Revision Date: 07.02.2025

1. Introduction

   This Privacy Notice outlines approach Aditya Infotech Limited (“CP Plus”, “AIL”, “we” ,”us” or “our”) having its office at A-12, Sector 4, Noida 201301, Uttar Pradesh, India to Data Protection and Privacy to fulfill its obligations under the applicable laws and regulations. This Privacy Notice applies to your Personal Information which is processed by us, whether in physical or electronic mode. By visiting this Application ("adityagroup.com") or providing your information, you expressly agree to be bound by this Privacy Notice and agree to be governed by the laws applicable to data protection and privacy. If you do not agree, the user shall bear the consequences of refraining from using or accessing the services. This Privacy Notice also describes how we collect, use, maintain, share, protect, disclose or otherwise process that information. Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it.

   In this Privacy Notice, the expressions ‘Personal Information’, ‘Data Principal’, ‘Fiduciary’, ‘Processor’ and ‘Processing’ shall have the meanings given to them in the applicable privacy laws.

   We are committed to treating data privacy seriously. It is important that you know exactly what we do with your personal information.

   This Privacy Notice is incorporated into The Company Terms and Conditions and Terms of Use by reference as if set forth fully therein, which must be reviewed and accepted by you.

2. Definitions

   In this Privacy Notice, the following definitions are used:

   • Cookies
     A small file placed on your device by our website or mobile application when you either visit or use certain features of our website or mobile application. A cookie generally allows a website to remember your actions or preference for a certain period of time.
   • Data
     Includes non-personal information, personal information and sensitive personal information about you, which either directly or indirectly in combination with other information, could allow you to be identified when you visit our website and/or mobile application.
   • Data Protection Laws
     Any applicable law for the time being in force relating to the processing of personal data, including but not limited to the Digital Personal Data Protection Act, 2023, and any rules, regulations, or guidelines issued thereunder. This explicitly references the DPDPA while remaining open to other applicable laws.
   • Partners
     Select third parties (including but not limited to any associate/Joint venture/subsidiaries of AIL ) with whom we have contracts for the businesses described in this Privacy Notice.
   • Service Providers
     Includes entities to whom we or other Aditya Group entities will disclose your Data in order to process information for a specific purpose pursuant to written contract.
   • Aditya Infotech Limited Entity
     AIL, and its subsidiaries, affiliates, associate companies and joint venture companies with whom we have a contractual arrangement to, inter alia, share data for the purposes described in this Privacy Notice.
   • User or You
     The natural person who accesses our stores, website or mobile application.

3. What information we collect about you

   AIL collects Data for various purposes set out in this Privacy Notice.

   This Data includes, without limitation, the following categories:

   • Contact information: first and last name, email address, postal address, country, employer, phone number and other similar contact data.
   • Financial information: payment instrument information, transactions, transaction history, preferences, method, mode and manner of payment, spending pattern or trends, and other similar data.
   • Technical information: website, device and mobile app usage, Internet Protocol (IP) address and similar information collected via automated means, such as cookies, pixels and similar technologies.
   • Transaction information: the date of the transaction, total amount, transaction history and preferences and related details.
   • Product and service information: Your account membership number, registration and payment information, and program-specific information, when you request products and/or services directly from us, or participate in marketing programs.
   • Personal information: Age, sex, date of birth, marital status, nationality, details of government identification documents provided, occupation, ethnicity, religion, travel history or any other personal information provided in responses to surveys or questionnaires.
   • Your reviews, feedback and opinions about our products, programmes and services.

4. Purpose of collecting the data

   • Providing Our Services
     When you register on the app, we process your username and password to grant access to services such as training courses, marketing materials related to purchased products, and prizes or gifts you wish to redeem. Additionally, we use this information to send invitations to marketing activities you’ve expressed interest in via the app.
   • Delivering, Troubleshooting, and Enhancing Services
     We use your personal data to enable functionality, assess performance, fix issues, and improve the usability and effectiveness of our products and services.
   • Communication
     Your contact information is used to communicate with you about our products and services through various channels, including phone, email, and chat.
   • Statistical Research
     We use automated tools to conduct statistical research on general trends in service usage, app and social media behaviour, and customer preferences. We may also periodically send surveys to gather insights into customer opinions and preferences.
   • Data Utilization
     To perform research, we may combine and analyze different data types described above. Aggregated data may also be merged with information from group companies or market research. Sensitive data will not be used for this research without your consent.
   • Interests and Benefits
     Statistical research helps us refine our services, provide better customer support, and improve the design and content of our app and products.

5. How we collect data

   We collect Data in the following ways:

   • Information You Give Us: We receive and store any information you enter on our website or mobile application or give us in any other way.
   • Automatic Information We Collect: We use "cookies", pixels and similar technologies to receive and store certain types of information whenever you interact with us. Please see the section below, titled "Data that is Collected Automatically" for more information.
   • E-mail Communications: To help us make e-mails more relevant and interesting, we often receive a confirmation (if your device supports such capabilities) when you open e-mail from us or click on a link in the e-mail. You can choose not to receive marketing emails from us by clicking on the unsubscribe link in any marketing email.
   • Automatic Information We Collect from Other Websites: We receive and store certain types of information when you interact with third-party websites that use our technology or with whom we have a specific agreement. Because we process this information on behalf of the applicable website operators, collection, processing, and use of such information is subject to the applicable website operators’ privacy policies and is not covered by our Privacy Notice.
   • Information from Other Sources: We may obtain information from other sources. An example of this is when you authorize a third-party website (such as the website of another Aditya Infotech Limited entity), to interact directly with our website or mobile application to provide or receive Data about you. In that case, we might receive such Data used by that third-party website to identify your account with that website.
   • Information Previously Provided to Aditya Infotech Limited Entities: Where you have shared any information previously with any of the AIL Entities and have consented to the further sharing of such information, such information will be shared with us by the AIL Entities.
   • Third-Party Software/Service Providers: We may use third party software, which is an analytics solution. Third party software may record: Screens visited, Interaction patterns (such as screen actions, gestures: taps, scrolls), and Device details (Type, Version, Model, Operating System). We are using the information collected by third party software to improve our app. Third party software does not collect personally identifiable information and does not track your browsing habits across apps. For more information see Privacy Notice for Information Collected by the third party services.

   You can make choices about our collection and use of your Data. For example, you may want to access, edit or remove your Data on our website or mobile application. When you are asked to provide Data, you may decline.

6. Data shared by you

   AIL may collect your Data in several ways from your use of our stores, website or mobile application. For instance:

   • When you register with us to receive our products and/or services;
   • When you conduct a transaction with us or attempt a transaction at our stores, on our website or mobile application;
   • When you complete surveys conducted by or for us;
   • When you elect to receive any communications (including promotional offers) from us;
   • From the information gathered by your visit to our stores, website or mobile application;

7. Child Data

   Our website and mobile application are not intended for use by minors, and we do not knowingly offer products or services to individuals under the age of 18.

8. Keeping data secure

   We will use technical and organisational measures to safeguard your Data, and we store your Data on secure servers. Technical and organisational measures include measures to deal with any suspected data breach. If you suspect any misuse or loss or unauthorised access to your Data, please let us know immediately by contacting us by e-mail at our email address provided at Clause 18 below.

9. Retention of data

   AIL retains Data for as long as necessary for the use of our products and/or services or to provide access to and use of our website or mobile application, or for other essential purposes such as complying with our legal obligations, resolving disputes, enforcing our agreements and as long as processing and retaining your Data is necessary and is permitted by applicable law. Because these needs can vary for different data types and purposes, actual retention periods can vary significantly.

   Even if we delete your Data, including on account of exercise of your right under Clause 10 below, it may persist on backup or archival media for audit, legal, tax or regulatory purposes.

10. Your Rights and choices

    When we process Data about you, we do so with your consent and/or as necessary to operate our business, meet our contractual and legal obligations, protect the security of our systems and our customers, or fulfill other legitimate interests of AIL as described in this Privacy Notice.

    You have the following rights in relation to your sensitive personal information and you can exercise it by submitting a request as described in the "How to Contact Us" section below.

    • Right to access information about personal data
    • Right to correction and erasure of personal data
    • Right of grievance redressal
    • Right to nominate
    • Right to withdraw consent U/S 6(4) of DPDPA.

    It is important that the Data we hold about you is accurate and current. Please keep us informed if your personal information changes during the period for which we hold it.

    If you are not satisfied with the resolution provided by the Data Fiduciary regarding your complaint, you have the right to escalate the matter to the Data Protection Board of India (‘the Board’. A dedicated link is available on our website and app for submitting complaints to the Board. Detailed guidance is provided to ensure a simple and accessible process link.

11. To exercise your rights, including accessing, reviewing, updating, or withdrawing your consent regarding your personal data, please contact us at privacy.grievance@adityagroup.com

    Your Duties:

    While Sharing your personal data with us you shall perform the following duties, namely:—

    • To comply with the provisions of all applicable laws for the time being in force while exercising rights applicable under law;
    • To ensure not to impersonate another person while providing personal data for a specified purpose;
    • To ensure not to suppress any material information while providing your personal data for any document, unique identifier, proof of identity or proof of address issued by the State or any of its instrumentalities;
    • To ensure not to register a false or frivolous grievance or complaint with us;
    • To furnish only such information as is verifiably authentic, while exercising the right to correction or erasure under the provisions of this Act or the rules made thereunder.

12. Where we store data

    Data collected under this Privacy Notice is hosted on servers located in India.

13. Processing your data

    We take steps to ensure that the Data we collect under this Privacy Notice is processed according to the provisions of this Privacy Notice and the requirements of applicable law.

    To ensure that your Data receives an adequate level of protection, we have put in place appropriate written contracts with Aditya Infotech Limited Entities, Partners and Service Providers that we share your Data with. This ensures your Data is treated by such parties in a way that is consistent with applicable law.

14. App Permission that we capture

    We ask for the following app permissions while onboarding, in order to optimize the experience for you:

    • Location
      Setting your location sharing to 'Always' helps us provide location-specific features, such as the availability of products or nearby device setup options. You can modify this setting anytime.
    • Camera
      This permission allows you to scan QR codes or take photos for device setup and configuration purposes.
    • Photos/Media/Files
      Access to media is required to save and retrieve images or files, such as screenshots or device configurations, on your device.
    • SMS
      This enables automatic OTP confirmation, simplifying the authentication process by eliminating the need for manual input.
    • Receive SMS
      We use this permission to send payment-related updates and notifications through our payment partners.
    • Access Wi-Fi State
      This helps optimize your application experience by monitoring Wi-Fi signal strength, especially during real-time device monitoring or video streaming.
    • Record Audio
      This permission enables audio during video monitoring or two-way communication through supported devices.
    • Bluetooth
      Bluetooth is used to connect and redirect audio to Bluetooth-enabled headsets or devices during video monitoring sessions.

15. Severability

    If any court or competent authority finds that any provision of this Privacy Notice (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this Privacy Notice will not be affected.

16. Changes to the privacy notice

    Our business changes constantly and our Privacy Notice may also change. We may e-mail periodic reminders of our notices and conditions, unless you have instructed us not to, but you should check our website and mobile application frequently to see recent changes. The updated version will be effective as soon as it is accessible. Any changes will be immediately posted on our website and mobile application, and you are deemed to have accepted the terms of the updated Privacy Notice on your first use of our website or mobile application or first purchase of the products and/or services following the alterations. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.

17. Privacy Contact Information

    To exercise your rights, including accessing, reviewing, updating, or withdrawing your consent regarding your personal data, please contact us at privacy.grievance@adityagroup.com. We welcome your question and comments about privacy notice. AIL will do it’s best to resolve any complaints as quickly as possible.