Privacy Policy

OUR APPROACH TO PRIVACY

Your Privacy is important to us.

Nuvoco Vistas Corporation Limited (hereinafter referred to as “Nuvoco” or “we” or “our”) recognizes that privacy is a fundamental human right and further recognizes the importance of privacy, security, and data protection to our customers and partners worldwide. We strongly encourage you to take some time to read our Privacy Statement in full.

About the Program and App

The Nuvoco Zero M Unnati App is a digital platform and loyalty program specifically designed for our valued Zero M Users .

Usage of App:

1. Scan – Allows Users to scan QR coupons on Nuvoco Zero M products to earn reward points.

2. Redeem – Enables Users to convert their earned reward points into monetary value redeemable directly into their bank account.

3. My Orders – Provides a record and history of the User’s transactions, including coupon scans and point redemptions.

4. Profile – Manages the User’s account details, including personal and bank information, and app preferences.

Nuvoco respects the privacy of every individual who visits or registers on our mobile app. Nuvoco is sensitive to the privacy concerns of its registered members to its mobile app and recognizes that you are concerned about the information you provide us and how we treat that information. This privacy statement (“Statement” or “Privacy Policy”) provides information about the ‘personal information’ that Nuvoco or its authorised contractor collects, and the ways in which Nuvoco uses that personal information (‘personal data’). This privacy policy supplements the other policies and is nota intended to override them.

Nuvoco reserves the right to revise and update this Privacy Policy at any time and such revision/update shall be effective immediately.

A. PRIVACY PRINCIPLES

TO WIN THE TRUST OF THE VISITORS AND REGISTERED USERS TO ITS MOBILE APP/WEBSITE, NUVOCO FOCUSES ON BELOW PRINCIPLES:

1. Data Access & Control: We will put you in control of your privacy with specific, informed & unambiguous choices with reasonable access along with the ability to review, correct, amend or delete the personal data you have shared with us.

2. Lawfulness, Fairness & Transparency: We are transparent in all data collection and use so as you can make informed decisions on your provided data. We only collect personal data which is relevant and limited to what is necessary for the purposes for which it is collected. Our data processing activities are conducted: a. With your consent; b. In order to fulfil our obligations to you (such as processing point redemption); c. For the legitimate purposes of advancing innovation and providing a seamless customer experience; or d. Otherwise in accordance with law.

3. Data Integrity & Purpose Limitation: We only use personal data for the purposes described at the time of collection or registration or for additional compatible purposes in accordance with law and as per this Privacy Policy. We take reasonable steps to ensure that personal data is accurate, complete and current and we only collect personal data which is relevant and limited to what is necessary for the purposes for which it is collected. We will keep personal data for no longer than is necessary for the purposes for which it was collected and then we will securely delete or destroy it.

4. Data Security & Strong legal protections: We consider your privacy as a fundamental human right and will respect your local privacy laws. To protect personal data against unauthorized use or disclosure, we implement strong information security controls in our own operations.

5. No content-based targeting: Except for the Benefits to you under this Statement, we will not use your email, chat, files or other personal content to target ads to you[VL1.1].

6.5. Benefits to you: When we do collect data, we will use it to benefit you and to make your experiences better.

B. PERSONAL INFORMATION COLLECTION

1. We will not collect any personally identifiable information i.e. Personal Data about you (such as your name, address, phone number, e-mail address, Log-ID & Password of mobile app etc.) unless you provide it to us voluntarily during the registration on the mobile app or while usage of the same. If you opt not to provide us with personally identifiable information at the time of registration or later, no material consequences will result, although you may not be able to get yourself registered or participate in certain promotions, receive product information, corresponding services, certain specialized features or able to effectively respond to any queries you may have or participate in any kind of feedback or services/information as described under this Statement (collectively referred as ‘Services’).

2. In general, you may download our mobile app without providing any Personal Information about yourself. However, we collect certain information from you on registration and during app usage, information to include the following but not be limited to, for the functioning of the Nuvoco Zero M Unnati App as follows:

I. Registration Data: Name, age, contact details (phone number, email), postal/billing address, and other identifiers. This is required for creating and managing your account.

II. Bank Account Details: Required for the redemption of reward points into money in the bank.

III. Profile & Account Information: Login credentials, app preferences, reward points balance, and transaction history (including point redemptions and transfers).

IV. Device Information: Device model, Operating System (OS), IP address, unique identifiers (such as MAC ID, UUID), browser type, and technical data. This helps ensure app stability, security, and a better user experience.

V. Product & Service Usage: Product coupon scan details, usage data, and redemption activities. This data is central to the operation of the loyalty program.

VI. User-Generated Content: Photos, videos, and voice recordings submitted via the app (e.g., for verification, contest participation, or feedback).

VII. Location Data: Geo-coordinates if optional Geo-fence features are used and you have granted permission.

VIII. Third-Party Data: Data obtained from social media logins or other third-party integrations, if you choose to link these services.

3. Pseudonymization: Anonymous answers to surveys or anonymous and aggregated information about how our products & Services are used. In certain cases, we apply a process of de-identification or pseudonymization to your data to make it reasonably unlikely to identify you through the use of that data with available technology.

C. CHILDREN PRIVACY

Nuvoco Services are made for the general public (specifically, adult Users). Nuvoco does not knowingly collect data from children as defined by local law without the previous consent of their parents or legal guardians or as otherwise permitted by applicable law.

D. USING PERSONAL INFORMATION

1. Nuvoco or its authorised contractors may store and process your personally identifiable information to understand your needs better and how we may improve our products and Services, and to contact you (viz. we may send you marketing or promotional materials or other information), we may respond to your comments or requests for information.

2. Your information may be shared with agents or contractors of Nuvoco in connection with Services that these individuals or entities perform for Nuvoco and ensure that they maintain the Confidentiality of the said shared information. Nuvoco will not give, share or forward your personal identifiable information to any outside organization or with third parties, unless Nuvoco needs to share your personal information to provide the product or Service you have requested (such as sharing bank details with a payment processor for reward redemption) and Nuvoco have asked for and obtained your explicit consent. The foregoing notwithstanding, if

a. Disclosure was required by law, rule or regulation or was in response to a valid order of a court or authorized agency of government or other legal process and/or;

b. We need to operate and also maintain the security of this mobile application, including to prevent or stop an attack on our computer systems or networks;

c. When Nuvoco finds your action on the mobile app violates the Nuvoco terms and condition or any of your usage guidelines for specific products or Services.

d. You request or authorize us to do so;

3. Nuvoco uses your Personal Information for the following purposes:

I. To provide better usability, troubleshooting and app maintenance.

II. To understand which parts of the mobile app are visited and how frequently.

III. To create your user ID and verify your identity.

IV. To prevent and trace fraudulent or inappropriate usage, particularly concerning coupon scanning and point redemption.

V. To identify you once you register on our mobile app.

VI. To assist you in completing transactions and point redemptions, administering your account, and processing payments to your bank account.

VII. To develop our existing products and services, together with general and statistical information.

VIII. To personalize product design and to provide you with services tailored for you.

IX. To understand how you are using our product & services and to develop more customer-oriented future products & services.

X. To provide marketing and promotional materials to you about our products and services (you may unsubscribe anytime).

XI. To contact you and respond to your questions or requests.

4. If you choose not to provide desired information, then we may not be able to provide the deliverables as stated in preceding points of Using Personal Information as described in this Statement, particularly essential services like reward redemption which requires Bank Account Details.

5. If you choose to access, update or correct the personal information, you may be able to do so at the profile section of the of the Mobile app

E. SECURING YOUR DATA: DATA RECIPIENTS, TRANSFER, AND DISCLOSURE OF PERSONAL INFORMATION

1. Nuvoco does not share your Personal Information with third parties for marketing purposes without seeking your prior permission.

2. Subject to obtaining your consent as may be required in some jurisdictions, we may share or disclose your personal data as necessary for the purposes described above and as further detailed below. Nuvoco shall share your Personal Information with:

a. Nuvoco’s Affiliates and/or with any of its subsidiaries: We may disclose the personal data we collect from you to our Affiliates and/or subsidiaries.

b. Third-Party Service Providers: We employ other companies and individuals to perform functions that are necessary for the provision of the Services, such as payment processors for reward redemption, analytics providers, and IT support. These third parties have access to personal data and sensitive personal data needed to perform the functions we have entrusted to them but may not use it for other purposes where they process your personal data on our behalf.

c. Business Transfers: If we are acquired by or merge with another company, or if substantially all of our assets are transferred to another company.

d. Legal Protection and in Response to Legal Process: To comply with applicable law, judicial proceedings, court orders, or to protect or enforce our rights.

3. Nuvoco shall take reasonable technical and organizational precautions to prevent the loss, misuse or alteration of your personal information.

4. Nuvoco does not, and will not, sell personal data to third parties.

F. NUVOCO COMMUNICATIONS

1. You can make or change your choices regarding subscription or registration or general communications from Nuvoco at the data collection point or by using methods described in this section.

2. You may opt out of receiving these general communications by using one of the following methods:

a. You may uninstall our mobile application.

b. You may choose not to log in to the mobile app.

c. You may remove the ID & Password by choosing ‘Delete Your Account’ in the mobile app.

d. You may change your consent or allow status using the mobile app for barring/disallowing notifications in mobile app.

G. DATA SECURITY

1. Nuvoco adopts reasonable and appropriate security practices and procedures including administrative, physical security, and technical controls in order to safeguard your Personal Information we collect and process on this mobile application.

2. To prevent unauthorized access, maintain data accuracy and ensure the correct use of information, we have put in place physical, electronic, and managerial procedures to safeguard and secure the personal data we collect through our Sites/mobile app and in the provision of our Services.

3. If you have a user name and password to access our Services, you should take steps to protect against unauthorized access to your password, phone and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private.

H. DATA RETENTION

1. Personal Information will not be retained for a period more than necessary to fulfil the purposes outlined in this privacy statement, unless a longer retention period is required by law or for directly related legitimate business purposes.[VL2.1][SK2.2][Rk2.3]

2. We determine appropriate retention period for the personal data by considering the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure, the purposes for which we process the personal data, and whether the personal data can be permanently and effectively anonymised.

I. CROSS-BORDER DATA TRANSFERS

Information that you submit for publication on the mobile app will be published on the internet and may be available around the world. You agree to such cross-border transfers of personal information.

J. CONTACT INFORMATION

If you have questions or concerns about this Privacy Policy, our data practices, or your rights, please contact our Grievance Officer at:

Grievance Officer:

• Name:

• Address:

• Phone:

• Email: