NP Infoserve Private Limited and its direct and indirect subsidiaries as well as foreign branch offices (which together comprise “NP Infoserve”), are committed to meeting legal and regulatory requirements regarding data protection and privacy where it conducts its business activities. This Privacy Policy (“Policy”) defines the minimum standards with respect to NP Infoserve collecting, processing, or otherwise using personal data, including information that may be considered as sensitive Personal Data (“Personal Data”) about individuals including NP Infoserve associates, business contacts, customers or vendors (“Individuals”).

Where NP Infoserve Private Limited controls other company entities, such other companies will be required to abide by the principles set in this Policy.

PRIVACY PRINCIPLES

NP Infoserve will handle Personal Data in accordance with the following principles. NP Infoserve ensures that its business partners and vendors comply with the principles of this Policy and applicable legal and regulatory compliance standards through appropriate contractual agreements.

Lawfulness of Processing NP Infoserve will collect, store, process, use, share, transfer, analyze or otherwise handle (“Process” or “Processing”) Personal Data in accordance with applicable legal requirements for legitimate business or compliance purpose or if individuals have provided consent to the Processing or any relevant basis as defined by the applicable laws or regulations.

Limit Collection and processing NP Infoserve will limit the Processing of Personal Data in terms of scope and duration, as is necessary for the intended purpose.

Transparency In accordance with applicable legal requirements, NP Infoserve will provide information to individuals that explains the scope and purpose of Processing, and whom to contact to seek clarifications about privacy or data protection.

Accuracy NP Infoserve will take all necessary measures, as required by applicable laws and regulations, to ensure that Personal Data processed are accurate for the intended purpose. Any inaccurate personal data, in the context of the purposes for which they are processed, will either be erased or rectified without delay. Accuracy of data may be subject to the data subject's duty to notify and/or utilise the options as outlined in Privacy Notices.

Security and Confidentiality NP Infoserve aims to protect the security and confidentiality of individuals’ Personal Data and implement physical, technical and organizational measures against accidental, unlawful or unauthorized destruction, loss, alteration, disclosure or access. NP Infoserve will ensure measures are appropriate to the risks represented by the Processing it carries out and the nature of those Personal Data.

Privacy by Design NP Infoserve incorporates the principles of Privacy by Design into all of its personal data processes executed using digital systems, technologies or manually. By default, privacy requirements are embedded into every standard, protocol and process followed by NP Infoserve.

Disclosure NP Infoserve discloses, when required/asked, personal data to third parties only for the purposes identified in the privacy notice, with the consent of the individual, or as required for lawful purposes. Third parties refer to public authorities, Law Enforcement Agencies and similar authorities.

DATA SUBJECT RIGHTS

In accordance with applicable legal requirements, NP Infoserve will provide opportunity to exercise data subject rights, which are available to the individuals in the context of their engagement with NP Infoserve. Such rights may include the right to request access to their Personal Data, to correct inaccurate or incomplete Personal Data or to object to the Processing of their Personal Data. Each Data Subject Request is validated and tracked to closure. As per the applicable law, and the engagement of data subject with NP Infoserve, there might be other rights available such as right to be forgotten, right to withdraw consent, right to data portability, etc. NP Infoserve will ensure its compliance and deploy all required measures to help data subjects exercise their rights granted.

DATA RETENTION

NP Infoserve will observe retention policies and procedures so that it deletes Personal Data after a reasonable time and the purposes are met. Exception applies if in the context of those purposes, it is necessary to keep the Personal Data indefinitely, or a law requires the Personal Data to be kept for a certain time. When NP Infoserve no longer needs to keep Personal Data for the purposes, for which they are held, it will delete them as soon as practicable.

JURSIDICTION-SPECIFIC REQUIREMENTS AND IMPLEMENTATION

National data protection and privacy laws may impose additional requirements on NP Infoserve for the Processing of Personal Data. Where required, NP Infoserve will establish procedures and guidelines in order to supplement the principles of this Policy and engage with relevant regulatory/ supervisory authority, as required.

PRIVACY ORGANIZATION AND CONTACT

NP Infoserve has set up a global Privacy Function, which is headed by the Head - Global Privacy Office of NP Infoserve, and which is tasked with overseeing and implementing privacy and applicable data protection requirements. Specific data protection or privacy functions and roles may be added for individual countries or geographies. NP Infoserve also appoints Data Protection Officers (or comparable function), where required by applicable laws. The privacy function is also responsible for deploying training and awareness programs and supporting the implementation of privacy principles into NP Infoserve business operations and processes. If you have questions about this Policy, please direct them to the contact details provided in privacy notice available at www.npinfoserve.com.

DATA BREACH REPORTING

All known or suspected incidents involving Personal Data must be reported immediately upon discovery. This includes incidents notified to NP Infoserve from any NP Infoserve associate, client, third party service provider or other business partner. NP Infoserve will provide education and awareness to its workforce regarding the procedures for reporting a suspected or confirmed incident. Each incident is investigated and tracked to closure.

IMPLEMENTATION

NP Infoserve has internal arrangements in place to ensure compliance with this Policy, to allow effective exercise of individuals' rights set out in this Policy and under applicable law, and to deal with any concerns from individuals that NP Infoserve may not have complied with the Policy and/or applicable law. All individuals can leverage these arrangements and/or exercise their rights by contacting their local Data Protection Officer.

CHANGES TO THE POLICY

NP Infoserve may update this Policy from time to time and without prior notice to individuals to reflect changes in law or privacy practices. If you have questions about this Policy, please direct them to the Head – Global Privacy Office or to the respective local Data Protection Officer, contact details of whom can be referred from privacy notice available at www.npinfoserve.com.