V. COOKIES

“Cookies” are small files that reside on Your device’s hard drive and generally contain an anonymous unique identifier and are accessible by the Platform that placed them there. Cookies do a lot of different jobs, such as letting you navigate between pages efficiently, remembering your preferences and generally improving the user experience. In addition, cookies can help Us to analyze the use of our Platform and online content (analytics cookies) and they can also facilitate/track the interaction on our Platform and online content with social media (e.g. links to social media sites, like buttons, etc.).

We can place cookies and other similar technology on Your device, including mobile device, in accordance with your preferences set on our cookie consent manager. Depending on your settings in our cookie consent manager on your device, the following information may be collected through cookies or similar technology: your unique device identifier, device IP address, information about your device’s operating system, mobile carrier and your location information (to the extent permissible under applicable law).

Most browsers allow you to manage how cookies are set, and to clear cookies and browsing data. Also, your browser may have settings allowing you to manage cookies on a site-by-site basis. For example, browser settings may allow you to delete existing cookies, allow or block all cookies, and set cookie preferences for websites. Certain browsers also have incognito/ Privacy mode, which doesn’t store your online history of visited sites or cookies on your device after you close all incognito windows.

You may refuse to accept Cookies by activating the setting on Your browser which allows You to refuse the setting of Cookies. However, if You select this setting, you may be unable to access certain parts of Platform. Unless You have adjusted Your browser setting so that it will refuse Cookies, Our system may issue Cookies when You log on to our Communication Medium.

Some cookies, web beacons and other tracking and storage technologies that We use are from third party companies (third party cookies), such as, but not limited to, Facebook, Google Analytics, Microsoft, Twitter, YouTube, Instagram, and Linkedin Analytics. These provide Us with web analytics and intelligence about our Platform which may also be used to provide services and targeted ads. The use of such third-party cookies is not covered by this Privacy Policy. Please refer to the respective privacy policy of such third-party companies for the same.

Additionally, We may use the services of certain third parties for the purpose of operating and administering the Platform. Such third-party service providers may collect the information sent by You as part of a web page request, including Cookies and your IP address and such information will be governed by the privacy policies of the third-party service providers.

DATA RETENTION

We will only retain Your Personal Information for as long as may be necessary for the performance of the Services and for the effective and safe functioning of the platform/ Mobile Application, including for the purposes of satisfying any legal, accounting, or reporting requirements. We reserve the right to retain your Personal Information for the purpose of maintaining records.

In some circumstances, We may anonymize Your Personal Information (so that it can no longer be associated with You) for research or statistical purposes in which case We may use this information indefinitely without further notice to You.

DISCLOSURE OF INFORMATION

We will share Your information with third parties only in such manner as described below:

a. We (including the Turbostart Angel Fund) may share the Information with third parties and in such an event, the third parties’ use of Your information will be bound by the Policy. We may store information in locations outside Our direct control (for instance, on servers or databases co- located with third-party hosting providers).

b. We may disclose Your information to any member of the network.

c. In the event that We sell or buy any business or assets, we may disclose Your Information, to the prospective seller or buyer of such business or assets. User, email, and visitor Information is generally one of the transferred business assets in these types of transactions. We may also transfer or assign such Information in the course of corporate divestitures, mergers, or dissolution.

d. We may disclose Your Information to third-party service-providers solely in the course of their provision of services to Us. We will take reasonable precautions to ensure that these service-providers are obligated to maintain the confidentiality of Your Information.

e. We may disclose Your Information if We are under a duty to do so in order to comply with any legal obligation, or in order to enforce or apply Our Terms of Use, or to protect the rights, property, or Our, Our users, or others safety. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

f. We may disclose Your Information to governmental and other statutory bodies who have appropriate authorization to access the same for any legal purposes.

g. We may share Your Information with our members, advisors, consultants, directors, employees (without limitation). We strongly recommend You not to share any sensitive, proprietary, and/or competitive information that may compromise the confidentiality of Your proposition.

TRANSFER OF YOUR PERSONAL INFORMATION

Your Personal Information is processed at Our operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to and maintained on computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may be different to those from Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

ACCESS TO USER INFORMATION AND YOUR CHOICE ABOUT YOUR INFORMATION

If We have collected Personal Information from You, You may make a request to exercise the following rights:

a. ‍The right to withdraw Your consent at any time where We rely on Your consent to process Your Personal Information;

b. A right to have Your information rectified if such information is found to be incomplete or inaccurate;

c. A right to object to Us processing data collected from You;

d. A right to request that We restrict the processing of Your Personal Information;

e. A right to be notified in the event of a breach of any Personal Information collected by the platform.

f. A right to access, update or to delete information that We have on You; and

g. The right to be provided with a copy of Your Personal Data in a structured, machine-readable and commonly used format;

‍ It is clarified that any rights that You may have under this Clause shall only be applicable and made effective15 (fifteen) days from the date of request for the exercise of such right and not to any consents, approvals or processing of information that has already taken place prior to such date.

You may decline to submit identifiable information through the platform, in which case You may not be allowed to access certain features / parts of the platform.

If You believe that any of Your Personal Information held by Us is inaccurate, and there is no option provided within the platform to correct or update such information, or if You would like to exercise any of the rights mentioned in this Clause, You may write to Us at the Email ID provided in Annexure A below.

It is Your responsibility to ensure that any information You provide to Us remains accurate and updated

RIGHT TO UNSUBSCRIBE

You always have the option to not provide information by choosing not to use the platform or a particular feature thereof (where such feature is available for opt-out). We may automatically use Our available technology to retain Your preferences.

When You update information, We usually keep a copy of the previous version for Our records. If You do not want to receive updates from Us, please update Your preferences or write to Us at the Email ID provided in Annexure A below. However, opting out of updates still governs Your use of the platform under the Terms of Use and Privacy Policy.

STORAGE AND SECURITY

We endeavor to protect the Information provided by, or collected about its Users from unauthorized access, alteration, disclosure, or destruction. In particular:

a. Turbostart review its Information collection, storage, and processing practices, including physical security measures, to guard against unauthorized access to Our systems and the Information gathered.

b. As a registered user with an account and a password, You are responsible for implementing an appropriately strong password, and keeping Your password confidential.

c. All information You provide to Us is stored on secured servers whether outside or within India. However, please bear in mind that the secure servers are not controlled by Us and are managed and operated by third party service providers. These servers use commercially available tools provided by such third-party storage providers to provide appropriate safeguards to preserve the integrity and security of Your information against loss, theft, unauthorized access, disclosure, reproduction, use or amendment.

d. Turbostart restrict access to the Information collected to Our employees, contractors, and agents who need to know that Information for processing it for Us. The employees, contractors, and agents are subjected to the obligation of strict confidentiality about the information accessed, and will face disciplinary action, including termination, if they violate this obligation.

e. We do not recommend transfer of sensitive Personal Data (such as credit card number and bank account details) via the Platform to other users. Users are recommended to do so offline, on the phone or via personal emails. We follow generally accepted industry standards to protect the Information submitted to us, both during transmission and after we receive it.

It is our policy to only use third-party support providers that are bound to maintain appropriate levels of data protection, security and confidentiality, and those that comply with applicable legal requirements for transferring Information outside the jurisdiction in which it was originally collected.

However, perfect security does not exist in using Platform and You accept the inherent security implications of data transmission over the internet and the world wide web. Your data cannot always be guaranteed as being completely secure. User, therefore, agree that security breaches beyond the control of Our standard security procedures are at User’s sole risk and discretion.

WE ASSUME NO LIABILITY FOR ANY DISCLOSURE OF INFORMATION DUE TO ERRORS IN TRANSMISSION, UNAUTHORIZED THIRD-PARTY ACCESS OR OTHER ACTS OF THIRD PARTIES, OR ACTS OR OMISSIONS BEYOND OUR REASONABLE CONTROL AND YOU AGREE THAT YOU WILL NOT HOLD US RESPONSIBLE FOR ANY BREACH OF SECURITY UNLESS SUCH BREACH HAS BEEN CAUSED AS A DIRECT RESULT OF OUR GROSS NEGLIGENCE OR WILFUL DEFAULT.

In the event that We become aware of any breach of the security of Your information, We will promptly notify You and take appropriate action to the best of Our ability to remedy such a breach.

If you know or have reason to believe that your account credentials have been lost, stolen, altered, or otherwise compromised, or in case of any actual or suspected unauthorized use of your account, please contact us by contacting the Grievance Officer at legal@turbostart.co

‍CHANGES TO POLICY

We reserve the right to modify this Policy at any time. Any changes made to its Policy in the future will be notified and made available to User using the Platform. User’s continued use of the services and the Platform shall be deemed as User’s acceptance of the varied privacy policy.

GENERAL TERMS

Turbostart and Turbostart Angel Fund along with its officers, directors, managers, partners, members, shareholders, employees, affiliates and agents make no representations or warranties and specifically disclaim any and all warranties of any kind, express or implied, with respect to the Platform and any content therein, including any representations or warranties with respect to merchantability, fitness for a particular purpose, title, non-infringement, availability, security, accuracy, freedom from viruses, malware or other damaging software, completeness, timeliness, functionality, reliability, sequencing or speed of delivery.

We reserve the right to cease providing, or to change, the Platform and content of such information (or any portion or feature thereof) at any time or frequency and without notice. All content on the Platform is presented only as of the date published or indicated and may be superseded by subsequent market events or for other reasons. Any transactions described on the Platform are for illustrative purposes only and may not be representative of all transactions engaged in by Turbostart.

Although certain individuals may be identified on the Platform as ‘venture partner’, ‘director’, or ‘executive director’, such titles reflect business usage that is customary within the venture capital and private equity industry and are not intended to indicate that any such individual is actually a partner of any partnership or director of any company as those terms are used for legal purposes.

DISCLAIMER

We cannot ensure that all of User’s private communications and other Information will never be disclosed in ways not otherwise described in this Privacy Policy. Therefore, although we are committed to protecting User’s privacy, We do not promise, and User should not expect, that the User’s Information will always remain private. As a User of the Platform, you understand and agree that User assumes all responsibility and risk for usage of the Platform, the internet in general, and the documents you post and access, and for User’s conduct on and off the Platform.

GRIEVANCE REDRESSAL

Turbostart respects and is sensitive to the rights as granted in the Applicable Laws. Any questions about the Privacy Policy or Our Information collection, use and disclosure practices, you may contact the Grievance Officer as per the details given hereunder. We will endeavor to use reasonable efforts to respond promptly to requests, questions or concerns User may have regarding the use of Information.

In accordance with the Applicable Laws, the name and contact details of the Grievance Officer are provided below. You may contact Grievance Officer to address any discrepancies and grievances you may contact the Grievance Officer to address any discrepancies and grievances you may have with respect to your Information with Turbostart.