Valorem Stack Private Limited

PRIVACY POLICY

This Privacy Policy ("Privacy Policy") describes Valorem Stack Private Limited's ("we", "us", "our" or the "Company"), a company incorporated under the laws of India having CIN No. U72900KA2019PTC124476 with its registered office at GNGi Elite, 11/3, Service Rd, Popular Colony, Mangammanapalya, Bangalore, Karnataka, India 560068, policies and procedures on the collection, use and disclosure of a User's information pursuant to the User's use of [Staff Attendance App Name] (the "App" or "Product"), a mobile and/or web application published by Valorem Stack Private Limited that enables business owners to record and manage the check-in, check-out and attendance of their staff.

The App is developed and distributed under the developer account of Valorem Stack Pvt. Ltd. and is part of the same ecosystem as the Company's other products, including myBillBook and mySandesh. We are committed to ensuring that any use or sharing of your information with anyone shall be only in accordance with the procedures described in this Privacy Policy.

The capitalized terms used in this Privacy Policy, but not defined herein, shall have the meaning given to such terms in the Terms of Service.

Please read this Privacy Policy before using the App or submitting any personal information. By using the App, it shall be deemed that the User is expressly consenting to be bound by the terms and conditions described in this Privacy Policy. The User may revoke its consent for providing sensitive information (as defined under the Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011) by reaching out to our support in writing. Please note that we may discontinue providing services which depend on or require such sensitive information.

1. Who this Policy covers — Business Owners and Staff

The App is used by two categories of individuals, and it is important to understand how this Policy applies to each:

  1. Business Owner / Account Holder ("User"): the person who registers for and operates the App to manage attendance. This is the person who provides consent to this Privacy Policy.
  2. Staff Member ("Staff"): an employee or worker whose attendance is recorded by the Business Owner in the App. The Staff's basic information (name and phone number) and attendance records are added and controlled by the Business Owner.

Where a Business Owner adds a Staff member's information to the App, the Business Owner represents and warrants that it has the necessary authority, and has obtained any consent required under Applicable Laws, to share that Staff member's personal information with us for the purpose of recording attendance. The Company processes Staff information on behalf of and at the instruction of the Business Owner.

2. Other applicable terms

This Privacy Policy is a part of and incorporated within, and is to be read along with, the Terms of Service (the "Terms of Service"). The User may view these Terms of Service within the App or at [link to Terms of Service].

3. Policy changes

We may change and update this Privacy Policy from time to time. Such changes may be made without prior notice, but any changes will apply only on a going-forward basis and not retroactively, unless specified otherwise. The User is encouraged to review this Privacy Policy before accessing the App to understand how any personal information provided will be used.

4. Links to other websites

The procedures and practices set forth in this Privacy Policy describe the use and disclosure of User Information collected through the App. The App may contain links to other websites. Any personal information collected when a User visits such websites is not governed by this Privacy Policy. The User is encouraged to exercise caution and review the privacy policies applicable to such websites before accessing them. The Company shall not be responsible for and has no control over the practices and content of any website accessed using the links contained in the App.

5. Competency to contract

By agreeing to this Privacy Policy, a User (being a natural person) represents that the User is at least the age of majority, i.e., 18 years, and is competent to contract. Where the User is registering on behalf of, and is the authorized representative of, a company, partnership or any other legal entity, such User has been duly authorized by such entity and is permitted under Applicable Laws to accept these terms. A natural person who is not of the age of majority or is not competent to contract may not use the App or provide any information to us.

6. Collection of information

Towards the provision of the Services and in cases where a User uses the App, we may collect the following information ("User Information"):

6.1. Information given by the User (Business Owner): Information you provide when creating or using an account, or when corresponding with us by phone, e-mail or otherwise. This may include, without limitation, your name, business name, e-mail address, phone number, and other information required to provide the Services and to protect against illegal activities.

6.2. Information about Staff added by the User: When a Business Owner adds a Staff member, the App collects the name and phone number of that Staff member, together with the attendance records (check-in and check-out times, dates, and derived attendance status such as present, absent, half-day or leave) generated through the use of the App.

6.3. Approximate (coarse) location information: Where enabled, and with the relevant permission, the App may collect approximate (coarse) location at the time of check-in or check-out to help the Business Owner confirm attendance. The App does not collect precise GPS coordinates. The App does not capture any photograph, selfie, facial image or biometric information for attendance verification.

6.4. Information collected automatically: With regard to use of the App, we may automatically collect and analyse technical information such as the IP address, login information, device details, time zone setting, operating system and other similar information; and information about a session such as material or information viewed, page response times, errors, length of visits, interaction information, and metadata such as date. We do not collect SMS, contacts, call logs, media files or other device resources for the purpose of this App without your consent.

6.5. Information from other sources: We may receive information about a User from other products and services used by the User within the Company's ecosystem, or from third parties such as analytics providers. We may also collect non-personally identifiable information.

7. Usage of User Information

User Information is used by us and our partners and service providers for various business purposes, which, among others, include:

We will use and retain only such basic minimal information as is necessary for the provision of the Services.

8. Storage of User Information

User Information in the possession and control of the Company is stored in accordance with Applicable Laws, including without limitation the Information Technology Act, 2000 and the Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011. By using the App or the Services, the User agrees and consents to the collection, storage and use of the User Information in the manner described in this Privacy Policy.

9. Dissemination of User Information

The User acknowledges that User Information and other data may be exported outside of India, processed and stored in a foreign country or countries where it may be accessed by other entities. User Information may also be transferred in accordance with Applicable Laws to Governmental Authorities, to affiliates of the Company, and to any potential buyers of the shares or assets of the Company. We may also share User Information (not being in the nature of sensitive personal information) with analytics providers and other third-party service providers for the provision of services to the Company and/or its Users. We do not sell User Information.

10. Information security

We take various reasonable steps and measures to protect User Information from misuse, loss, unauthorised access, modification or disclosure. We use industry-standard secure server layer encryption and access control on our systems, together with other reasonable security practices and procedures. While we make best possible efforts to securely store User Information, we do not guarantee that there will be no unintended disclosures on account of a data breach, unauthorized access, or security failure. We give no warranties and shall not be liable for any breach of security caused by malicious attacks, errors, or omissions not wilfully initiated by us, and any transmission is at the risk of the User.

11. Retention of User Information

We may, at our discretion, retain any User Information for as long as a User is active on the App, as required under agreements with the Company, or as required under Applicable Laws. A Business Owner may delete a Staff member's records at any time from within the App. We shall not be responsible for any destruction of User Information after the closure or termination of a User's account.

12. Cookie policy

A "cookie" is a packet of information stored on a browser by a server so that it can later be read back. To improve the responsiveness of the App for Users, we may use "cookies" or similar electronic tools to collect information.

13. Local storage policy

To facilitate the provision of the Services, we may store information locally on the User's device. The User consents to the local storage of information on the User's device for the facilitation of the Services or provision of the App.

14. User's rights in relation to User Information

15. Contact details / Grievance Officer

In case a User has any queries or any discrepancies/grievances with respect to the User Information provided, in accordance with the Information Technology Act, 2000 and the rules thereunder, please contact:

Name: Valorem Stack Private Limited Support Email: support@mybillbook.in Phone number: +91 740041 7400 Grievance Officer: Mr. Rakesh Yadav — grievanceofficer@flobiz.in Address: GNGi Elite, 11/3, Service Rd, Popular Colony, Mangammanapalya, Bangalore, Karnataka, India – 560068 (10:30 AM to 7:30 PM, Monday to Friday except public holidays)

16. Updates to the Privacy Policy

We reserve the right, at any time, to add to, change, update or modify this Privacy Policy. The latest Privacy Policy will be available on this page and within the App.