The portal, https://www.vnzinsights.com (the “website”) is owned and operated by VARKA NET ZERO PVT. LTD. (“Company”, “us”, “we”, “our”), a private limited company incorporated under the Companies Act, 1956, having CIN No. U70200HR2023PTC114905 in India.

Company is engaged in the business of providing consulting services and market insights to its customers across various businesses globally.

This privacy policy (“Privacy Policy”) sets out the information security practices of our website, including the type of information collected as well as the manner in which such information is collected, stored, used and shared. This Privacy Policy has been 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 the online portal of the Company. Any reference in this Privacy Policy to “you”, “your”, “customer” or “user”, would mean the person who accesses and/or uses the website, in any manner.

Our privacy policy is in place to make you feel secure when visiting our site. We are committed to maintaining your Personal Information, being any information that is capable of identifying you as an individual person, as you use this site.

We request you to go through this Privacy Policy and the Terms of Use carefully before you decide to use this website.

By using our website and services 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 sensitive personal information(as defined herein) in the manner prescribed in this privacy policy. If you do not agree to the terms of this privacy policy, please do not use the website, subscribe to the services or share your information with us.

A. OWNERSHIP OF INFORMATION/RIGHT TO USE

A.1 We do not claim any ownership interest in the Personal Information collected by the website from you, i.e., you continue to own the Personal Information even after you share it with us.

A.2 By providing us with Personal Information, you represent that you have the right to share it with us and allow us to use, store, process and disclose it in the manner prescribed in this Privacy Policy.

B. COLLECTION OF PERSONAL INFORMATION

B.1 We may collect, share and process Personal Information (as defined below) provided by you in the following forms:

• information provided by you such as your name, age, address, email ID and phone number;
• information that you provide directly to us via email or electronic communication;
• information that you provide to us over telephone. We may make and keep a record of such information shared by you; and
• information that you provide to us in physical form, whether sent through post or courier or handed over to our representatives in person.

B.2 For the purpose of this Privacy Policy, “Personal Information” consists of information relating to the following:

• Personal identifiers like names, address, age, emails, phone numbers
• Login IDs and passwords;
• physical, physiological and mental health condition, sexual orientation, medical records and history, biometric information;
• any details relating to the above as provided to a body corporate for providing services; and
• any details relating to the above, received by a body corporate 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 Information.

B.3 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 within the website, 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 website.

C. USE OF INFORMATION COLLECTED

C.1 Our primary goal in collecting your Personal Information is to improve user experience by adding new features and functionalities, customizing the content you see on our website, fulfilling your requests for certain services and contacting you to discuss our services.

C.2 Cookies. Cookies are small pieces of information saved by your browser. Cookies are used to record various aspects of your visit to the website and assist us in providing you with uninterrupted service. Cookies may be stored in your browser when you access the website or may be added when you visit third-party applications or websites. This anonymous information is maintained distinctly and is not linked to the Sensitive Personal Information that you submit to us. We use cookies collected to:

• authenticate your login information;
• enable our security features;
• display targeted advertisements; and
• improve and develop the features of the website.

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 website.

C.3 Communication- We may use email, newsletters, push notifications, short message service (SMS), multimedia message service (MMS) or other forms of communication to:

• respond to any queries that you may have;
• provide information relating to any services, if availed by you and obtain feedback from you;
• promote the website and services offered by us. You may receive such communications when you have agreed to be/registered as a user on the website.

D. SHARING OF INFORMATION

D.1 To the extent necessary to provide continuous services to you, we may share your Personal Information with the following third-parties, without notice to you:

• our partners, advisors and/or consultants, who work with us to provide services to you, help us communicate with you or assist with the maintenance of the website, on a ‘need-to-know’ basis;
• governmental authorities, in such manner, as permitted or required by applicable law; and
• another business entity, should we plan to merge with, or be acquired by that business entity, or undergo re-organization, amalgamation or restructuring of our 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 Personal Information.

D.2 Legal Proceedings- In the event, we are required to respond to legal notices, court orders or other legal processes, your Personal Information may be disclosed to legal authorities pursuant to such notices, court order or legal process, which may be without notice to you.

E. LINKS TO THIRD-PARTY WEBSITES AND APPLICATIONS

E.1 The website and any communication sent to you by us may also contain 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.

E.2 We are not responsible for any form of communication, 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.

E.3 The inclusion or exclusion of third-party content does not imply any endorsement by us of such content, websites or applications. The information provided by you to such third-party websites or applications shall be governed in accordance with their respective privacy policies and it is recommended that you review such privacy policies prior to using third-party websites or applications.

E.4 These third-party websites and applications may use technology to send advertisements directly to your browser. In such cases, the third-party websites and applications 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 may use, and the information practices of these third-party websites and applications are not covered by this Privacy Policy. Please contact them directly for more information about their privacy practices.

F. SECURITY OF INFORMATION

F.1 We strive to ensure the security, integrity, and privacy of your Personal Information and to protect your Personal Information against unauthorized access, use, alteration, disclosure or destruction. This website has stringent security measures (physical, electronic and managerial) in place to protect against the loss, misuse, and alteration of the Personal Information under our control.

F.2 You shall have a right to view and modify the information provided by you on the website. Whenever you change or access your account settings or information, we offer the use of a secure server. The website 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 any services.

F.3 In the event we become aware of any security breaches on the website, we will promptly notify you and take appropriate action, to the best of our ability, to remedy such a breach.

F.4 Notwithstanding anything contained in this Privacy Policy or elsewhere, we shall not be held responsible for:

• any security breaches on third-party websites or applications or for any actions of third parties that receive your Personal Information; or
• any loss, damage or misuse of your Personal Information, if such loss, damage or misuse is attributable to a Force Majeure Event. For the purpose of this Privacy Policy, a “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 of any kind, riots, insurrection, war, acts of government, computer hacking, unauthorized access to your mobile or storage device, crashes, breach of security and encryption.

G. DATA RETENTION and OPTING OUT

Your information will be retained with us as long as you engage with us. If you wish to remove your information from our servers or request that we no longer use your information and/or cancel your account, you may contact us at connect@varkaconsulting.com. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, enforce our agreements or for other business purposes.

You may, at any time, choose to opt-out of receiving further communications from us. To be completely removed from our mailing list, you may contact us at connect@varkaconsulting.com. If you are using an e-mail forwarding service or other similar services please make sure to include the correct e-mail address or addresses.

H. NOTIFICATION OF CHANGES

H.1 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 website so that you may review the amended and/or updated terms prior to continuing to use the website. The most current version of this Privacy Policy will govern our relationship with you and your data.

H.2 As always, if you object to any of the changes to our terms and no longer wish to use the website, you may deactivate your account on the website. Using our services or accessing the website after a notice of change has been sent to you or published on the website shall constitute your consent to the amended and/or updated terms.

I. CONNECT FOR PRIVACY QUESTIONS

Should you have questions about the Privacy Policy or our information collection, use, and disclosure practices, you may contact us at connect@varkaconsulting.com. 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.

YOU HAVE READ THIS PRIVACY POLICY AND AGREE TO ALL OF THE PROVISIONS CONTAINED ABOVE

With Effective from Date: 13/09/2023