Ace of Pubs (AoP), a proprietorship established in May 2018 (“AoP” or the “Proprietorship”) has a strong commitment to all of its Users of the mobile application ‘Ace of Pubs’ as modified from time to time (“App”) and telecommunication media like SMS, email, phone calls etc. (together the “Platform”), including respecting and ensuring that Your privacy is protected.

In this Privacy Policy, the use of words like “we” or “us” or “our” shall mean appropriate reference to the AoP

This privacy policy (“Privacy Policy”) explains how we collect, use, share, disclose and protect Personal information about the Users of the Services, including the End-Users (as defined in the Terms of Use). We created this Privacy Policy to demonstrate our commitment to the protection of your privacy and your personal information. Your use of and access to the Services is subject to this Privacy Policy and our Terms of Use. Any capitalized term used but not defined in this Privacy Policy shall have the meaning attributed to it in our Terms of Use. This Privacy Policy also covers our treatment of personally identifiable information collected from User information that we acquire in the course of our business.

By accepting this Privacy Policy and the Terms and Conditions, You expressly consent that all Your personal information collected by us through this Platform may be used and disclosed as set out in this Privacy Policy and subject to the applicable law and are eligible, as per our Terms and Conditions, to use the Platform as a Registered Member, as applicable. If You do not agree please do not use or access our Website or the Platform. By accessing the services provided by the Platform You agree to the collection and use of Your data by the Proprietorship in the manner provided in this Privacy Policy. As the services of our Platform evolve, we may revise this Privacy Policy from time to time. The Privacy Policy does not apply to the procedures and practices followed by entities that are not managed, owned or controlled by the Proprietorship or to the people that are not engaged, employed or managed by the Proprietorship. For clarity, this Privacy Policy does not apply to the procedures and practices followed by any of the present or future shareholders of the Company.

BY USING THE SERVICES OR BY OTHERWISE GIVING US YOUR INFORMATION, YOU WILL BE DEEMED TO HAVE READ, UNDERSTOOD AND AGREED TO THE PRACTICES AND POLICIES OUTLINED IN THIS PRIVACY POLICY AND AGREE TO BE BOUND BY THE PRIVACY POLICY. YOU HEREBY CONSENT TO OUR COLLECTION, USE AND SHARING, DISCLOSURE OF YOUR INFORMATION AS DESCRIBED IN THIS PRIVACY POLICY. WE RESERVE THE RIGHT TO CHANGE, MODIFY, ADD OR DELETE PORTIONS OF THE TERMS OF THIS PRIVACY POLICY, AT OUR SOLE DISCRETION, AT ANY TIME. IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY AT ANY TIME, DO NOT USE ANY OF THE SERVICES OR GIVE US ANY OF YOUR INFORMATION. IF YOU USE THE SERVICES ON BEHALF OF SOMEONE ELSE (SUCH AS YOUR CHILD) OR AN ENTITY (SUCH AS YOUR EMPLOYER), YOU REPRESENT THAT YOU ARE AUTHORISED BY SUCH INDIVIDUAL OR ENTITY TO (I) ACCEPT THIS PRIVACY POLICY ON SUCH INDIVIDUAL’S OR ENTITY’S BEHALF, AND (II) CONSENT ON BEHALF OF SUCH INDIVIDUAL OR ENTITY TO OUR COLLECTION, USE AND DISCLOSURE OF SUCH INDIVIDUAL’S OR ENTITY’S INFORMATION AS DESCRIBED IN THIS PRIVACY POLICY.

SECURITY OF DATA

This Privacy Policy is published in compliance with, inter alia: i. Section 43A of the Information Technology Act, 2000; ii. Regulation 4 of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information) Rules, 2011 (the “SPI Rules”); iii. Regulation 3(1) of the Information Technology (Intermediaries Guidelines) Rules, 2011.

COLLECTION OF PERSONAL INFORMATION

When you access the Services, or have any interaction with us via any mode of communication including, but not limited to, emails, telephone calls or fax etc., we may ask you to provide to us certain personal information to identify you or could be used to personally identify you. You hereby consent to the collection of such information by AoP and declare that you are providing such information with your free consent, with proper authority and without any undue influence. Without prejudice to the generality of the above, information collected by us from you may include (but is not limited to) the following: iv. personal information (such as name, Parent’s name, country, city, state, full address, educational qualification, ethnicity etc.) v. contact data (such as your email address and phone number); vi. demographic data (such as your gender, your date of birth, and your pin code); vii. such other information that may be required based on the circumstances and your requirement of services from us; viii. such other information that you intend to provide to us (such as information shared by you with us through emails or letters). The information collected from you by AoP may constitute ‘personal information’ or ‘sensitive personal data or information’ under the SPI Rules. “Personal Information” means any information that relates to a natural person, which, either directly or indirectly, in combination with other information available or likely to be available with a body corporate, is capable of identifying such person. The SPI Rules further define “Sensitive Personal Data or Information” of a person to mean personal information about that person relating to: ix. passwords; x. financial information such as bank accounts, credit and debit card details or other payment instrument details; xi. physical, physiological and mental health condition; xii. sexual orientation;

PRIVACY STATEMENTS

When You use our Platform, we collect and store Your personal information which is provided by You from time to time. Our primary goal in doing so is to provide You a safe, efficient, smooth and customized experience. To avail the services offered on the Platform, You need to be eligible as per our Terms and Conditions and You will also need to register using our registration form available on the App, where You may be required to provide us with information including Your name, date of birth, contact number, email ID, user ID, password, residence / place of business information and other personal information as indicated on the forms throughout the Platform. Where possible, we indicate which fields are required and which fields are optional. You always have the option not to provide information by choosing not to use a particular service or feature on Platform. We may automatically track certain information about You based upon Your behavior on our Platform. We use this information to do internal research on our users’ demographics, interests, and behavior to better understand, protect and serve our Users. This information is compiled and analyzed on an aggregated basis. If You are affiliated or registered with us then the personal information You provide, including name, address etc, allows us to inform You about updates or changes to services and terms and conditions of providing You the services. We use data collection devices such as “cookies” on the App to help analyze our web page flow or App usage, measure promotional effectiveness, and promote trust and safety. “Cookies” are small files placed on Your hard drive that assist us in providing our services by enabling our web server to collect certain information from the browser or device. We offer certain features that are only available through the use of a “cookie”. We also use cookies for a number of purposes, including to allow You to enter Your password less frequently during a session, to simplify logging process for registered users, to start a session when logging into our App on our device to remember Your username between sessions, to provide the mechanisms of online payment if applicable, to enable traffic monitoring, Cookies can also help us provide information that is targeted to Your interests. Most cookies are “session cookies,” meaning that they are automatically deleted from Your hard drive or device at the end of a session. You are always free to decline our cookies if Your browser permits (or delete them by looking at the help menu of Your browser or device), although in that case You may not be able to use certain features on the Website or App and You may be required to reenter Your password more frequently during a session. A cookie does not give us access to Your device, or information other than the data You choose to share with us. We also allow other Users to comment about matters shared or posted by You. In the ordinary course of business, our system does not receive, store or process any credit/debit card names, numbers, expiration dates, CVV number or equivalent, to affect any payment on our App. Hence, this Privacy Policy does not cover the protection of Your payment details, if applicable. The protection of Your payment details may be covered by any privacy policy provided by the relevant third-party payment service providers. If You choose to post messages on any of our discussion fora, message boards, chat rooms or other message areas or leave feedback or comments for other Users whether by phone, email, letters or on the App, we will collect that information You provide to us and if need be aggregate. We retain this information as necessary to resolve grievances, provide user support, troubleshoot problems and show to various parties as indicators of Your credibility as permitted by applicable law. We may also proactively request for Your feedback and testimonials to help us improve our services or about the services or conduct of other Users via online forms, post, email, phone, mobile or fax. We may also contact You to inform You about offers, news, information etc. about the Platform and our services. If You do not wish to be contacted, please write to us at info@aceofpubs.com

CHANGE TO PRIVACY POLICY

AoP may update this Privacy Policy at any time, with or without advance notice. In the event there are significant changes in the way AoP treats User’s personally identifiable information, or in the Privacy Policy itself, AoP will display a notice on the App or send Users an email, as provided for above, so that you may review the changed terms prior to continuing to use the Services. As always, if you object to any of the changes to our terms, and you no longer wish to use the Services, you may contact info@aceofpubs.com to deactivate your account. Unless stated otherwise, AoP’s current Privacy Policy applies to all information that AoP has about you and your account. If a User uses the Services or after a notice of changes has been sent to such User or published on the App, such User hereby provides his/her/its consent to the changed terms.

CHILDREN’S AND MINOR’S PRIVACY

AoP strongly encourages parents and guardians to supervise the online activities of their minor children and consider using parental control tools available from online services and software manufacturers to help provide a child-friendly online environment. These tools also can prevent minors from disclosing their name, address, and other personally identifiable information online without parental permission. Although the AoP services/ the App are not intended for use by minors, AoP respects the privacy of minors who may inadvertently use the mobile application.

CONSENT TO THIS POLICY

You acknowledge that this Privacy Policy is a part of the Terms of Use and you unconditionally agree that becoming a User of the App and its Services signifies your (i) assent to this Privacy Policy, and (ii) consent to AoP using, collecting, processing and/or disclosing your Personal Information in the manner and for the purposes set out in this Privacy Policy. Your use of the App and use of the Services is subject to this Privacy Policy and the Terms of Use.