PRIVACY POLICY - IMGlobal Media Private Limited^®

1. INTRODUCTION

A. The entity comprising IMGlobal Media Private Limited, its subsidiaries and affiliated companies (collectively referred to as the "Company", "IM", "we," "us," or "our") respects and is committed to protecting your privacy and safeguarding of your personal information("Personal data").

B. This comprehensive Privacy Policy ("Privacy Policy" or "Policy") outlines the methods and principles governing our how we collect, use, process, disclose, and protect information and your personal data in connection with use of our products, services, websites including but not limited to House of Dobe - the digital platform for sustainable living (Hereinafter referred to as "DoBe"), and P.U.R.P.O.S.E. Pulse (our campaign for intent mapping of users).

C. By accessing or using any of our services, products and website, you consent and acknowledge that you have read, understood and agreed to the processing of your personal data in accordance with the terms and practices of this policy and our Terms of Use.

D. Please note that this Policy does not apply to our partners, each of whom may maintain their own privacy policy and in situations you interact with such partners, we request you to review the privacy policy applicable to that particular site, service, or interaction.

2. SCOPE AND APPLICATION

A. This Privacy Policy is an electronic record under the Information Technology Act, 2000, and the rules made thereunder. It complies with the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data of Information) Rules, 2011, and the Digital Personal Data Protection Act, 2023.

B. This policy applies to all users, visitors, vendors, service providers, commercial partners and customers (collectively referred to as the "Users", "You", "Yours") of our platforms and services including DoBe and P.U.R.P.O.S.E. Pulse.

3. CONSENT OF THE USER

A. The User, by accessing or using any of our services, products and websites gives a free, specific, informed, unconditional, unambiguous consent to the specified practices and terms described in this Privacy Policy.

B. In case the User is a minor, then consent given shall be that of his or her legal guardian and it will be deemed that such consent is free, specific, informed, unconditional, unambiguous consent to the specified practices and terms described in this Privacy Policy.

4. INFORMATION WE COLLECT

A. User Provided Information:

a. Pursuant to this policy IM collects and processes the information shared by the User at the time of registration or sign up. Information like personal data that can be reasonably be used directly or indirectly which identifies the user's presence on our various platforms, such information shall include, but not limited to the user's name, sex, postal address, email address, telephone number, date of birth, nationality, educational qualification, professional details, biometrics, PAN, Aadhar, GST verification.

b. Not sharing the requisite data may lead to certain features being restricted, unavailable, unusable including inability of the user to create or sign up or register for products, services and platforms of IM including DoBe and P.U.R.P.O.S.E. Pulse.

c. Where IM seeks any device permission and you decide to provide such permissions such as contact list, photos, camera, gallery, location, microphone, SMS, storage, phone calls, then IM may collect, retain and use the data sourced through such device permissions.

d. Information generated through use of services, products and websites of IM: Apart from the personal information, the user also exposes itself to providing non-personal data and information that may or may not reveal their identity which includes details pertaining to the services, products you avail including but not limited to your interactions with DoBe and P.U.R.P.O.S.E. Pulse, any Credit Economy, transaction details, chosen method of payment and information shared during customer support instances, demographic information, statistical data from personal data, or aggregated calculations to analyse the percentage of users accessing a specific domain or website features.

e. Technical information such as unique identifiers, device IDs, and other identifiers: this may include Internet Protocols (IP) addresses, information about nearby Wi-Fi access points, browser types, operating systems, manufacturer and model of your device, preferred language, and other platforms used by the user.

B. Information collected from third parties: PAN, AAdhar, GST, other KYC, financial information from another payment portal, details pertaining to purchase of products and services from third parties and their affiliations.

C. At IM, we create comprehensive user profiles by combining various types of data to provide the user with a more personalized and meaningful experience making the user profile consolidates personal information (such as your name and contact details), non-personal data (like your interests and activity patterns), demographic information (including your location and professional background), and technical data (such as device and usage information). This consolidated profile serves as the user's digital identity within our impact ecosystem on our platforms, allowing us to showcase the user's social impact journey, connect with like-minded individuals and organizations, and participate in meaningful initiatives through IM platforms including DoBe and P.U.R.P.O.S.E. Pulse.

5. METHODS OF INFORMATION AND DATA COLLECTION

A. Direct User Submissions: When you interact directly with our platforms and services, including DoBe and P.U.R.P.O.S.E. Pulse, you may provide information by filling out surveys/forms, creating accounts, or engaging with our features. This includes information submitted during account registration, profile creation, purchase transactions, customer service interactions, surveys, and feedback submissions. We collect this information when you enter it into our platforms or transmit it to us through any other direct means of communication.

B. Automated Data Collection Technologies: Our systems employ various automated technologies to collect information about your equipment, browsing patterns, and platform interactions in order to facilitate analysis of application services, user engagement, measurement of promotional effectiveness and other business related considerations. These technologies include:

a. Essential cookies necessary for platform functionality

b. Analytics cookies that help us understand user behavior

c. Preference cookies that remember your settings

d. Marketing cookies that help deliver relevant content

Cookies are used to reduce the frequency of password entry during a session, and assist in obtaining information beneficial for tailoring services more precisely according to the user's interests.

C. You have the discretion to decline our cookies if your device allows, although this may limit your ability to utilize certain features on the application, products, website, services by IM.

D. User Contributions: You may also provide information for us to publish, display, or post on our platform, products and website. Once posted we are not responsible for user contribution related information and so you may provide it to us at your own risk.

6. UTILISATION OF DATA

A. The collected information and data may be utilised, stored and processed by us to provide, maintain, protect, and improve our services and establish and sustain a secure and trusted environment including compliance with our legal obligations and adherence to our policies, while respecting your privacy rights and choices.

B. Essential Services Delivery: We utilize your data to authenticate your identity, maintain your account, process your transactions, and deliver our core platform features, products and services including DoBe and P.U.R.P.O.S.E. Pulse. This processing is fundamental to providing you with access to our services and includes managing your login credentials, maintaining session security, and ensuring platform stability.

C. User Experience Personalization: Your information enables us to tailor your platform experience to your preferences and needs. We analyze your interaction patterns, content preferences, and platform behavior to customize navigation flows, recommend relevant content, and present features that align with your interests and usage patterns. We may share such information with our advisers, third party service partners and other affiliates in order to provide a seamless user experience.

D. Technical Service Optimization: We process technical data to monitor platform performance, identify and resolve technical issues, optimize loading times, and maintain system stability and security.

E. Service Updates and Notifications: Your contact information enables us to send essential service notifications, including security alerts, platform updates, changes to our terms or policies, application updates and important account-related information. These communications are integral to our service delivery and cannot be opted out of while using our platforms.

F. Marketing Communications and Promotions: With your consent, we utilize your information to send promotional materials, newsletters, and marketing communications about our services, features, and partner offerings. You can opt-out of receiving marketing and promotional material from us at any time or remove your contact information from all our lists and newsletters by following the unsubscribed instructions provided or writing an email to us at contact@impresario-global.com and for DoBe platform write to us at Contact@do-be.ai.

G. Research and Innovation: Your data contributes to our research initiatives aimed at understanding user needs, market trends, and emerging opportunities.

H. Quality Assurance: We process information to maintain and improve service quality, including testing new features, verifying system integrity, and ensuring platform reliability.

I. Legal Compliance: We process information as required to comply with applicable laws, regulations, and legal obligations, including responding to legal requests, protecting our legal rights, and maintaining required records.

J. Customer Support: the information and data we collect may be used to assist you when you contact our customer support services, to investigate and address your queries, and monitor and improve our customer support responses. This information may also be used for staff training and quality assurance.

7. DISCLOSURE OF DATA

We share your information with care and purpose, ensuring alignment with our mission of amplifying social impact while protecting your privacy.

A. Primary Disclosure Partners: We may share your personal data with IM Corporate Group and Affiliated Entities which includes members of the IM Global Media Private Limited, associated impact ventures and social enterprises within our group, Affiliated impact assessment bodies.

B. Strategic Partners and Service Providers: We share data with business partners, third parties and service providers who help us deliver our services. These partners are contractually bound to maintain strict confidentiality of all personal data, use information solely for specified purposes, implement appropriate security measures, comply with our social impact standards and delete or return all personal data after service completion all governed with a Non-Disclosure Agreement between the concerned parties.

C. Social Impact Collaborators: We may share data with:

a. Verified social enterprises and NGOs

b. Sustainable product manufacturers and suppliers

c. Impact investors and grant-making organizations

d. Social impact researchers and academics

e. Community organizations and grassroots movements

D. Secondary Disclosure Circumstances - We may also disclose your personal data in a Business Transitions:

a. During evaluation or execution of any merger, acquisition, or reorganization; or to potential buyers or investors, when selling or transferring business assets; or In events of organizational restructuring, ensuring data protection continuity; or during impact partnership formations or dissolutions

E. Legal and Regulatory Compliance

a. For compliance with any judgment or decree or order issued under any law for the time being in force in India

b. To comply with governmental or regulatory requests

c. For tax and audit purposes related to social impact claims

d. To verify impact credentials and certifications

e. To maintain transparency in impact reporting

f. To relevant regulatory authority

g. for the State and any of its instrumentalities to provide or issue to the Data Principal/User such subsidy, benefit, service, certificate, licence or permit

h. for the performance by the State or any of its instrumentalities of any function under any law for the time being in force in India or in the interest of sovereignty and integrity of India or security of the State

i. for responding to a medical emergency involving a threat to the life or immediate threat to the health of the Data Principal/User or any other individual

j. for taking measures to provide medical treatment or health services to any individual during an epidemic, outbreak of disease, or any other threat to public health

k. for taking measures to ensure safety of, or provide assistance or services to, any individual during any disaster, or any breakdown of public order.

F. Some of our rewards, promotions, campaigns, programs, events, may be co-branded or sponsored by third parties and us. If you opt in for such rewards, promotions, campaigns, programs, events, in that case your information may be collected and shared with such third parties.

G. You may note that any user data or information related to his or her KYC which includes Aadhar details, PAN details, GST details will not be shared or disclosed to any other user or third party.

H. For clarity, we do not sell or lease such personal data and information with any third party.

8. CONSENT TO DATA STORAGE, TRANSFER AND PROCESSING

A. Data Storage: The data and information collected by IM including from DoBe platform and P.U.R.P.O.S.E. Pulse Campaign is stored in databases which are hosted on RDS Servers by Amazon Web Services in India.

B. Scope of Transfer: We may transfer and process your personal data globally as necessary to:

a. Deliver our social impact initiatives and services

b. Maintain our operations

c. Fulfill our contractual obligations

d. Comply with legal requirements

e. Achieve our legitimate business purposes

C. Third-Party Processing: We may engage trusted third-party service providers and partners globally to process your personal data. All such parties are contractually bound to:

a. Process data only as instructed by IM

b. Maintain appropriate security measures

c. Comply with applicable data protection laws

d. Protect the confidentiality of your personal data

D. International Data Processing and Storage: Your personal data may be transferred to, processed, and stored in countries other than your country of residence. These countries may have data protection laws that differ from, and may be less comprehensive than, those in your jurisdiction.

E. Your Rights: You may request information about countries where your data is processed and withdraw your consent at any time (however, this may affect the user's access to certain services as applicable).

F. Duration: this consent remains valid for the duration of our relationship and as long as we retain your personal data in accordance with applicable laws and our data retention policies.

G. Information sharing with the third-party advertising platforms including but not limited to LinkedIn, Meta, and Google:

a. The user agrees and consents to sharing of their personal information including phone number, email address and any other relevant and required information or interaction with the third-party advertising platforms including but not limited to LinkedIn, Meta, and Google for marketing and advertising purposes by the Company.

b. However, in case of a refusal to share such information by the User, the User may submit a written request for deletion of his or her or their account to contact@impresario-global.com for IM and at Contact@do-be.ai for Dobe websites, with the subject line "Deletion of Account".

c. However, please note that information shared prior to your request for deletion of an account cannot be retroactively removed from third-party advertising platforms including but not limited to LinkedIn, Meta, and Google.

d. Additionally, the personal information shared by the Company will be fully encrypted and hashed before any further sharing or transmission with the third party.

e. Your decision to delete the account will affect your ability to use the Company's offerings and services or impact the quality of service provided.

f. The Company reserves the right to maintain certain data sharing relationships as required for essential business operations or as mandated by applicable laws and regulations.

g. Data sharing and analysis enables the Company to refine the offerings, services, identify trends, personalize content recommendations, and deliver more relevant advertisements tailored to your interests and preferences.

h. The Company strives to implement appropriate technical and organizational safeguards to protect your information during this process, and any sharing with third-party analytics providers or marketing partners is conducted in accordance with applicable data protection laws and our Privacy Policy.

9. DATA SECURITY AND GOVERNANCE

A. At IM, data security and governance are paramount to our operations. We are committed to ensuring the confidentiality, integrity, and availability of the data entrusted to us by our clients and users across all our platforms including DoBe and P.U.R.P.O.S.E. Pulse. We adopt reasonable safeguards to protect your personal data from unauthorized access, use and disclosures.

B. Our data security measures include robust encryption protocols, access controls, regular security audits, and ongoing employee training on data handling best practices. We adhere to industry standards and compliance requirements to protect against unauthorized access, disclosure, alteration, and destruction of data.

C. Additionally, we implement stringent governance practices to ensure that data is collected, processed, and utilized in a lawful and ethical manner. This includes clear policies and procedures for data handling, privacy compliance, and risk management.

D. Modification and deletion of personal information:

a. Unless we require a longer retention period or permitted by law, IM will store your data for as long as you are associated with IM, or until you request it to be deleted, whichever is later.

b. Upon request for data deletion by the User, The Company retains the right to retain it as backup or archival media for legal, tax, or other legal and regulatory purposes.

E. Subject to applicable data protection laws, you may be entitled to any of the following rights:

a. Confirmation as to whether or not or which of your personal information is being processed by IM; and If we are processing your personal information:

i. Purposes of the processing;

ii. Categories of data concerned;

iii. Recipients or categories of recipients to whom the personal information is disclosed, including the identity of any service providers we use to process your personal information on our behalf;

iv. Copy of the personal information being processed and of any available information as to the source of the information, except where prohibited by law.

b. You have the right to request your information from IM at any time and restrict or rectify it by contacting us.

c. You have the Right to access, update, edit and delete Your information.

d. You have the right to grievance redressal by writing to us at contact@impresario-global.com and for DoBe related grievances specifically write to Contact@do-be.ai.

F. It may be noted that IM will not respond to multiple requests raised in furtherance of Clause 9(E) if it is ascertained that the requests by the user are false, frivolous, misleading, illegal, or directly or indirectly violate the law of the land.

G. Subject to applicable data protection laws and other laws, you are required to adhere to following duties, subsequently you undertake to:

a. comply with the provisions of all applicable laws for the time being in force

b. to ensure not to impersonate another person while providing your personal data for a specified purpose;

c. 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;

d. to ensure not to register a false or frivolous grievance or complaint with IM or any other Government authority or Courts of Law;

e. to furnish only such information as is verifiably authentic, while exercising the right to correction or erasure.

H. IM takes reasonable care to ensure that your personal information is accurate, and where necessary, kept up to date. If it is determined that your personal information is inaccurate or out of date, we take every reasonable step to correct it.

I. Exceptions: It may be necessary to contact you in some cases if you have withdrawn your consent in the following scenarios:

a. For legal reasons

b. pending contractual obligation with IM

c. outstanding dues or payments with IM

d. IM needs to contact you to deliver a service you have already paid for.

J. While using services, products and websites of IM you may encounter or access the links to third party websites/apps not affiliated with IM. Please note that IM holds no responsibility for their privacy policy, terms of use, terms and conditions, content of those other websites, or any other acts/omissions by such third parties during your encounter or access to third party websites/apps not affiliated with IM.

10. REFUND AND CANCELLATION POLICY

A. At IM, we maintain a strict no-refund and no-cancellation policy for all our services and products, including DoBe and P.U.R.P.O.S.E. Pulse. Once you have initiated a relationship with us by purchasing any of our services, subscriptions, or products, or by engaging with our platforms including but not limited to DoBe and P.U.R.P.O.S.E. Pulse, we do not process refunds or cancellations under any circumstances. This policy has been implemented to ensure the integrity of our service delivery and maintain the quality of our user ecosystem. We encourage all users to carefully review our service offerings, terms, and conditions before making any purchase or commitment. By proceeding with any transaction or engagement with us, you acknowledge and agree to this non-refundable and non-cancellable nature of our services.

B. Subscription Cancellation: In case there is a subscription model on any of the services, products or platforms of IM including DoBe, then the subscribers may cancel their subscription at any time through their account settings or by contacting our support team at contact@impresario-global.com and Contact@do-be.ai. However, the user shall be subject to the following conditions upon cancellation:

a. No refunds will be issued for the current billing period

b. Access to premium features and services will continue until the end of the current billing cycle

c. All data and content associated with the account will remain subject to this Policy

d. Cancellation must be completed at least 72 hours before the next billing cycle to prevent automatic renewal

e. The user remains responsible for any charges incurred prior to cancellation.

C. Automatic Renewal: In case there is a subscription model on any of the services, products or platforms of IM; unless cancelled, subscriptions automatically renew for the subsequent billing cycle at the then-current rate. Users acknowledge that the renewal charges will be automatically processed using the payment method available and price changes will be communicated at least 30 days before implementation. Any failed payment attempts may result in service interruption. Users are responsible for maintaining accurate billing information and multiple failed payment attempts may result in account suspension.

D. Exceptional Circumstances: Any refund consideration is strictly limited to certain exceptions wherein; the user shall prove unauthorized transactions due to security breaches of our system, verifiable technical errors on our platform resulting in multiple charges, any/or documented cases of fraudulent use, such request must be submitted within 72 hours of the transaction any request post this timeline shall not be considered. Such circumstances shall be verified by our security and technical teams.

11. CHANGES AND MODIFICATIONS TO PRIVACY POLICY

A. IM reserves the right to modify this policy from time to time. Any amendments shall take effect immediately upon posting this policy online or making it publicly available. We request you to periodically review the policy for the most recent information on the Company's privacy practices.

B. If you continue to use Platform after those changes are in effect, it will be deemed that you agree to the revised Privacy Policy.

12. RETENTION

A. Personal data will be retained only for the duration necessary to fulfill the purpose elucidated in this Policy, unless a longer retention period is necessitated by law or for directly related legitimate business purposes. Once the personal data is no longer required, it will be disposed of or archived securely.

13. JURISDICTION AND APPLICABLE LAW

A. By visiting this Platform, you agree that the laws of India govern this Privacy Policy and any dispute arising in respect hereof shall be subject to and governed by the courts at Lucknow, Uttar Pradesh.

14. CONTACT

A. For questions or concerns or grievance redressal or modification of personal data in this Privacy Policy please write to us at the following Email: contact@impresario-global.com and for matters specific to DoBe and P.U.R.P.O.S.E. Pulse Contact@do-be.ai.