Effective date: 2022-11-09

1. Introduction

Winfo Solutions is committed to protecting the personal information it collects from you.

This Privacy Policy explains how we collect, safeguard and disclose information that results from your use of our Website.

We use your data to provide and improve the functionality and your user experience in respect of our Website. By using our Website, you agree to the collection and use of information in accordance with this policy.

Our Privacy Policy, along with our Website Terms of Use, and any additional data privacy notices on our Website or targeted emails, govern all use of our Website.

2. Definitions:

Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).

Usage Data is data collected automatically either generated by the use of our Website or from our Website infrastructure itself (for example, the duration of a page visit).

Cookies are small files stored on your device (computer or mobile device).

Data Controller means a natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal data are, or are to be, processed. For the purpose of this Privacy Policy, we are a Data Controller of your data.

Data Processor means any natural or legal person who processes the data on behalf of the Data Controller.

Data Subject is any living individual who is the subject of Personal Data.

The User is the individual using our Website. The User corresponds to the Data Subject, who is the subject of Personal Data.

Website means www.winfosolutions.com

3. How Winfo Solutions protects your Personal Data

Winfo Solutions protects your personal data in three important ways:

• Data Protection Policy – a global data protection policy that sets out the safeguards that apply across Winfo Solutions regardless of where we process your Personal Data.
• Data Protection Policies – including, without limitation, how we handle Subject Access requests, and a complaints procedure.
• Where applicable, Standard Contract Clauses (SCC) – a well used data protection mechanism for cross-boarder transfers of Personal Data

4. Information Collection and Use

The primary purpose of our Website is to provide a resource and a key communication channel for providing information about our solutions and services. We collect several different types of information for various purposes to provide and improve our Website for you. It is important to Winfo Solutions that you feel secure when visiting our Website and we are committed to protecting your privacy when you do so.

5. Types of Data Collected

Winfo Solutions collects information via its Website in two ways:

• Directly from the User, for example, when you provide information to sign up for a newsletter or register a comment on a forum;
• Indirectly from the User, for example via the Website’s technology.

We may process and collect the following Personal Data:

5.1 Personal Details

While using our Website, we may ask you to provide us with certain Personal Data that can be used to contact or identify you . This Personal Data may include, but is not limited to:

• i. Email address
• ii. First name and last name
• iii. Phone number
• iv. Address, Country, State, Province, ZIP/Postal code, City
• v. Cookies and Usage Data
• vi. Future Communication Preferences

We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link .

Winfo Solutions does not tend to collect Personal Data regarding children (as defined by local legal requirements). In the unlikely event that Winfo Solutions were to collect Personal Data of children, Winfo Solutions will comply with all applicable laws and regulations with respect to the processing of such data, including where applicable by obtaining consent from the parent or guardian.

5.2 Usage Data

We may also collect information that your browser sends whenever you visit our Website or when you access our Website by or through any device (“Usage Data”).

This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Website that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When you access our Website with a device, this Usage Data may include information such as the type of device you use, your device unique ID, the IP address of your device, your device operating system, the type of Internet browser you use, unique device identifiers and other diagnostic data.

5.3 Location Data

We may use and store information about your location if you give us permission to do so (“Location Data”). We use this data to provide features of our Website, to improve and customize your use of our Website.

You can enable or disable location services when you use our Website at any time by way of your device settings.

5.4 Tracking Cookies Data

We use cookies and similar tracking technologies to track the activity on our Website and we hold certain information.

Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyze our Website.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies or decline the use of certain cookies, you may not be able to use some portions of our Website.

Cookies are typically categorised as session cookies or persistent cookies. Session cookies help you navigate through the website, effectively keeping track of your progress from page to page so that you are not asked for information you have already provided during the current visit session. Cookies are stored in temporary memory of your device and erased when the web browser is closed. In contrast, persistent cookies, store user preferences for current and successive visits. They are written on your devices hard drive and are still valid when you restart your browser.

Examples of Cookies we use:

• i. Session Cookies: We use session cookies to operate our Website.
• ii. Preference Cookies: We use preference cookies to remember your preferences and various settings on our Website.
• iii. Security Cookies: We use security cookies for security purposes.
• iv. Advertising Cookies: We use advertising cookies to serve you with advertisements that may be relevant to you and your interests.

While our Website at this time does not recognise automated browser signals regarding tracking mechanisms such as “do not track” instructions. You can generally express your privacy preferences regarding the use of most cookies and similar technologies through your web browser. Look under the heading ‘Tools’ or similar heading in your particular browser for information about controlling cookies. You can set your browser in most instances to notify you before you receive a cookie, giving you the chance to decide whether to accept it or not. You can also generally set your browser to turn off cookies.

5.5 Other Data

While using our Website, we may also collect the following information: sex, age, date of birth, place of birth, passport details, citizenship, registration at place of residence and actual address, telephone number (work, mobile), details of documents on education, qualification, professional training, employment agreements, NDA agreements, information on bonuses and compensation, information on marital status, family members, social security (or other taxpayer identification) number, office location and other data.

6. How does Winfo Solutions use information that we collect

We use Personal Data to provide you with information that you request, [process online job applications] and for other purposes which we would describe to you at the point where your Personal

Data is collected or which will be obvious to you. For example:

• i. to fulfil your requests for newsletters or other content;
• ii. to provide and maintain our Website;
• iii. to personalize your experience of our Website;
• iv. notify you about changes to our Website;
• v. to allow you to participate in interactive features of our Website when you choose to do so;
• vi. to provide customer support;
• vii. to gather analysis or valuable information so that we can improve our Website;
• viii. to monitor the usage of our Website;
• ix. to detect, prevent and address technical issues;
• x. to fulfil any other purpose for which you provide it;
• xi. to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
• xii. to provide you with notices about your account and/or subscription, including expiration and renewal notices, email-instructions, etc.;
• xiii. to provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information;
• xiv. for remarketing services to advertise on third party websites to you after you visited our Service. We and our third-party vendors use cookies to inform, optimize and serve ads based on your past visits to our Website.
• xv. in any other way we may describe when you provide the information;
• xvi. for any other purpose with your consent.

7. Links to Third Party Websites and Social Media

Our Website may include links to third party sites. Winfo Solutions has no control over, and assumes no responsibility for, the information practices of websites to which our Website provides links, nor does Winfo Solutions endorse or make any representation about such third party sites or any information, software, or other products, services or material found there, or any results that may be obtained from using them. When you link to another website, Winfo Solutions privacy practices and the terms and conditions of this Privacy Policy no longer apply. We strongly advise that you review each sites’ privacy and security policies to determine such practices and whether you wish to disclose personally identifiable information on them.

8. Social Networks and Third Party Plug-ins

Our Websites may include plug-ins from social networks or other third parties. An example of a plugin is the Facebook “Like” button. When legally permitted, these plugins may communicate with and send information to the party that provided the plugin, even if you do not click on the plug in. This information may include your IP address, information about your browser and device and the address of the Website page you are visiting on our site.

Loading, using or clicking the plugins may also place, read and transmit cookies. These cookies may contain a unique identifier the social network or third party assigns to you. The loading, functionality and your use of the plugins are governed by the privacy policy and terms of the party that provided that plug in.

9. Social Network and Third Party Log-in

Our Website may allow you to log in using a social network or other third party account. An example of a third-party log in is “ Log in with Facebook”. Logging into one of our sites with your social network or other third party account may allow us to gather information that you give us permission to access from that social network or third party. The log in feature may also transfer information to the social network or third party, such as your username, and password, to authenticate you.

The social network or third party may also automatically collect information such as your IP address, information about your browser and device, and the address of the web page you are visiting on our site. The login feature may also place and read cookies from that third party that may contain a unique identifier the social network the third party assigns to you. The functionality of and your use of the login is governed by the privacy policy and terms of the party that provided the log in functionality.

10. Retention of Data

We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy, or otherwise communicated to you at the point of collection. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws).

We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period, except when this data is used to strengthen the security or to improve the functionality of our Website, or we are legally obligated to retain this data for longer time periods.

11. Transfer of Data

Your information, including Personal Data, may be transferred to – and maintained on – computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

If you are located outside India, UK, US and choose to provide information to us, please note that we transfer the data, including Personal Data, to India, UK, US and process it there.
Winfo Solutions will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organisation or a country unless there are adequate controls in place including the security of your data and other personal information.

12. Who do we share Personal Data with?

We sometimes rely on third party service providers to perform a variety of business operations on our behalf. This may include facilitating our Website, performing Website related services or assist us in analyzing how our Website is used. In doing so, we may need to share or disclose the Personal Data you have provided for a specific purpose. These third parties shall have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Such purposes may include, but are not limited to:

• i. personalizing your experience on our websites tailored to your interests;
• ii. conducting research and analyze data to improve User experience of our Website;

Other cases, where we may disclose your information, include, without limitation:

• i. to our subsidiaries and affiliates;
• ii. to fulfill the purpose for which you provide it;
• iii. for the purpose of including your company’s logo on our website;
• iv. for any other purpose disclosed by us when you provide the information;
• v. with your consent in any other cases;
• vi. if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Winfo Solutions, our customers, or others.

13. Where will your Personal Data be processed?

As a global organization, Winfo Solutions has global IT systems and Personal Data we process may be routed, stored, or transferred internationally through our global organization in accordance with our Data Protection Policy.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your data transmitted to our site. Any transmission is at your own risk. Once we have received your information, we will use strict procedures and the security features described to protect your Personal

Data against unauthorised access.

14. Security of Data

Winfo Solutions is committed to keeping personal information secure. We have implemented appropriate organisational and technical measures designed to protect Personal Data from loss, unauthorised access, misuse, alteration, disclosure or destruction to maintain accuracy and to ensure the appropriate use of information. Only Winfo Solution’s personnel and its affiliates, business partners or third party service providers, who have legitimate business purpose, will have access to Personal Data. Such personnel have agreed to maintain the confidentiality of such information. Winfo Solutions ensures data minimization standards across its operations.

15. Your Data Protection Rights

Depending on the laws of your country of residence, you may have certain data protection rights, with respect to your Personal Data.

Such rights may include:

• i. the right to access, update or to delete the information we have on you;
• ii. the right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete;
• iii. the right to object. You have the right to object to our processing of your Personal Data;
• iv. the right of restriction. You have the right to request that we restrict the processing of your personal information;
• v. the right to data portability. You have the right to be provided with a copy of your Personal Data in a structured, machine-readable and commonly used format;
• vi. the right to withdraw consent. You also have the right to withdraw your consent at any time where we rely on your consent to process your personal information;

Please note that we may ask you to verify your identity before responding to such requests. Please note, we may not able to action your request(s) without some necessary data.

When your Personal Data is retained, Winfo Solutions undertakes to make all reasonable efforts to maintain the accuracy of the Personal Data as submitted and verified by you. However, Winfo Solutions does not assume responsibility for verifying the information you submit, save to the extent this is legally required. When practicable, if Winfo Solutions is informed that any Personal

Data that we have collected about you is no longer accurate, Winfo Solutions will make appropriate corrections based on the updated information provided,. Queries in this regard should be made to [info@winfosolutions.com].

If you wish to be informed what Personal Data we hold about you, or you wish to invoke any other rights that you may have regarding the Personal Data that Winfo Solutions holds about you if, please email us at info@winfosolutions.com

16. Your Data Protection Rights under the California Privacy Protection Act (CalOPPA)

CalOPPA is the first state law in the nation to require commercial websites and online services to post a privacy policy. The law’s reach stretches well beyond California to require a person or company in the United States (and conceivable the world) that operates websites collecting personally identifiable information from California consumers to post a conspicuous privacy policy on its website stating exactly the information being collected and those individuals with whom it is being shared, and to comply with this policy.

According to CalOPPA we agree to the following:

0.1. users can visit our site anonymously;

0.2. our Privacy Policy link includes the word “Privacy”, and can easily be found on the home page of our website;

0.3. users will be notified of any privacy policy changes on our Privacy Policy Page;

0.4. users are able to change their personal information by emailing us at info@winfosolutions.com.

Our Policy on “Do Not Track” Signals:

We honor Do Not Track signals and do not track, plant cookies, or use advertising when a Do Not Track browser mechanism is in place. Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.

You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

17. Your Data Protection Rights under the California Consumer Privacy Act (CCPA)

If you are a California resident, you are entitled to learn what data we collect about you, ask to delete your data and not to sell (share) it. To exercise your data protection rights, you can make certain requests and ask us:

0.1. What personal information we have about you. If you make this request, we will return to you:

0.0.1. The categories of personal information we have collected about you.

0.0.2. The categories of sources from which we collect your personal information.

0.0.3. The business or commercial purpose for collecting or selling your personal information.

0.0.4. The categories of third parties with whom we share personal information.

0.0.5. The specific pieces of personal information we have collected about you.

0.0.6. A list of categories of personal information that we have sold, along with the category of any other company we sold it to. If we have not sold your personal information, we will inform you of that fact.

0.0.7. A list of categories of personal information that we have disclosed for a business purpose, along with the category of any other company we shared it with.

Please note, you are entitled to ask us to provide you with this information up to two times in a rolling twelve-month period. When you make this request, the information provided may be limited to the personal information we collected about you in the previous 12 months.

0.2. To delete your personal information. If you make this request, we will delete the personal information we hold about you as of the date of your request from our records and direct any service providers to do the same. In some cases, deletion may be accomplished through de-identification of the information. If you choose to delete your personal information, you may not be able to use certain functions that require your personal information to operate.

0.3. To stop selling your personal information. We don’t sell or rent your personal information to any third parties for any purpose. We do not sell your personal information for monetary consideration. However, under some circumstances, a transfer of personal information to a third party, or within our family of companies, without monetary consideration may be considered a “sale” under California law. You are the only owner of your Personal Data and can request disclosure or deletion at any time.

If you submit a request to stop selling your personal information, we will stop making such transfers.

Please note, if you ask us to delete or stop selling your data, it may impact your experience with us, and you may not be able to participate in certain programs or membership services which require the usage of your personal information to function. But in no circumstances, we will discriminate against you for exercising your rights.

To exercise your California data protection rights described above, please send your request(s) by email: info@winfosolutions.com

Your data protection rights, described above, are covered by the CCPA, short for the California Consumer Privacy Act. To find out more, visit the official California Legislative Information website.

The CCPA took effect on 01/01/2020.

18. Questions and Complaints

If you have any questions concerning data protection and privacy or wish to make a complaint about the use of your Personal Data, you can complain directly to Mr. Venkata Nori, Managing Director, Winfo Solutions at Venkata.nori@winfosolutions.com You also have the right to complain to the Data Protection Authority in your territory.

Additionally, if you want to let us know about this Website and marketing permissions, please contact Mr. Venkata Nori, Managing Director, Winfo Solutions at Venkata.nori@winfosolutions.com

19. Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on our Website, prior to the change becoming effective and update “effective date” at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.