PRIVACY POLICY

1. PREAMBLE & SCOPE OF APPLICABILITY

1.1. This Privacy Policy (“Policy”) governs the collection, processing, retention, utilisation, disclosure, preservation, and governance of all data, information, communication, submissions, and digital interactions undertaken by any User (“User / Visitor / Client / Counterparty”) accessing or interfacing with Aararu Holdings Pvt Ltd through any medium, including but not limited to the Company’s website, portals, platforms, forms, communication channels, or service engagements.

1.2. By accessing, submitting, communicating, enquiring, or transacting with Aararu Holdings, the User irrevocably consents to the terms of this Policy in full, as well as the full binding authority of the Aararu Corporate Constitution, including all annexures, schedules, internal data governance frameworks, and cyber-incident response protocols.

2. SUPERIOR AUTHORITY OF THE AARARU CORPORATE CONSTITUTION

2.1. All data-related matters—including but not limited to collection, storage, processing, confidentiality, lawful disclosure, breach response, cyber-incident protocol, and user compliance—shall be governed by the Aararu Corporate Constitution, including:

• Annexure L — Digital Data & Record Management Policy,
• Annexure M — Cyber Incident Response & Escalation Framework,
• Schedule A9 — Engagement & Association Protocol,
• All present and future constitutional documents.

2.2. Any User engaging with Aararu Holdings is automatically and unconditionally bound to these constitutional instruments and may not revoke consent under any circumstances.

3. DATA COLLECTION & CATEGORIES OF INFORMATION

3.1. Aararu Holdings collects data, whether explicitly provided or implicitly transmitted, including but not limited to:

A. User-Provided Information

• Full name, email ID, phone number, address, organisational affiliation
• Documents, files, presentations, business information
• Queries, interests, preferences, form submissions
• Uploaded materials, attachments, or communication records

B. Automatically Collected Information

• IP address, device footprint, browser metadata
• Session logs, click-stream data, traffic patterns
• Behavioural and engagement analytics
• Digital identifiers, geolocation approximations
• Tracking data from cookies or equivalent technologies

C. Sensitive & Business-Critical Information

• Proprietary information voluntarily shared by the User
• Business strategy, financial models, internal structures
• Intent of collaboration, partnership, acquisition, or service hiring
• Any information disclosed during calls, chats, messages, emails, or meetings

3.2. Data may be collected with or without direct notice, depending on operational necessity.

4. PURPOSE OF DATA PROCESSING

4.1. Aararu Holdings uses collected information for purposes including but not limited to:

• Verification, authentication, and identification procedures
• Internal strategic evaluation and service customisation
• Risk assessment, fraud prevention, and internal security measures
• Communication, advisory, consulting, and service delivery
• Development and refinement of proprietary business frameworks
• Enforcement of contractual, constitutional, and legal obligations
• Analytics, optimisation, and internal decision-making processes

4.2. The User acknowledges that the Company reserves full discretion to determine the purpose and extent of data use.

5. CONSENT & IRREVOCABILITY

5.1. Submission of any information constitutes explicit and irrevocable consent.

5.2. Consent cannot be withdrawn, revoked, disputed, modified, or renegotiated.

6. DATA STORAGE, RETENTION & PRESERVATION

6.1. Aararu Holdings retains all User data for indefinite duration, unless the Company determines otherwise.

6.2. The Company is under no obligation to delete, anonymise, restrict, or remove User data.

6.3. The User waives all rights to request deletion, modification, or limitation of their data.

7. DISCLOSURE OF INFORMATION

7.1. Aararu Holdings may disclose information under circumstances determined solely by the Company, including but not limited to:

• Compliance with internal constitutional enforcement mechanisms
• Escrow partners, legal counsel, regulatory advisors
• Third-party vendors assisting in internal operations
• Government, regulatory, or statutory bodies (where mandatory)
• Internal directors, shareholders, and authorised officers

7.2. The Company reserves full authority to disclose data without notice.

8. CONFIDENTIALITY, NON-CIRCUMVENTION & NON-BYPASS

8.1. All Users are automatically bound by confidentiality and non-disclosure obligations.

8.2. Users shall not share, forward, duplicate, or transmit any communication or Company-related data.

8.3. Any attempt to bypass, circumvent, or engage competitors using Company data constitutes a breach.

9. DATA SECURITY & CYBER INCIDENT RESPONSE

9.1. Aararu Holdings maintains internal cyber-governance mechanisms defined under Annexure M.

9.2. Users may not hold the Company liable for:

• cyber breaches,
• unauthorised access,
• data leaks,
• third-party attacks,
• technological failures.

9.3. The User acknowledges that all digital interactions carry inherent risks and voluntarily accepts such risks in full.

10. USER OBLIGATIONS

10.1. User agrees to:

• Provide accurate information
• Not engage in fraud, impersonation, or misrepresentation
• Not misuse, manipulate, or attempt unauthorised access to systems
• Adhere strictly to the Aararu Corporate Constitution

10.2. Any breach shall invoke legal escalation, forfeiture of rights, and termination of relationship.

11. LIMITATION OF LIABILITY

11.1. Aararu Holdings shall not be liable for:

• direct or indirect damages,
• loss of business,
• loss of data,
• reputational harm,
• misuse by third parties,
• errors, delays, or inaccuracies,
• acts of force majeure or external interference.

11.2. User agrees that the Company’s liability is zero under all circumstances.

12. GOVERNING LAW & JURISDICTION

12.1. This Policy is governed by the laws of India and the Aararu Corporate Constitution.

12.2. Any dispute shall be resolved exclusively through internal mechanisms defined under the Constitution.

12.3. No external court, arbitration body, or authority shall have jurisdiction unless explicitly permitted by the Company.

13. AMENDMENTS

13.1. Aararu Holdings may amend, revise, or restructure this Policy at any time, without notice.

13.2. Continued use constitutes unconditional acceptance of all updates.

14. ACCEPTANCE

By accessing or engaging with Aararu Holdings, the User hereby confirms:

• Acceptance of this Privacy Policy,
• Acceptance of data collection and processing practices,
• Acceptance of indefinite retention,
• Acceptance of all disclosure rights granted to the Company,
• Acceptance of the Aararu Corporate Constitution as superior legal authority.