PRIVACY POLICY

1. BACKGROUND AND KEY INFORMATION

1.1 Applicability

This Privacy Policy applies to all individuals who access or use Quiet Cool LLP's ("QC") Platform and/or avail Services through it. References to "you" or "Customer" refer to end users of the Platform.

By using the Platform, you acknowledge and consent to the collection, storage, processing, use, and disclosure of your personal data in accordance with this Policy.

1.2 Updates

QC reviews this Policy periodically and may update it from time to time to reflect changes in law, technology, or business practices. Any updates will be published on the Platform. Your continued use of the Services after such updates shall constitute acceptance of the revised Policy.

1.3 Third-Party Services

The Platform may include links to or integrations with third-party websites, applications, or services. QC does not control or endorse such third parties and is not responsible for their privacy practices or content. When you access third-party links or services, you do so at your own risk, and we encourage you to review their privacy policies before sharing any personal data.

2. PERSONAL DATA WE COLLECT

QC may collect, process, and store the following categories of personal data when you access, use, or interact with the Platform and Services:

2.1 Contact Data

Includes your phone number, email address, postal address, and geolocation (where services require it).

2.2 Identity & Profile Data

Includes your name, username or account identifiers, gender, profile picture, and any identification documents you may provide for verification.

2.3 Transaction Data

Includes records of service bookings, billing details, payments made, UPI IDs, and limited card details processed securely through third-party payment processors.

2.4 Technical Data

Includes information automatically collected when you use the Platform, such as IP address, device identifiers, browser type, operating system, mobile network information, application usage statistics, and geolocation data.

2.5 Usage Data

Includes information about your interaction with the Platform and Services, such as booking history, service preferences, clicks, time spent, navigation paths, ratings, and feedback.

2.6 Marketing & Communications Data

Includes your communication preferences, survey responses, reviews, and interactions with QC's marketing campaigns, notifications, or promotional messages.

2.7 Voluntary Data

Includes any information or content that you voluntarily provide to QC, such as comments, uploaded documents or images, feedback, or participation in promotions.

2.8 Aggregated & Anonymized Data

QC may collect, use, and share aggregated or anonymized data for research, analytics, trend identification, or service improvement. Such data:

• • Does not directly or indirectly identify you as an individual;
• • Is created by removing or masking personal identifiers;
• • May be retained and used indefinitely for statistical or business purposes without further notice to you.

3. HOW WE COLLECT PERSONAL DATA

QC collects personal data about you through the following sources:

3.1 Direct Interactions

We collect data that you provide directly when you:

• • Create or update your account on the Platform.
• • Book or manage services.
• • Communicate with QC for support, inquiries, or dispute resolution.
• • Participate in surveys, feedback forms, contests, or promotions.
• • Share content such as reviews, comments, or uploaded files.

3.2 Automated Technologies

When you use the Platform, certain information is automatically collected through:

• • Cookies and Tracking Technologies – small files that track usage, preferences, and activity.
• • Server Logs – data relating to device type, IP address, time of access, and app/web interactions.
• • Pixels, Tags, and SDKs – technologies that measure engagement, enable analytics, and improve service delivery.

3.3 Third-Party Sources

We may also receive data about you from trusted external sources, including:

• • Service Professionals – who provide services booked by you through QC.
• • Payment Gateways & Processors – for verification and transaction-related information.
• • Analytics & Advertising Providers – who help us improve services and marketing effectiveness.
• • Publicly Available Sources – such as government databases, public directories, or social media (where legally permitted).

4. USE OF PERSONAL DATA

QC uses your personal data for the following purposes:

4.1 Service Delivery

• • To verify your identity and create/manage your account.
• • To enable you to book, manage, and avail QC Services.
• • To share necessary details with service professionals for execution of jobs.
• • To facilitate payments, track transactions, and generate invoices.

4.2 Customer Experience

• • To improve, personalise, and optimise the Platform and Services.
• • To communicate service updates, booking confirmations, alerts, and promotional offers.
• • To collect feedback, reviews, and survey responses to enhance quality.

4.3 Support & Complaint Handling

• • To address queries, complaints, or disputes raised by you.
• • To provide customer support in line with Service Level Agreements (Annexure A).

4.4 Safety, Security & Compliance

• • To detect, investigate, and prevent fraud, abuse, or misuse of the Platform.
• • To monitor compliance with QC's policies, Terms & Conditions, and applicable laws.
• • To protect the safety, rights, and property of QC, its customers, and service professionals.

4.5 Legal & Regulatory Requirements

• • To comply with obligations under the Information Technology Act, 2000, Consumer Protection Act, 2019, GST regulations, and other applicable laws.
• • To respond to lawful requests from courts, regulators, or government authorities.

5. COOKIES & TRACKING TECHNOLOGIES

5.1 Use of Cookies

QC uses cookies, pixels, beacons, and other tracking technologies ("Cookies") to enhance your experience on the Platform. Cookies help us to:

• • Recognise returning users and remember login details or preferences.
• • Maintain session integrity and provide a secure browsing experience.
• • Analyse Platform traffic, usage patterns, and trends to improve functionality.
• • Deliver personalised advertisements, offers, and recommendations.
• • Measure the effectiveness of marketing campaigns.

5.2 Types of Cookies

a) Essential Cookies – Required for the Platform to function (e.g., login authentication, security).

b) Performance Cookies – Collect information on how users interact with the Platform, enabling us to optimise performance.

c) Functional Cookies – Store your preferences (e.g., language, location) to personalise services.

d) Advertising/Targeting Cookies – Track browsing behaviour to deliver relevant ads and promotions.

5.3 Third-Party Cookies

QC may allow trusted third-party service providers (e.g., analytics, advertising networks, payment gateways) to place cookies on your device. These providers are responsible for their own privacy practices, and we encourage you to review their policies.

5.4 User Control

• • You may disable or manage cookies via your browser or device settings.
• • Please note, disabling essential cookies may limit or prevent access to certain Platform features.

5.5 Consent

By continuing to use the Platform, you consent to QC's use of cookies and tracking technologies as described in this Policy.

6. DISCLOSURE OF PERSONAL DATA

QC may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to confidentiality obligations:

6.1 Service Professionals

• • Your data (e.g., name, contact number, service address, service history) may be shared with authorised Service Professionals to enable them to perform the services you have booked.

6.2 QC Affiliates & Group Entities

• • Personal data may be shared within QC's group companies and affiliates for operational, administrative, analytical, or customer support purposes.

6.3 Trusted Vendors & Partners

We may share your data with third-party service providers, such as:

• • Payment processors and gateways.
• • IT infrastructure providers (e.g., hosting, cloud services).
• • Customer communication and marketing partners.
• • Data analytics and advertising networks.
• • Logistics, warranty, and spare-part suppliers (if applicable).

6.4 Regulators & Government Authorities

Personal data may be disclosed where required:

• • By applicable law, regulation, legal process, or enforceable government request.
• • To enforce QC's legal rights, Terms of Service, or Privacy Policy.
• • To protect QC, its customers, Service Professionals, or the public against harm, fraud, or security risks.

6.5 Successors & Acquirers

• • In the event of a business transition (such as merger, acquisition, investment, restructuring, or sale of assets), your data may be transferred to the new entity as part of the transaction, subject to the same privacy commitments.

6.6 With Your Consent

QC will share your personal data with third parties in cases where you have provided explicit consent.

• • Such consent will always be obtained in a clear and specific manner.
• • You retain the right to withdraw your consent at any time under Section 7.4 (Right to Withdraw Consent).
• • Withdrawal of consent will not affect processing carried out lawfully prior to such withdrawal.

6.7 Franchise & Service Partners

Your personal data may be shared with authorized QC franchise partners or service fulfilment providers, strictly for the purpose of delivering services you have booked. These partners are contractually bound to handle your data only as per QC's policies and applicable laws.

7. YOUR RIGHTS IN RELATION TO PERSONAL DATA

As a user of QC's Platform and Services, you have the following rights regarding your personal data, subject to applicable laws:

7.1 Right to Access

• • You may request details of the personal data QC holds about you, including how it is being processed.

7.2 Right to Correction & Updating

• • You may request correction of inaccurate, incomplete, or outdated personal data at any time.

7.3 Right to Deletion

• • You may request deletion of your personal data where:
• • It is no longer necessary for the purpose for which it was collected.
• • You withdraw consent (where processing is based on consent).
• • Retention is not required under law or for dispute resolution.

7.4 Right to Withdraw Consent

• • Where QC relies on consent to process your data (e.g., for marketing), you may withdraw your consent at any time. Withdrawal will not affect lawful processing prior to withdrawal.

7.5 Right to Data Portability

• • You may request a copy of your personal data in a commonly used, machine-readable format, to the extent feasible.

7.6 Right to Restrict Processing

• • You may request QC to restrict further processing of your personal data in certain circumstances, such as when verifying accuracy or objecting to processing.

7.7 Right to Object to Direct Marketing

• • You may object to the processing of your personal data for marketing or promotional purposes at any time.

7.8 Right to Grievance Redressal

• • You have the right to raise complaints regarding data handling practices. QC's Grievance Officer details are provided in Section 15 (or Annexure F).

7.9 Timeframe for Response

• • QC will acknowledge rights-based requests within 7 working days and will endeavour to fulfil them within 30 working days, subject to applicable law.

7.10 Limitations

• • Some rights may be restricted under Indian law, including for reasons of national security, fraud prevention, compliance with legal obligations, or enforcement of QC's Terms.

8. DATA SECURITY & STORAGE

8.1 Security Measures

QC implements appropriate technical, organizational, and physical safeguards to protect your personal data against unauthorized access, alteration, disclosure, or destruction, including but not limited to:

• • Encryption of sensitive data during transmission and storage.
• • Secure servers & firewalls for Platform hosting.
• • Role-based access controls ensuring only authorised personnel can access customer data.
• • Call masking and OTP verification for safe communication with Service Professionals.
• • Regular audits and penetration testing of QC systems.

8.2 User Responsibilities

While QC takes reasonable precautions, you are responsible for:

• • Maintaining the confidentiality of your account credentials.
• • Using strong, unique passwords and updating them periodically.
• • Immediately notifying QC of any unauthorised access or suspected breach.

8.3 Data Storage Location

• • Personal data is primarily stored on secure servers located within India.
• • In certain cases, data may be transferred to servers outside India, subject to compliance with applicable Indian laws and adequate protection measures.

8.4 Data Retention

QC will retain your personal data only for as long as necessary to fulfil the purposes outlined in this Policy, including:

• • For the duration of your account and reasonable time after closure.
• • As required by applicable laws (tax, accounting, regulatory).
• • For resolving disputes or enforcing agreements.

8.5 Data Breach Protocol

• • In the event of a data breach likely to result in harm, QC will:
• • Notify affected users and relevant regulators within legally prescribed timelines.
• • Take immediate steps to contain the breach and mitigate risks.
• • Provide guidance to users on protective measures.

9. DATA RETENTION & DELETION

9.1 Retention Periods

QC retains your personal data only for as long as necessary to:

• • Fulfil the purposes for which it was collected.
• • Provide Services and maintain transaction history.
• • Comply with legal, tax, accounting, or regulatory obligations.
• • Resolve disputes and enforce agreements.
• • Certain transactional data (e.g., invoices, GST records) may be retained for up to 8 years as required under Indian tax and accounting laws."

9.2 Customer-Initiated Deletion

• • You may request deletion of your account and personal data at any time by writing to privacy@quietcool.in or through the QC Platform settings (if available).
• • QC will process such requests within 7 working days, subject to legal retention requirements.
• • Deletion will result in loss of access to your QC account and Services history.

9.3 Exceptions to Deletion

QC may retain certain data despite a deletion request if required for:

• • Compliance with applicable laws (e.g., GST, consumer protection).
• • Pending disputes, investigations, or audits.
• • Security, fraud detection, and abuse prevention.

9.4 Anonymization

Where retention is no longer required, QC may anonymize or aggregate personal data so that it no longer identifies you. Such anonymized data may be retained and used indefinitely for analytics, business intelligence, and service improvements.

9.5 Backups

• • Deleted data may continue to exist in QC's secure backup systems for a limited period (up to 90 days) before being permanently removed.
• • Backup data will not be used for operational, analytical, or business purposes during this retention period.
• • All backup data is automatically purged on expiry of the retention period, ensuring that no personal data remains beyond the prescribed duration.

10. POLICY UPDATES

10.1 Periodic Review

QC may review and update this Privacy Policy from time to time to reflect changes in law, technology, business operations, or service offerings.

10.2 Notification of Changes

• • Minor updates will be published directly on the Platform.
• • For material changes (e.g., changes in how we process personal data or your rights), QC will notify you via:
• • The Platform (pop-up/banner notice), and/or
• • Email, SMS, or push notification (where feasible).

10.3 Continued Use

Your continued use of the Platform and Services after such updates will constitute your acceptance of the revised Privacy Policy.

10.4 Effective Date

Each version of the Privacy Policy will carry its "Last Updated" date at the top for reference.

11. GRIEVANCE OFFICER

11.1 Appointment

In compliance with the Information Technology Act, 2000, the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, and the Consumer Protection Act, 2019, QC has appointed a Grievance Officer for addressing privacy-related concerns and user complaints.

This officer shall also serve as the designated Data Protection Officer (DPO) under the Digital Personal Data Protection Act, 2023, once its provisions are notified and applicable.

11.2 Grievance Officer Details

• • Name: [To be appointed]
• • Designation: Grievance Officer – Data Privacy
• • Email: [Insert QC official grievance email]
• • Address: Quiet Cool LLP, [Registered Address], Mumbai – 400008, Maharashtra, India

11.3 Complaint Handling Timelines

• • All complaints will be acknowledged within 48 hours of receipt.
• • Complaints will be resolved within 30 days from the date of acknowledgement, subject to the nature and complexity of the issue.

11.4 Escalation

If a complaint remains unresolved within the stipulated time, customers may escalate the matter to the appropriate regulatory authority in India, as per applicable law.