Maple Digital Technology International Private Limited including its affiliates (collectively, Maple or We or Our or Us ) is engaged in the business of sale of pre-owned smartphones and trade-in of Apple products. Through our online website available at the hyperlink reference herein ( Website ), we allow visitors ( Customer or you or your) to visit, access, and purchase a wide range of pre-owned Android and iOS smartphones, amongst other goods (Products ) and through our Maple stores ( Stores ), we allow Customer to trade-in your Apple smartphones [collectively ( Services )].

This Policy outlines our practices in relation to the Personal Information (defined below) that our Customers such as you, share with us and we collect from you, when you visit, access or transact from our Website and the manner in which we collect, use, hold, transfer and process the Personal Information provided. We are committed to protecting your Personal Information and respecting your privacy.

This Policy forms an integral part of the Terms and Conditions ( Terms and Conditions) which govern your access to the Services. Please note that this Policy is to be read in consonance with the Terms and Conditions, and unless specifically defined in this Policy.

For the purposes of this Policy, the following capitalized terms shall have the meaning assigned to them below:

Customer Information or Information shall mean information (as more fully detailed in Clause 3 hereunder) collected from Customers, when they access, or avail of our Services through the Website and/Stores.

Personal Information with reference to any natural person, is defined under the SPDI Rules to mean any information that relates to such person, which, either directly or indirectly, in combination with other information available or likely to be available to a body corporate, is capable of identifying that person.

Sensitive Personal Data or Information (SPDI) is defined under the SPDI Rules to mean Personal Information about a person relating to their:

Any information that is freely available or accessible in the public domain or information which can be obtained by a governmental agency under the Right to Information Act, 2005 (legislation which requires public authorities to disclose certain kinds of information) or any other law in force is excluded from the definition of SPDI.

Affiliates shall mean, with respect to Maple, any person that directly or indirectly through one or more intermediaries, controls or is controlled by or is under common control with either Maple, including entities that own and/or operate online Stores or provide a platform to access our Services online.

For various purposes as set out in this Policy, we may collect Personal Information (including information that qualifies as SPDI) from you, including, but not limited to:

We are entitled to and will rely upon the accuracy of the Information furnished by you, as well as the accuracy of other data automatically collected or obtained when you access our Stores or avail of the Services.

We collect your SPDI directly from you. All SPDI provided by you to us is voluntary.

Your acceptance of this Policy constitutes your express consent to us for inter alia collecting, storing, recording, processing, using, disclosing, sharing or transferring to our affiliates and/or any third parties, whether located in India or in any other country, the Personal Information (including SPDI) for the purposes specified in this Policy. You agree that the Personal Information (including SPDI) may be shared with our affiliates, and government agencies mandated under the law to obtain information for the purpose of verification of identity, or for prevention, detection, investigation including cyber incidents, prosecution, and punishment for offences.

You may choose to not provide us with any or all Information, but in the event that you do so, we may be unable to provide you with our Services and/or access to the Stores.

We use the Personal Information collected from you through Stores and otherwise for various purposes including, inter alia:

Where necessary for us to comply with our legal/ regulatory obligations;

Where necessary for us to provide Services and to operate our business, including but limited to:

For invoicing, technical notices, updates, security alerts and support and administrative messages;

For analyzing the use of our resources, troubleshooting problems and other internal business purposes and services, including without limitation, warehousing services, IT support services, and data analysis services;

For research, analyzing data, tracking trends, building algorithms, creating databases for rating systems, recommendations engines and related purposes;

To process and fulfil your request for Services, respond to any queries or grievances that you may have and to communicate information to you including in relation to your inquiries about the Services offered;

To comply with health and safety obligations, and maintain security at the Stores;

For non-targeting reasons such as frequency capping, compliance, billing, ad reporting or delivery, market research, determining footfall at the Stores;

For communicating with you about upcoming events, and news about products and Services by all modes of communication including but limited to message, SMS, WhatsApp messages (in consonance with the applicable privacy policies including this Policy), email, telecommunication services;

To communicate updates about Services, details about new features and Products available in the Websites, special offers, promotional announcements, consumer surveys, and to assist you with operational requests such as refunds and returns, if applicable. These communications may be by various methods, such as email, push notifications, WhatsApp, text messages.

We may process your Personal Information without your knowledge or consent where required by applicable law or regulation for the purposes of verification of identity or for prevention, detection, or investigation, including of cyber incidents, prosecution for offences;

Protect, investigate, and deter against fraudulent, unauthorized, or illegal activity;

Protecting you, other Customers, employees and our business against, and preventing, harm of any kind, financial loss and other legal or information security risks;

In connection with loyalty programs owned and operated by us or by other Affiliates; and

Creating a customer profile based on data provided by you on using the Website;

Designing customized marketing and promotional campaigns for you based on your customer profile;

To create curated product-based collections such as top-rated or best-selling products basis your product reviews and purchase history;

To onboard you on one or more group-wide platforms or super-apps;

For enabling transactions across group entities;

To share or transfer your Personal Information to an Affiliate, our vendors or service providers or other Third Parties, for the purposes specified in this Policy including to, (i) perform any Services or processing on our behalf; (ii) market/ promote other services and products generally offered by us or Affiliates or any other platforms; (iii) give effect to any services that we avail from our Affiliates or vendors.

We may collect your Personal Information in several ways from your use of our Services. For instance:

when you register with us to receive our products and/or services.

when you conduct a transaction or attempt a transaction on our website/app or Platform.

When you, complete surveys conducted by or for us.

when you elect to receive any communications (including promotional offers) from us.

from the information gathered by your visit to our website.

We request you not to provide Personal Information about any other person unless you are authorized or required to do so under a contractual obligation or applicable law.

Subject to applicable law, we (or any person on our behalf) may at our sole discretion, transfer your Personal Information to any other body corporate (as defined under the IT Act) or a person in India, or located in any country. When your Personal Information is transferred, we will require that the transferee entity complies with the terms of this Policy and applicable data privacy laws.

You also acknowledge that, due to the interconnected nature of our business operations, we (Maple and Affiliates including any successor entity) may require to share your Personal Information amongst each other, as required, for the purposes mentioned in this Policy, including for marketing and promotional communications from our Affiliates.

Personal Information held by us may be disclosed, inter alia, to the following third parties for the purposes specified in this Policy or our other policies or as required or permitted under applicable law:

Protecting Maple: We may share Personal Information when we believe that disclosure is reasonably necessary (a) to comply with a law, regulation or compulsory legal request; (b) to protect us or an Affiliate’s intellectual property rights; (c) to protect us against harm or financial loss; (d) when we believe disclosure is necessary to protect individuals’ vital interests; (e) in connection with an investigation of suspected or actual fraudulent or illegal activity, and (f) to ensure safety of the aviation ecosystem, airport premises and/or connected operations. This may include exchanging information with other companies and organizations for fraud protection, risk management and dispute resolution.

Third Parties: We may also share your Personal Information with other third parties where you request or authorize us to do so.

We may transfer your Personal Information to recipients in India, where we are headquartered, and other countries. These countries may not have the same level of data protection laws as the country in which you initially provided the information. If we transfer your Personal Information to other countries, we will protect that information as described in this Policy, as disclosed to you at the time of data collection or as described in our program-specific privacy policy.

We will use technical and organizational measures to safeguard your Personal Information, including measures to deal with any suspected data breach. We store your Personal Information on secure servers. If you suspect any misuse or loss or unauthorized access to your Personal Information, please let us know immediately by contacting us through e-mail at grievances@mapledti.com .

We retain your Personal Information for as long as necessary for the purposes laid out in this Policy, unless a longer period is permitted or necessary under law. Once the purpose is met or the applicable retention period expires, your Personal Information will be deleted or anonymized in accordance with our data retention policies.

However, in compliance with legal and regulatory requirements, certain data may be retained on backup or archival media for limited purposes such as audits, legal obligations, tax or regulatory compliance. This data will be securely handled and stored, and will only be used for these specific lawful purposes.

You may have various rights in relation to the Personal Information that we hold about you. To get in touch with us about any of your rights under Data Protection Laws, please use the contact details set out in this Policy. We will seek to deal with your request without undue delay, and in any event, within any time limits provided for in Data Protection Laws (subject to any extensions to which we are lawfully entitled). Please note that we may keep a record of your communications to help us resolve any issues which you raise. Where we are legally permitted to do so, we may refuse your request.

You may be entitled to the following rights in relation to your Personal Information:

To get in touch with us about these rights, promotional communications or to request to review, update, or delete your Personal Information or to otherwise reach us, please submit a request by e-mailing us atgrievances@mapledti.com. We will respond to your request within 30 days.

If any court or competent authority finds that any provision of this Policy (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this Policy will not be affected.

To the extent you avail our Services through applications or websites of third parties, you acknowledge and agree that we are not responsible for any collection or disclosure of your Personal Information by them. Please note that such applications or websites may have their own privacy policies governing the collection, storage, retention and disclosure of your information that you may be subject to. We recommend that you exercise reasonable diligence, as you would in traditional offline channels and practice judgment and common sense before committing to any transaction or exchange of information, including but not limited to reviewing the third-party website or application’s privacy policy.

We reserve the right to change, modify, add or delete portions of this Policy, at our sole discretion, at any time. While we will periodically inform you of any material changes to the Policy, you are responsible to check for updates regularly to make note of any changes. If we make any changes to this Policy, we will change the “Last Updated” date above to reflect the date of the most recent update.

You agree that your continued use of the Services means that you accept and agree to the changes in the Policy.

In order to address any discrepancies and/or grievances that you may have in relation to this Policy there is a designated “Grievance Redressal Officer”, whose contact details are as below:

Name: Legal Team

Email: grievances@mapledti.com

Disclaimer: We cannot ensure that your Information will never be disclosed in ways not described in this Policy. Therefore, although we are committed to protecting your privacy, we do not promise, and you should not expect, that your Information or private communications will always remain private. As a Customer of our Services, you understand and agree that you assume all responsibility and risk for your use of the Services, the internet generally, and the information you post or access and for your conduct on and off the premises of our Stores.

Governing Law and Jurisdiction: This Policy shall be governed by the laws of India as applicable between residents of India without regard to any principles of conflict of laws. Any and all disputes arising hereunder shall be subject to the exclusive jurisdiction of the courts at Mumbai

By consenting to this Policy, you hereby provide your express and explicit consent to the aforesaid collection, transmission, publication, storage, retention, and any other usage of Personal Information (including SPDI) by Maple as per this Policy and as may be notified to you, from time to time. In case you do not consent to any of the usage, transmission, and/or publication of your Personal Information as detailed hereinabove, you may opt to not accept this Policy.

In the event of any changes in applicable Data Protection Laws in India, including the implementation of the Digital Personal Data Protection Act, 2023 and/or rules thereunder, you expressly consent to the Maple’s continued use, storage, collection and disclosure of your Personal Information. You agree to provide such additional consents and approvals, in the format and manner requested by us. If you choose not to provide such additional consents and approvals, we may be need to modify the terms of our Services or discontinue providing them to you.