This Privacy Policy describes:

• The types of personal data we collect;
• The purposes for which we collect such data;
• How we process, store, and protect your data;
• Your rights as a Data Principal under the Act;
• Our grievance redressal mechanism.

By accessing our website at https://crossbondindia.com/ (the “Site”) or providing us with your personal data, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy.

1. INTRODUCTION

Crossbond India (“Crossbond,” “we,” “us,” or “our”) is committed to protecting the privacy and security of your personal data in compliance with the Digital Personal Data Protection Act, 2023 (the “Act”).

2. DEFINITIONS

Capitalized terms used in this policy have the meaning assigned to them under the Digital Personal Data Protection Act, 2023:

“Data Principal”

You — the individual to whom the personal data relates.

“Data Fiduciary”

Us — Crossbond India — who determines the purpose and means of processing your personal data.

“Personal Data”

Any data about an individual who is identifiable by or in relation to such data.

“Processing”

Any operation performed on personal data, including collection, recording, storage, use, sharing, erasure, etc.

“Consent”

A free, specific, informed, unconditional, and unambiguous agreement with a clear affirmative action.

3. NOTICE TO DATA PRINCIPALS (SECTION 5 OF THE ACT)

4. INFORMATION WE COLLECT

4.1 Personal Data Collected with Consent

We collect personal data only when you voluntarily provide it to us by filling out an enquiry form on our website. The data collected is strictly limited to:

• Full Name
• Email Address
• Phone Number

Legal Basis: Your consent (Section 6 of the Act).

4.2 Data Collected through Automated Means (Cookies)

We use cookies and similar technologies to enhance your browsing experience. Cookies are small text files placed on your device.

Purpose of Cookies: To remember your preferences and track website activity.

Google Analytics: We use Google Analytics to analyze website performance and browsing patterns. Google Analytics collects anonymized data about your device, operating system, and browsing history. It does not collect any personally identifiable information.

Control over Cookies: You may control or disable cookies through your browser settings. However, disabling cookies may affect the functionality of the Site.

4.3 No Collection of Sensitive Data

We do not collect any sensitive personal data (such as financial information, passwords, biometric data, etc.) through our website.

4.4 No Collection from Browsers

We do not collect any personal information from users who merely browse our website without filling out an enquiry form.

5. GROUNDS FOR PROCESSING PERSONAL DATA (SECTION 4 OF THE ACT)

We process your personal data only on the following lawful grounds:

5.1 Consent (Section 6)

Where processing is based on your consent:

• We obtain your consent through a clear affirmative action (e.g., clicking “Submit” on the enquiry form).
• Your consent is free, specific, informed, unconditional, and unambiguous.
• We provide you with the option to access this notice in English or any language specified in the Eighth Schedule to the Constitution (upon request).
• We provide contact details of our Grievance Officer for any communication.

5.2 Certain Legitimate Uses (Section 7)

We may process your personal data without consent for the following legitimate uses:

• To respond to enquiries initiated by you (purpose for which you voluntarily provided the data);
• To comply with any legal obligation or law for the time being in force in India;
• To comply with any judgment, decree, or order issued under any law.

6. HOW WE USE YOUR PERSONAL DATA

We do not use your personal data for any marketing or promotional purposes.

7. SHARING AND DISCLOSURE OF PERSONAL DATA

7.1 No Sharing with Third Parties

We do not share, sell, rent, or trade your personal data with any third parties for commercial or marketing purposes.

7.2 Exceptions

The only exceptions where your personal data may be accessed or disclosed are:

7.3 Data Processors

If we engage any Data Processor to process personal data on our behalf, we shall do so only under a valid contract as required under Section 8(2) of the Act, ensuring they comply with the same level of data protection.

8. YOUR RIGHTS AS A DATA PRINCIPAL (CHAPTER III OF THE ACT)

Under the Digital Personal Data Protection Act, 2023, you have the following rights:

How to Exercise Your Rights: To exercise any of these rights, please contact our Grievance Officer at info@crossbondindia.com with the subject line: “Data Principal Rights Request”.

9. DATA SECURITY OBLIGATIONS (SECTION 8 OF THE ACT)

We implement appropriate technical and organizational measures to ensure the security of your personal data, as mandated under Section 8(5) of the Act:

• Secure Servers: Your data is stored on secure servers with restricted access.
• Firewalls: We employ firewalls to prevent unauthorized access to our systems.
• Access Control: Access to personal data is limited to authorized personnel only on a need-to-know basis.
• Regular Reviews: We regularly review our security practices to ensure ongoing protection.

9.1 Personal Data Breach

In the unfortunate event of a personal data breach that compromises the confidentiality, integrity, or availability of your personal data:

• We shall intimate the Data Protection Board of India in the form and manner prescribed;
• We shall intimate each affected Data Principal;
• We shall take urgent remedial or mitigation measures as directed by the Board.

10. DATA RETENTION AND ERASURE (SECTION 8(7) OF THE ACT)

We retain your personal data only as long as necessary to fulfill the specified purpose for which it was collected.

Note: If you have not approached us for the specified purpose for such time period as may be prescribed under the Act, the purpose shall be deemed to no longer be served.

11. GRIEVANCE REDRESSAL MECHANISM (SECTION 13 OF THE ACT)

In compliance with Section 5(3) and Section 8(9) of the Act, we have established a robust grievance redressal mechanism.

11.1 Grievance Officer Details

11.2 How to File a Grievance

You may file a grievance in writing via email to info@crossbondindia.com with the subject line clearly marked as “GRIEVANCE”.

Your grievance should include:

• Your full name and contact details;
• A clear description of the issue or complaint;
• Any supporting documents or references.

11.3 Grievance Redressal Process

• Acknowledgment: We will acknowledge receipt of your grievance within a reasonable time.
• Resolution: We shall endeavour to resolve your grievance within the prescribed timeframe.
• Exhaustion of Remedy: As per Section 13(3) of the Act, you are required to exhaust the opportunity of redressing your grievance with us before approaching the Data Protection Board of India.

11.4 Duties of Data Principal (Section 15)

While exercising your rights or filing a grievance, you are expected to:

• Comply with all applicable laws;
• Not impersonate another person;
• Not suppress material information;
• Not register false or frivolous grievances;
• Furnish only verifiably authentic information.

12. COOKIES AND AUTOMATED DATA COLLECTION

12.1 What Are Cookies?

Cookies are small text files stored on your device when you visit a website. They help websites remember your preferences and understand how you interact with the site.

12.2 Cookies We Use

12.3 Managing Cookies

You can control and manage cookies through your browser settings. Most browsers allow you to:

• View and delete cookies;
• Block cookies from specific sites;
• Block all cookies (may affect website functionality).

12.4 Google Analytics

We use Google Analytics to analyze website traffic and improve user experience. Google Analytics collects anonymized information about:

• Your device type and operating system;
• Browser type;
• Pages visited and time spent;
• Referring websites.

Google’s use of this data is governed by their Privacy Policy available at: https://policies.google.com/privacy.

13. CHILDREN’S DATA (SECTION 9 OF THE ACT)

Our website and services are not directed at children (individuals below 18 years of age).

We do not knowingly collect or process personal data of children. If we become aware that we have inadvertently collected personal data from a child without verifiable parental consent, we will take steps to delete such information promptly.

We do not undertake tracking, behavioral monitoring, or targeted advertising directed at children.

14. INTERNATIONAL DATA TRANSFERS (SECTION 16 OF THE ACT)

We do not currently transfer any personal data outside India. If in the future we need to transfer personal data outside India, we shall comply with any restrictions notified by the Central Government under Section 16 of the Act.

15. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in:

• Our data processing practices;
• Legal or regulatory requirements;
• Operational requirements.

The “Effective Date” at the top of this page indicates when this policy was last revised. We encourage you to review this Privacy Policy periodically. Your continued use of our Site after such changes constitutes your acceptance of the updated Privacy Policy.

16. LEGAL JURISDICTION

This Privacy Policy shall be governed and construed in accordance with the laws of the Republic of India, including the Digital Personal Data Protection Act, 2023. Any dispute arising out of or relating to this Privacy Policy or our services shall be subject to the exclusive jurisdiction of the courts located in New Delhi, India.

17. CONSENT AND ACKNOWLEDGEMENT

By providing your personal data to Crossbond India via our enquiry form at https://crossbondindia.com/, you:

• Acknowledge that you have read and understood this Privacy Policy;
• Give your free, specific, informed, unconditional, and unambiguous consent to the processing of your personal data as described herein;
• Confirm that the information provided by you is accurate and complete;
• Agree to notify us of any changes to your personal data.

18. CONTACT INFORMATION

If you have any questions, concerns, or requests regarding this Privacy Policy or our data processing practices, please contact us: