# Nudgebee Privacy Notice

Last Revised: (January 15, 2024)

Introduction

This Privacy Notice details how Nudgebee, Inc. and its affiliates (“us“, “we” or “Company“) process information of users of our website (each, “you” or “User“) collected through our website (the “Services“).

The details of the Company are as follows:

Nudgebee CloudXP Pvt Ltd

Teerth Tower D/704 SR NO,28/2 Nr. Raj Hotel, Pashan-Sus Road
Pune, Maharashtra 411021
India

Our data protection officer may be contacted by email at: privacy@nudgebee.com

We may revise this notice from time to time, in our sole discretion, and the most current version will always be posted on our website (as reflected in the “Last Revised” heading). We encourage you to visit this page regularly for any changes.

What information we collect

We may collect personal information about you as follows (“Personal Information“):

- Voluntary Information: We may collect information that you provide us voluntarily. For instance, when you communicate with us via the ‘contact us’ option on the Service, or by requesting to schedule a demo.

- Device Information: We may collect specific types of connection details and information with regard to your device, software or hardware that may identify you. Such information may include: browser type, device identifiers, and IP address.

Legal basis

The Company processes Personal Information as is necessary to carry out your request in connection with voluntary information you provide and for the Company’s legitimate business interest in connection with voluntary information and device information.

Cookies

We may use cookies and other technologies or methods of web and mobile analysis (e.g., Pixels, Beacons etc.) to gather, store, and track certain information related with your access to and activity through the Services. A “cookie” is a small piece of information that a website assign to your device while you are viewing a website. Cookies are very helpful and may be used for various different purposes. These purposes include, among other things, allowing you to navigate between pages efficiently, enabling automatic activation of certain features, remembering your preferences and making the interaction between you and the Services quicker, easier and smoother.

We use the following types of cookies:

- Session Cookies which are stored only temporarily during a browsing session in order to allow normal use of the system and are deleted from your device when the browser is closed.
- Persistent Cookies which are saved on your device for a fixed period and are not deleted when the browser is closed. Such cookies are used where we need to identify who you are for repeated visits (for instance, to allow us to store your preferences for the next visit to our page).

You may remove the cookies by following the instructions of your device preferences. However, if you choose to disable cookies, some features of the Services may not operate properly and your online experience may be limited.

How we use the information

We use the information in the manners described in this Privacy Policy. In addition to the purposes listed herein, the information we collect, which may include your Personal Information, is used for the following purposes:

- To provide our Users with the Services and to improve our Services;
- To provide Users with marketing material on our products and services;
- To investigate and resolve disputes in connection with your use of the Services;
- To detect and prevent fraudulent and illegal activity or any other type of activity that may jeopardize or negatively affect the integrity of the Services; and
- To investigate violations and enforce our policies, and as required by law, regulation or other governmental authority, or to comply with a subpoena or similar legal process or respond to a government request.

With whom we share the information and for what purpose

We do not rent or sell any Personal Information. We may share Personal Information with the following recipients:

- our third party vendors engaged in providing services in connection with the Services;
- our subsidiaries and affiliated companies;
- auditors or advisers of our business processes; and
- any potential purchasers or investors in the Company.

We may share Personal Information with our recipients for any of the following purposes: (i) storing or processing Personal Information on our behalf (e.g., cloud computing service providers); (ii) assisting us with our business operations (e.g., issuing credit cards and processing transactions); and (iii) performing research, technical diagnostics, personalization and analytics that will enable us to improve the Services.

We may also disclose Personal Information, or any information you submitted via the Services if we have a good faith belief that disclosure of such information is helpful or reasonably necessary to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce our policies (including our agreements), including investigations of potential violations thereof; (iii) investigate, detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues; (iv) establish or exercise our rights to defend against legal claims; (v) prevent harm to the rights, property or safety of us, our affiliates, our users, yourself or any third-party; (vi) for the purpose of collaborating with law enforcement agencies; and (vii) in case we find it necessary in order to enforce intellectual property or other legal rights.

International transfer

Since we operate globally, it may be necessary to transfer data, including Personal Information, to other countries than the country in which the information was collected. In these instances, we will transfer your data only based on standard data protection clauses adopted by the European Commission.

For how long we retain the information

We retain the information that we collect from our Users for as long as we are providing the Services to the applicable customer. Retention periods will be determined taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time. Under applicable regulations, we may keep records containing Users’ Personal Information, account opening documents, communications and anything else as required by applicable laws and regulations.

We may rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion.

Your privacy rights

Certain jurisdictions provide Users with certain statutory rights to their Personal Information. Subject to exemptions provided by law, and with proper identification, you may have the right to certain actions to your Personal Information such as:

- Right to verify your Personal Information (to access, delete, change or update any Personal Information relating to you. For example, if you believe that your Personal Information is incorrect, you may ask to have it corrected or deleted);
- Right to see what Personal Information about you we have;
- Right to request that we erase Personal Information about you (subject to any other legal obligation that may require us to keep that information);
- Right to restrict us from processing Personal Information pertaining to you (for example, you may request that we will stop using or sharing your Personal Information with third-parties); and
- Right to export Personal Information in a portable format.

If you wish to exercise any of these rights, contact us at: privacy@nudgebee.com. When handling your request, we will ask for additional information to confirm your identity (which may include Personal Information). However, please note that if you choose not to allow us to process your Personal Information, we may be prevented from providing our Services.

Please note that these rights are not absolute and may be subject to our own legitimate interests and regulatory requirements.

If you wish to raise a complaint on how we have handled your Personal Information, please contact us directly at: privacy@nudgebee.com

If you are not satisfied with our response or believe we are collecting or processing your Personal Information not in accordance with the laws, you can file a complaint to the applicable data protection authority.