Privacy Policy

SolarSquare Energy Private Limited (“SolarSquare”/“We”/ “Us”) is committed to upholding the privacy and security of the information supplied by every person (“User”/“You”) accessing and using any version of the https://www.solarsquare.in/ (“Website”). This Privacy Policy explains the manner in which We collect and use User information. By accessing or using the Website You signify that You have read, understood and agree to be bound by this Privacy Policy. This Privacy Policy does not apply to information collected from residents of countries other than India.

Your access and use of the Website following any such change constitutes your agreement to follow and be bound by this Privacy Policy, as updated or modified. For this reason, We encourage You to review this Privacy Policy each time You access and use the Website. Your use of the Website and any disputes arising therefrom, is subject to this Privacy Policy.

We reserve the right to update or modify this Privacy Policy at any time without prior notice and such changes shall be effective immediately upon posting the updated or modified Privacy Policy on the Website and We shall not be bound to inform you of any modifications hereof.

On occasion, SolarSquare may offer special programs, activities, events or promotions (“Programs”) that have unique or additional specific terms, privacy notices and/or consent forms that explain how any information You provide will be processed in connection with the Programs. You should review the applicable terms before interacting or participating in the Programs.

PERSONAL INFORMATION

a)We shall collect personal information of the User, by which he/ she/ it, as a person can be identified, including without limitation, name, gender, age, date of birth, height, weight, mobile number, address, email address, any identity proof number, phone number, health and fitness related information etc (“Personal Data” or “Personal Information”2) as set forth in clause 3 of this Privacy Policy. It is hereby clarified that:

(i)While some User information has to be mandatorily provided, others are optional and certain portions of the information shall remain private and some shall be displayed to other Users; We shall always let the User know which is which.

(ii)Additional information may be gathered during subsequent use of the Website by the User, whenever the User chooses to provide it.

HOW DOES SOLARSQUARE COLLECT PERSONAL INFORMATION?

a)Certain mandatory information shall be collected at the time of registration on the Website which is required to enable the User to login to the Website and for Us to verify the User’s identity; and to safeguard against illegal activities like fraud, cheating, misappropriation, etc. as may be determined by Us; and/or our banking and service partners.

b)In order to use the facilities and services available on the Website, the User may be required, from time to time, to provide certain additional personal information after registration on the Website, which information shall be collected only upon receiving the User’s express consent.

c)We may also automatically receive and collect certain information from your participation in SolarSquare programs or contests, industry and associations, and other anonymous information in standard usage logs through the web server, including mobile-identification information obtained from the equivalent of "cookies" sent to the Website, including mobile network information, standard web log information, traffic to and from our Website, tracking inside the Website and any other available information, from:

i)an IP address, assigned to the device used by the User;

ii)the domain server through which the User accesses the Website and the functions and features therein; and

iii)the type of device used by the User (“Device”).

It is hereby clarified that such usage information collected is not associated with any Personal Data and is tagged to the unique identifier of a particular Device.

d)The User may choose to provide Us with access to certain personal information stored by third parties like social networking sites (e.g. Facebook and Twitter). We shall have access to such information to the extent allowed by the User’s privacy settings on that site and the User’s specific authorization. In the event the User associates a User account managed by Us with an account maintained with any third party to enable Us to access certain information maintained in such third party managed accounts, the User agrees that We may collect, store and use such information in accordance with this Privacy Policy.

e)After obtaining the User’s specific consent to allow the Website to access the User’s SMS inbox, we may collect relevant information from text messages (SMS) received by the Users from providers of services and/or products (including but not limited to retail outlets, financial institutions, mobile carriers and utility companies), that shall enable us to provide better services and products to the Users. We shall only access business messages that originate from alphanumeric senders.

f)In order to enhance our ability to provide valuable services and experiences to the User, We may:

i)automatically receive, collect and analyse your location information which may be accessed through a variety of methods including, inter alia, GPS, IP address, and cell tower location; and

ii)collect information pertaining to your Device and your usage thereof, including, inter alia, the names of the other applications on your mobile Device and how you use them, information about your Device, and information about your use of features or functions on your Device.

Links to Other Web Sites

Our web site contains links to information on other web sites. On web sites we do not control, we cannot be responsible for the protection and privacy of any information that you provide while visiting those sites. Those sites are not governed by this Privacy Policy, and if you have questions about how a site uses your information, you’ll need to check that site’s privacy statement.

INFORMATION COLLECTED

a)We may collect the following information:

i)Contact information and preferences (such as name, email address, mailing address, phone number, and emergency contact information);

ii)Biographical and demographic information (such as date of birth, age, gender3);

iii)Payment-related information we need to complete a transaction (such as credit card number and financial account information);

iv)Username and password that You may select in connection with establishing an account on our Website;

v)Publicly available information;

vi)Internet activity, such as Your Internet Protocol (“IP”) address, browsing history, Your search history and information on Your interaction with the SolarSquare and our advertisements;

vii)Device information;

viii)Geolocation data, e.g., Your physical location or movements (See “Cookies and Other Tools” below);

HOW DOES SOLARSQUARE USE PERSONAL INFORMATION?

a)Generally, SolarSquare may also use Your information to:

Provide Our products and services to You and make them better,

Develop new products and services,

Fulfill Your requests,

Provide customer service and dealing with requests, enquiries, complaints or disputes and other customer care related activities,

v)Send You administrative communications regarding SolarSquare’s products or Solar Square Services,

vi)Notify You about special promotions or offers that may be of interest to You,

vii)Invite You to participate in surveys about our products or services,

viii)Better understand the interests of our customers and visitors who use SolarSquare services,

ix)Maintain Solar Square’s online services,

x)Evaluate how You and other Users interact with our online services,

xi)Protect Solar Square and our Users,

xii)Secure our online services including our Website,

xiii)Conduct audits related to our current interactions with You,

xiv)Debug the site and service to identify and repair errors that impair existing intended functionality,

xv)Defend ourselves in litigation and investigations and to prosecute litigations,

xvi)Comply with our legal and regulatory obligations.

b)Solar Square may also use information collected from You or about You to offer You customized content, including to:

i)Recognize new or past visitors to our Website,

ii)Remember Your personal preferences, and

iii)Show You more relevant and meaningful advertisements based on Your interests.

c)Solar Square may also use Your information for other purposes disclosed to You from time to time. When You send an email message or otherwise contact Solar Square through its Website, We may use the information provided by You to respond to Your communication. Solar Square may also archive such Information and/or use it for future communications with You to inform You regarding updates, newsletters, offers, new services and promotions.

d)We may use Personal Information for our internal business purposes, such as data analysis, audits, developing new products, enhancing our Website, improving our Solar Square services, identifying usage trends and determining the effectiveness of our promotional campaigns.

e)We may aggregate and/or de-identify data about customers and site visitors and use it for any purpose, including product and service development and improvement activities.

f)You acknowledge that you are licensing Us to use, modify, display, distribute and create new material from the information you provide through the Website to render certain services on the Website. By providing such information, you automatically agree, or promise that the owner of such information has expressly agreed to allow or license, as the case may be, Us to use the information in the manner set out in this Privacy Policy. We may, to the extent permitted by law, also use, license, reproduce, distribute disclose, and aggregate, non-personally identifiable information that is derived through your use of the Website and you hereby provide consent for the same.

DOES SOLAR SQUARE SHARE PERSONAL INFORMATION?

a)Solar Square may share Your information within the Solar Square group companies/associates.

b)We shall not use User information for any purpose other than in connection with the Website. We shall not rent, sell or share User information and shall not disclose any of the User’s Personal Information to third parties. However, we share Personal Information with our vendors, contractors, business and service partners, or other third parties (collectively, “Service Providers”). Service Providers may include analysis firms, advertisers, payment processing companies, customer service and support providers, email, IT services and SMS vendors, web hosting and development companies and fulfillment companies.

c)Some Service Providers may collect personal data on behalf of Solar Square. These third parties may be provided with access to personal data needed to perform their functions. In addition, Solar Square’s practice is to require its Service Providers to keep Your Personal Information confidential and to use Personal Information only to perform functions for Solar Square.

d)If Solar Square sells all or part of one of its product lines or divisions, Your information may be transferred to the buyer. Solar Square reserves the right to disclose Your information to respond to authorized information requests from government authorities, to respond to valid judicial requests, to address national security situations, to provide security and investigate potential fraud, or when otherwise required by applicable law.

e)Solar Square may disclose Your Personal Information as required by law to any competent law enforcement body, regulatory or government agency, court or other third party where We believe the disclosure is necessary or appropriate to comply with a regulatory requirement, judicial proceeding, court order, government request or legal process served on Us, or to protect the safety, rights, or property of Our customers, the public, Solar Square or others, and to exercise, establish or defend Solar Square’s legal rights.

f)We will not use User information for any purpose other than in connection with the Website. We will not rent, sell or share User information and will not disclose any of the User’s personally identifiable information to third parties, unless:

i)it is pursuant to obtaining the User’s permission;

ii)it is in connection with the services being rendered through the Website;

iii)it is to help investigate, prevent or take action regarding unlawful and illegal activities; suspected fraud, potential threat to the safety or security of any person, violations of Solar Square’s terms and conditions6 (“Terms of Use”), or as defence against legal claims;

iv)it is a case of special circumstances such as compliance with court orders, requests/order, notices from legal authorities or law enforcement agencies compel us to make such disclosure; and

v)it forms part of the information We share with advertisers on an aggregate basis.

COOKIES AND OTHER TOOLS

a)Solar Square collects information about You by using cookies, tracking pixels, web beacons and other technologies (collectively, “Tools”). We use this information to better understand, customize and improve User experience with Our websites, services and offerings as well as to manage Our advertising. This information can make Your use of Our products and services easier and more meaningful by allowing Solar Square to provide better service, customize sites based on consumer preferences, compile statistics, provide You with more relevant advertisements based on Your interests, analyze trends and otherwise administer and improve Our Solar Square Services. If We have collected Your Personal Information, We may associate this personal data with information gathered through the Tools.

b)Your web browser can be set to allow You to control whether You will accept cookies, reject cookies, or to notify You each time a cookie is sent to Your browser. If Your browser is set to reject cookies, websites that are cookie-enabled will not recognize You when You return to the website, and some website functionality may be lost. The Help section of Your browser may tell You how to prevent Your browser from accepting cookies.

c)In furtherance of clause 3 of this Privacy Policy, the following information is collected when visiting Our Website:

i)Log data: When You use Our Website, our servers automatically record information (“Log Data”), including information that Your browser sends whenever You visit Our Website. This log data may include Your Internet Protocol address, the address of the webpages You visited that had Solar Square features, browser type and settings, the date and time of Your request, how You used websites and cookie data.

ii)Cookie data: Depending on how You are accessing Solar Square services, we may use “cookies” (a small text file sent by Your computer each time You visit our sites, unique to Your Solar Square account or Your browser) or similar technologies, to record log data. When we use cookies, we may use “session” cookies (that last until You close Your browser) or “persistent” cookies (that last until You and/or Your browser delete them). For example, we may use cookies to remember Your personal preferences, such as sections of the Website that You visit frequently, Your user ID, or other settings so You do not have to set them up every time You visit, and we may use cookies to serve You relevant advertising tailored to Your interests. Some of the cookies we use are associated with Your Solar Square account (including Personal Information about You, such as the email address You gave us), and other cookies are not.

iii)Social media plugins and data. In addition, Our Website may use social media plugins (e.g., the Facebook "Like" button, '"Share to Twitter"' button) to enable You to easily share information with others. When You visit any of our online Solar Square services, the operator of the social plugin can place a cookie on Your computer, enabling that operator to recognize individuals who have previously visited our websites. If You are logged into the social media website (e.g., Facebook, Twitter, Google+) while browsing on our Solar Square services, the social plugins allow that social media website to receive information that You have visited our Solar Square services. The social plugins also allow the social media website to share information about Your activities on Our Website with other users of their social media website. Solar Square does not control any of the content from the social plugins. For more information about social plugins from other social media websites You should refer to those sites' privacy and data sharing statements.

If You choose to link Your social media or Google account to Solar Square, this allows Us to obtain information from those accounts (such as Your friends or contacts). The information We obtain from these services often depends on Your settings or the applicable provider's privacy policies, so please check these policies before granting Us access. You agree that We are not responsible for any acts or omissions by these social media service providers. If You give Us permission to access this information, We will use it for the purposes described in this Privacy Policy.

iv)Device information. In addition to log data, We may also collect information about the device You are using to access Our services, including what type of device it is, what operating system you are using, device settings, unique device identifiers and crash data. Whether We collect some or all of this information often depends on what type of device You are using and its settings. For example, different types of information are available depending on whether You are using a Mac or a PC, or an iPhone or an Android phone. To learn more about what information Your device may make available to us, please also check the policies of Your device manufacturer or software provider.

v)Interest Based Advertising. Solar Square hopes to deliver to You advertising for products and services You need or want. Solar Square uses common tracking tools, such as cookies, pixels, web beacons, and similar technologies, to automatically collect information about Users for purposes of enhancing their online experience and delivering more meaningful advertisements. Like many companies, Solar Square may also utilize third-party advertising vendors and other partners to collect this information.

Like most companies, We place advertisements where we think they will be most relevant to customers. One way We do so is by allowing network advertising companies with whom We work to place their own Tools when an individual visits Solar Square Website. This enables the network advertising company to recognize individuals who have previously visited Solar Square Website and to serve You ads based on Your web browsing activity, purchases, interests and/or other information—a practice commonly referred to as interest-based advertising (“IBA”) or online behavioral advertising (“OBA”). These advertising companies may also use these types of technologies to recognize You across the devices You use, such as a mobile phone or a laptop, and serve You ads on websites You visit and applications You use.

vi)Retargeting. One way in which we deliver more meaningful advertisements is through a common form of online advertising known as “retargeting” or “remarketing.” Retargeting works by serving ads on one site based on an individual’s online activities on a different, unrelated site. For example, if You look at Solar Square products on an Solar Square website, You may later see an advertisement for Solar Square products when You visit third-party sites. To do this, Solar Square or its advertising vendors may use a device ID, cookie, pixel, web beacon or similar technology placed by Solar Square or our third-party vendor when You visit Our Website or third-party websites or apps. The placing of these cookies or other technologies on Your device may enable You to be identified across multiple websites. You should consult the privacy policies of our vendors and other websites that You visit to understand how they collect and use Your data.

WHAT CHOICES DO I HAVE ABOUT HOW SOLAR SQUARE COLLECTS AND USES INFORMATION ABOUT ME?

a)Certain Solar Square Service may ask whether You wish to opt-out or opt into Our offers, promotions and additional services that may be of interest to You.

b)Marketing and other communication

1)You may receive notifications and emails from Us on the contact address/es registered with Us. If You no longer wish to receive such materials from Us on a going-forward basis, You may opt-out of receiving such materials. You may unsubscribe by following the instructions included in the notification or email. We will endeavour to comply with Your request as soon as reasonably practicable. It is hereby clarified that Solar Square shall retain such information as collected for registration for a period of one hundred and eighty days after any cancellation or withdrawal of the User’s registration, as the case may be.

2)However, even if You opt out of receiving such communications, We retain the right to send You non-marketing communications (such as security alerts, administrative messages and information about changes to Our Privacy Policy).

3)The User may correct or update any information online. In the event of loss of access details, the User may retrieve the same or receive new access details by sending an e-mail to: [email protected]

c)In furtherance of clause 3 of this Privacy Policy, the following information is collected when visiting Our Website:

c)Your privacy choices

You may have certain rights and choices regarding Our processing of Your personal data. Depending on Your jurisdiction, applicable law may entitle You to additional consumer rights, including the right (with certain limitations and exceptions) to:

i)Know the categories and/or specific pieces of Personal Information collected about You, including whether Your Personal Information is sold or disclosed, and with whom Your Personal Information was shared;

ii)Access a copy of the Personal Information We retain about You; and

iii)Request deletion of Your Personal Information.

a)If and when a User is desirous of having his/her name and other details removed from our records, immediately upon receiving the User’s written request to that effect We shall, subject to the terms hereof, remove and/delete all such information.

b)If the User no longer wishes to receive notifications about our services, The User may change his/her notification preferences by contacting us at [email protected] We reserve the right to close the User account if the User opts out of receiving certain crucial notices that are required by Us to perform the services through the Website.

d)We reserve the right to verify Your identity in connection with any requests regarding Personal Information to help ensure that We provide the information We maintain to the individuals to whom it pertains and allow only those individuals or their authorized representatives to exercise rights with respect to that information. If You are an authorized agent making a request on behalf of a consumer, We may require and request additional information to verify that You are authorized to make that request.

e)We reserve the right to deny Your request if We cannot verify Your identify. Where We deny Your request in whole or in part, We will endeavour to inform You of the denial and provide an explanation of our actions and the reasons for the denial.

f)We will not restrict or deny You access to our Solar Square Service because of choices and requests You make in connection with Your Personal Information. Please note, certain choices may affect our ability to deliver the Solar Square Service. For example, if You sign up to receive marketing communications by email, then ask Solar Square to delete all of Your information, We will be unable to send You marketing communications.

HOW DOES SOLAR SQUARE SECURE INFORMATION?

a)Solar Square will take reasonable steps to protect the security of Your information during transmission from Your computer and/ or mobile to our servers, as well as to protect Personal Information in Our possession from unauthorized access, disclosure, alteration or destruction however, the confidentiality of information transmitted over the Internet cannot be guaranteed. We urge You to exercise caution when transmitting Personal Information over the internet. Solar Square cannot guarantee that unauthorized third parties will not gain access to Your information; therefore, when submitting Personal Information to Our Website, You must weigh both the benefits and the risks.

b)We shall use generally accepted industry standards to protect the User information submitted to Us, both during transmission and upon receipt. However, please be advised that, no method of transmission over the internet, or method of electronic storage, is 100% secure. Therefore, even though we strive to use commercially acceptable means to protect user information, we cannot guarantee its absolute security and Your use of the Website is at Your sole risk and discretion. Solar Square Website may link to third-party websites that are not controlled by Solar Square or subject to Solar Square Privacy Policy. You should check the privacy policies of such third-party websites before submitting Personal Information.

WEBSITE IS NOT FOR MINOR

a)The Website should only be used or accessed by persons who are competent to enter into a legally binding contract under the Indian Contract, 1872. If You are a minor (i.e. You are under the age of 18 years), You may use the Website only with the involvement of Your parent or guardian. Solar Square does not knowingly collect or use any information from minors. We do not knowingly allow minors to order Our products, communicate with Us, or use any of Our online services. If You are a parent and become aware that Your child has provided Us with information, please contact us on the website or by e-mailing us at [email protected]

THIRD PARTY SITES

a)We may provide links to websites and other third-party content that is not owned or operated by Solar Square. The websites and third-party content to which we link may have separate privacy notices or policies. Solar Square is not responsible for the privacy practices of any entity that it does not own or control.

b)If You provide any Personal Information through a third-party site, Your interaction and Your Personal Information will be collected by, and controlled by the privacy policy of, that third party site. By using the services, You agree that we will not be liable for any damage or loss caused by Your use of or reliance on any content, advertising, products, or other materials on or available from these third party websites. We recommend that You familiarize yourself with the privacy policies and practices of any such third parties, which are not governed by this Privacy Policy.

HOW CAN I CONTACT SOLAR SQUARE?

a)If You have questions about Your information, please contact us by clicking on the “Contact Us” link on the website You are visiting or by e-mailing us at [email protected]

b)In all communications to Solar Square, please include the email address used for registration (if applicable), the website address or the specific Solar Square program to which You provided Personal Information and a detailed explanation of Your request. We will do our best to respond to all reasonable requests in a timely manner.

c)Grievance officer

i)In accordance with Information Technology Act 2000 and rules made there under, the name and contact details of our Grievance Officer are provided below

NAME: Shreya Mishra

ADDRESS: Stanford Tower, next to Shoppers Stop, S.V. Road, Andheri (W), Mumbai 400058

TEL: 9920377126

EMAIL: [email protected]

ii)The Grievance Officer shall acknowledge the complaint within twenty four hours and dispose off such complaint within a period of 15 (fifteen) days from the date of its receipt;

iii)Solar Square shall, within 24 (twenty-four) hours from the receipt of a complaint made by a User, in relation to any content which is prima facie in the nature of any material which exposes the private area of such individual, shows such individual in full or partial nudity or shows or depicts such individual in any sexual act or conduct, or is in the nature of impersonation in an electronic form, including artificially morphed images of such individual, take all reasonable and practicable measures to remove or disable access to such content which is hosted, stored, published or transmitted by it.

iv)The Solar Square shall implement a mechanism for the receipt of complaints under the above clause which may enable the individual or person to provide details, as may be necessary, in relation to such content or communication link.

HOW WILL I KNOW WHETHER SOLAR SQUARE HAS UPDATED THIS POLICY?

a)Solar Square shall periodically inform its Users, at least once every year, that in case of non-compliance with the Terms of Use or this Privacy Policy, it has the right to terminate the access or usage rights of the Users to the Website immediately or remove non-compliant information or both, as the case may be.

b)Solar Square periodically, and at least once in a year, inform the Users of its Terms of Use or this Privacy Policy or any change thereof, as the case may be.

FOOTNOTES

i) Please note that this policy is in accordance with the Information Technology Act, 2000 (“IT Act”) and rules thereunder. Rule 4(1) of the Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011 (“Data Protection Rules”) requires body corporates to have a privacy policy in place and published on its website. The consent for use/processing of the SPDI is usually obtained by having such person accept the terms of the body corporate’s privacy policy.

ii)Rule 3 of the Data Protection Rules defines sensitive personal data or information (“SPDI”) of a person to mean such personal information which consists of information relating to (i) password; (ii) financial information such as bank account or credit card or debit card or other payment instrument details; (iii) physical, physiological and mental health condition; (iv) sexual orientation; (v) medical records and history; (vi) biometric information. Thus, a person’s personal information, such as medical history and physiological conditions, are considered SPDI under the Data Protection Rules. When a body corporate (i.e. any company and includes a firm, sole proprietorship or other association of individuals engaged in commercial or professional activities, per Section 43A of the IT Act) collects, stores, transfers or processes such information, certain requirements under the Data Protection Rules are triggered.

iii)Rule 5(3) of the Data Protection Rules provides that while collecting information directly from the person concerned, the body corporate or any person on its behalf shall take such steps as are, in the circumstances, reasonable to ensure that the person concerned is having the knowledge of (a) the fact that the information is being collected; (b) the purpose for which the information is being collected; (c) the intended recipients of the information; and (d) the name and address of (i) the agency that is collecting the information; and (ii) the agency that will retain the information. Request the company to please confirm if this information is collected and its purpose.

iv)Rule 5(5) of the Data Protection Rules provides that the information collected shall be used for the purpose for which it has been collected.

v)Rule 7 of the Data Protection Rules provides that a body may transfer SPDI to any other body corporate or a person in India, or located in any other country, that ensures the same level of data protection that is adhered to by the body corporate as provided for under these rules. The transfer may be allowed only if it is necessary for the performance of the lawful contract between the body corporate and provider of information or where such person has consented to data transfer.

vi)Request the company to please include the hyperlink to the terms of use herein.

vii)This is in accordance with Rule 3 (1) (h) of the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021 (“Intermediary Rules”).

viii)There are requirements such as allowing users to opt-out (Rule 5(7) of the Data Protection Rules) or modify (Rule 5(7) of the Data Protection Rules) their SPDI if required.

xi)The Data Protection Rules also mandate the implementation of reasonable security practices and procedures in order to keep the SPDI secure. This requirement is fulfilled if the body corporate conforms to the international standard IS/ISO/IEC 27001 on “Information Technology – Security Techniques – Information Security Management System – Requirements” or similar standards that are approved and notified by the Central Government. As on date, no such standards have been notified.

x)There is a requirement to appoint a ‘Grievance Officer’ (Rule 5(9) of the Data Protection Rules), whose contact details are to be published on the website. Request Solar Square to please designate a Grievance Officer and include his name and contact details herein.

xi)This is in accordance with Rules 3 (1) (c) and 3 (1) (f) of the Intermediary Rules.