Introduction

Euler Ident Private Limited (“Company”, “we”, “our”) is committed to protecting personal data in accordance with the Digital Personal Data Protection Act, 2023. Pitha (“App”, “Platform”) is operated by Euler Ident Pvt Ltd, which acts as the Data Fiduciary under the DPDP Act.

This Privacy Policy explains how we collect, process, and safeguard personal information when you access our website or mobile application. We believe it is important for you to understand how your data is handled to ensure transparency, trust, and compliance with applicable law.

For the purposes of this Policy:

• “You” / “Yourself” refers to the individual user of the website or application.

• “Users” refers collectively or individually to all persons accessing the platform,

including parents, schools, and transport service providers.

• “We” / “Us” / “Our” refers to Euler Ident Pvt Ltd, the legal entity responsible for data processing.

This Policy is designed to help you feel confident about the privacy and security of your personal details, and to clarify your rights under the DPDP Act.

Applicability of Privacy Policy

This web application/mobile application are intended for use by:

1. Parents who wish to know the real-time whereabouts of their child’s school commute through school-operated or market transport services; and

2. Transport Service Providers and Schools who elect to use the application/website totrack vehicles and provide real-time location updates to parents.

By accessing or using the platform, all users acknowledge that their personal and/or business information (including but not limited to Aadhaar, PAN, business licence, GST certificate, and other identifiers) may be collected, processed, and stored in accordance with the Digital Personal Data Protection Act, 2023. Anyone can access our website without necessity to provide its personal data.

The purpose of processing your personal data by the Company and collection of information about you are as follows (the “Purpose”):

1. Your intention to use Services;

2. In order for us to provide the user with the ordered and purchased Services;

3. For verifying your identity and providing customer care service and assistance;

4. Analyse your use of our Website and Services to better understand how they are being used so we can improve our Services and the user experience, and engage and retain users.

We may use your Personal data to: (a) improve your browsing experience by personalizing the Website and to improve the Services; (b) send information to you by email regarding registration status, password verification, payment confirmation; (c) send you communications relating to your use of the Services, and (d) provide our partners with statistical information about our users by secured channels under data processing agreements (DPA); send you marketing and promotional materials and messages.

As you are willing to use Services you are required to provide your personal data (to registeran account and purchase a software and/or services), thus becoming a user of Services.

With this Purpose we collect and process two types of information:

(1) aggregate (meaning collective data that relates to a group or category of customers) tracking and Website usage information that we gather automatically as you access ourWebsite, as

(2) the browser types and versions used,

(3) the operating system used by the accessing system,

(4) the website from which an accessing system reaches our Website (socalled referrers),

(5) the date and time of access to the Website,

(6) the Internet service provider of the accessing system, and

(7) any other similar data and information that may be used in the event of attacks on our information technology systems.

When using these general data and information, we do not draw any conclusions about the users. Rather, this information is needed to

(1) deliver the content of our Website correctly,

(2) optimize the content of our Website as well as its advertisement,

(3) ensure the long-term viability of our information technology systems and Website technology, and

(4) provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack.

Therefore, we analyze anonymously collected data and information statistically, with the aim of increasing the data protection and data security of our company, and to ensure an optimal level of protection for the personal data we process.

Please be aware that you are not obliged to provide us with your personal data. However, if you do not provide us with KYC/KYB (including but not limited to your name and email address), you may not be able to create an account to log into and make a purchase of Services, consequently, to use these Services.

CHILDREN’S PRIVACY

Provision of our Services is generally not aimed at children. This Website and mobile application are not intended for use by individuals under the age of 18 years, as defined under the Digital Personal Data Protection Act, 2023 (DPDP Act).

We do not knowingly collect personal data from children or minors. Parents and legal guardians are encouraged to monitor their children’s internet usage and to instruct them never to provide personal information on our platform without parental consent.

If we obtain actual knowledge that we have collected personal data from a child without verifiable parental consent, we will:

1. Promptly delete such data, unless retention is legally required;

2. Ensure compliance with the DPDP Act and applicable industry guidelines; and

3. Notify the parent or guardian, where appropriate.

In accordance with Section 9 of the DPDP Act:

• Parental Consent is mandatory before processing any child’s personal data.

• We will not engage in tracking, behavioral monitoring, or targeted advertising directed at children.

• We will not process children’s data in any manner that is likely to cause harm to their well-being, psychological health, or social development.

Information Sharing

We do not sell your personal information. We may share your personal data only to the extent necessary to provide you the service and in accordance with applicable law in the following circumstances:

• Service Providers:We may share personal data with third-party service providers who support our operations (such as hosting providers, cloud service providers, and payment gateways), strictly on a need-to-know basis and subject to contractual confidentiality and data protection obligations.

• Business Entity: Where your use of our website/application/web app is facilitated, sponsored, or managed by a business entity (such as an educational institution or enterprise), your personal data may be shared with or made accessible to such entity in accordance with the applicable contractual arrangements, user permissions, and the agreed scope of us

• Legal Compliance: We may disclose personal data where required to comply with applicable laws, regulations, court orders, governmental or regulatory requests, or where such disclosure is necessary to enforce our rights, investigate or prevent fraud or security issues, or protect the rights, property, or safety of Euler Ident Pvt Ltd, our users, or others.

• Cross-Border Transfers: Personal data may be processed on servers located in India and, where applicable, outside India, subject to DPDP Act safeguards.

• Children’s Data: Children’s data is shared only with parents and schools/transport providers, not beyond. We will not share children’s personal data for tracking, profiling, or advertising purposes.

Consent Limitation: Data will only be shared in accordance with the consent provided by the user, unless otherwise required by law.

Your Rights

Depending on applicable laws, you may have the following rights:

• Right to Access: Obtain confirmation and a copy of your personal data

• Right to Rectification: Correct inaccurate or incomplete data

• Right to Erasure: Request deletion of your personal data, subject to applicable laws,statutory or regulatory retention requirements, court orders, and lawful directions of competent authorities, and to the extent such data is required for compliance, dispute resolution, or enforcement of legal rights.

• Right to Restrict Processing: Limit how your data is used

• Right to Object: Object to data use based on legitimate interest

• Right to Nominate: You may nominate another individual to exercise your rights in the event of your death or incapacity.

• Right to Withdraw Consent: Where processing is based on consent, you may withdraw such consent at any time. Withdrawal will not affect the lawfulness of processing prior to withdrawal.

To exercise these rights, you can contact us at mail ID: privacy@eulerident.com. If your data was submitted to us by any Business entity, please reach out to that entity directly. You may lodge a complaint with our Grievance Officer using the same mail address privacy@eulerident.com, regarding the processing of your personal data.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, applicable laws, regulatory requirements, or business operations. Any updates will be published on this page with a revised “Last Updated” date.

Such updates shall become effective upon publication, unless otherwise required by applicable law. Where changes materially affect the manner in which your personal data is processed, we will provide you with appropriate notice and, where required under the Digital Personal Data Protection Act, 2023, obtain your renewed consent.

Your continued use of the Services after such updates constitutes acknowledgment and acceptance of the revised Privacy Policy

Data Retention

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required under applicable laws, regulatory obligations, contractual requirements, or lawful directions of competent authorities.

• Purpose Limitation Data is retained strictly for the purposes stated in this Privacy Policy (e.g., service delivery, identity verification, compliance).

• Legal and Regulatory Compliance Certain categories of data may be retained for statutory periods (e.g., tax, accounting, or audit requirements).

• Secure Deletion or Anonymization – Once retention is no longer required, personal data will be securely deleted or anonymized to prevent identification.

• Children’s Data If personal data of children is collected with parental consent, it will be retained only for the duration necessary to provide the service and then securely deleted.

• User Rights You may request erasure of your personal data, subject to statutory retention requirements and lawful directions.

• Account Information such as name, email, and KYC/KYB identifiers will be retained until you delete your account or withdraw consent, subject to statutory requirements.

• Financial Records including payment confirmations, invoices, and GST/TDS data will be retained for the statutory period prescribed under tax and accounting laws (generally up to eight years).

• Commute Tracking Data such as vehicle location logs and trip details will be retained only for 6 months, after which it will be securely deleted.

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