Last updated: 27/02/2024

Welcome to ZebraLearn website and application (collectively referred to as ‘Platform) provided by ZebraLearn Private Limited (‘ZebraLearn’, ‘Company’, ‘We’ or ‘Our/s’). At ZebraLearn, We are committed to protecting your privacy and ensuring the security of your personal information.

Purpose

This Privacy Policy (‘Policy’) outlines Our practices regarding the collection, use, maintenance and disclosure of information when you use Our Platform collected from its users or visitors (each referred to as a ‘User/s’, ‘You’or ‘Your’) through its Platform. By accessing or using Our Platform, You consent to the practices described in this Privacy Policy.

About Us

The Company is engaged in the business of book publishing and provides for an ed-tech platform that delivers learning programs, courses and workshops exclusively focused on the subject matter of finance (collectively, ‘Services’). Services would include any other future services the Company provides/proposes to provide.

You expressly agree to be bound by the terms and conditions of this Privacy Policy, the Terms of Use, and the applicable service/product terms and conditions by visiting this Platform, providing Your information. You also expressly agree to be governed by the laws of India, including but not limited to the laws governing data protection and privacy. Please refrain from using or gaining access to OurPlatform if You disagree.

Information supplied by the Users

1. Information We collect

We will only collect and process Personal Information about You where We have lawful basis to do so. Our primary purpose in collecting Your information, including personal information from You is to deliver personalized Services and its various features. We may collect the following types of information when You use Our Platform:

1.1.Personal Information: When You create an account or use Ourservices, We may collect personal information such as:

∙ Name

∙ Email ID (for verification via OTP generation)

∙ Date of Birth

∙ Phone Number (Optional)

The Information as supplied by the Users enables us to provide the Services and improve the ZebraLearn Platform Services and provide You the most user-friendly experience.

Any Information provided by You will not be considered as personal information if it is freely available and/or accessible in the public domain or is not deemed as personal information under the applicable law. Further, any reviews, comments, messages, blogs posted/uploaded/conveyed/communicated by Users on the public sections of the Site becomes published content and is not considered as personal information which is subject to this Policy.

In case You choose to decline to submit Information on the ZebraLearn Platform, We may not be able to provide certain Services on the website to You. We will make reasonable efforts

to notify You of the same at the appropriate time. In any case, We will not be liable and/or responsible for the denial of certain Services to You due to not receiving the necessary Information from You.

Additionally, the Users have an option to verify their email and phone number details by going to the ‘Verify Now’ option in their profile.

When You register with the ZebraLearn Platform, We may (at Our discretion) contact You from time to time about updates of Your Information.

2. How We Use Your Information

The information collected by the Users may be used in the following ways: 2.1. Providing Services: We use Your personal information to:

∙ Register You on Our Platform and manage Your account,

∙ Provide You with customer or technical support including addressing support queries or to diagnose any problems with Our servers or otherwise.

2.2. Improving Our Services: We use usage and technical information to analyze and improve the functionality and performance of Our Platform as mentioned below: ∙ Research, analyze and understand Our audience in order to improve Our Services; evaluate Your eligibility for certain types of offers, products or services and market such products or services to You;

∙ Determine Your geographic location, to provide You localized content including advertisements, personalized recommendations, allow You to continue watching/using previous content at another time, and to determine Your Internet service provider to troubleshoot a technical issue, and help us quickly and efficiently respond to inquiries and requests;

∙ Analyze and measure how effective Our advertising is by determining which media sources should be paid for delivering a desired action e.g. users who install Our Platform or subscribe (also known as 'attribution'), so that we pay for demonstrated value and don't overspend.

∙ To provide You with a personalised service and experience; We do this by linking some or all of Your Personal Information such as transactions done with ZebraLearn with Your activity on Our Platform across all Your devices and associating and storing this information with a unique platform generated identifier that is generated for each User

(guest as well as registered User). When a guest User subsequently registers and creates an account, the information and data relating to such User's past activities gets added to and associated to the registered account.

∙ In other contexts, if the processing of Your Personal Information is subject to the EU General Data Protection Regulation, We use Your Personal Information where the processing is in Our legitimate interests and not overridden by Your fundamental rights and freedoms (for example, Our direct marketing activities in accordance with Your

preferences) such as to Display or target advertisements on the Platform based on Your registration or profile information, location and/or Your activity on the Platform across all Your streaming devices (including inferred information through usage and log data) which is associated with Your device advertising identifier (IDFA, GAID etc) – this is typically referred to as 'interest-based advertising'. We also display contextual advertisements on the Platform but these are not targeted to any particular User and does not make use of any information that personally identifies You or precisely locates You (contextual advertising is advertising which We target based on the content being viewed, for example if You are watching a particular sporting event We may serve adverts of companies or products related to that particular sport or the age-group most likely to be watching).

2.3. Communication: We may use Your contact information for the following reasons:

∙ Send You tran sactional emails/SMS or to provide You with information, direct marketing, online and offline advertising and other materials regarding products, services and other offers from time to time in connection with the ZebraLearn App Service or its parent, subsidiary and affiliated companies ("Platform Entities") and its joint ventures.

∙ To send You important updates, notifications, and promotional materials related to Our Services.

2.4. Legal and Regulatory Compliance:

We may use Your information to comply with legal and regulatory obligations or otherwise whenever the law requires us to get Your permission or where We have stated We may seek Your permission in this Privacy Notice. In some contexts, We use Your Personal Information where We have a legal obligation to do so or to protect Your vital interests or those of another person to:

∙ Prevent, detect and investigate potentially prohibited or illegal activities, including fraud, and enforcing Our terms (such as determining free trial eligibility); ∙ Confirm Your identity if You are exercising legal rights;

∙ Notify You about changes in the Terms of Use or in this Privacy Notice; ∙ Carry out Our obligations and enforce Our rights arising from any contracts entered into between You and Us/Our distributor.

3. Information automatically tracked while using the App or Site

3.1. Demographic and Related Information: We may reference other sources of demographic and other information in order to provide You with more targeted communications and promotions. We use Google Analytics, among others, to track the User behaviour on Site.

3.2. Log File Information: Our Servers automatically collect limited Information about Your device's connection to the internet, including Your IP address, when You visit Our Site or use the App. We automatically receive and log Information from the App and/or Your browser including but not limited to IP address, Your device or computer's name, and Your operating system, We may also collect log Information from Your device, including but not limited to Your location, IP address, Your device's name, device's serial number or unique identification number (e.g. UDID on Your iOS device, Android ID or ADID on Your Android Device), Your device operating system, browser type and version, CPU speed, and connection speed etc.

4. Analytics

We use usage and technical information to analyze, research, analyze and understand Our audience in order to improve Our Services:

4.1.To perform analytics and conduct customer research, including general market research or surveying Our customers' needs and opinions on specific issues, generating sales and traffic patterns, and to analyze advertising effectiveness, both on an anonymous basis (e.g., by aggregating data) or on an individual basis (if legally permissible), in combination with other information collected from tracking technologies and aggregate it with information collected from other Users using Our Platform, to attempt to provide You with the Services and a better experience on the Platform. For example, one of the ways We use this information is to count the number of times an advert or other content is viewed because this might be the metric by which Our advertisers pay us. This information is compiled and analyzed on an aggregated basis.

4.2.Our Platform may collect information about the pages you visit for the purpose of improving User experience, providing personalized content, and analyzing Platform performance. This information may include but is not limited to page views, time spent on

pages, and interactions with content. We use this data in an aggregated and anonymized form to gain insights into User preferences, optimize content delivery, and enhance the overall functionality of Our Platform. This information is treated with the utmost confidentiality, and we do not share individual User page-view data with third parties unless required by law. It is important to note that while we collect this information, we do not associate it with personally identifiable information unless explicitly provided by you, such as through User account details.

4.3.Our Platform may collect information about the amount of time Users spend on each page for analytical purposes and to enhance User experience. This data includes the duration of visits to specific pages, and it helps us understand User engagement, improve content relevance, and optimize the overall functionality of Our Platform. We treat this information with the utmost confidentiality, and it is used in an aggregated and anonymized form. Individual User visit durations are not shared with third parties unless required by law. Additionally, we do not associate this data with personally identifiable information unless explicitly provided by you, such as through User account details.

4.4.In the event of an application crash, we may automatically collect certain information related to the crash for diagnostic purposes. This may include but is not limited to device information, app version, and the circumstances leading to the crash. The purpose of collecting this information is to identify and address technical issues, improve the stability of Our app, and enhance the overall User experience. This crash information may be collected anonymously and will be used solely for internal analysis and troubleshooting. We do not use this data for any other purpose or share it with third parties, except as required by law.

4.5.Our Platform may collect information related to in-app product tracking for the purpose of improving User experience, providing personalized recommendations, and analyzing User preferences. This information may include, but is not limited to, details about products viewed, added to cart, purchased, and other related interactions within the Platform. We use this data in an aggregated and anonymized form to enhance Our product offerings, optimize in-app navigation, and tailor content to better suit User interests. Individual User

product tracking information is treated with the utmost confidentiality, and we do not share this data with third parties unless required by law. It is important to note that while we collect in-app product tracking data, we do not associate it with personally identifiable information unless explicitly provided by you, such as through User account details.

Use of Cookies

Our Platform may use ‘cookies’ to enhance User experience. User's web browser places cookies on their device for record-keeping purposes and sometimes to track information about them. User may choose to set their web browser to refuse cookies, or to alert You when cookies are being sent. If they do so, note that some parts of the Platform may not function properly. By continuing to visit the Platform, You are agreeing to the use of cookies and similar technologies for the purposes We describe in this Policy. If You prefer not to receive cookies or web beacons, then You should stop using Services, or consult Your browsing and third party cookie settings. We use cookies and other technologies for analyzing and optimizing Our websites as well as for marketing purposes. Our partners may also assign their own cookies to Your browser, a process that We do not control. Kindly refer to Our Cookies Policy separately for more information on how We use cookies.

Accessing, Updating and Deleting Your personal data

When Users use the Site (or any of its sub sites) / App, we make good faith efforts to provide Users, as and when requested by Users, with access to their Information and shall further ensure that any personal information or sensitive personal data or other Information found to be inaccurate or deficient shall be corrected or amended as feasible, subject to any requirement for such personal

Information or sensitive personal data or Information to be retained by law or for legitimate business purposes.

We ask individual Users to identify themselves and the Information requested to be accessed, corrected or removed before processing such requests, and We may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, or would be extremely impractical (for instance, requests concerning Information residing on backup tapes), or for which access is not otherwise required.

In any case, where We provide Information access and correction, We perform this service free of charge, except if doing so would require a disproportionate effort. Because of the way We maintain certain services, after You delete Your Information, residual copies may take a period of time before they are deleted from Our active servers and may remain in Our backup systems

You have the ability to access, modify and remove the personal information collected from you through the following means:

1. To update information, You provided directly, log in to Your account using Your credentials on the Platform and make changes at any time.

2. To delete Your account, the following steps should be followed:

∙ Log In: Begin by logging into Your account on the Platform using the credentials you used during the registration process.

∙ Navigate to Settings: Once logged in, proceed to the 'Settings' or 'Profile Settings' section. This is typically located in the menu or navigation bar of the Platform.

∙ Find Account Removal Option: Look for and select the 'Request Account Removal' or 'Delete Account' option within the settings. This option is designed to initiate the account deletion process. This may take upto 24-48 hours.

∙ Confirmation Process: After selecting the account removal option, the Platform will guide you through the deletion process. Follow the on-screen instructions carefully to confirm the deletion of Your account.

∙ Irreversible Action: It's important to note that this process is irreversible. Once you confirm the deletion, all associated data, including Your profile information and any stored content, will be permanently removed from Our system.

∙ Contact Support: If you encounter any difficulties or have questions about the account deletion process, Our support team is here to assist you. Feel free to reach out to them for guidance and clarification.

It's important to note that even after account termination, the following consequences will ensue:

1. Data Retention: Please be informed that certain information may be retained by us for legal and internal purposes, even subsequent to the deletion of Your account.

2. Impact on services: It is important to note that the deletion of Your account may result in the loss of access to specific services or features associated with Your account. 3. Third-Party Integrations: If You initially signed up or logged in using a third-party account, additional steps may be necessary to unlink Your account from these third-party integrations. 4. Some or all of Your data may still be visible to others due to factors such as copying, sharing, or posting on third-party platforms.

5. The Platform retains Your data for legitimate purposes, in compliance with applicable laws, for tasks like meeting legal obligations, resolving disputes, and enforcing agreements.

For any inquiries or assistance concerning the account deletion process, Our dedicated support team is readily available. Please feel free to reach out to them at [●].

Link to third party sites/ad-servers

The Site may include links to other websites such as advertisers, blogs, content sponsorships, vendor services, social networks, etc. Such websites are governed by their respective privacy policies, which are beyond Our control. Once You leave Our servers (You can tell where You are

by checking the URL in the location bar on Your browser), use of any information You provide is governed by the privacy policy of the operator of the site You are visiting and We make no representation or warranty on how Your information is stored or used on third-party servers. That policy may differ from Ours. If You can't find the privacy policy of any of these sites via a link from the website's homepage, You should contact the website directly for more information.

Information storage and backup

From time to time, We take backup of Your data on ZebraLearn App on Our cloud database. This is done for the purpose of enabling Users to get their data back in case their phone's data becomes unusable, or phone gets lost, or the User moves to a new phone device. We also use this backup to provide useful insights and information related to their spends such as weekly spends in a month, insights related to spend behavior, etc., and to provide information related to User spends, patterns and User data in the form of aggregated and anonymized statistics on data such as User spends by category, date, time, network credits, etc.

We shall keep User’s Information in Our records till the period of time where We can potentially offer the App Services to the Users. After such period of time where ZebraLearn App Services are no longer relevant to a User, We remove all the Information pertaining to a particular User from Our records.

Data Security

We take appropriate security measures to protect against unauthorized access to or alteration, disclosure or destruction of data including accidental or intentional manipulation, loss from access by unauthorised parties. These include internal reviews of Our data collection, storage and processing practices and security measures, including appropriate encryption and physical security measures to guard against unauthorized access to systems where We store personal data. All Information gathered on the ZebraLearn Platform is securely stored within the controlled database. Access to the servers is password-protected and is strictly limited.

Our security measures are regularly reviewed and updated to reflect technological developments. Regardless of where Your personal information is transferred or stored, We take all steps reasonably necessary to ensure that personal information is kept secure, however, please understand that no transmission of data over the internet or any other public network can be guaranteed to be 100% (one hundred percent) secure.

We seek to ensure compliance with the requirements of the applicable data protection laws to ensure the protection and preservation of the User’s privacy and personal Information. We have physical, electronic, and procedural safeguards that comply with the laws prevalent in specific jurisdiction to protect User’s Personal Information. By accepting the terms of this Policy, You agree that the standards and practices being implemented by us, are reasonable and sufficient for the protection of Your personal information.

We will contact You regarding any breach of the security, confidentiality, or integrity of Your unencrypted electronically stored Personal Information to You via email or any other feasible manner in the most expedient time possible and without unreasonable delay, insofar as consistent with the legitimate needs of law enforcement and will undertake all measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.

Revocation of consent

A User can revoke his consent to the processing of his personal information at any time with effect for the future. Please note that withdrawing consent does not affect Our right to continue to collect, use and disclose personal information where such collection, use and disclosure without consent is permitted or required under applicable laws.

Your Choices

You can update or delete Your account information at any time by logging into Your account settings. The personal information of the User will be stored for the length of time needed to fulfill the purposes outlined in this privacy policy unless a longer retention period is required or permitted by law.

Changes to this Privacy Policy

We may alter Our Policy from time to time to incorporate necessary changes in technology, applicable law, any other variant or in Our practices for other operational, legal, and regulatory reasons. In any case, We reserve the right to change (at any point of time) the terms of this Policy or the Terms of Use. We may update this Privacy Policy from time to time to reflect changes in Our practices or for other operational, legal, or regulatory reasons. We will notify You of any material changes by posting a notice on Our Website. In any case, You are advised to review this Policy periodically on the Site to ensure that You are aware of the latest version. We retain the right to modify Our Privacy Policy as deemed necessary. Any alterations to the policy will be duly reflected on this page, accompanied by an updated "Last Updated" date.

Severability

In the event that any provision and/or clause and/or term of this Policy is found to be invalid, void and unenforceable by a Court of any competent jurisdiction, then the remaining provisions will remain in force in accordance with the original intention of ZebraLearn.

Governing Law and Dispute Resolution

The Courts in India alone shall have exclusive jurisdiction for all and any matters arising out of or concerning or relating to or touching this Policy.

In the event that any dispute arises between the Parties in connection with this Policy, the Parties shall conduct negotiations in good faith to solve such dispute. If mutual resolution cannot be reached within 15 (fifteen) days after the commencement of such negotiations, the same shall be settled by a binding arbitration conducted by a sole arbitrator, appointed jointly by both parties and governed by the Arbitration and Conciliation Act, 1996. In the event of any dispute arising out of this Policy The arbitral award will be final and binding upon the Parties. The venue, place and seat of the arbitration shall be Surat, India and the language of the arbitration proceedings shall be English or Hindi or Gujarati. The Parties can also opt to resolve the dispute(s) in order to reach amicable resolution through online mode via Zoom/ Google Meet platform. This Policy, and the rights and obligations of the Parties shall remain in full force and effect pending the award in such arbitration proceeding, which award, if appropriate, shall determine whether and when, any termination shall become effective.

Intellectual Property

Any User or person who has access to the Site or the information contained therein, expressly recognizes that Zebralearn Private Limited, and/or its Affiliates, are the owners, and/or legitimate licensees, as well as any brand, trade name or any other industrial property right or copyright that appears on the Site. Likewise, the User acknowledges that Zebralearn Private Limited has been the developer of the concept of ZebraLearn App, so it is known to said User that said information and/or concept are protected by Indian laws and international copyright treaties. Therefore, any reproduction, modification, alteration, use or any other use given to said information and/or concept is prohibited.

Disclaimer

In case any personal information is shared by You with us, which is not requested by us during registration, (whether mandatory or optional), we will not be liable for any information security breach or disclosure in relation to such information.

If You have any questions regarding this Policy or the protection of Your personal information, please contact Our data protection officer/grievance officer.

In the event of any inconsistency between the English version and other language versions, the English version shall prevail.

Subject to any exceptions under applicable laws, You may at any time:

1. Request for access to, or for correction or rectification of Your Personal Data; 2. Request to limit the Processing or Your Personal Data;

3. Seek further information or clarification from us regarding this Privacy Notice; or 4. Raise any grievance relating to the processing of Information provided by You.

You may contact Our Grievance Officer at legal@zebralearn.com or write to us at the following address:

Zebralearn Private Limited

Email: hello@zebralearn.com

Contact: +91 7984460832

We may to the extent not limited by the law:

1. Charge a fee for processing Your request for access or correction to the Personal Data; and/or,

2. Refuse to comply with Your request for access or correction of the Personal Data and give You a reason for Our refusal.