PRIVACY POLICY

Version 2.0

Last revised date: September 20, 2025

This document constitutes a computer-generated electronic record under Rule 3 of the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021, as amended from time to time. Being electronically generated, it does not require any physical or digital signature.

ANGELIC INFOTECH Private Limited (“Company”, “we”, “us”, or “our”), an entity incorporated under the Companies Act with Corporate Identification Number U74999RJ2021PTC077075, is registered with the Financial Intelligence Unit under registration number VA00031314. The Company offers a range of products and services— either directly or through its affiliates, group entities, licensees, or partner organizations—via its official website https://suncrypto.in, along with its associated mobile applications and software platforms.

This Privacy Policy (“Policy”) forms an integral part of the SUNCRYPTO Terms refers collectively to the Terms of Use, this Privacy Policy, and all other rules, policies, frequently asked questions (FAQs), guidelines, and instructions (including any related hyperlinks) that may be published or made available on our application from time to time. All of these are deemed to form a unified and binding part of the SUNCRYPTO Terms.

Capitalized terms used but not defined in this Privacy Policy shall have the meaning ascribed to them in the SUNCRYPTO Terms.

BY ACCESSING OR USING OUR ONLINE PLATFORMS, OR BY REGISTERING AN ACCOUNT WITH US, YOU ACKNOWLEDGE THAT THIS POLICY CONSTITUTES A BINDING LEGAL AGREEMENT BETWEEN YOU AND US. YOU HEREBY PROVIDE YOUR FREE, INFORMED, SPECIFIC, UNAMBIGUOUS, AND VOLUNTARY CONSENT TO THE COLLECTION, USE, ACCESS, PROCESSING, STORAGE, DISCLOSURE, TRANSFER, AND PROTECTION OF YOUR PERSONAL DATA IN ACCORDANCE WITH THIS POLICY AND FOR THE PURPOSES STATED HEREIN. IN CERTAIN INSTANCES, YOUR ACCEPTANCE OF THIS POLICY MAY BE RECORDED BY TICKING A CHECKBOX STATING “I AGREE WITH THE TERMS & CONDITIONS.” IF YOU DO NOT AGREE OR UNDERSTAND THE CONTENTS OF THIS POLICY, YOU ARE ADVISED NOT TO PROCEED WITH THE USE OF OUR PLATFORMS. YOU RETAIN THE RIGHT TO WITHHOLD OR WITHDRAW YOUR CONSENT AT ANY TIME BY INFORMING US IN WRITING, ALTHOUGH SUCH WITHDRAWAL MAY IMPACT YOUR CONTINUED ACCESS TO THE SERVICES.

PERSONAL DATA AND PROTECTED INFORMATION

“Data Protection Law” refers to all applicable data protection, data security, and privacy laws governing the Company, including but not limited to the Indian Information Technology Act, 2000 and its associated rules and regulations, as well as any other laws regulating the collection, storage, use, transmission, or disclosure of Personal Data, information we handle with care, or information derived from telephone calls, emails, facsimiles, or other forms of communication.

“Personal Data” means any information that relates to an identified or identifiable natural person. This includes data that directly identifies an individual (such as name, identification number, or unique job title) or indirectly identifies them (such as date of birth, IP address, telephone number, device identifiers, household information, or online identifiers). It encompasses any information classified as "personal data" or its equivalent under applicable data protection law.

“Information We Handle with Extra Care” in relation to a person means personal information that includes:

(i) Financial information such as bank account, credit card, debit card, or other payment instrument details;
(ii) Passwords;
(iii) Sexual orientation;
(iv) Biometric information;
(v) Physical, physiological, or mental health conditions;
(vi) Medical records or health history;
(vii) Any such data received, processed, or stored by us under lawful contract or as otherwise permitted by IT Reasonable Security Practices and Procedures and Sensitive Personal Data or Information Rules, 2011; and
(viii) Any information related to the above clauses by us for processing, stored or processed under lawful contract or otherwise.

INFORMATION WE COLLECT, USE, STORE, DISCLOSE, AND PROCESS

We may collect, use, store, disclose, and process the following categories of information about you:

INFORMATION YOU PROVIDE TO US

You may be required to provide personal data (including information we handle with care) while creating a user account or during ongoing use of our platforms. You agree to provide accurate, up-to-date information. This may include:

1. Identification Details: Full name, date of birth, nationality, gender, photograph, etc., used to create and verify your profile.
2. National Identifiers: Government-issued ID numbers (e.g., any one or all Officially valid documents such as Aadhaar, Passport, etc., including PAN details), for linking your identity with your registered profile.
3. Contact Information: Email address, phone number, and postal address, used for communication, support, and service delivery. Any additional information shared via surveys, contests, or customer support is also collected.
4. Financial Information: Bank account details, PAN, debit/credit card numbers, UPI IDs, tax details, digital asset wallet addresses, transaction history, and credit history, used for transaction processing and compliance.
5. Location Data: we may seek your location data for providing certain Services or in order to enable you to access certain features of the Online Platforms or in the event we suspect any fraudulent transactions.
6. Transaction Data: Details of digital asset transfers (e.g., recipient name, wallet addresses, amounts, timestamps).
7. Business/Employment Details: Job title, business type, office address, and—in the case of entities—corporate documents, beneficial ownership, and KYC data. If you are not a natural person, this would extend to your constitutional documents, shareholding and beneficial holding details, company master data, and any other substantive proof you may submit to us as part of our KYC and verification processes.
8. Other Communications: Information shared during support chats, legal investigations, surveys, or general queries, including for assistance in case of matters related to law enforcement and investigations.

INFORMATION WE COLLECT AUTOMATICALLY

When you use our platforms, we automatically collect certain technical and behavioral data, such as

1. Device & Technical Information: IMEI, IMSI, UUID, MAC address, OS version, device specs, network data, IP address, browser type, time zone, OS/platform info.
2. Permissions-Based Access: Device access to SMS, storage, location, contacts, camera, microphone, photos/videos, and notifications—subject to your settings.
3. Usage Data: URLs visited, timestamps, trade and transaction attempts, search activity, page interactions (scrolls, clicks, mouse movements), response times, and error logs.
4. Transaction Metadata: Technical data tied to the content you upload or transmit (e.g., geolocation, timestamps, attribution).
5. Cookies & Tracking: We use cookies, pixels, and other tracking technologies for performance, personalization, and analytics. Some third-party tools may also use similar technologies, and we aim to inform you and seek consent before use.

This information is used to operate, secure, and enhance our Services, ensure compliance, and tailor your experience on our platforms.

INFORMATION FROM THIRD PARTIES

We may also receive data from:

1. Partners and Public Sources: Including KYC partners, public databases, credit bureaus, social media platforms, joint marketing affiliates, and other permitted channels under applicable law.
2. Service Providers: Subcontractors, ad networks, analytics and search engines, wallet and exchange providers, and infrastructure (e.g., cloud services).
3. Aggregated Data: Browser-level data and analytics in anonymized or grouped formats. This data may be combined with other information you provide to optimize our Services and compliance obligations.

We also work closely with select third parties (including, for example, subcontractors and service providers such as advertising networks, analytics providers, search information providers, online intermediaries and exchanges, Digital Assets market participants, wallet and other Digital Asset service providers, and infrastructural services, including cloud service providers) and may receive information about you from such sources. We may also collect and receive information in an aggregated form from different browser types for analysis.

Disclaimer: We collect only the Personal Data necessary to provide our Services, including KYC verification, transaction processing, fraud prevention, and personalized user experience. Any new purpose for data processing not listed here will require your explicit consent, obtained through a clear and separate request.

SMS ACCESS FOR AUTO-FILL OF TRANSACTION DETAILS

If applicable, and to facilitate automatic entry of the Transaction ID/Reference/UTR number associated with your deposit, we may require access to your SMS inbox. This allows our system to read relevant transactional messages and auto-fill the necessary details, eliminating the need for manual input by you. We will seek your explicit consent to access and read such SMSs (unless your device settings already grant this permission by default). Please note, our systems are programmed to read only transactional SMSs containing keywords linked to our partner entities.

Should you choose to manually enter the Transaction ID/Reference/UTR number during a deposit, you acknowledge and accept responsibility for any input errors that may lead to delays or failure in reflecting the transferred amount in your wallet. Importantly, your SMS data is not uploaded to our servers, shared with any third party, or used for advertising purposes. All access remains strictly local and limited to the required transactional information.

Disclaimer: To auto-fill transaction IDs (e.g., UTR numbers), we may request access to SMSs from specific partners (e.g., ABC BANK) containing predefined keywords. You will be prompted to provide explicit consent via an app pop-up, which you may revoke at any time through app settings. Only relevant transactional SMSs are accessed locally, and no other messages are read or stored.

THE LEGAL 'WHY' BEHIND EVERY BIT OF DATA WE USE

We process your personal data lawfully, fairly, and transparently, and only for specific, explicit, and legitimate purposes as communicated to you. The legal basis for processing your personal data will depend on the nature and context of our engagement with you and may include one or more of the following:

1. To fulfill a contract or take steps prior to entering into one, such as providing the services you request or meeting our obligations under our agreement with you.
2. To comply with applicable legal and regulatory obligations in India, including but not limited to obligations under the Information Technology Act, 2000, the Prevention of Money Laundering Act, 2002, the DPDP Act, 2023, and guidelines issued by statutory authorities and regulators from time to time.
3. To serve our legitimate business interests, such as enhancing user experience, improving our Services, and communicating with you regarding Suncrypto’s updates, offers, events, and promotions—provided this does not override your rights or freedoms. You may opt out of marketing communications at any time by clicking the “unsubscribe” link in our emails.
4. Based on your explicit and informed consent, which we may seek from you periodically for specific purposes where required by law or for processing that does not fall under the above categories.

Sharing your personal data with us is voluntary; however, if you choose not to provide certain requested information, we may not be able to deliver some or all of our Services effectively.

WHAT HAPPENS TO YOUR DATA ONCE IT REACHES US?

By providing your consent under this policy, you authorize us to collect, use, copy, transmit, process, disclose, store, and back up your personal data and/or information, which we handle with care for the purposes of delivering our Services and for the additional purposes outlined below.

*Please note that we are not responsible for the authenticity of any Personal Data, Information we handle with care, or other identification information provided by you or any third party acting on your behalf.

We may use your information for the following purposes:

1. To operate and administer our platform and services effectively;
2. To create and manage your user account, maintain your profile, and authenticate your identity;
3. To facilitate the use of features and services offered via our online platforms;
4. To process transactions related to digital assets;
5. To fulfil our contractual obligations under any agreement between you and the Company;
6. To perform KYC verification of your tax identification and other identification documents, including OTP generation and MPIN setup or third-party verification, based on your explicit consent;
7. To detect, prevent, and report suspicious or illegal activities, including money laundering, and to comply with legal obligations and enforce our legal rights;
8. To enable us or our selected third-party partners to provide relevant services;
9. To address inquiries, concerns, and complaints;
10. To provide information on promotions, offers, surveys, events, products, or services that may be of interest to you, and to communicate with you regarding our services;
11. For marketing, market research, and user profiling;
12. To tailor content and service offerings to your preferences;
13. To improve and personalize our services, ensure platform security, and enhance your overall experience;
14. To conduct internal research and analysis of user demographics, interests, and behaviors to better understand and serve our users;
15. To perform any other activities as required or authorized under applicable laws;

For any other purpose for which we seek and obtain your consent.

Data Transfers Due to Business Changes

In the event that our company undergoes a merger, acquisition, or sale of assets or business, your Personal Data may be transferred to the relevant third party. Should such a transfer result in your data being governed by a different privacy policy, we or the successor entity shall obtain your prior consent before processing your data under the new policy.

DISCLOSURE AND SHARING OF YOUR INFORMATION

You consent to the disclosure and sharing of your Personal Data with third parties in accordance with this policy. This includes data you provide directly, as well as information received from third parties based on your prior authorization. SunCrypto may share your data with our affiliates, group companies, business partners, and trusted third-party service providers who assist us in delivering core services such as platform functionality, analytics, in-app support, marketing, and data hosting. Such sharing is carried out strictly for the purposes and on the legal bases outlined in this Policy—for example, to improve user experience, measure performance, or enhance service features. Additionally, we may share aggregated or anonymized data that does not identify you personally for purposes including regulatory compliance, market and demographic analysis, benchmarking, advertising, and other legitimate business activities.

In certain cases, we may be obligated or reasonably required to disclose your Personal Data to comply with applicable laws, legal requests, or orders from courts, regulators, enforcement agencies, financial institutions, or government authorities. Disclosure may also occur to prevent fraud, identity theft, money laundering, or abuse of our services, or to address technical issues, protect vital interests, or enforce our contractual rights. Furthermore, we may engage trusted third-party vendors—such as KYC/AML verification providers like Signzy, Hyperverge, cloud service partners, and analytics firms—who are contractually bound to uphold the standards of the Digital Personal Data Protection Act, 2023 (DPDP Act) and equivalent data protection frameworks. We perform periodic compliance audits and remain accountable for any misuse by such third parties, subject to applicable law.

*Note: By agreeing to this Privacy Policy, you provide your consent for the above disclosures.

DATA SECURITY PRECAUTIONS

1. We have in place commercially reasonable technical and security measures to prevent unlawful access to or accidental loss of Personal Data collected including those prescribed under applicable laws. We do this by having in place a range of appropriate technical and organizational measures, including firewalls, encryption measures and disaster recovery plans. All Personal Data you provide to us is stored on our secure servers. We ask you not to share your password with anyone and to follow general internet etiquette in operating your User Account with us. In public areas, you should exercise caution and not leave your computer/device unattended, especially while logged into your User Account. The use of established malware and virus protection software and apps for your device is recommended.

2. Please remember that if you post any of your Personal Data in public areas of the Online Platforms, such information may be collected and used by others over whom we have no control.

3. You understand and acknowledge that any transmission through the internet is not completely secure and is at your own risk. While we will do our best to protect your Personal Data, we cannot guarantee or give any warranties in this regard and hereby disclaim all liabilities for any breach of security, malicious attacks, error, omission or commission concerning the data transmitted through the Online Platforms or leading to a breach of data or information of the User. We are not responsible for the circumvention of any privacy settings or security measures contained on the Services or Platforms done by you.

4. If you suspect any misuse or loss of or unauthorized access to your personal information, please let us know immediately. Please raise your concern at help@suncrypto.in in the first instance, and we will investigate the matter and update you as soon as possible on next steps.

5. We also may subject ourselves to regular checks by third-party security evaluation specialists and restrict access to your Personal Data by our personnel on a need-to-know basis only. Once we have received your Personal Data, we will use strict procedures and security features to try to prevent, as far as is reasonably possible, unauthorized access to your Personal Data.

6. We implement robust security measures, including encryption and firewalls, to protect your Personal Data. While we strive to prevent breaches, we are not liable for losses caused by your negligence (e.g., sharing passwords) or unauthorized acts beyond our reasonable control, provided we have complied with our obligations under the DPDP Act, 2023. Any breach will be promptly investigated and reported per applicable laws.

DATA RETENTION AND STORAGE

SunCrypto retains your Personal Data for the duration that your User Account remains active and for an additional period of 10 (ten) years after the last transaction on our Platform. This retention period is prescribed by legal frameworks, including the Prevention of Money-laundering Act, 2002 (PMLA); PML (Maintenance of Records) Rules 2005; Information Technology Act, 2000; Digital Personal Data Protection Act, 2023 (DPDP Act); and other applicable laws.

This extended retention ensures compliance with regulatory obligations such as Know Your Customer (KYC) requirements, legal audits, governmental or judicial investigations, enforcement of contractual rights, and resolution of disputes.

1. KYC and Transactional Data: Retained for a statutory period of 10 years from the date of cessation of activity, in line with the PMLA. Further, KYC and transaction data will be stored for any additional time periods for resolution of disputes, for the purpose of investigations or ongoing prosecutions, or in case of any suspicious/illegal transactions, for enforcement of any agreements, and/or as necessitated or authorized under Applicable Laws, and/or in order to protect your vital interests or the vital interests of another natural person.
The retention period may be extended in accordance with the Applicable Law and shall only be for such a period as is authorized by Applicable Law or as is absolutely necessary for us to comply with Applicable Law and/or for the provision of our Services to you.
2. Usage Data: Non-critical information, such as browsing history or activity logs, may be retained for up to 2 years to support operational analytics, platform improvements, or security monitoring.
After the applicable retention periods, we securely delete the data using industry-standard erasure techniques to ensure it is unrecoverable and inaccessible to unauthorized parties.
Upon account deletion, residual data may temporarily remain in backup or archival systems until overwritten. This data is considered “beyond use,” meaning it is no longer accessible to our personnel nor subject to active processing.
We do not retain data indefinitely, and any extension of retention is done strictly in accordance with legal mandates. We also disclaim any liability for the availability or retrieval of Personal Data after the expiry of the mandated retention period or closure of your User Account.

ENGAGEMENT OF THIRD-PARTY VENDORS

We may engage a range of third-party service providers to support the delivery of our Services. These service providers may be utilized for various purposes, including but not limited to:

(a) verifying your identity and documentation for payment processing;
(b) cross-checking information with public databases;
(c) conducting fraud detection and risk assessments;
(d) enabling service functionality through external platforms and software tools;
(e) providing customer support and marketing services;
(f) managing and processing claims; and
(g) any other purposes for which we obtain your explicit consent from time to time. These third-party service providers will have limited access to your Personal Data strictly to the extent necessary for performing their functions and in accordance with our strict instructions/directions, security measures, and privacy policies.

DATA COLLECTION THROUGH COOKIES AND SIMILAR METHODS

Cookies are small data files stored on your computer’s hard drive that contain information such as your user ID, preferences, pages visited, and activities performed while browsing the Online Platforms. These files function as data collection tools that help us analyze website traffic and assess the effectiveness of our promotional efforts. Most cookies used are "session cookies," which are automatically removed from your device once you end your session. You have the option, subject to your browser settings, to refuse or delete cookies at your own discretion, cost, and responsibility. However, please note that disabling cookies may limit your ability to fully access or use certain features and functionalities of the Online Platforms. We may use cookies and similar tracking technologies to enhance your experience on our Online Platforms and to store your preferences as a User. These small files of letters and numbers, stored on your browser or device (with your consent), help us distinguish you from other Users and support the delivery of personalized services, improved functionality, and security features.

By continuing to browse our Platforms, you consent to the use of such cookies. Usage of cookies is not linked to personally identifiable information. Additionally, we may automatically collect and analyze certain information about your behavior while using our Platforms or Services. This data, compiled on an aggregated basis, enables us to conduct internal research into user demographics, preferences, and behavior to better serve and protect our Users. We also utilize third-party analytics tools, which may employ cookies, web beacons, and server logs to gather insights on user interaction. These third parties may use the information collected to customize and deliver advertisements within their own networks. Please note, we do not have control over cookies deployed by such external service providers, which may include performance and targeting cookies.

We primarily use cookies to personalize your experience on our Online Platforms and to store your authentication token, allowing you to remain logged in without re-entering it on each visit. The information contained in these cookies is not directly linked to any personal data you may provide while using the Online Platforms. You have the option to disable cookies by adjusting your browser settings to refuse some or all types of cookies. Please note, however, that blocking all cookies—including those essential for site functionality—may limit or prevent your access to certain sections of our Online Platforms or the ability to use some of our Services. Additionally, if you choose to send us personal communications (such as emails or letters), or if such correspondence is shared with us by other users or third parties regarding your activities or posts on our Platforms, we may collect and retain that information as part of our records.

LINKS TO EXTERNAL WEBSITES AND APPLICATIONS

Our Services and Online Platforms may contain links to third-party websites or applications. By accessing these links, you may be redirected to external platforms that are not owned, operated, or controlled by us. We do not take responsibility for the content, privacy practices, or operations of such third-party platforms. Interactions with these platforms may involve sharing your Personal Data directly with them, with us, or with both. These third parties may handle your Personal Data in accordance with their own privacy policies and terms, which we strongly advise you to review carefully before providing any information. You acknowledge and agree that we are not liable for any loss of privacy, misuse of Personal Data, or other damages arising from your use of or reliance on such third-party websites or applications

YOUR RIGHTS UNDER THIS PRIVACY POLICY

You have the right to manage your Personal Data held by us in the following ways:

1. Verify whether we retain any of your Personal Data and access such information;
2. Request a copy of your Personal Data in a structured, commonly used, and machine-readable format (or, where feasible, request its transfer to another data controller);
3. Request corrections to any inaccurate or incomplete Personal Data, by notifying us in writing, and we will rectify it as soon as reasonably practicable;
4. Understand our policies and practices relating to the handling of your Personal Data;
5. Withdraw your consent where processing is based on consent, for specific purposes;
6. Request the deletion or erasure of your Personal Data;
7. Lodge any concerns or complaints with our Grievance Officer/Data Protection Officer (DPO).

You may exercise any of the above rights by submitting a request at help@suncrypto.in . While most requests can be addressed promptly, complex inquiries may require additional time and effort. We reserve the right to charge a reasonable fee for processing access requests, where applicable.

Please note, the Company may retain part or all of your data in accordance with its internal policies or as mandated by Applicable Law.

RIGHT TO RESTRICT DATA USAGE

We are unable to process your Personal Data and/or Information we handle with care to provide access to our Online Platforms or process any service application without your prior consent. To withdraw your consent for data processing, please send a written request to dpo@suncrypto.in using your registered email address, including your user ID. We will acknowledge your request within 48 hours and process it within 7 business days, unless required by law to continue processing. Withdrawal may result in restricted access to certain services, such as trading or wallet functionality, or account deactivation, as detailed in our Terms of Use.

Please note that the withdrawal of consent does not affect the legality of any data processing carried out based on consent provided prior to such withdrawal.

You will also have the option to opt out of receiving marketing communications. By exercising this option, you confirm that you do not wish to:

a. receive direct marketing communications via phone, SMS, email, fax, mail, or any other channel; and
b. allow us to share your Personal Data with any third party for their own advertising or marketing purposes, regardless of whether they are affiliated with the Company.

However, if you apply for or use a Service that is offered in partnership with a co-branded entity, this opt-out shall not apply to such co-branding partner where you have separately consented to the sharing of your data.

YOUR RESPONSIBILITIES AS A USER

You agree to:

a. Refrain from impersonating any individual or misrepresenting your identity when providing information to us;
b. Avoid submitting any false, frivolous, or misleading grievances or complaints through our redressal channels or to any regulatory authority;
c. Provide only accurate and verifiable information, especially when exercising your rights to correct or erase personal data under Applicable Laws; and
d. Abide fully by the terms of this Privacy Policy and the associated Terms of Use at all times.

PRIVACY FOR CHILDREN AND VULNERABLE INDIVIDUALS

Unless expressly stated otherwise, access to our Online Platforms and Services is restricted to individuals who are at least 18 (eighteen) years of age.

We recognize the importance of protecting the Personal Data of individuals with disabilities who are legally represented by a guardian under Applicable Law. If you are a person with a disability and have a lawful guardian, you may access and use our Services only under the direct supervision of your guardian. In such cases, the lawful guardian must provide verifiable consent on your behalf. By agreeing to this Policy and providing consent, you confirm that you are the lawful guardian of the individual concerned. For users with disabilities requiring a guardian, verifiable consent from the guardian is mandatory.

Disclaimer: Our Services are restricted to users aged 18 and above, verified through KYC processes. If we inadvertently collect Personal Data from individuals under 18, such data will be immediately deleted upon detection.

TRANSNATIONAL PROCESSING OF PERSONAL DATA

Subject to Applicable Laws, we may transfer and store your Personal Data outside India ("Alternate Country") in order to support our business operations. Such transfers may be carried out by us, our Affiliates, or trusted partners located in foreign jurisdictions. We ensure that any such transfer is conducted lawfully and solely to fulfill our contractual or legal obligations, including the provision of Services to you.

Only that portion of your Personal Data which is legally permissible for transfer under Applicable Laws will be transferred. By continuing to use our Services, you acknowledge and consent to such international transfers.

When transferring your Personal Data from India to any Alternate Country, we adhere to all relevant legal and regulatory requirements, including establishing a lawful basis for the transfer and implementing appropriate safeguards to maintain an adequate level of data protection. We will also ensure that the recipient entity is bound to protect your Personal Data to a standard that is at least comparable to that required under Indian data protection laws.

Subject to the DPDP Act, 2023, we may transfer your Personal Data to trusted partners or affiliates for operational purposes, such as cloud storage or transaction processing. Such transfers are protected by standard contractual clauses and regular audits to ensure compliance with Indian data protection standards. In case of concerns regarding cross-border data handling, you may contact our DPO at dpo@suncrypto.in or escalate to the Data Protection Board of India.

USAGE AND COLLECTION OF NON-IDENTIFIABLE AND NON-PERSONAL DATA

NON-PERSONAL INFORMATION refers to data that does not directly identify you. When you visit or interact with our Online Platforms—or with third-party service providers engaged by us—we may collect certain non-identifiable information such as the pages you browse, domain names, sections of the website you interact with, URLs accessed, and similar usage data. This helps us understand user behavior and improve your overall online experience.

We may use or share non-personal information for various purposes, including analytics, personalization, and service enhancements. In some cases, we may embed identifiers (such as email addresses) in digital assets like images. Where non-personal data is combined with personal data in a manner that makes identification possible, we will treat such combined data as Personal Data in accordance with this Policy.

ROBUST DATA SECURITY MEASURES

1. We will report any theft or loss of Personal Data in accordance with applicable Data Protection Laws.
2. The collection or access of Personal Data by us is strictly limited to what is necessary to fulfill our obligations in providing services, complying with legal requirements, or as otherwise expressly consented to by you. We do not share your Personal Data with any third party except as explicitly outlined in this Policy.
3. You acknowledge and agree that, aside from the uses specified herein, we reserve the right to collect, use, or analyze Personal Data in an anonymized or aggregated form for analytical or research purposes.
4. We strongly advise against including any Information we handle with care in emails sent to us. Please refrain from sharing credit/debit card details or other sensitive information through unsecure communication channels such as email.
5. Notwithstanding anything contained in this Policy, we shall not be held liable for any loss, damage, or misuse of your information if it results from a Force Majeure Event (as defined in our Terms).

UPDATES TO THIS PRIVACY POLICY

This Policy may be revised or updated from time to time, as required by applicable laws or in response to operational or business needs. We will provide you with appropriate notice of any material changes. We encourage you to review this Policy periodically to stay informed about our privacy practices. Your continued use of the Online Platforms after such updates shall be deemed as your acceptance of the revised Policy and Terms.

SEVERABILITY

If any provision of this Policy is determined to be invalid, void, or unenforceable by a court of competent jurisdiction, such determination shall not affect the validity or enforceability of the remaining provisions, which shall continue in full force and effect.

COSTS AND FEES FOR EXERCISING DATA RIGHTS

We are committed to facilitating your rights under the Digital Personal Data Protection Act, 2023, including your right to access, correct, delete, or obtain a copy of your Personal Data. These services are provided free of charge in most cases.

However, in limited circumstances where a request is manifestly unfounded, repetitive in nature, excessive, or imposes a disproportionate administrative burden, we reserve the right to charge a reasonable fee to cover the actual cost of processing such requests. In such cases, you will be notified in advance about any applicable fee and the rationale behind it. You will have the opportunity to withdraw or modify your request if you choose not to proceed. We will never impose a fee merely for the purpose of deterring the exercise of your rights under Applicable Law.

NOTICES

We may provide any notice to you under any of our policies by sending a message to the email address then associated with your User Account. Notices we provide by email will be effective when we send the email. It is your responsibility to keep your current email address active. To give us notice under any of our policies, you must contact us by support email at help@suncrypto.in, by courier to/via our registered address at Plot C-26D, RIICO INDUSTRIAL AREA, MALVIYA NAGAR, JAIPUR, RAJASTHAN 302017 or the Data Protection Officer at dpo@suncrypto.in, or by electronic communication via the Online Platforms from time to time for such purpose. Notices provided by the courier will be effective 1 (one) business week after they are sent. Notices provided by registered mail will be effective 3 (three) business days after they are sent.

GRIEVANCE HANDLING & DATA PROTECTION OVERSIGHT

If you have any grievances, feedback, or queries regarding the collection, use, disclosure, or security of your Personal Data, or wish to exercise your data protection rights, you may contact us at help@suncrypto.in or our Data Protection Officer (DPO) at dpo@suncrypto.in Please mention “Privacy Policy” in the subject line and clearly outline your concern, attaching any supporting documentation where applicable

All communications will be securely logged and used solely for the purpose of addressing your request. We are committed to acknowledging your grievance within 48 hours of receipt and aim to resolve all issues in a fair, transparent, and timely manner. Our grievance redressal mechanism is designed to uphold professionalism and respect in all user interactions.

If your grievance is not satisfactorily addressed within a reasonable time or remains unresolved, you may escalate the matter to the Data Protection Board of India, as per the applicable provisions of the Digital Personal Data Protection Act, 2023.