We, M/s. SMARTCHAIN INNOVATION PRIVATE LIMITED, a company duly incorporated under the Companies Act, 2013 and having its registered office at C-298, Abul Fazal Enclave - II, South Delhi, Delhi, 110025, India (“Fashinza”) (hereinafter referred to as the “Company” “us”, “we” or “our”), To carry on the business of Advertising and marketing for SMES, Heavy Engineering, Fabrics, Garments, Creating virtual malls, stores, shops, creating Marketing catalogues, Engineering Consultancy services, net commerce/Engineering solutions for business to business and business to consumers, online Engineering Support services like Manufacturing Cost Estimation, Technical & Managerial problem solving through the engagement of virtual consultants. business of online shopping, marketing of consumer and other goods, trading in and outside India but does not include banking and money circulating business, Online supplying of engineering materials to SMEs ,Online Logistical solutions & support ,Project management etc. through our Website/ App (if applicable) ( “Platform”). Reference to “you” or “your” in this Privacy Policy refers to the users of this Platform, whether or not you access the services offered by us (“Services”) or consummate a transaction on the Platform.

We are fully committed to respecting your privacy and shall ensure that your personal information is safe with us. This privacy policy sets out the information practices of our Platform including the type of information that is collected, how the information is collected, how the information is used and with whom it is shared (“Privacy Policy”). This Privacy Policy is published in accordance with the provisions of the Information Technology Act, 2000 and the rules made thereunder that require publishing the privacy policy and terms of use on an online portal of the Company. We request you to go through this Privacy Policy and the Terms of Use carefully before you decide to use this Platform.

BY USING OUR PLATFORM, SERVICES AND THE APP (IF APPLICABLE) OR BY OTHERWISE GIVING US YOUR INFORMATION, YOU AGREE TO THE TERMS OF THIS PRIVACY POLICY. YOU ALSO EXPRESSLY CONSENT TO OUR USE AND DISCLOSURE OF YOUR PERSONAL INFORMATION (AS DEFINED BELOW) IN THE MANNER PRESCRIBED UNDER THIS PRIVACY POLICY AND FURTHER SIGNIFY YOUR AGREEMENT TO THIS PRIVACY POLICY AND THE TERMS OF USE (AVAILABLE AT https://fashinza.com/privacy-policy). IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, DO NOT SUBSCRIBE TO THE SERVICES, USE THE PLATFORM AND DO NOT GIVE US ANY OF YOUR INFORMATION.

DEFINITIONS

“App” shall mean the software application proposed to be launched, which can be downloaded from a public forum and installed and operated on any computer or handheld device.

“Force Majeure Event” shall mean any event that is beyond our reasonable control and shall include, without limitation, sabotage, fire, flood, explosion, acts of God, civil commotion, strikes or industrial action or any kind, riots, insurrection, war, acts of government, computer hacking, unauthorized access to your mobile or storage device, crashes, breach of security and encryption.

“Platform” shall mean the App (if applicable) and the Website, as the context may so require.

“Sensitive Personal Data or Information” consists of information relating to the following:

1. passwords;
2. financial information such as bank account or credit card or debit card or other payment instrument details;
3. physical, physiological and mental health condition;
4. sexual orientation;
5. medical records and history;
6. biometric information;
7. any detail relating to the above clauses as provided to us for providing service; and
8. any of the information received under above clauses by us for processing, stored or processed under lawful contract or otherwise.

Provided that, any information that is freely available or accessible in public domain or furnished under the right to information act, 2005 or any other law for the time being in force shall not be regarded as sensitive personal data or information. “third party(ies)” refers to any person or entity other than you or us. “website” shall mean www.fashinza.com.

COLLECTION OF INFORMATION

We are the sole owner of the information collected through the platform. We may collect and process sensitive personal data or information provided by you in the following forms:

1. Information provided by you at the time of registration such as your name, age, address, email id and phone number. Providing additional information beyond what is required at the time of registration is entirely optional and can be altered or removed by you at any time;
2. Information that you provide directly to us via email or electronic communication;
3. Information that you provide to us over telephone. We may make and keep a record of such information shared by you; and
4. Information that you provide to us in physical form whether sent through post or courier or handed over to our representatives in person.

Every computer/mobile device connected to the internet is given a domain name and a set of numbers that serve as that computer's Internet Protocol or “IP” address. When you request a page from any page within the Platform, our web servers automatically recognize your domain name and IP address. The domain name and IP address reveal nothing personal about you other than the IP address from which you have accessed the Platform.

USE OF INFORMATION COLLECTED

Our primary goal in collecting your Sensitive Personal Data or Information is to customize the content you see on our Platform, to fulfil your requests for certain Services and to contact you in the future to discuss our Services.

Cookies: Cookies are small pieces of information saved by your browser. Cookies are used to record various aspects of your visit and assist us to provide you with uninterrupted service. Cookies may be set in your browser by us when you access the Platform or may be set in when you visit Third Party apps or websites. This anonymous information is maintained distinctly and is not linked to the Sensitive Personal Data or Information that you submit to us. We use cookies collected to:

1. Authenticate your login information;
2. Enable our security features;
3. Show you advertising; and
4. Improve and develop the features of the Platform.

Please feel free to change your browser settings if you do not wish to accept cookies. However, please note that changing your browser setting may affect your experience on the platform.

Communication: We may offer email, app notifications (if applicable), short message service (sms), multimedia message service (mms) or other forms of communication to respond to any queries that you may have, to provide any information in connection with the relevant services availed by you and to ensure that such services have been provided to you in a timely manner. You may receive such communication when you have registered as a user.

SHARING OF INFORMATION

To the extent necessary to provide you the Services, we may provide your Sensitive Personal Data or Information to the following Third Parties without notice to you:

1. Supply partners, who work on behalf of or with us to provide you with such services, to help us communicate with you or to maintain the Platform, on a 'need to know' basis.
2. Governmental authorities, in such manner as permitted or required by applicable law;and
3. Another business entity, should we plan to merge with, or be acquired by that business entity, or re- organization, amalgamation, restructuring of business. Should such a transaction occur, that other business entity (or the new combined entity) will be required to follow this Privacy Policy with respect to your Sensitive Personal Data or Information

Legal proceedings: In the event, we are required to respond to subpoenas, court orders or other legal process, your Sensitive Personal Data or Information may be disclosed pursuant to such subpoena, court order or legal process, which may be without notice to you.

LINK TO THIRD PARTY WEBSITES AND APPS

The Website, the App (if applicable) and any other communication sent to you may also contain/display Third Party advertisements and links to other websites, applications or products and services. You agree and acknowledge that these websites and applications are operated by Third Parties and are not controlled by, or affiliated to, or associated with us, unless expressly specified. We are not responsible for any form of transmission, whatsoever, received by you from any such Third Party. Accordingly, we do not make any representations concerning the privacy practices or policies of such Third Parties or terms of use of such websites or applications, nor do we control or guarantee the accuracy, integrity, or quality of, without limitation, the information, data, text, software, music, sound, photographs, graphics, videos, messages or other materials available on such websites or applications. The inclusion or exclusion does not imply any endorsement by us of such websites, applications, the Third Party, or the information on such websites or such applications. The information provided by you to such Third Party websites or applications shall be governed in accordance with the privacy policies of such websites or applications and it is recommended that you review the privacy policy on any such websites and applications prior to using such websites or applications

These Third-Party websites and applications and advertisers may use technology to send advertisements directly to your browser. In such cases, the Third-Party websites, applications or advertisers automatically receive your IP address. They may also use cookies, JavaScript, web beacons and other technologies to measure the effectiveness of their advertisements and to personalize advertising content. We do not have access to or control over cookies or other features that such Third Party websites and applications and advertisers may use, and the information practices of these Third Party websites and applications and advertisers are not covered by this Privacy Policy. Please contact them directly for more information about their privacy practices.

SECURITY OF INFORMATION

We strive to ensure the security, integrity and privacy of your Sensitive Personal Data or Information and to protect your Sensitive Personal Data or Information against unauthorized access, alteration, disclosure or destruction. The Platform has stringent security measures (physical, electronic and managerial) in place to protect against the loss, misuse, and alteration of the Sensitive Personal Data or Information under our control. You shall have a right to view and modify the contents of your profile on the Platform. Whenever you change or access your account information, we offer the use of a secure server. The Platform servers are accessible only to authorized personnel and your information is shared with our employees and authorized personnel on a 'need to know' basis, to complete the transaction and to provide the Services. We are not responsible for any breach of security or for any actions of any Third Parties that receive your Sensitive Personal Data or Information. The Services are also linked to Third Party sites and we are not/shall not be responsible for the privacy practices or the content of such sites. Notwithstanding anything contained in this Privacy Policy or elsewhere, we shall not be held responsible for any loss, damage or misuse of your Sensitive Personal Data or Information, if such loss, damage, or misuse is attributable to a Force Majeure Event.

DATA RETENTION

Your information will be retained with the Company as long as your account is active. If you wish to cancel your account or request that the Company no longer uses your information, you may contact the Company at +91 44 4957 1987 or send an email to info@traktez.com. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements or for other business purposes.

MINOR’S PRIVACY

Platform is not intended for use by minors and we strongly encourage you and your representatives to supervise the online activities of your and your representatives’ minor children.

NOTIFICATION OF CHANGES

We may update this Privacy Policy at any time, with or without advance notice. In the event, there are significant changes in the way we treat your Personal Information, or in the Privacy Policy document itself, we will display a notice on the Platform so that you may review the changed terms prior to continuing to use the Platform. As always, if you object to any of the changes to our terms, and you no longer wish to use the Platform, you may contact us at contact@fashinza.com, to deactivate your account. Unless stated otherwise, our current Privacy Policy applies to all information that we have about you and your account. Using our Services or accessing the Platform after a notice of changes has been sent to you shall constitute your consent to the changed terms.

ADDRESS FOR PRIVACY QUESTIONS

Should you have questions about the Privacy Policy or our information collection, use and disclosure practices, you may contact us at the address: at C-298, Abul Fazal Enclave - II, South Delhi, Delhi, 110025. We will use reasonable efforts to respond promptly to requests, questions or concerns you may have regarding our use of your Personal Information. Except where required by law, we cannot ensure a response to questions or comments regarding topics unrelated to this Privacy Policy or our privacy practices.

GRIEVANCE OFFICER

In accordance with the Information Technology Act, 2000 and the rules made thereunder, the name and contact details of the Grievance Officer are provided below:

• Name: Mr. Pawan Gupta
• Co-Founder
• Contact Number: +91 9911401663
• Email Id: pawan.gupta@fashinza.com

Policy for NDNC

By using the website and/or registering yourself at Fashinza.com you authorize us to contact you via email or phone call or SMS and offer you our services, imparting product knowledge, for which reasons, personally identifiable information may be collected. And Irrespective of the fact if also you have registered yourself under DND or DNC or NCPR service, you still authorize us to give you a call from the Fashinza for the above mentioned purposes till 365 days of your registration with us. This Privacy Policy covers Fashinza treatment of personally identifiable information that Fashinza collects when you are on the Fashinza site, and when you use Fashinza services. This policy also covers Fashinza treatment of any personally identifiable information that Fashinza business partners share with Fashinza. This policy does not apply to the practices of companies that Fashinza does not own or control or to people that Fashinza does not employ or manage. Fashinza collects personally identifiable information when you register for a Fashinza account, when you use certain Fashinza products or services and when you visit Fashinza pages. Fashinza may also receive personally identifiable information from our business partners. When you register with Fashinza, we ask for your first name, last name, contact no. and email. Once you register with Fashinza and sign in to our services, you are not anonymous to us. Also, during registration, you may be requested to register your mobile phone and email id, pager, or other device to receive text messages, notifications, and other services to your wireless device. By registration you authorize us to send SMS/email alerts to you for your login details and any other service and product requirements.