Privacy Policy

Simplify Infotech Private Limited (“Company” or “We” or “Us” or “Our” and their connotations) respects Your privacy and We are committed to protecting the privacy and security of Your personal information, including protected health information (PHI) and sensitive data through this Privacy Policy and in compliance with all applicable laws and regulations.

If You have any questions or concerns about this privacy notice, or with regards to Your personal information, please contact Us at support@koinx.com .

We have created this Privacy Policy to inform You of Our policies regarding the collection, use, and disclosure of personal information (also referred to here as “Personal Information”) as well as the rights and choices You may have associated with that information. For any requests or inquiries in relation to this Privacy Policy, please see the Contact Us section below.

This policy describes what information We collect when You use Our Platform sites, services, mobile applications, products, and content (“Services”). It also provides information about how We store, transfer, use, and delete that information, and what choices You have with respect to the information.

The information on this page applies to the Personal Information We collect about Your interactions, use, and experience with Our Services, including accounting, bookkeeping, reporting, analytics, cryptocurrency transaction management, and other  networks, embeddable widgets, downloadable software (including any development kits and any associated tools, also known as SDKs), mobile applications, beta products, and other services that We provide, through Our website at https://www.koinx.com (including through integrations with third-party software, integrations or applications) (Our “Website”) and/or Our app on iOS or Android (Our “App” and together with Website, hereinafter referred to as “Platform”).

About Our Privacy Policy

The Platform gathers certain information with prior consent from the following: the users utilising the Platform as described in the Terms and any visitors of the Platform (collectively “Users” or “You” and their connotations).

This Privacy Policy (‘‘Privacy Policy’’) is meant to help the Users understand what information We collect, why We collect it, what information We disclose and how the Users can update, manage, export, and delete their information. It shall be read in compliance with the applicable laws in the places We operate.

Your Consent:

The Users will be deemed to have read, understood and agreed to the terms as provided in this Privacy Policy once they provide their consent or continue using the Platform after this Privacy Policy is presented to them. By granting their assent to this Privacy Policy, Users provide consent to such use, collection and disclosure of Personal Information as prescribed in this Privacy Policy.

We reserve the right to update or change Our Privacy Policy at any time and the Users should check this Privacy Policy periodically. To inform You of any material change as regards the manner in which We collect or process Your information, including changes to this Privacy Policy, Our updated Privacy Policy will be posted by Us on the Platform, indicating the date on which the Privacy Policy was updated at the top of the Privacy Policy. We will endeavour to notify You for any such material changes, on a best efforts’ basis. 

Scope of this Privacy Policy

This Privacy Policy applies to all Company websites that link to it. It also applies to the products and services provided by Us through these websites, Our mobile applications, and applications posted by Us on Our online marketplace and in other third-party online marketplaces.

This policy applies to personal information and content We collect:

1. Based on the use of the Services.
2. In communications email, text, and other electronic messages between You and Services via web forms or chat.
3. In communications submitted to the Services using web forms and the social media/comment features on the Services.
4. When You interact with Our advertising and applications on third-party websites and services if those applications or advertising include links to this policy.

It does not apply to information collected by:

1. Us offline or through any other means, including on any other website or apps operated by Us or any third party. You should review the terms and policies of those websites or apps before clicking on any links; and
2. any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Services.

How to use the Services?

The User may access or sign-up on the Platform to avail the Services provided by the Company. While accessing or signing-up, You are required to provide Us with certain information about Yourself.

Information that You provide Us

All information collected by the Company is with the Users’ consent. The Company is however free to use, collect, and disclose information of the Users which is in the public domain.

When Users use or sign-up to the Platform, the Users may provide the Company with certain information including Personal Information voluntarily, specific to the nature of the service being availed on the Platform, and/or certain information may be collected by the Company depending solely on the usage of the Platform.

The Users hereby consent to the collection of such information by the Company.

Information collected by the Company shall include but not be limited to the following:

• Account Information - Users that choose to register on the Platform, will have to provide a valid email address or phone number. The User can also choose to enter a display name and/or add a profile picture that will be used to represent them in conversations. If You as a User choose to sign up with an external authentication service, e.g. Google Sign-In, We will fetch and store email address, name and profile image URL from this service. Additionally, if You upload or provide financial transaction data, including data from cryptocurrency wallets and/or bank accounts via APIs on the Platform, We will collect and store this information in accordance with this Privacy Policy and applicable data protection laws.

• Transaction Information - Customers that choose to purchase a paid version of the Services or transact via the Platform, may be required to provide billing details such as credit card information, banking information, billing email, location at the time of transaction, and/or a billing address. This information is collected by Our payment processing partners, including debt collectors, as necessary for processing transactions and availing the Services. While We do not store or process payment information directly, We may facilitate its transmission to Our payment processors in compliance with applicable data protection laws and this Privacy Policy.

• Event registrations and other form submissions - We record information that You submit when You (i) register for any event, including webinars or seminars, (ii) subscribe to Our newsletter or any other mailing list, (iii) submit a form in order to download any product, whitepaper, or other materials, (iv) participate in contests or respond to surveys, (v) submit a form to request customer support, get a quote or to contact Us for any other purpose, or (vi) register for any or all of the Services offered on the Platform.

• Interactions with Us - We may record, analyze and use Your interactions with us, including email, telephone, and chat conversations with Our sales and customer support professionals, for improving Our interactions with You and other customers.

Information collected automatically

• Information from browsers, devices and servers - When You as a User interact with the Services, We collect and process metadata to provide additional context about the way the Service is being used. We collect information that web browsers, mobile devices and servers make available, such as the internet protocol address, browser type, language preference, time zone, referring URL, date and time of access, operating system, mobile device manufacturer and mobile network information. We include these in Our log files to understand more about visitors to Our websites.

• Information from cookies and tracking technologies - We use temporary and permanent cookies to identify Users of Our services and to enhance User experience, in accordance with our cookie policy (“Cookie Policy”) displayed at https://koinx.com/cookie-policy. Without prejudice to anything to the contrary contained in the Cookie Policy, we use cookies for improving performance, User experiences across our Platform and Services, and for authenticating and securing Users on the Platform. This may require us to use cookies for purposes which may include, without limitation, functionality, performance, advertising, and for enabling access to the Platform and Services, through strictly necessary cookies. For more information please refer to Our Cookie Policy, as updated from time to time.

• Information from application logs and mobile analytics - We collect information about Your use of Our products, services and mobile applications from application logs and in-house usage analytics tools, and use it to understand how Your use and needs can improve Our products. This information includes clicks, scrolls, features accessed, access time and frequency, errors generated, performance data, IP addresses, storage utilized, User settings and configurations, and devices used to access and their locations.

Information that We collect from third parties

• Signups using federated authentication service providers - You can log in to the Platform and/or Services using supported federated authentication service providers such as Facebook, Twitter, LinkedIn, Microsoft and Google. These services will authenticate Your identity and give You the option to share certain personal information with Us, such as Your name and email address.

• Referrals - If someone has referred any of Our products or services to You through any of Our referral programs, that person may have provided Us Your name, email address and other personal information. You may contact Us at support@koinx.com to request that We remove Your information from Our database. If You provide Us information about another person, or if another person gives Us Your information, We will only use that information for the specific reason for which it was provided to us.

• Information from social media sites and other publicly available sources - When You provide feedback or reviews about Our products, interact, or engage with Us on marketplaces, review sites or social media sites such as Facebook, Twitter, LinkedIn and Instagram through posts, comments, questions and other interactions, We may collect such publicly available information, including profile information, to allow Us to connect with You, improve Our products, better understand User reactions and issues, or to reproduce and publish Your feedback on Our websites. We must tell You that once collected, this information may remain with Us even if You delete it from these sites. We may also add and update information about You, from other publicly available sources.

Third parties may collect certain information by way of cookies, through Our Platform. Such information may be collected, inter alia, for the following purposes: (a) advertising; (b) marketing; and (c) data analytics.

You also provide information to Us through Our Services, including Your reviews, photographs, videos, comments, lists, followers, the Users You follow and other information in Your account profile.

If the Company has reasons to suspect that the information provided by any User is misleading, inaccurate, obsolete or incomplete, the Company reserves the right to refuse provision of the Services to the User, at its sole discretion without incurring any liability to the User or any third-party. We will not be liable for reliance on or consequences of any misleading, inaccurate, obsolete or incomplete information.

When You sign in to Your account on the Platform, You consent to Our collection, storage, and use, in accordance with this Privacy Policy.

How and Why do We use Your Personal Information?

1. We collect Personal Information only necessary for the following purposes:

• To communicate with You (such as through email) about products that You have downloaded and services that You have signed up for, changes to this Privacy Policy, changes to the Terms of Service, or important notices;
• To keep You posted on new products and services, upcoming events, offers, promotions and other information that We think will be of interest to You;
• To ask You to participate in surveys, or to solicit feedback on Our products and services;
• To comply with legal and regulatory requirements, including the GDPR, DPDP Act, HIPAA and SOC II;
• To set up and maintain Your account, and to do all other things required for providing Our services, such as enabling collaboration, providing website and mail hosting, and backing up and restoring Your data;
• To understand how Users use Our products and services, to monitor and prevent problems, and to improve Our products and services;
• To provide customer support, and to analyze and improve Our interactions with customers;
• To detect and prevent fraudulent transactions and other illegal activities, to report spam, and to protect the rights and interests of the Company, its Users, third parties and the public;
• To update, expand and analyze Our records, identify new customers, and provide products and services that may be of interest to You;
• To analyze trends, administer Our websites, and track visits or navigation on Our websites to understand what visitors are looking for and to better help them;
• To monitor and improve marketing campaigns and make suggestions relevant to the User;
  
• To improve and enable You to avail Our Services, increasing efficiency of existing features, and develop new features;
• To assess Your application credentials and potentially provide You with a job in case You applied for a job;
• To effectively deliver Our services to You, We use Your Personal Information and other information to engage in important supporting activities such as:

-billing and collections, including maintenance of records in the event of a subsequent billing dispute;

-preventing fraud, violations of Our acceptable use policies, and unlawful activities;

-troubleshooting, quality control, and analytics; and

-monitoring the performance of Our systems and platform.

• To notify You of necessary information related to the Platform and Services and Your account on the Platform from time to time;        

• To maintain records and provide You with an efficient, safe and customized experience while using the Platform;

• To analyse overall trends to help Us improve the Platform and Services, including displaying detailed analytics to Users;

• To verify Your identity and prevent fraud or other unauthorized or illegal activity;

• As We believe to be necessary or appropriate, and only as permitted under applicable law (a) to comply with legal process; (b) to respond to requests from public and government authorities, including public and government authorities outside Your country of residence; (c) to protect Our operations, including in connection with investigating security incidents; or (d) to protect Our rights, privacy, safety or property; (e) to transfer the data and the rights associated therewith to a third party as part of reorganization or a sale of the assets of any division of the Company or the entire Company itself;

• We may use Personal Information, including sensitive information of the Users to create non-identifiable “aggregate data” for the purposes of marketing, research and analysis;

• If You provide to Us any ideas, proposals, suggestions, recommendations or other materials (“Feedback”)

• And in any other way consistent with this Privacy Policy and to support the above activities.

2. We may combine the Personal Information We collect or remove pieces of Personal Information to limit or prevent identification of a particular User or device to help with the purpose of research and marketing. This Privacy Policy does not apply to Our use of such aggregated or de-identified information.

3. We normally collect or use Personal Information from You or others only where We have Your consent to do so, where We need the personal information to perform a contract with You, or where the processing is in Our legitimate interests and not overridden by Your data protection interest or fundamental rights and freedom. In some cases, We may have legal obligation to collect or retain personal information or may need the personal information to protect Your vital interests or those of another person. If European data protection law applies and We act as a controller, Our lawful basis for collecting and using the personal information described in this Privacy Policy will depend on the personal information concerned and the specific context in which We collect or use it.

4. We keep Your personal information for no longer than necessary for the purpose for which it is processed. The length of time for which We retain personal information depends upon the purpose for which We collect and use it and/or as required to comply with the applicable laws.

What are Your Choices?

• Platform and/ or Services - Continued use of the Service will constitute the Users’ acknowledgment of and their consent to abide and be bound by the modified Privacy Policy. Users have the right to opt out of the Platform and/ or Services at any moment. In addition, the Users can, by sending an email to support@koinx.com, inquire whether the Company is in possession of their Personal Information, and they may also require the Company to delete and destroy all such information, upon request.

• Disable cookies - You can disable browser cookies before visiting Our websites. However, if You do so, You may not be able to use certain features of the websites properly.

• Marketing Opt-out Preferences - You can opt out of marketing messages by writing to Us at support@koinx.com. Please note that We may send You one message to confirm You want to opt out. If You are a registered User of Our Services, We may continue to send transactional or relationship messages after You opt out of marketing messages.

• Account Deletion – You can close Your account and request for deletion of the data.

How do We share Your Personal Information with third-parties?

• With Service Providers - We may share Your Personal Information with Service Providers to provide single sign-on services, and to provide, monitor and analyze the use of Our Services. These service providers are authorized to use Your personal information only as necessary to provide these services to us.

• For business transfers - We may share or transfer Your Personal Information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.

• With Affiliates - We may share Your Personal Information with Our Affiliates, in which case We will require those Affiliates to honor this Privacy Policy. Those Affiliates may collect additional Personal Information or PHI during Your use of their products and services, if You elect to use those products and services. Affiliates include Our parent company and any subsidiaries, joint venture partners or other companies that We control or that are under common control with us.

• With business partners - If you opt-in to any features or services which are provided by or through Our third-party service providers, referral partners, or other business partners, and subject to your consent, We may share Your Personal Information with such business partners for the purpose of providing these features or services.

• With law enforcement -– The Company may be requested to disclose information to competent law enforcement officials or authorities, if We receive an order, judgment, directions, or a similar instruction as per applicable laws. However, We will undertake best efforts to limit the extent of any such disclosure to the information which directly and materially relates to the order, judgment, directions, or instruction, and will notify You of any such disclosure, unless We are specifically restricted to do so under applicable laws.

• Publicly, but only with Your permission - We may share Your Personal Information publicly with Your permission. For example, with Your permission, We may publicly post Your photograph, Your name, professional titles, and comments on the “Reviews” section of Our websites.

• Company discretion - The Company may also disclose Your Personal Information in the good faith belief that such action is necessary to:

• Comply with a legal obligation
• Protect and defend the rights or property of the Company
• Prevent or investigate possible wrongdoing in connection with the Service
• Protect the personal safety of Users of the Services or the public
• Protect against legal liability

Please note that We do not sell or trade Your Personal Information to third parties.

Do We use Cookies?

Yes. Cookies are small files that a site or its service provider transfers to Your computer’s hard drive through Your Web browser, only if You allow, that enables the sites or service providers’ systems to recognize Your browser and capture and remember certain information.

We use cookies to understand and save Your preferences for future visits, to advertise to You on other sites, and to compile aggregate data about site traffic and site interaction so that We can offer better site experiences and tools in the future.

You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but You can usually modify Your browser setting to decline cookies. If You delete or decline cookies, some features of the Platform may not work or may not work as designed. For more information on cookies and how to disable them, You can consult the information provided by the Interactive Advertising Bureau at www.allaboutcookies.org.

However, if You choose to disable cookies, You may be unable to access certain parts of Our Platform. A banner asking You to accept Our cookies policy will be displayed upon the first visit to Our Platform (or the first visit after You delete Your cookies). Unless You have adjusted Your browser setting so that it will refuse cookies and/or You have not accepted Our cookies policy, Our system will issue cookies when You log on to Our Platform.

How long do We retain Your Personal Information?

We retain Your personal information for as long as it is required for the purposes stated in this Privacy Policy. Sometimes, We may retain Your information for longer periods as permitted or required by law, such as to maintain suppression lists, prevent abuse, if required in connection with a legal claim or proceeding, to enforce Our agreements, for tax, accounting, or to comply with other legal obligations. When We no longer have a legitimate need to process Your information, We will delete or anonymize Your information from Our active databases. We will also securely store the information and isolate it from further processing on backup discs until deletion is possible.

We store Your account information for as long as Your account is active and a reasonable period thereafter in case You decide to re-activate the services, or for so long as We need to retain it for legitimate purposes, such as to collect debts, or comply with Our legal obligations, resolve disputes, enforce Our agreements, support business operations, and continue to develop and improve Our services.

While You’re an active customer, We retain the communications usage information generated by Your use of the services until the information is no longer necessary to provide Our services, and for a reasonable time thereafter as necessary to comply with Our legal obligations, resolve disputes, enforce Our agreements, support business operations, and continue to develop and improve Our services.

We collect device-specific information from You when You access the Platform, or You have installed Our software on Your device. If You do not revoke Our access to this information via the privacy settings on Your device, We will retain this information for as long as Your account is active.

Notwithstanding with the above and the fact that We will generally store Your Personal Information until it is no longer necessary to provide the services or otherwise relevant for the purposes for which it was collected, please note that We may also retain Your information for a longer period of time to defend and/or protect Our legal or business interests during the applicable statute of limitation period or as otherwise required by law, court order, or other applicable regulation.

How We protect Your Personal Information?

The security of Personal Information is important and We have implemented reasonably sufficient means to protect the same, including access controls and data encryption. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure and We cannot guarantee its absolute security. We have implemented best industry practices and security policies, rules and technical measures to protect the data, including Personal Information, that is under the Company’s control from unauthorised access, improper use or disclosure, unauthorised modification and unlawful destruction or accidental loss. However, for any data loss or theft due to unauthorized access to the Users’ electronic devices through which the Users avail the Services, We shall not be held liable for any loss whatsoever incurred by the Users or any third-party.

When payment information is being transmitted on or through the Platform, it will be protected by encryption technology of a third-party payment services providers, including payment gateways. You agree, acknowledge and consent to such sharing of Your information with third party service providers to process payments and manage Your payment-related information. The Company does guarantee that the transmissions of Your payment-related information or other information will always be secure.

Do We transfer Your Personal Information internationally?

All or any information processed by the Company may be transferred, processed, and stored anywhere in the world, including, but not limited to, countries of the European Union, the United Kingdom, the United States, India, or such other countries, which may have different data protection laws from the laws in the country of Your residence. We undertake to safeguard Your information in accordance with the applicable laws.

In the event We transfer Your Personal Information to countries outside the European Economic Area, We endeavour to put in place necessary safeguards to ensure that the said data transfer shall comply with the applicable laws and regulations. If You are a resident of the European Union and/or subject to the European General Data Protection Regulation (Regulation (EU) 2016/679), please reach out to Us at Our contact details below with the specifics of Your request/s, and We will ensure that Your data collected, stored, and/or used by Us (if any) and their privacy are protected in accordance with the laws and regulations applicable in Your jurisdiction. We would like to make sure that You are fully aware of Your data protection rights, which may include the right to access, rectification, erasure, restrict or object to processing, data portability, etc. If You make a request under this head, We will endeavour to respond within 45 days.

Disclaimers:

The Platform may contain links to other websites. Please note that when Users click on one of these links, they are entering another website over which We have no control and for which We will bear no responsibility. Often these websites require the User to enter their Personal Information. We encourage and recommend the Users to read the privacy policies of all such websites as their policies may differ from Our Privacy Policy. Users agree that We shall not be liable for any breach of Your privacy of Personal Information or loss incurred by their use of such websites or services. The inclusions or exclusions are not suggestive of any endorsement by the Company of the website or contents of the website. The Users may visit any third-party website linked to the Platform at their risk.

You also may provide information (such as ratings, reviews, tips, photos, comments, likes, bookmarks, friends, lists, etc.) to be published or displayed on publicly accessible areas of Our Services, or transmitted to Us or third-parties (collectively, "Contributions"). Your Contributions are posted on and transmitted to others at Your own risk. Although We limit access to certain pages, You may set certain privacy settings for such information by logging into Your account profile. Additionally, We cannot control the actions of other Users of Our Services with whom You may choose to share Your Contributions. Therefore, We cannot and do not guarantee that Your Contributions will not be viewed by unauthorized persons. We may display this information on the Services, share it with businesses, and further distribute it to a wider audience through third party sites and services. You should be careful about revealing any sensitive details about Yourself in such postings.

What are Your Rights?

As a User, the Company grants You complete control of the information submitted by You. The rights pertaining thereto are enumerated below:

• The right to access the information We have on the User. You have a right to request that We provide You with a copy of Your Personal Information that We hold, and You have the right to be informed of: (a) a summary of Your Personal Information which is being processed us; (b) the processing activities undertaken by Us with respect to Your Personal Information; (c) the data controller’s identity (i.e., information about persons who control the manner in which Your Personal Information is processed); and (d) the entities or categories of entities to whom Your Personal Information may be transferred.

• The right of rectification. You have a right to rectify in the profile section of the Platform or request that We rectify inaccurate Personal Information, complete the incomplete Personal Information or update the Personal Information. We may seek to verify the accuracy of the Personal Information before rectifying it.

• The right to erasure. You can also request that We erase Your Personal Information in limited circumstances where:

1. it is no longer needed for the purposes for which it was collected; or
2. You have withdrawn Your consent (where the data processing was based on consent); or
3. following a successful right to object (see right to object); or
4. it has been processed unlawfully; or
5. to comply with any legal obligations of the Company.

We are not required to comply with Your request to erase Personal Information if the processing of Your Personal Information is necessary (a) for compliance with a legal obligation; (b) or for the establishment, exercise or defence of legal claims.

• The right to withdraw consent. Users have the right to withdraw their consent at any time, when consent is given pertaining to Personal Information.

• The right to lodge a complaint with the local supervisory authority. You have a right to lodge a complaint with the Data Protection Board of India if You have concerns about how We are processing Your Personal Information. We ask that You please attempt to resolve any issues with Us first, although You have a right to contact Your supervisory authority at any time.

• The right to be informed. Users have the right to be informed about third parties with which their Personal Information has been shared.

• The right to unsubscribe. You may always opt-out of receiving future e-mail messages and newsletters from the Company. We provide You with the opportunity to opt-out of receiving communications from Us by choosing the appropriate options for unsubscribing under Your emails. To opt-out, You can also send Us a message at support@koinx.com. Please note, however, that You generally cannot opt-out of service-related announcements, e.g., if the Service is temporarily suspended or if delivery of a product or service is delayed.

• The right to nominate. Users shall have the right to nominate any other individual, who shall, in the event of death or incapacity of such User, exercise the rights provided above.

We may ask You for additional information to confirm Your identity and for security purposes, before disclosing the Personal Information requested to You. We reserve the right to charge a fee, where permitted by law, for instance, if Your request is manifestly unfounded or excessive.

You can exercise Your rights by contacting Us at support@koinx.com. Subject to legal and other permissible considerations, We will make every reasonable effort to honour Your request promptly or inform You if We require further information in order to fulfil Your request.

We may not always be able to fully address Your request, for example, if it would impact the duty of confidentiality We owe to other Users, or if We are legally entitled to deal with the request in a different way.

Legal Age and Capacity for Consent in Your Jurisdiction

Our Services are intended for adults, but can also be used by minors (below the legal age of consent in their respective jurisdiction/s) subject to the legal consent of their parent or legal guardian in accordance with applicable law, including without limitation compliance with the Children’s Online Privacy Protection Act (“COPPA”) and the Digital Personal Data Protection Act, 2023 (“DPDP Act”). We do not knowingly collect Personal Information from children who are under 13, however, if You are not a minor and intend to avail the Services, or if You are the legal guardian of a minor intending to avail the Services, You hereby agree and acknowledge that You have provided Your informed and unconditional consent on behalf of Yourself or on behalf of the minor (as applicable), in accordance with applicable laws. If We learn that We have collected Personal Information from a minor without legal/parental consent, We will take steps to delete such information as soon as possible. If You become aware of any information We may have collected from or of a minor, please contact Us at support@koinx.com, and We will delete that information as soon as possible.

Legally Binding and Legal-Related Disclosures

We will disclose your Personal Information if we are required to do so by law within India’s jurisdiction, or in the good-faith belief that such action is necessary to comply with Indian laws, in response to a court order, judicial or other government subpoena or warrant, or to otherwise cooperate with law enforcement.

Do residents of India or other regions in Southeast Asian countries have specific privacy rights?

This Section provides additional information about Our Policy relevant to You if You are from India or any other Southeast Asian country.

For information about the Personal Information that We collect and how We collect it, please refer to “INFORMATION COLLECTED” Section of this Privacy Policy. The purposes for which We collect such Personal Information are provided under the Section “USE OF THE INFORMATION COLLECTED”. The categories of third-parties with whom We may share Your Personal Information are listed in the “DISCLOSURE OF THE INFORMATION COLLECTED” Section of this Privacy Policy.

To the extent We contract with vendors who are from India and other Southeast Asian countries, We ensure that specific safeguards have been established to protect Your Personal Information.

Do residents of the European Economic Area (EEA, including EU), Switzerland and the UK have specific privacy rights?

This Section provides additional information about Our Privacy Policy relevant to You if You are from the European Economic Area (the EEA), United Kingdom, and Switzerland (together “European Area Countries”). It supplements and should be read in conjunction with the rest of the Privacy Policy.

Under the European Area Countries’ privacy laws, We are the Controller with respect to Your data.

Where it is necessary to obtain Your prior consent to the processing concerned in order for Us to be allowed to do it (for example, direct marketing activities), We will obtain and rely on Your consent in relation to the processing concerned. Otherwise, We will process Your Personal Information only where the processing is necessary:

• for the performance of a contract to which You are a party or in order to take steps at Your request prior to entering into such a contract;

• for the purposes of the legitimate interests (Art. 6(1)(f) GDPR) pursued by Us or another person, provided that this will only be in circumstances in which those legitimate interests are not overridden by Your interests or fundamental rights and freedoms which require protection of Personal Information;

• for the fulfilment of Our legal obligations– the legal basis for processing of Your Personal Information will be the necessity for compliance with a legal obligation which We are subject to (Art. 6(1)(c) GDPR).

For information about the Personal Information that We collect and how We collect it, please refer to “INFORMATION COLLECTED” Section of this Privacy Policy. The purposes for which We collect such Personal Information are provided under the Section “USE OF THE INFORMATION COLLECTED”. The categories of third-parties with whom We may share Your Personal Information are listed in the “DISCLOSURE OF THE INFORMATION COLLECTED” Section of this Privacy Policy.

Additional Privacy Rights for European Area Countries’ Residents

In addition to the rights provided under Section “RIGHTS OF THE USERS”, the California residents are also entitled to the following rights:

• Data erasure – In certain situations, GDPR gives You the “right to be forgotten.” You can invoke this right where one of the following grounds applies:

1. the Personal Information are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
2. You withdrew consent to the processing of Personal Information and there is no other legal ground for continuing to process it;
3.  You object to the processing of Your Personal Information when there are no overriding legitimate grounds for processing;
4. You object to the processing of Your Personal Information for marketing purposes;
5. Your data is processed unlawfully;
6. the Personal Information have to be erased for compliance with a legal obligation.

• Complaints to the relevant public authority – In connection with Our actions as the controller of Your Personal Information, You are entitled to lodge a complaint to the relevant supervisory authority. You can find the list of local authorities responsible for data protection across the EU and their contact details at https://edpb.europa.eu/about-edpb/about-edpb/members_en. The relevant public authority in the UK is the Information Commissioner’s Office (https://ico.org.uk/). The relevant public authority in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC) (https://www.edoeb.admin.ch/edoeb/en/home.html).

We encourage You to first contact Us at support@koinx.com.

You can obtain a copy of the security measures We apply for the transfer of Personal Information to third countries by contacting Us at support@koinx.com.

Data Controller and Data Processor; Data Protection Officer

With regard to personal information, We may collect from You or that You may provide, We process that Personal Information or “personal data” as a “controller,” as such terms are defined in the General Data Protection Regulation (“GDPR”).

All personal information collected by Us through the Platform/Services are stored exclusively in secure hosting facilities provided by MongoDB Atlas. We have a data processing agreement in place with our providers, ensuring compliance with the GDPR and all applicable regulations. All hosting is performed in accordance with industry-standard security controls. All transfers of data from the EEA are done in accordance with regulations.

Contact Information for Data Protection

Data Protection Representative (EU & UK)

Simplify Infotech Private Limited has appointed DataRep as our Data Protection Representative for individuals in the European Union (EU), the United Kingdom (UK), and the European Economic Area (EEA). This allows our customers in these regions to contact DataRep directly in their home country regarding any data protection queries. If you are located in the EU, UK, or EEA and wish to raise a question or exercise your rights regarding your personal data, you may do so through the following methods:

• Email: datarequest@datarep.com (Please quote "Simplify Infotech Private Limited" in the subject line)
• Online Form: www.datarep.com/data-request
• Mail: You may send inquiries to DataRep at the most convenient address from their listed locations across the 27 EU countries, the UK, Norway, and Iceland. (Annexure A)

Important: When mailing inquiries, please ensure that your letter is addressed to "DataRep" and not "Simplify Infotech Private Limited", or it may not reach us. Also, clearly reference "Simplify Infotech Private Limited" in your correspondence.

Upon receiving your request, we may require verification of your identity to ensure your personal data is not disclosed to unauthorized individuals. For details on how DataRep handles personal data, please refer to their Privacy Policy.

Data Protection Representative (All other regions)

If you are outside the EU, UK, or EEA, please contact our Data Protection Officer (DPO), Guna Shekar Proddaturi, directly via email at dpo@koinx.com.

Do California residents have specific privacy rights?

This Section for California Residents supplements the Privacy Policy to comply with the California Consumer Privacy Act of 2018 ("CCPA") and the California Privacy Rights Act ("CPRA") of 2023.

The CCPA and the CPRA are California laws that provide its residents with certain rights over information about them, including notice about the categories of Personal Information We have collected from them in the preceding twelve (12) months and the purposes for which the information is used or disclosed, and correction of Personal Information.

In the preceding 12 months, depending how You interact with Our Platform, We may have collected the following categories of Personal Information (as defined under Cal. Civ. Code §1798.140(v)(1)):

• Identifiers, such as Your name, address, unique personal identifier, email, phone number, or similar identifiers.
• Commercial information, such as information relating to transactions with Us involving You or the person that You work for (for example, details of products developed by Us or Services that We have supplied to, or obtained from, You or the person You work for), and information about events to which You or those related to You are invited, and Your Personal Information and preferences to the extent that this information is relevant to organising and managing those events.
• Internet or other electronic network activity information, such as technical information, including the Internet protocol (IP) address used to connect Your computer to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, click-stream data, locale preferences, Your mobile carrier, and system configuration information.
• Geolocation data, such as geolocation, to the extent You have configured Your device to permit Us to collect such information.
• Information relating to evaluation of Your mental health and inferences drawn from any of the information listed above, such as Your preferences, characteristics, behaviour and attitudes.

For more information about the Personal Information that We collect and how We collect it, please refer to “INFORMATION COLLECTED” Section of this Privacy Policy. The purposes for which We collect such Personal Information are provided under the Section “USE OF THE INFORMATION COLLECTED”. The categories of third-parties with whom We may share Your Personal Information are listed in the “DISCLOSURE OF THE INFORMATION COLLECTED” Section of this Privacy Policy.

Sales of Personal Information under the CCPA

The Company does not sell Personal Information, nor do We possess any actual knowledge of any sale of Personal Information.

Additional Privacy Rights for California Residents

In addition to the rights provided under Section “RIGHTS OF THE USERS”, the California residents are also entitled to the following rights:

• Non-Discrimination. It is the right of California residents not to receive any discriminatory treatment from Us for the exercise of their rights conferred by the CCPA.

• Authorized Agent. Only the Users, or someone legally authorized to act on behalf of the Users, may make a verifiable consumer request related to their Personal Information. Users may also make a verifiable consumer request on behalf of their minor children. To designate an authorized agent, please contact Us at support@koinx.com and provide written authorization signed by the User and his/her designated agent.

• Verification. To protect Users’ privacy, We will undertake the following steps to verify Users’ identity before fulfilling their request. When You make a request, We will ask You to provide sufficient information that allows Us to reasonably verify that You are the person about whom We collected Personal Information or an authorized representative, which may include asking You for additional proof of identity and asking questions regarding Your account and use of Our Services.

• California “Shine the Light” law. California’s “Shine the Light” law (California Civil Code Section 1798.83) permits Users of Our Services who are California residents to request and obtain from us, once a year and free of charge, a list of third parties with whom We have shared any Personal Information belonging to any of Our Users, for their marketing purposes. To make such a request, please contact Us at support@koinx.com.

• If You are under 18 years of age and reside in California having a registered account with Us, You have the right to request removal of unwanted data that You publicly post on the website. To request removal of such data, please contact Us using the contact information provided below, and include the email address associated with Your account and a statement that You reside in California. We will make sure the data is not publicly displayed on the website, but please be aware that the data may not be completely or comprehensively removed from all Our systems (e.g. backups, etc.).

• Do not track. As per California law, CalOPPA (California Business & Professions Code Section 22575(a)), it is required that We let You know how We respond to web browser Do Not Track (“DNT”) signals. DNT is a privacy preference that Users may set in their web browsers. Please acknowledge that We do not respond to such DNT requests at this time.

Response Timing: We are required to respond to any of the verifiable consumer requests to exercise these above rights within 45 days. Should We be unable to comply within 45 days, We will contact You and let You know whether We can complete Your request or whether We need more time to complete Your request with reason. Any disclosure We provide will only cover the 12-month period preceding the verifiable consumer request’s receipt.

Regarding information We disclose to third parties, You have the right to opt out of such disclosure at any time. You can exercise Your right to opt out (or any other rights on Our website) by emailing Us at support@koinx.com.

Do Nevada residents have specific privacy rights?

If You are a resident of Nevada, You have the right to opt-out of the sale of certain Personal Information to third parties who intend to license or sell that Personal Information. You can exercise this right by contacting Us at support@koinx.com with the subject line “Nevada Do Not Sell Request” and providing Us with Your name and the email address associated with Your account. Please note that We do not currently sell Your Personal Information as sales are defined in Nevada Revised Statutes Chapter 603A.

Changes to this Privacy Policy

We may amend this Privacy Policy from time to time. Use of information We collect now is subject to the Privacy Policy in effect at the time such information is used. If We make changes in the way We use Personal Information, We will notify You by posting an announcement on Our Website or sending You an email. You are bound by any changes to the Privacy Policy when You use the Website or the Services after such changes have been first posted.

Grievance Officer

Any complaints, abuse or concerns with regards to content and or comment or breach of the terms in this Privacy Policy shall be immediately informed to the designated Grievance Officer as mentioned below in writing or through email signed with the electronic signature:

Name: Bhawik Bhimrajka

Email: grievance-officer@koinx.com

Your use of the Platform and any dispute over privacy is subject to this Privacy Policy and Terms.

Contact Us

If there are any questions regarding this privacy policy, You may contact Us using the information below:

support@koinx.com

ANNEXURE A

Listed locations of DataRep