Introduction

PERRO TECHNOCARE PRIVATE LIMITED ('MyPerro', 'we', 'us', or 'our') is a company incorporated under the Companies Act, 2013, with its registered office at F.NO.104, P.NO.2&3 G.NO151, SHRI SAMARTH CLASSIC, Aurangabad Railway Station, Aurangabad, Aurangabad 431005. MyPerro operates the MyPerro mobile application and web platform (collectively, the 'App') that provides an integrated suite of pet-technology services, including pet health tracking, health metrics monitoring and geofencing.

This Privacy Policy ('Policy') describes how MyPerro, acting as a Data Fiduciary under the Digital Personal Data Protection Act, 2023 ('DPDP Act'), and as a body corporate under the Information Technology Act, 2000 ('IT Act'), collects, receives, uses, stores, processes, transfers, protects, and discloses Personal Data and Sensitive Personal Data or Information ('SPDI') relating to its users.

Scope

This Policy applies to all natural persons ('Data Principals' / 'Users') who access or use the App, register an account, avail any service, visit our website, interact with our community features, or otherwise provide Personal Data to MyPerro, regardless of the device or platform used.

1. Personal Data

For the purpose of this Policy, "Personal Data" shall have the meaning ascribed to it under Section 2(t) of the Digital Personal Data Protection Act, 2023 ("DPDP Act"), meaning any data about an individual who is identifiable by or in relation to such data, whether directly or in combination with other information.

Personal Data includes, without limitation, the following categories of data that MyPerro may collect from or about you:

• a. Your name, date of birth, government-issued identification (only where legally required), mailing address, email address, telephone number(s), profile photograph, and any other information you voluntarily submit to us;
• b. Pet-related information, including your pet's name, species, breed, age or date of birth, weight, physical description, medical history, vaccination records, health alerts, dietary preferences, and behavioural logs;
• c. Payment-related information, including your bank account details, UPI IDs, credit or debit card information (processed exclusively by PCI-DSS-compliant payment gateways), and transaction history;
• d. Precise and approximate location data, collected via GPS, Wi-Fi, cellular networks or IP address, in connection with location-based pet care services and smart collar tracking functionality; and
• e. Information about your use of the App and our services, including device identifiers, IP addresses, operating system details, session duration, browsing behaviour within the App, and crash/error logs.

2. Collection of Personal Data

We may collect your Personal Data from you through various means, including but not limited to instances when you:

• a. Register an account on the App or submit any registration form (electronic or otherwise) in connection with our products or services;
• b. Pair or activate your MyPerro smart collar device and connect it to your App account;
• c. Use or access any features of the App, including GPS tracking, health logs, or community features;
• d. Purchase products through the MyPerro marketplace or enter into any transaction with us;
• e. Interact with our customer support team via telephone, email, live chat, social media or any other channel;
• f. Sign up for or update any account, subscription, loyalty programme, or mailing list with us;
• g. Respond to surveys, promotions, contests or market research initiatives conducted by us;
• h. Post or share content in the MyPerro community, pet forums, breed groups or review sections;
• i. Enable location permissions on your device to use location-based pet services or smart collar live tracking;
• j. Submit a job application or otherwise communicate with us for any employment-related purpose; or
• k. Submit your Personal Data to us for any other reason.

3. Sensitive Personal Data or Information

Some of the Personal Data that we collect may constitute Sensitive Personal Data or Information ("SPDI") as defined under Rule 3 of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 ("SPDI Rules"). This may include:

• a. Passwords: Stored only in hashed and salted form using industry-standard cryptographic algorithms; plain-text passwords are never retained;
• b. Financial information: Bank account details, credit or debit card details, and other payment instrument information, to the extent processed through our platform prior to transmission to payment gateways;
• c. Health-related data: Medical records, prescriptions, treatment notes, and health history shared during online veterinary consultations or uploaded as part of your pet's health profile; and
• d. Biometric data: Only if you use biometric authentication on your device, such data is processed locally by your device's operating system and is not transmitted to or stored on MyPerro servers.

We collect SPDI only with your explicit consent and in strict compliance with Applicable Laws. In the event that you are required to furnish any documentation or information for any purpose which may incidentally contain SPDI not required for that purpose, you agree to redact such SPDI before providing such documentation or information to us.

4. Provision of Third-Party Personal Data by You

If you provide Personal Data of a third party to us, you represent, warrant and confirm that:

• a. Before disclosing such Personal Data to us, you would have and had obtained consent from the individual whose Personal Data are being disclosed to us, to permit you to disclose the individual's Personal Data for one or more of the Purposes; and permit us to collect, use, disclose and/or process the individual's Personal Data;
• b. Any Personal Data of an individual that you disclose to us is accurate; and
• c. You are validly acting on behalf of such individual and that you have the authority to provide their Personal Data to us.

5. Use and Disclosure of Personal Data

In order to effectively provide you with the products and services that you require, we need to collect a range of Personal Data about you. In general, we will or may, subject to Applicable Laws, use, disclose and/or process your Personal Data for one or more of the following purposes ("Purpose"):

• a. Register and manage your account and authenticate your identity on the App;
• b. Provide, activate and manage the MyPerro smart collar device and its GPS tracking, health monitoring, and geofencing functionality;
• c. Facilitate, implement and/or formalise (including processing any payments related to) any transactions made through the App;
• d. Send vaccination reminders, health alerts, medication schedules, and other pet care notifications;
• e. Facilitate participation in the MyPerro pet community, including forums, breed groups, reviews, and user-generated content features;
• f. Communicate with you and respond to your queries, requests, and complaints;
• g. Process and fulfil marketplace orders and coordinate delivery through logistics partners;
• h. Verify or update your personal particulars and maintain the accuracy of your records;
• i. Conduct due diligence, fraud detection, risk assessments, and security monitoring;
• j. Provide information about the products and services of MyPerro and our partners which may be of interest to you, subject to your marketing consent;
• k. Review, improve, manage the delivery of and enhance our products and services, including analysing customer needs, conducting market research, and data analytics;
• l. Facilitate business transactions including mergers, acquisitions or asset sales, subject to appropriate confidentiality obligations;
• m. Communicate with you regarding changes and developments to our policies, terms and conditions, and other administrative matters;
• n. Handle and resolve complaints or disputes, and conduct investigations as required;
• o. Prevent, detect and investigate security breaches and crime, including fraud, money laundering, and other risks;
• p. Protect and enforce our contractual and legal rights and obligations;
• q. Manage and maintain appropriate records and comply with our internal policies and procedures;
• r. Comply with any applicable rules, regulations, laws, codes of practice or guidelines, or assist in law enforcement by relevant authorities including the Data Protection Board of India and CERT-In; and
• s. Any other purpose related to or ancillary to any of the above.

6. Cookies and Tracking

MyPerro's web platform and App use cookies and similar tracking technologies. The following categories are deployed:

• a. Required for the App to function correctly (e.g., session management, login authentication). These cannot be disabled without affecting core functionality.
• b. Enable enhanced features such as remembering user preferences, saved pet profiles, language settings, and personalised configurations.
• c. Collect aggregated information about how users navigate the App to help us improve performance and user experience.
• d. Used to deliver relevant communications and measure their effectiveness. Deployed only with your explicit prior consent.
• e. Set by third-party service providers including payment gateways, map services, and analytics platforms, each governed by their respective privacy policies.

When you first visit our web platform, you will be presented with a Cookie Consent Banner permitting you to accept, reject, or customise non-essential cookies. You may modify your preferences at any time through the Cookie Settings panel accessible on our website.

7. Disclosure to Third Parties

Your Personal Data will be protected and kept confidential. Subject to the provisions of Applicable Laws, your Personal Data may, depending on the products and/or services concerned, be disclosed to the categories of third parties set out below. Such disclosure may be subject to additional legal requirements depending on the nature of the transfer. Your Personal Data will, in each case, only be disclosed to the extent necessary for the relevant Purpose.

The third parties are:

• a. Other divisions, departments or entities within MyPerro;
• b. Logistics and courier partners (such as Delhivery, BlueDart, or last-mile delivery services) for the purpose of fulfilling and tracking marketplace orders, to whom your name, delivery address, and order details will be shared;
• c. PCI-DSS-compliant payment gateway operators (such as Razorpay, PayU or Cashfree) for the processing of transactions. MyPerro does not store or transmit full card numbers or banking credentials;
• d. Our agents, contractors, consultants, and specialist advisers contracted to provide management, administrative, financial, legal, audit, insurance, research, information technology, training, or storage services;
• e. Relevant government authorities, regulatory bodies, the Data Protection Board of India, law enforcement agencies, or courts, to comply with any applicable law, regulation, court order, direction issued under the DPDP Act, or CERT-In direction;
• f. Affiliates, joint venture partners, business partners, investors, and/or assignees or transferees in connection with any merger, acquisition or asset sale, subject to appropriate confidentiality obligations; and
• g. Any other party as may be consented to by you or as may be notified to you by us in subsequent notices.

We require all organisations which obtain or process Personal Data as our service providers to acknowledge the confidentiality of such data and to abide by and comply with Applicable Laws. We have data processing agreements in place with all such third parties requiring that they use Personal Data only for the specified Purpose and implement appropriate security safeguards.

8. Retention of Personal Data

We may retain your Personal Data for as long as it is necessary for the Purposes for which it was collected, or as otherwise required or permitted by Applicable Laws, or in order to establish, exercise or defend legal claims. The following indicative retention periods apply:

• a. Account and profile data: duration of active account plus three (3) years following deletion;
• b. Pet medical records: seven (7) years from the date of the relevant record entry;
• c. Payment and transaction records: eight (8) years from the date of transaction, in accordance with the Income Tax Act, 1961 and the Central Goods and Services Tax Act, 2017;
• d. Consent records: duration of the relevant processing activity plus three (3) years, in accordance with Section 6 of the DPDP Act;
• e. ICT event logs and security records: one hundred and eighty (180) days, in accordance with CERT-In directions issued in April 2022; and
• f. Usage and analytics data: twenty-six (26) months, anonymised after six (6) months.

Where we no longer require your Personal Data for those Purposes, we will securely delete or anonymise such Personal Data in accordance with our internal data retention and disposal policy. Backup copies will be purged within ninety (90) days of primary deletion.

9. Pre-Orders

MyPerro is currently accepting pre-orders for its smart pet collar device ("Device") through the App and website. In connection with processing your pre-order, MyPerro collects Personal Data including your name, email address, mobile number, delivery address, and payment information. Such data is collected and processed solely for the purpose of fulfilling your pre-order, communicating order status and estimated dispatch timelines, and processing payment authorisation and, where applicable, refunds.

By submitting a pre-order, you consent to MyPerro using your email address and mobile number to send you order confirmation, estimated delivery updates, and product launch communications relating to your pre-ordered Device. Transactional communications directly related to the fulfilment of your pre-order, such as dispatch notifications, tracking updates, and delivery confirmations, cannot be opted out of as they are necessary for the performance of the pre-order contract.

When you join a waitlist prior to the formal opening of pre-orders, MyPerro collects your name and email address solely for the purpose of notifying you when pre-orders become available.

10. Contact Us

If you have any questions about this Policy or any queries relating to your Personal Data, or you would like to obtain access and/or make corrections to your Personal Data, please contact us at:

11. Governing Laws

This Policy shall be governed in all respects by the laws of India. For the avoidance of doubt, the Applicable Laws will apply to the processing of your Personal Data. Any dispute arising out of or in connection with this Policy shall be subject to the exclusive jurisdiction of the courts at Bangalore, India.

12. Revisions

This Policy will be reviewed from time to time by us. We may also update this Policy to take account of new laws and technology, changes to our business operations and environment, and changes to the rules notified under the DPDP Act.