Thank you for your interest in Greenathol. We welcome you, the user of our website www.greenathol.com (“User”, “you”, “your”). The website www.greenathol.com, (“Portal”), is owned and operated by Greenathol Ebiz Private Limited, a company incorporated under the provisions of the Companies Act, 2013 (hereinafter referred to as “Greenathol”).The Portal is a platform in the form of an electronic marketplace and an intermediary that: a) provides a platform for merchants/vendors/sellers (“Seller”) to advertise, exhibit, make available and offer to sell various products to other users/buyers/customers (“Buyer”); b) provides services to facilitate the engagement of Buyers and Sellers on the platform (“Services”).

This Privacy Policy (“Policy”) contains the manner and details in which Greenathol, and its affiliates, (collectively, “we”, “our”, “us”, “Portal”) collects and processes the data/information that you provide while availing our Services available on our Portal.

We collect and process certain data, in the course of providing our Services, through the Portal/other online features. We understand that the data that we may collect in the course of providing you Services, may contain information that is personal in nature. Since we value the privacy and security of your personal information as much as you do, we would like you to understand the exact nature of the personal data that we collect from you and how we will use it, store it and whom we may share it with.

Please read our End User License Agreement (EULA), available at www.greenathol.com. This Policy and the EULA are to be read in consonance and form part of a single understanding. Please refer to the age requirement clause provided under the EULA.

Any capitalized terms not defined herein, shall be interpreted to mean as defined in the EULA. The terms ‘Personal Information’ and ‘Sensitive Personal Information or Information’ shall have the meaning ascribed to it under the Information Technology Act, 2000, as amended, read with the rules made thereunder.

1. WHAT IS THE AIM OF THIS POLICY?

1.1. This Policy governs the manner in which Greenathol handles all personal data provided by you while using the Services.
This Policy is specifically aimed at achieving the following:
(a) Helping you understand the exact nature of the personal data/Personal Information that we collect;

(b) Explaining why we collect and what we do with the personal data personal data/Personal Information that you share with us.

(c) Explaining to you, your rights in relation to what personal data personal data/Personal Information we use and how we can use it.

1.2. This Policy may get updated from time to time pursuant to change in applicable law, scope of our Services or otherwise. The date at the top of the Policy shall reflect the date on which the Policy was last revised. In the event there are material changes to the Policy, we may send you an additional notice by way of a notification or adding a statement on the Services. While we will try to keep you apprised of material policy changes, it is not our duty to inform you of any and every change that is brought about in this Policy and you should visit our Portal to peruse the Policy from time to time.

1.3. Should you have any questions or concerns in relation to this Policy, you are always welcome to contact us by writing to us at nodalofficer@greenathol.com and we’ll endeavour to do our best to address them.

1.4. Although we aim to be completely transparent in the manner we choose to protect your privacy, you may not agree with the terms of this Policy. In that case, please remember it is your choice whether you wish to continue using our Services.

2. INFORMATION THAT WE COLLECT FROM YOU WHILE PROVIDING THE SERVICES

2.1. For effective and optimal utilisation of our Services, we collect the certain user data from our users. Such information/ data is requested at the time of you logging in to the Portal. The following type of user data is collected by us for our Services:

Your complete name	Date of Birth
Your device’s geographic location	Your contact details such as your email address, phone number;
Feedback about Greenathul Services	Business / firm-related details, including registration documents (where applicable), licenses, bank account details as well as information of officials / any other person designated as point of contact
Chat/interaction history with Greenathul (through chat bot, etc.)	KYC details
any other information

2.2. We would like to highlight that the aforementioned collection of data/ Personal Information/ Sensitive Personal Information by us is always done subject to the terms of the EULA. We keep the legitimate interests of our users in mind at all times and any data/ Personal Information/ Sensitive Personal Information, collection and processing is done in accordance with the applicable law. Availing our Services requires you to receive text messages or emails (from us or third-party service providers) with One-Time Passwords (OTPs) for the purposes of registering on the Portal.

3. INFORMATION THAT IS GENERATED BY YOU WHILE AVAILING THE SERVICES

We understand that you will be sharing information with other users during the use of our Services. We will retain any of your information shared with other users (such as messages, media, voice messages, etc.) (“Media”) for the purposes listed in this Policy and under applicable law. All such Media are stored locally on your Device. In the course of your usage of the Services on the Portal, you would allow us to access Media. We will be entitled to use such Media for the purpose of business development, creating product improvements and ensuring better Services to You.

4. TECHNICAL INFORMATION COLLECTED BY US THROUGH YOUR USE OF THE SERVICES

Certain type of technical information is automatically collected by us when you use the Portal. Such technical information includes information about type of Device (such as unique device ID, network connection type, provider, network and device performance, browser type, operating system, version of the website). All information is collected with your consent pursuant to your acceptance of the EULA.

5. HOW WE COLLECT AND SHARE YOUR PERSONAL INFORMATION

Your information may be collected by us through all or any of following methods:

(a) Accessing formats / documents / information / portals made available through the Portal;

(b) Your interaction through interactive communication tools such as chat bot; or

(c) Your enrolment under various schemes/offers on the Website.

6. WHY WE COLLECT AND PROCESS PERSONAL DATA/PERSONAL INFORMATION

(a) To allow us to create and administer your Account (as defined in our EULA) on the Portal and provide support services.

(b) To comply with legal obligations and requests by law enforcement.

(c) To establish, exercise, or defend legal claims.

(d) To conduct business planning and forecasting.

(e) Financial and business interest in marketing, promotional, and advertising purposes.

(f) To constantly enable us to diagnose and identify any technical advancements, troubleshoot issues.

(g) Improve our Services and develop new Services from time to time.

(h) To detect, investigate and prevent fraudulent transactions and other illegal activities and protect the rights and property of Greenathol.

7. USAGE OF THE DATA

While providing the Services, the personal data/Personal Information that you would share with us, its usage by us would inter alia include the following:

(a) to provide you with the Services and improve upon them.

(b) to answer your questions or requests for information or handle your complaints.

(c) to assess and evaluate your performance on the Portal and award ratings in accordance with the terms of the EULA.

(d) to ensure that facilities provided by us on the Services is presented in the most effective manner for you and for your computer or other Devices.

(e) to carry out our obligations arising from any agreements entered into between you and us.

(f) to notify you about updates or changes to Services, website and features and content.

(g) to understand your geographic location to help us identify groups of users by general geographic market (such as zip code, state or country).

(h) to serve our advertisements to you through third party platforms, such as Facebook, Twitter, Instagram, LinkedIn or Google, on other sites and apps or across your Devices, to the extent that you have provided consent for such uses under applicable law.

(i) to contact you to provide Services, information, receive feedback, and assist you with completion of transactions or other issues relating to the Services.

(j) we may also ask you to complete surveys that we use for research purposes, although you have the option to not respond to them.

8. TRACKING TECHNOLOGIES

8.1. Greenathol uses technologies such as cookies, beacons, tags, and scripts to enable a service to recognize your Device so you don't have to provide the same data several times during one task, to recognize that you may have already given a username and password so you don't need to do it for every web page requested, and to measure how people are using the Services.

8.2. As a principle, we do not use any personal data/Personal Information belonging to you or shared by you to serve any targeted advertisements to you. You may, however, receive advertisements/ notifications from us in relation to (i) our latest features on the Portal; or (ii) new features developed by us (including that of our affiliates); or (iii) suggestions from us to improve your user experience of Greenathol.

8.3. Please note that this does not opt you out of being served advertisements. You may continue to receive generic ads on these third-party platforms. You may also opt out of receiving advertisements across Devices by adjusting your ad preference in your relevant Device account, Google account or Apple account.

8.4. We use cloud storage to store content data and preferences. Various browsers may offer their own management tools for removing HTML5.

8.5. We use third party trackers to let us know when users have visited the Portal and used the Services by “clicking-through” our sponsored advertising or content hosted on third party platforms. The Services use third party analytics code to gather statistical data. Such an analytics code sets cookies to help us accurately estimate the number of visitors to the Services and the volume of usage of the Services. This is done to ensure that the Services are available when you want them and are fast. We will acquire consent from you in order to use such trackers to the extent required by applicable law.

9. COOKIE POLICY

INFORMATION COLLECTED USING COOKIES AND OTHER WEB TECHNOLOGIES

Like many website owners and operators, we, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through your use of our Services. We use Technologies that are essentially small data files placed in a Device that allow us to record certain pieces of information whenever you open or interact with our Services, and to recognize you across Devices. We use automated data collection tools such as cookies and Web Beacons to collect certain information.

COOKIES

A cookie is a small text file that is placed on the hard drive of your Device by a web page server. Cookies contain information that can later be read by a web server in the domain that issued the cookie to you. Web beacons, tags, and scripts may be used on the Portal or in emails to help us deliver cookies, count visits, understand usage and advertising campaign effectiveness, and determine whether an email has been opened and clicked on. We may receive reports based on the use of the Technologies by our service/ analytics providers on an individual and aggregated basis.

Why does Greenathol use cookies?

When you visit our Portal, we may place a number of cookies in your browser. These are first-party cookies, and they allow us to hold session information as you navigate within the site. For example, we use cookies on our Portal to improve your experience, and track and analyse usage, navigational, and other statistical information. You can control the use of cookies at the individual browser level. If you choose not to activate cookies or to later disable them, you can still visit our Portal, but your ability to use some features may become limited.

Cookies Greenathol uses

Many jurisdictions require or recommend that website operators disclose the type of cookies they use and occasionally get consent from Users before placing certain cookies.

We may use any of the following categories of cookies on our Portal as detailed below. Each cookie falls within one of these five categories:

Type of Cookies	Description
Essential Cookies	Essential cookies (first-party cookies) are sometimes called “strictly necessary” as without them we cannot provide many services that you need on a website. For example, essential cookies help remember your preferences as you move around the Portal.
Analytics Cookies	These cookies track information about website visits so we can make improvements and report our performance. These cookies collect information about how visitors use the website, which site the User came from, the number of each User’s visits, and how long a User stays on the website. We might also use analytics cookies to test new features to see how Users react to them.
Functionality or Preference Cookies	During your visit to the website, these cookies are used to remember information you have entered or choices you make such as your username, language, or region. They also store your preferences when personalizing the website to optimize your use of Portal, for example, your preferred language. These preferences are remembered through the use of the persistent cookies, and the next time you visit the website you won’t have to set them again.

10. SENSITIVE DATA

When you make an Account with us and use the Services, you have access to features that allow you to share information on the Portal. Some of the information you choose to provide us may be considered “special” or “sensitive” in certain jurisdictions. By choosing to post this information on the Portal, you consent to our processing of that information.

11. YOUR RIGHTS OVER THE PERSONAL DATA/PERSONAL INFORMATION THAT YOU SHARE WITH US

Your rights	Explanation
Right to confirmation and access	The right to be informed of, and request access to your personal data/Personal Information that is collected and processed by us.
Right to correction, rectification, and erasure	The right to request that any incomplete or inaccurate personal data/Personal Information provided be updated, corrected or erased.
Right to restrict	The right to request that we temporarily or permanently stop processing all or some part of the personal data/Personal Information that you provide to us.
Right to object	The right, at any time, to object to us from processing your personal data/Personal Information on grounds relating to your particular situation; The right to object to your personal data/Personal Information being processed for direct marketing purposes.
Right to data portability	The right to request a copy of your personal data/Personal Information in an electronic format and the right to have such personal data/Personal Information transferred or transmitted to a third-party service.
Right to not be subject to automated decision making	The right to not be subject to a decision based on automated decision making basis the personal data/Personal Information that you share with us. This includes profiling, in the event that such profiling would have a legal effect on you or a similar significant effect.

12. WHO DO WE SHARE YOUR DATA WITH?

From time to time and in accordance with applicable law, we may share your personal data/Personal Information with third-parties such as (i) service providers and advisors; (ii) fraud prevention vendors; (iii) payment processors; (iv) law enforcement authorities; (v) our affiliates; (vi) advertising partners; (vii) data analytical engines; (viii) social media partners of Greenathol (to the extent required); (ix) any entity who seeks to acquire or invest in Greenathol.

13. HOW DO WE PROTECT YOUR DATA?

We implement technical and organisational measures to help protect the security of your personal data/Personal Information including pseudonymisation, encryption, access, and retention policies to guard against unauthorised access and unnecessary retention of personal data/Personal Information in our systems.

Unfortunately, the transmission of information via the internet is not completely secure. Although we implement and maintain reasonable measures to protect your personal information, we cannot guarantee the security of the information transmitted through our Services, therefore we do not assume any responsibility for any transmission of your information which you do at your own risk.

14. RETENTION AND DELETION OF DATA

Retention of data: We collect and store your data for only as long as it is necessary for you to access your Account to use the Services on the Portal. In addition to this, we may also retain your data for legitimate and essential business purposes, including but not limited to making data-driven business decisions, complying with legal obligations and resolving any disputes that may arise from time to time.

Deletion of data: Unless legally allowed or legally mandated to store such data, upon receiving a request, we will delete all your personal data/Personal Information or anonymize it so that such data is no longer identifiable to you as an individual.

Finally, and this is important, you should understand that users who see the content you provide can always save it using any number of techniques: screenshots, in-app functionality, or any other image-capture technology. It is also possible, as with any digital information, that someone might be able to access messages forensically or find them in a Device’s temporary storage. Keep in mind that, while our systems are designed to carry out our deletion practices automatically, we cannot guarantee that deletion will occur within a specific timeframe. And we may need to suspend those deletion practices if we receive a valid legal process asking us to preserve content or if we receive reports of abuse or other EULA violations.

15. TRANSFER OF DATA

While Greenathol is based in India, we may transfer your data to third-parties that are located in countries other than India or to the country you are accessing the Services from. Therefore, your personal data/Personal Information may be subject to privacy laws that are different from your country. In such an instance, please note that Greenathol shall transfer your personal data/Personal Information in accordance with applicable privacy laws and your acceptance of the EULA and this Policy as well as use of our Services shall be considered as consent towards such transfer of personal data/Personal Information.

16. THIRD PARTY MICRO-APPLICATIONS AND LINKS

The Services offered on the Portal may contain links to external websites or include micro-applications belonging to or developed by third parties integrated with the Portal. We have no responsibility in relation to the accuracy, completeness and quality of the information contained within such third-party sites/ micro-applications and you agree that you access these sites at your own risk.

17. NON PERSONAL DATA

In the course of your usage of the Services on the Portal, you would allow us to collect non personal data which will include the usage data collected in relation to needs, preferences, interests, feedback, trends, demographics, onsite traffic metrics, social media engagement rate, conversion factors etc. of the users. Such data would not include any personal information which is non-anonymised. We will be entitled to use such data for the purpose of business development, creating product improvements and ensuring better Services to You.

18. CONTACT US

If you have any questions regarding this Policy, please feel free to reach out to us by contacting our Grievance Officer/Data Protection Officer Mr. Sachin Malusare by writing an email to nodalofficer@greenathol.com or by writing to us at the following address:

Entity Name: Greenathol Ebiz Private Limited

Registered Office Address: 4TH Floor, D.No. 16/612-1, Gandhi Road – 3, Madanapalle, Chittoor, Andhra Pradesh 517325

Branch Office Address: 607, Surya Kiran Building, Tolstoy Marg, Connaught Place, New Delhi – 11 0001

Grievance Officer: Mr. Sachin Malusare

Email Address: nodalofficer@greenathol.com

Phone Number: 011-46569187

Mobile Number: 9324422202