PRIVACY POLICY

Privacy Statement

PLEASE READ THIS PRIVACY STATEMENT/PRIVACY POLICY CAREFULLY. “YOU” AND “YOUR” SHALL REFER TO THE CUSTOMER OR SUBSCRIBER OR VISITOR OF THE IMPACTVIBES PRIVATE PRIVATE LIMITED WEBSITE https://justconnect.biz. “WE,” “OUR” OR “US” SHALL REFER TO IMPACTVIBES PRIVATE LIMITED, PROVIDING OR OFFERING SERVICES TO YOU OR CUSTOMER OR SUBSCRIBER OF THE JUST CONNECT ( IMPACTVIBIES PRIVATE LIMITED).

This Privacy Statement/Policy explains the collection, use, protection, disclosure, sharing and transfer, if any, of “personal information” by JUST CONNECT (IMPACTVIBES PRIVATE LIMITED) By using our website or our products/services or otherwise providing information to us through this website, you consent that your personal information may be used and handled as described in this Privacy Statement.

This Privacy Policy is subject to changes as per applicable laws and regulations and shall stand amended from time to time.

Definition of Personal Information Personal Information includes:

Personally Identifiable Information: “Personally Identifiable Information” is information that is about, or can be related to, an identifiable individual. It includes any information that can be linked to an already identified individual or used to directly or indirectly identify an individual. Personal information does not include information that is anonymous, aggregated, or is no longer identifiable to a specific person.

Sensitive Personal Data or Information: “Sensitive Personal data or Information” means personal information which is more sensitive in nature viz. financial information such as Bank account or credit card or debit card or other payment instrument details, Biometric details, passwords or authentication information for any of our products or services etc.

For the purposes of this Privacy Statement, sensitive personal data or information has been considered as a part of Personal Information.

This Privacy Statement describes the Personal Information which we may collect and our approach towards handling or dealing with the same. This Privacy Statement is designed to enable you understand:

• Personal information that we collect and methods of collection

• Purposes of collection and usage of personal information

• Measures taken by us to protect your personal information

• Usage of Cookies, Device Identifiers and other similar technologies

• Location Based Services (LBS)

• Disclosure, Sharing and Transfer of your Personal Information

• Ways by which you can access and update your Personal Information

This Privacy Statement is provided for your information and is not intended to limit or exclude your rights under laws and regulations applicable in India.

1. Collection of Personal Information

JUST CONNECT (IMPACTVIBES PRIVATE LIMITED) and its authorized Third Parties will collect information pertaining to your identity, demographics, and related evidentiary documentation. For the purposes of this document, a ‘Third Party(ies)’ is a service provider which is associated with JUST CONNECT(IMPACTVIBES PRIVATE LIMITED) and is involved in handling, managing, storing, processing, protecting and transmitting information on behalf of JUST CONNECT (IMPACTVIBES PRIVATE LIMITED) This also includes all sub-contractors, consultants and/or representatives of the Third party.

The information we collect about you will depend on our services you use and/or subscribe to. We may hold information relating to you that you have provided to us on Customer Acquisition/Application form (CAF) or that we may have obtained from another source such as our suppliers or from marketing organizations and credit agencies. We may also collect your personal information when you use our services, websites, and applications or otherwise interact with us during the course of our relationship.

The information we may collect includes, but is not limited to, the following:

• Your name, father’s name, mother’s name, spouse’s name, date of birth, current and previous addresses, telephone number, mobile phone number, email address, occupation and any such information contained in the documents used as proof of identity and proof of address.

• Your sensitive personal information such as Bank account or credit card or debit card or other payment instrument details, Biometric details, physiological information, passwords or authentication information for use of our products or services etc.

• We may use cookies and other techniques, such as web beacons, to collect information about how you use our websites, and web-related products and services. This allows us to customize our website for you so that it is relevant to your interests and needs.

• Your preferences for particular services when you tell us what they are or when we assume what they are based on how you use our products and services.

• Your contact with us, such as: a note or recording of a call you make to one of our contact centers, an email or letter you send to us and other records of any contact you have with us.

• Device Identifiers which are used to identify your mobile device for interest-based targeted advertising.

• Use of Personal Information:

The information that we collect from you is held in accordance with applicable laws and regulations in India. It may be used by us for a number of purposes connected with our business operations and functions. We may use this information to contact you regarding matters relevant to the underlying service provided. Further we may use and analyze your personal information for various lawful purposes and enrichment of service experience. If required for business and to provide better services to you, we may share your information with our business partners and third parties (during our business association with them), while you are availing service through us.

The purpose for which your personal information may be used includes, but is not limited to:

• Provide, maintain and improve our services;

• Verify your identity as mandated by laws and regulations;

• Process your orders and applications;

• Keep you informed about services unless you do not want to receive our marketing messages; Respond to any questions or concerns that you may have about using our network, products or services;

Carry out any activity in connection with a legal, governmental or regulatory requirement on us or in connection with legal proceedings, crime or fraud prevention, detection or prosecution;

Carry out activities connected with the running of our business such as personnel training, quality control, network monitoring, testing and maintenance of computer and other systems and in connection with the transfer of any part of our business in respect of which you are a customer or a potential customer;

Other usages that you may consent to;

IMPACTVIBES PRIVATE LIMITED will retain your information for as long as we have to by law and as per directions of the regulatory & law enforcement authorities.

3. How We Protect Your Personal Information

We adopt reasonable security practices and procedures, to include, technical, operational, managerial and physical security controls in order to protect your personal information from unauthorized access, or disclosure while it is under our control.

• To prevent unauthorized access, maintain data accuracy, and ensure the correct use of information, we maintain appropriate physical, electronic, and managerial procedures to safeguard and secure the information and data stored

• on our system.

• We have specialized security teams who constantly review and improve our measures to protect your personal information from unauthorized access, accidental loss, disclosure or destruction.

• Our security practices and procedures limit access to personal information on a need to know basis. Further, our employees, to the extent they may have limited access to your personal information on a need to know basis, are bound by JUST CONNECT(IMPACTVIBES PRIVATE LIMITED) Code of Conduct and confidentiality policies which obligate them to protect the confidentiality of your personalinformation.

• We take steps to ensure that our contracted third parties adopt reasonable level of security practices and procedures to ensure security of personal information. We cannot protect any information that you make available to the general public in any publicly accessible area of our website or any other media.

• When we dispose of your personal information, we use reasonable procedures to erase it or render it unreadable.

• No data transmission over the Internet is completely secure and for reasons outside of our control, security risks may still arise. Any personal information transmitted to us or from our online products or services will therefore be at your own risk. However, we will strive to ensure the security of your information. We observe reasonable security measures to protect your personal information against hacking and virus dissemination.

In case of any concerns the privacy officer can be contacted at justconnect.biz

4. Use of Cookies and similar technologies

We may use cookies and other interactive techniques to collect personal and non-personal information about you. The cookies mean that our website platforms may remember you to personalize the content and how you've used the site every time you come back; understand what you like and use about our website; understand what you do not like and do not use on our website; provide a more enjoyable, customized service and experience, and help us develop and deliver better products and services tailored to our customers’ interests and needs.

We may sometimes use a persistent cookie to record details such as a unique user identity and general registration details on your PC. This helps us recognize you on subsequent visits to this website so that you don't have to re- enter your registration details each time you visit us and allows us to carry out the activities mentioned above.

JUST CONNECT(IMPACTVIBES PRIVATE LIMITED) does not have access to or control of the cookies /device identifiers that may be placed and used by third party applications, websites or platforms. These third party sites have separate and independent privacy policies. We, therefore, have no responsibility or liability for the content and activities of these third party sites. Nonetheless, we seek to protect the integrity of our website/applications.

Most browser technologies (such as Internet Explorer, Chrome, etc.) allow you to choose whether to accept cookies or not – you can either refuse all cookies or you can set your browser to alert you each time that a website tries to set a cookie.

5. Disclosure, Sharing and Transfer of Personal Information Authorized Third Parties:

JUST CONNECT (IMPACTVIBES PRIVATE LIMITED) may at its discretion employ, contract or include third parties external to itself for strategic, tactical and operational purposes. We may disclose and/or transfer your personal information or other information collected (as

defined in section 1: Collection of personal information), stored and processed by us to such third parties. Such third parties though external to the Company, will always be entities which are covered by contractual agreements. This may also include:

• Sharing your Sensitive Personal Data or Information. However, we shall seek explicit consent from you at the time of collection if we intend to share your Sensitive Personal Data or Information with third parties.

• Customer Verification agencies.

• Credit-reference agencies, fraud-prevention agencies, business-scoring agencies or other credit-scoring agencies.

• Our Business partners involved in delivering and improving our services.

• Our IT vendors hosting our websites and applications; operating various features available on the website and applications; sending emails; analyzing data; providing search results and links and assisting in fulfilling your orders.

Government Agencies:JUST CONNECT( IMPACTVIBES PRIVATE LIMITED ) may also share your personal information with Government agencies or other authorized law enforcement agencies (LEAs) mandated under law to obtain such information for the purpose of verification of identity or for prevention, detection, investigation including but not limited to cyber incidents, prosecution, and punishment of offences. This may also include sharing your Sensitive Personal Data or Information.

Other Scenarios: We may transfer personally identifiable information as an asset in connection with a merger or sale (including any transfers made as part of an insolvency or bankruptcy proceeding) involving all or part of our business or as part of a corporate reorganization, stock sale or other change in control. JUSTCONNECT (IMPACTVIBES PRIVATE LIMITED) may disclose Contact Information in special cases where we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be violating our terms and conditions of use or may be causing injury or interference with our rights, property, our customers or anyone who could be harmed by such activities.

6. Update of Personal Information

We strive to keep our records updated with your latest information. To this end, if you see any discrepancy in your personal information or if a part of your personal information changes, we request you to reach out to our customer service at https://justconnect.biz.

and communicate the change(s) for updating our records. You may however need to walk in to any of our stores and follow prescribed procedures to request or update your personal information.

7. Notification of Changes

JUST CONNECT(IMPACTVIBES PRIVATE LIMITED) reserves the right to amend / alter / modify and /or change this Privacy Statement at its sole discretion as needed based on change in technology, laws, rules and regulations both national and international as may be applicable, orders and instructions from judicial, quasi-judicial , administrative authorities and Licensor viz DOT apart from business exigencies and consumer interest at large . If there is such change to our Privacy Statement, the same shall be updated on the Company website and from such date of updating the Privacy policy will be displayed on the website and shall be applicable.

8. Contact Us

We are committed to safeguarding your personal information collected and handled by us and look forward to your continued support for the same. In case of any feedback or concern regarding protection of your personal information, you may reach us by contacting https://justconnect.biz

9. Eligibility

The Website is only meant for use by a Sender, either being a Principal Entity or a Registered Telemarketer, for the purposes stated in the scope. If you do not fall under any of the categories stated above, you cannot use the Website. If you are a minor i.e. under the age of 18 years, you cannot use the Website. We reserve the right to terminate your account and / or refuse to provide you with access to the Website if it is brought to our notice or if it is discovered that you are incompetent to contract.

Payment declaration by Principal Entity:

We have applied for a Principal Entity registration on DLT (Distributed Ledger Technology) portal of M/s VCon Mobile & Private Limited as prescribed under the TCCCPR regulations, 2024 issued by TRAI. We are also in agreement that the registration fee towards Principal Entity registration shall be paid by us directly or through a third party on our behalf through our login credential via JUST CONNECT (IMPACTVIBES PRIVATE LIMITED) portal and as a Principal Entity we shall be solely responsible for all compliance(s) with regard to the regulations governing the PE registration process & any banking or legal obligations as applicable.