1. Scope and Purpose

This Policy explains how we collect, use, store, process, disclose, and protect your personal information while offering our services. It applies to all online and offline interactions between you and SocialPE. It does not apply to third-party sites, payment gateways, or partner networks accessed through links on our Platform. This Policy constitutes an electronic record under the Information Technology Act, 2000 and related rules, including the SPDI Rules (2011). It does not require a physical signature.

2. Information We Collect

We may collect personal and sensitive information directly from you or indirectly from third-party sources to provide services effectively.

a.Information You Provide

When you register or use our services, we may collect:

• Name, mobile number, date of birth, gender, and email address.
• KYC documents such as PAN, Aadhaar, driving licence, signature, and photograph (especially for digital gold investments).
• Banking and payment details: bank account number, IFSC, UPI ID, card details, billing address, payment history.
• Permissions granted via the app such as access to gallery, SMS (for OTP verification), location, or contact list (for referral tracking).
• Details of your recharges, bill payments, OTT purchases, cashback transactions, and digital gold holdings.
• Referral data, cashback earnings, and purchase history from partner networks like Amazon.
• Communications, support messages, or feedback shared via chat, email, or in-app forms.

b. Automatically Collected Information

When you use the Platform, we collect:

• Device information: device type, OS version, browser type, mobile network, IP address, and unique identifiers.
• Usage data: login timestamps, pages viewed, buttons clicked, and service interactions.
• Location data: approximate or precise location (if enabled) to provide nearby offers or verify transactions.
• Log and analytics data: through cookies, tracking pixels, and analytics tools to understand user behaviour and improve performance.

c. Third-Party Information

We may receive data from:

• Payment gateways, UPI service providers, telecom operators, and biller networks for transaction confirmation.
• KYC agencies or partners to validate identity information.
• Affiliate partners (like Amazon or Flipkart) for cashback and referral processing.

3. Purpose of Data Collection

We use your information to:

1. Register and manage your account on the SocialPE app.
2. Facilitate digital gold transactions (purchase, transfer, redemption).
3. Enable mobile recharge, DTH, and utility bill payment through integrated APIs.
4. Process OTT subscriptions and renewals.
5. Track refer-and-earn activities, compute eligible rewards, and prevent referral fraud.
6. Manage cashback offers and ensure payout of valid earnings.
7. Authenticate your identity (KYC/OTP) and secure your transactions.
8. Communicate updates, service notifications, and promotional offers.
9. Improve app performance, design, and customer experience.
10. Comply with applicable laws, taxation, and anti-money-laundering (AML) regulations.

Your information also helps us personalise offers, improve reliability, and provide quick resolution to your queries.

4. How We Share Your Information

We respect your privacy and do not sell personal data. However, information may be shared under these circumstances:

• Service providers: Payment gateways, KYC partners, gold vendors, OTT content partners, and recharge/bill payment aggregators — only to fulfil your requests.
• Business partners: Cashback and referral partners such as Amazon, telecom service providers, or other merchants where you transact through SocialPE.
• Regulators or authorities: When legally required for audits, tax filings, or law-enforcement purposes.
• Corporate affiliates: Subsidiaries, group companies, or successors during a merger or restructuring (subject to confidentiality).

All partners are bound by data-protection obligations to handle your information securely.

5. Cookies and Tracking Technologies

We use cookies, local storage, and similar technologies to:

• Recognize repeat visitors and maintain login sessions.
• Analyse traffic patterns, performance, and app usage.
• Offer personalised deals, cashback alerts, and referral recommendations.

You can disable cookies via your browser or device settings, but certain features may not function properly.

6. Data Retention

We retain personal information only as long as necessary for the purposes described here or as mandated by law. For instance, transaction records for digital gold, recharges, and bill payments are retained to comply with RBI, tax, and AML regulations. After the retention period, data is securely deleted or anonymised.

7. Data Security

We employ appropriate administrative, technical, and physical safeguards to protect your data from loss, misuse, or unauthorised access. These include encryption, firewalls, access controls, and secure cloud infrastructure. While we take reasonable precautions, no online platform can guarantee absolute security. You must keep your password confidential and log out after each session.

8. Your Rights

You may:

• Access or download your personal information.
• Request correction of inaccurate or incomplete details.
• Request deletion of your account (subject to retention obligations).
• Opt out of marketing or promotional communications.
• Withdraw consent for specific permissions like location access or SMS reading.

To exercise these rights, contact us at [email protected]. We may verify your identity before processing any request.

9. Children’s Privacy

Our services are designed for users aged 18 years or above. We do not knowingly collect personal data from minors. If a minor has provided information, we will promptly delete it upon notice.

10. Third-Party Links

Our Platform may include links to third-party websites, OTT providers, bill-payment partners, or shopping portals. Their data practices are governed by their own privacy policies, and we are not responsible for their actions.

11. International Transfers

Data collected by SocialPE may be processed in or transferred to locations outside India through secure and compliant systems. We ensure adequate protection standards in line with Indian data-protection norms.

12. Updates to this Policy

We may update this Policy periodically to reflect changes in law, technology, or business practices. The revised version will carry an updated “Last Updated” date and will be posted on the Platform. Continued use of the Platform after updates implies acceptance of the revised Policy.

13. Consent

By using the SocialPE app or website, registering an account, or performing any recharge, bill payment, OTT purchase, or gold investment, you acknowledge that you have read and understood this Policy and consent to the collection, use, and disclosure of your data as described. If you act on behalf of another person or entity, you confirm you are authorised to bind them to this Policy.

14. Contact Us

If you have any questions, concerns, or complaints regarding this Privacy Policy or data handling, please contact us:

SOCIALPE ITES PRIVATE LIMITED

Email: [email protected]

Effective 10-Oct-2025

This Privacy Policy is effective as of 10-Oct-2025. We encourage you to check for updates periodically to stay informed about our data practices. Thank you for choosing SocialPe, and we look forward to providing you with a safe and rewarding experience within our app.

Disclaimer: This Privacy Policy is an electronic record under the Information Technology Act, 2000 and does not require any physical or digital signature. SocialPE remains committed to maintaining transparency and ensuring that your trust and data privacy are always protected.