-to-know basis, and only to enable them to perform their services.
2. International Transfer: Your Personal Data may be transferred to and maintained on computers located outside of Your state, country or other governmental jurisdiction where the data protection laws may differ from those of Your jurisdiction.
   
   If You are located outside India and choose to provide information to Us, please note that We transfer the information, including Personal Data, to India and process it there. Your consent to this Privacy Policy followed by Your submission of Your Personal Data represents Your agreement to that transfer.
3. We may disclose Your Personal Data to law enforcement or regulatory authorities and / or government agencies, as applicable. We may disclose Your Personal Data if required to do so for compliance of a legal obligation under applicable laws or in good faith belief that such disclosure is reasonably necessary to respond to summons, court orders, or other legal process, law enforcement authorities, government authorities, courts, dispute resolution bodies, our regulators, auditors and any party appointed or requested by our regulators to carry out investigations or audits of our activities. Your Personal Data may be shared, without obtaining prior consent, with government agencies mandated under the applicable laws or any law in India to obtain Your Personal Data for the purpose of verification of identity, or for prevention, detection, investigation including cyber incidents, prosecution, and punishment of offences. Your Personal Data so obtained by the government agency or authority is not published or shared with any third party, unless the disclosure to any third party is required by an order under the applicable laws in India for the time being in force.
4. We may also disclose Your Personal Data to respond to claims that the uploaded content violates the rights of a third party, or protect the rights, property or personal safety of Our Users or the general public.
5. We may share and/ or transfer some or all of Your Personal Data with another business entity should We plan to merge with, or be acquired by that business entity, or for the purposes of M&A transactions, reorganization, amalgamation or restructuring of our business.
6. If We share and/ or transfer Your Personal Data to third parties for purposes stated in this Privacy Policy, We will use best endeavors to put in place appropriate controls and safeguards to ensure that Your Personal Data is adequately protected and processed only for specified and reasonable purposes in a manner that is fair, transparent and has a lawful basis, and is stored for no longer than is necessary.

6. Your rights as Users

1. Access information about Personal Data: You can request a summary of the Personal Data which is being processed by Us and the processing activities undertaken by Us with respect to such Personal Data. You can also request for the identities of all data fiduciaries and data processors with whom Your Personal Data has been shared by Us along with a description of such Personal Data shared.
2. Option to not provide the Personal Data: You can always elect not to disclose Your Personal Data to Us. However, please keep in mind that We may need some information to allow You to register with Us or for You to take advantage of some or all of the features offered on Our Platform, and if You choose not to provide that information, Your ability to use our Platform and services may be limited.
3. Correction of data: You have an option to always access Your account and Your Personal Data in order to view, add, alter, update and/or modify Personal Data provided to Us.
4. Erasure of Personal Data: You can request for erasure of any Personal Data being handled or processed by Us.
5. Deactivation and/or deletion: You have a right to request for deactivation of Your account, and post such deactivation, Your Personal Data shall not be collected or processed. However, Your Personal Data collected by Us till the deactivation of Your account shall be maintained by Us at least for a period of one hundred and eighty (180) days, post which it may be deleted if not required to be retained as per applicable law.
6. Right to withdraw consent (not limited to deactivation and/or deletion): You have the right to withdraw Your consent previously given for the collection, use or processing of all and/or any part of the Personal Data collected by Us, however, please note that this may disrupt Your user experience on Our Platform. You may withdraw Your consent by writing to Us at app@arkaleadership.com. We shall discontinue processing Your Personal Data (and require other third-parties to discontinue processing) once We receive a request from You in writing, however, We have a right to retain and will not be held liable for processing any Personal Data that We collected prior to the said withdrawal request. We may also need to continue processing if such processing is required or authorized under laws applicable in India.
7. Right to grievance redressal: Please see Section 11 of the Privacy Policy on the grievance redressal mechanism available to You.
8. Right to nominate: You have the right to nominate any other individual who can, in the event of death or incapacity, exercise rights on Your behalf.
9. Timeline: We will respond to Your request as soon as reasonably possible. In general, our response will be within 30 (thirty) business days. In the event We are not able to respond to You within 30 (thirty) business days after receiving Your request, We will inform You in writing, of the time by which We will be able to respond to Your request. If We are unable to provide you with the Personal Data or to make a correction requested by You, We shall inform You of the reasons why We are unable to do so (except where We are not required to do so under applicable Indian laws).

7. Data Security

1. We use commercially reasonable security measures (including physical, electronic and procedural measures) to safeguard Personal Data against loss, misuse, damage or modification and unauthorised access or disclosure. However, no system for transmitting or storing information electronically can be completely secure. Therefore, we cannot guarantee that Personal Data or other communications will always remain secure.
2. We maintain Personal Data pertaining to You in our business records as per current regulatory requirements. We have secure and appropriate data collection, storage, and processing practices. Our security measures protect against unauthorized access, alteration, disclosure or destruction of Your Information including Your username and other data stored on the mobile application or in our database.
3. All private information exchange and transactions on the Platform happen through secured communication channels and is protected. Securing Your Personal Data is of paramount importance to Us.
4. From time to time, We may reveal general statistical information about our Platform, such as number of Users, etc., however, this will be anonymized or de-identified.
5. Only those of our employees, who need access to Your information in order to perform their duties as mentioned in the purpose section of this Privacy Policy, are allowed such access. Our employees and/or any other person processing Your Personal Data will respect the internal rules and procedures related to the Personal Data protection, including the technical and organizational security measures implemented to protect Your Personal Data.
6. In this context, We regularly review and update our practices to enhance Your privacy and ensure that its internal rules and procedures are duly followed. Our data collection, handling and processing practices are also continually reviewed to ensure compliance with the applicable data protection and privacy laws and regulations in India.
7. We assume no liability or responsibility for disclosure of Your Personal Data due to errors in transmission, unauthorized third-party access, or other causes beyond our control.
8. If You have come across a vulnerability or would like to report a security incident, You can directly contact the Grievance Officer by using the contact information provided in Section 11 of this Privacy Policy.

8. Retention of data

1. We will retain Your Personal Data and any data only for the period necessary to fulfil the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by Indian law.
2. Pursuant to withdrawal of consent or cancellation of registration, We will retain Your Personal Data for a period of at least one hundred and eighty (180) days.
3. Under Indian laws, We process Your Personal Data with Your consent. However, You are entitled to withdraw Your consent any time and ask Us to stop such processing, in which case We will process Your data for a short period of time after this (and solely to allow Us to implement Your requests), provided there is no other legal ground for further processing.
4. If deleting Your data would make ongoing research impossible, or significantly impair it, We may keep the necessary part of Your data for use solely as required for that research. After that, Your Personal Data will be deleted or anonymized.

9. General

1. To help Us in protecting Your privacy, You should maintain secrecy of Your login information, if any, provided to You in connection with Your account. You should not share/transfer/ disclose Your account related information with anyone, nor will any of our representative(s) ask You for the same. Access of Your account by someone other than You is also prohibited.
2. You acknowledge and agree that if You provide any Personal Data that is untrue, inaccurate, not current or incomplete (or becomes untrue, inaccurate, not current or incomplete over a period of time), or We have reasonable grounds to suspect that such Personal Data is untrue, inaccurate, not current or incomplete, We may not be able to provide You with continued access to our Platform. Your Personal Data collected and access to our Platform is subject to the Terms of Use of our Platform available at [●], and You are advised to read the same carefully in conjunction with this Privacy Policy.

10. Changes to privacy policy

1. The Privacy Policy may be amended from time to time, and will indicate the update by changing the “Last Updated” date at the beginning of this privacy policy. This could be undertaken to reflect changes to the Platform or the applicable Indian laws. We will provide You with the updated Privacy Policy by appropriate means as required by applicable Indian laws. In any case, We recommend that You review this Privacy Policy each time You use the Platform.
2. Once posted on our Platform or otherwise notified to You, the revised Privacy Policy supersedes all previous versions, and continued access to and/or use of our Platform after the date of such revision constitutes your acknowledgment of such changes and agreement to be legally bound by the terms of the revised Privacy Policy.

11. Grievance Redressal Mechanism and Grievance Officer

1. For the purpose of grievance redressal or in the event You have any questions regarding our privacy practices or this Privacy Policy, please contact our Grievance Officer:

Name:
Postal Address:
Email: app@arkaleadership.com
2. We will acknowledge Your complaints/ grievances within 1 (one) business day and resolve such complaints/ grievances within 15 (fifteen) business days.