Privacy and Security Policy by TurningCloud Solutions Pvt Ltd ("SM")

1. INTRODUCTION

TurningCloud Solutions Pvt Ltd ("we", "us", "our") provides cloud-based software for supply chain planning and operations. This Privacy & Security Policy explains how we collect, use, disclose, and protect personal data processed through our Supplymint Website and/or SaaS Platform ("Platform").

2. SCOPE

This Policy applies to all users of our Platform, including end users of subscribing customers, and covers data collected via our Platform. We collect data solely for the purposes of providing, maintaining, and improving our Platform.

3. DATA COLLECTION

We may collect the following categories of data, including personal data:

• Identity data (name, email, job title)
• Contact data (phone number, address)
• Usage data (IP address, device info, access logs, analytics)

4. LEGAL BASIS FOR PROCESSING PERSONAL DATA

We process personal data based on one or more of the following grounds:

• Your consent
• The necessity of processing for the performance of a contract with you
• Compliance with legal obligations
• Legitimate interests (e.g., platform security, analytics), provided such interests do not override your fundamental rights and freedoms

5. USE OF DATA

Personal data is used to:

• Provide and maintain our services and the Platform
• Authenticate users and manage accounts
• Respond to support requests
• Improve platform functionality and security
• Comply with regulatory obligations

6. DATA SHARING

We may share personal data with trusted third-party service providers (e.g., cloud hosting, analytics, payment processors) strictly for facilitating your use of the Platform. All sub-processors are bound by contractual obligations to implement equivalent data protection and security measures. Further, personal data may be shared with regulatory authorities if required as per law.

7. INTERNATIONAL TRANSFERS

Where personal data is transferred outside your jurisdiction, we ensure adequate safeguards are in place, such as Standard Contractual Clauses (EU/UK), compliance with applicable US state laws, or adherence to restrictions under India's DPDP Act. We will notify you of any material changes to transfer mechanisms.

8. DATA SECURITY

We implement appropriate technical and organizational measures to protect personal data, including encryption, access controls, intrusion detection, and regular security audits. Our employees and sub-processors are trained in data protection and bound by confidentiality obligations.

9. DATA RETENTION

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by law. Once retention periods expire, data will be securely deleted or anonymized. You may request deletion of your data at any time, subject to legal and contractual obligations.

10. USER RIGHTS & GRIEVANCE REDRESSAL

Depending on jurisdiction, users may have rights to:

• Access, correct, update or delete personal data
• Object to or restrict processing
• Withdraw consent
• Lodge complaints with a supervisory authority
• Data portability

We have a dedicated channel to oversee compliance and respond to data protection inquiries. Requests can be submitted to: support@supplymint.com. All grievances will be acknowledged and addressed within the legally mandated timeframe (e.g., 7 days under India's DPDP Act).

11. COOKIES & TRACKING

We use cookies and similar technologies for session management and analytics. Users can manage preferences via browser settings.

12. CHILDREN'S PRIVACY

Our services are not intended for individuals under the age of 18. We do not knowingly collect data from minors.

13. CHANGES TO THIS POLICY

We reserve the right to modify this Policy at any time. Changes will be posted on this page with an updated effective date. Continued use of the Platform constitutes acceptance of the revised Policy. You are responsible for regularly checking the Policy, determining if there have been any changes and reviewing such changes.

14. CONSENT MANAGEMENT

Where consent is required, we will obtain it in a clear, informed, and verifiable manner. You may withdraw your consent at any time without affecting the lawfulness of processing carried out prior to withdrawal. We maintain records of consent to demonstrate compliance.

15. BREACH NOTIFICATION

In the event of a personal data breach, we will notify the relevant supervisory authority and affected individuals without undue delay, and in any case within the timeframes required by applicable law (e.g., 72 hours under GDPR, statutory timelines under US state laws, and reporting obligations under India's DPDP Act).

16. THIRD PARTIES

Third-party ad servers or ad networks use technologies like cookies, JavaScript, or Web Beacons that are used in their respective advertisements and links that appear on the Platform, which are sent directly to your browser. They automatically receive your IP address when this occurs. These technologies are used to measure the effectiveness of their advertising campaigns and/or to personalize the advertising content that you see on websites that you visit. Note that SM has no access to or control over these cookies that are used by third-party advertisers, and disclaims all liability to the fullest possible extent.

17. ORDER OF PRECEDENCE

Where the Platform is used by a business customer under a signed Software as a Service (SaaS) Subscription Agreement ("MSA"), SM acts as a Data Processor and the business customer acts as the Data Controller. In such cases, the processing of personal data is governed by the Data Processing Addendum ("DPA") that forms part of the MSA, and that DPA prevails over this Policy in the event of any conflict. An individual user of the business customer accesses the platform pursuant to an End User License Agreement ("EULA"). Such individual users consent that the MSA and DPA control and govern this relationship. In the absence of an MSA, the Terms of Service governs the relationship between SM and the user, and the former prevails over the latter in the event of any conflict. For liability and other matters not contained in this Policy, the MSA or Terms of Service, as applicable, control.

18. CONTACT US

For questions or concerns, contact:

TurningCloud Solutions Pvt Ltd

Tower B-703, Unitech Business Zone Nirvana Country, South City II, Sector 50, Gurugram, Haryana

122018

Email: support@supplymint.com