MANDIR PATH PVT. LTD.

PRIVACY POLICY

1. INTRODUCTION

This Privacy Policy (“Policy”) explains how Mandir Path Pvt. Ltd. (“Mandir Path”, “Company”, “we”, “us” or “our”) collects, uses, discloses, retains and otherwise processes Personal Information when you access or use the Mandir Path mobile application, website and related services (collectively, the “Platform”) from the United States.

The Platform facilitates devotional, religious and spiritual experiences in digital form. Depending on the features made available, these may include virtual puja, scheduled streams, Panchang, mantras, aartis, devotional streaks, virtual Coins and Bricks, the Virtual Daan Patra, and related services (the “Services”).

This Policy should be read with the Platform’s Terms and Conditions and any applicable feature-specific terms. If you do not agree with this Policy, please do not provide Personal Information to us or use features for which such processing is necessary, subject to any rights available to you under applicable law.

This Policy is written to meet United States federal and state privacy and consumer-protection requirements, including Section 5 of the Federal Trade Commission Act, the Children’s Online Privacy Protection Act and its implementing rule (“COPPA”), the California Consumer Privacy Act as amended by the California Privacy Rights Act (“CCPA”), the California Online Privacy Protection Act (“CalOPPA”), and the comprehensive consumer privacy laws of other states (together, “US Privacy Laws”). Section 13 contains additional information for residents of certain states.

“Personal Information” means information that identifies, relates to, describes, or is reasonably capable of being associated with or linked to you or your household or device, as defined by US Privacy Laws. It does not include information that is de-identified, aggregated or publicly available as those terms are defined by law.

2. WHO WE ARE AND HOW TO CONTACT US

Business / Company: Mandir Path Pvt. Ltd.

Registered Office: H-8 F, Hauz Khas, New Delhi – 110016, India

Privacy Contact Email: support@mandirpath.com

Complaints Email: grievance@mandirpath.com

Telephone: ____________________

Please use the contact details above to ask questions about this Policy, make a privacy request, or raise a complaint. We will respond within the periods described in Section 11. If you need this Policy in an alternative format because of a disability, please contact us.

3. PERSONAL INFORMATION WE COLLECT

The Personal Information we collect depends on the features you use and the information you choose to provide. We do not collect every category listed below from every user. This Section also serves as our “notice at collection”; we also show a short notice in the App at the point where we collect information.

3.1 Registration and account information

When you register or use an account, we may collect your name, mobile number, email address (if you choose to provide one), account identifiers, authentication or verification information (such as one-time passcodes), and other details you provide in connection with your account. Please provide accurate and current information where required and keep it updated.

3.2 Custom Photos and User Content

Where the Platform permits, you may upload photographs or other content, including a photograph of yourself, a family member or a deity, for a profile, virtual altar, greeting or another feature (“Custom Photos” and, together with other content you submit, “User Content”). You are responsible for ensuring that you have the right, and any permission required by law, to upload images or information about other people. Do not upload photographs of a child unless you are that child’s parent or legal guardian. We do not use facial-recognition technology or create face templates or other biometric identifiers from Custom Photos.

3.3 information about other people

Your information may reveal your religious beliefs or practices and is treated as sensitive information under Section 5.1. If you provide information about another person, such as a family member, you confirm that you are entitled to do so. Do not provide information about a child unless you are the child’s parent or legal guardian.

3.4 Purchases, payments and Virtual Units

We may process information about purchases of Coins and Bricks, subscriptions (if offered), and other paid Services. This may include the item or service purchased, amount and currency, date and time, transaction or order reference, payment status, refund status, and records needed to verify or reconcile a transaction.

Payments are processed through authorised payment service providers and/or the relevant App Store (such as the Apple App Store or Google Play). The Company does not store your payment card details. Payment providers separately collect and process payment information under their own terms and privacy policies.

3.5 Service and usage information

We may process information about your use of the Platform, such as devotional streaks, Reward Coins credited, Purchased Coins or Bricks purchased or used, Virtual Daan Patra activity, and related transaction or account records. This information helps us provide the Services, maintain accurate records and respond to queries.

3.6 Technical, device and diagnostic information

When you use the Platform, we or our service providers may automatically receive technical information needed to operate, secure and troubleshoot it, such as device and operating-system information, App version, device identifiers, IP address (from which we may derive your approximate location, such as city or region), log data, crash reports, diagnostic information, and information about your interactions with Platform features. (We do not collect precise geolocation. – confirm)

3.7 Communications and support

If you contact us, submit a complaint, report content, or request support, we may process your contact details, the contents of your communication, supporting documents or screenshots, and records of how the matter is handled.

3.8 Information from third parties

We may receive limited information from payment service providers, App Stores, authentication providers, service partners or other third parties where necessary to confirm a transaction, provide a requested Service, address a complaint, prevent fraud or comply with law.

3.9 Summary of categories collected in the last 12 months

The table below summarises, using the categories defined in the CCPA, the Personal Information we have collected in the preceding 12 months. “Purposes” refers to the lettered purposes in Section 4. If the Platform has been available for less than 12 months, this table covers the period since launch.

We do not create profiles of you for advertising purposes or to infer other characteristics about you, and we do not use automated decision-making technology to make decisions that produce legal or similarly significant effects about you. [confirm]

4. HOW WE USE PERSONAL INFORMATION

We may use Personal Information for the following purposes, to the extent relevant to the feature you use:

1. to create, authenticate, maintain and secure your account;
2. to provide, operate and personalise the Platform and the Services you request;
3. to use Custom Photos and other information for the specific personalisation or service requested by you;
4. to process and verify purchases, payments, refunds where applicable, subscriptions if offered, and transaction records;
5. to credit, maintain and record Reward Coins, Purchased Coins and Bricks and related activity;
6. to respond to questions, complaints and support queries;
7. to maintain, troubleshoot, debug, test and improve the security, performance and functionality of the Platform;
8. to detect, investigate and prevent fraud, security incidents, unauthorised access, misuse, abuse or breaches of the Terms and Conditions;
9. to communicate important service notices, security alerts, policy changes and transaction-related messages;
10. to comply with applicable law, subpoenas, court orders, valid legal process, and lawful requests from government authorities; and
11. to establish, exercise or defend legal claims and protect the rights, safety and property of the Company, users or others.

We will not use Personal Information for purposes that are materially different from those described in this Policy, or that are incompatible with them, without giving you notice and, where required by law, obtaining your consent.

5. SENSITIVE INFORMATION AND PURPOSE-SPECIFIC USE

5.1 Religious and other sensitive information

Because the Platform is a devotional service, some information you provide, such as devotional activity and photographs of religious content, may reveal your religious beliefs or practices. US Privacy Laws treat this as sensitive information. We collect and process it only (i) with your consent, which we ask for before you submit it, and (ii) to provide the Services you request, such as fulfilling your booking, and for security, fraud-prevention and legal-compliance purposes that the law permits. We ask for this consent on a separate screen in the App (or on the relevant web form) that is not part of your acceptance of the Terms and Conditions, and we keep a record of it. You may decline to provide this information and still use features that do not require it.

We do not sell this information, share it for cross-context behavioural advertising, use it for advertising or profiling, or use it to infer other characteristics about you. You may withdraw your consent at any time as described in Section 11. Withdrawal does not affect processing carried out before you withdrew, and we may be unable to provide a Service that requires the information. Because we use sensitive personal information only for these purposes, we do not offer a separate “Limit the Use of My Sensitive Personal Information” link. If this changes, we will add the link and update this Policy.

5.2 Custom Photos and Platform Videos

A Custom Photo may be processed to provide the feature or service for which you uploaded it. As stated in the Terms and Conditions, we will not use a Custom Photo for advertising or promotion without your separate consent.

5.3 User Content

We may host, store, reproduce, format, display or transmit User Content to the extent reasonably necessary to operate the Platform, provide Services, moderate content, maintain security, handle complaints and comply with law. We will not use User Content for advertising or another commercial purpose beyond these purposes without your consent, as provided in the Terms and Conditions. (We do not use User Content or sensitive information to train machine-learning or artificial-intelligence models. – confirm)

5.4 Virtual Daan Patra and donations

We may process transaction and offering information to record an offering and apply the amount corresponding to Purchased Coins or Bricks in the manner displayed to you before the offering. Offering Reward Coins is symbolic and does not result in a payment to a temple, deity, trust or third party, as stated in the Terms and Conditions.

5.5 Panchang, mantras and devotional content

The Platform may use third-party providers for Panchang data, mantras, aartis and other devotional content. Those providers may process technical or usage information as necessary to supply their services, in accordance with their applicable terms. The Company does not independently prepare Panchang data or verify all third-party devotional content, as described in the Terms and Conditions.

6. WHEN WE DISCLOSE PERSONAL INFORMATION

We disclose Personal Information only as reasonably necessary for the purposes described in this Policy, and subject to applicable law. Recipients may include:

1. payment service providers, banks, payment-system participants and App Stores, for payment processing, purchase verification, refunds or subscription administration;
2. service providers and contractors, such as hosting, storage, security, customer-support, communication, diagnostic and maintenance providers, that process Personal Information on our behalf under contracts that limit their use of it to providing services to us;
3. Service Partners, where you request a service that they perform. We provide only the information needed to fulfil your booking, and we do so at your direction;
4. third-party content or service providers whose services are integrated into the Platform;
5. professional advisers, auditors or insurers, where reasonably necessary for business, legal or compliance purposes;
6. courts, law-enforcement agencies, regulators or other government authorities, where disclosure is required or permitted by law, such as in response to a subpoena or court order, or where necessary to protect rights, safety or property. Disclosures made in response to a legal demand will be limited to what we are legally required or permitted to provide; and
7. a successor, acquirer or relevant entity in connection with a merger, restructuring, financing or transfer of all or part of the business. If the recipient will use your Personal Information in a way that is materially inconsistent with this Policy, we will give you notice.

6.1 No sale or sharing of Personal Information

In the preceding 12 months, we have not “sold” or “shared” Personal Information (as those terms are defined in the CCPA), including the Personal Information of consumers we know to be under 16 years of age, and we do not use or disclose Personal Information for targeted advertising.

6.2 Categories disclosed for a business purpose in the last 12 months

Any category may also be disclosed to government authorities and professional advisers where required by law, and to a successor in a business transfer, as described above.

7. COOKIES, SDKs, ANALYTICS, DO NOT TRACK AND GLOBAL PRIVACY CONTROL

The Platform uses cookies, software development kits (SDKs), logs and similar technologies for functionality, security, diagnostics and analytics. For more detail, see our Cookies Policy.

[List the tools actually used, e.g. crash-reporting and analytics SDKs, and what each does. Talk to your tech partners]

These providers act as our service providers and may use the data only to provide services to us. We do not use third-party advertising SDKs or cross-context behavioural advertising technologies. [confirm] If we begin to do so, we will update this Policy, provide an opt-out, and obtain any consent required by law.

Do Not Track. Because there is no uniform industry standard, the Platform does not respond to browser “Do Not Track” signals. Global Privacy Control. We treat a Global Privacy Control (“GPC”) signal received through your browser or device as a valid request to opt out of the sale or sharing of Personal Information for that browser or device and, where we can identify it, your linked account.

You may be able to control certain permissions through your device settings. Disabling a necessary technology or permission may affect the availability or functioning of some features.

8. CHILDREN AND TEENS

8.1 Children under 13

The Platform is not directed to children under 13, and you must be at least 13 years old to create an account. We do not knowingly collect Personal Information from children under 13 without verifiable parental consent. If we learn that we have collected Personal Information from a child under 13 without it, we will delete the information promptly. A parent or guardian who believes we have collected information from their child may contact us to review it, ask us to delete it, or refuse further collection. We use a neutral age screen at registration and do not allow a person who indicates that they are under 13 to create an account.

If we later offer features directed to children under 13, or knowingly collect their Personal Information, we will first update this Policy, give parents the direct notice COPPA requires, obtain verifiable parental consent, obtain separate parental consent for any disclosure to third parties that is not integral to the service, and publish the retention and third-party disclosure information COPPA requires.

8.2 Teens aged 13 to 17

Users aged 13 to 17 should use the Platform with the knowledge and supervision of a parent or guardian. We do not sell or share the Personal Information of consumers we know to be under 18, and we do not use it for targeted advertising or profiling. California residents under 18 who are registered users may ask us to remove content or information they have posted on the Platform by contacting us. Removal may not be complete or comprehensive, and the law does not require us to remove content in every circumstance.

8.3 Photographs of other people

Please see Section 3.3. If you believe that a child’s Personal Information has been provided to us or processed in a manner that may violate applicable law, please contact us using the details in Section 2.

9. DATA RETENTION

We retain Personal Information only for as long as reasonably necessary for the purposes for which it was collected, including to provide the Services, comply with law, maintain required business and transaction records, resolve disputes and complaints, prevent fraud, and establish or defend legal claims. We do not retain Personal Information indefinitely. Where a fixed period is not stated below, we determine retention by the purpose for which the information is held, our legal and accounting obligations, applicable limitation periods, and whether you have asked us to delete it.

Where law requires preservation, or where information is reasonably necessary for legal proceedings, security investigations or the establishment or defence of legal claims, it may be retained for the applicable period. When Personal Information is no longer needed, we will delete it or de-identify it.

10. SECURITY OF PERSONAL INFORMATION

We maintain reasonable administrative, technical and physical safeguards designed to protect Personal Information against unauthorised access, disclosure, alteration, loss or misuse. These may include access restrictions, encryption in transit, monitoring and controls appropriate to the sensitivity of the information and the risks involved.

No method of electronic transmission or storage is completely secure, and we cannot guarantee absolute security. Please keep your account credentials and one-time passcodes confidential and notify us promptly if you suspect unauthorised access to your account. If a breach of security affects your Personal Information, we will notify you and, where required, regulators, as required by applicable federal and state breach-notification laws.

11. YOUR PRIVACY RIGHTS AND CHOICES

11.1 Your rights

Depending on the state in which you live, and subject to exceptions in the law, you may have the right to:

1. Know and access: confirm whether we process your Personal Information and obtain the categories of Personal Information we have collected about you, the sources, the purposes, the categories of third parties to whom we disclose it, and the specific pieces of Personal Information we hold, in a portable format where technically feasible;
2. Correct inaccurate Personal Information;
3. Delete the Personal Information we hold about you;
4. Opt out of the sale or sharing of your Personal Information, targeted advertising, and profiling that produces legal or similarly significant effects. We do not engage in these activities (see Section 6.1);
5. Limit the use and disclosure of sensitive personal information (California). See Section 5.1;
6. Withdraw consent that you gave for the processing of sensitive information;
7. Be free from discrimination: we will not deny you Services, charge you different prices, or give you a different level of quality because you exercised a privacy right; and
8. Appeal our decision on a request, as described in Section 11.4.

11.2 How to make a request

Email us at [support@mandirpath.com] with the subject line “Privacy Request”, [or use the privacy or account-deletion option in the App’s settings]. Please tell us your name, the mobile number linked to your account, the type of request, and your state of residence. You may also use an authorised agent to make a request for you. We may require the agent to provide your written permission and may contact you directly to verify the request. A parent or legal guardian may make a request on behalf of a minor child.

11.3 Verification and timing

We must verify that a request comes from the person whose information it concerns. We will usually do this by matching the information you give us with your account details, including by sending a one-time passcode to your registered mobile number. We will not ask for more sensitive information than we need for this purpose. We will confirm receipt of your request within 10 business days and respond within 45 days. We may extend that period once by up to a further 45 days where reasonably necessary, and we will tell you why. Requests are free, unless a request is manifestly unfounded, excessive or repetitive, in which case the law may allow us to charge a reasonable fee or decline. If we deny a request, we will explain why. For California residents, you may request information about Personal Information collected on or after January 1, 2022 that is older than 12 months, unless doing so is impossible or involves disproportionate effort.

11.4 Appeals

If we deny your request, you may appeal by replying to our decision or by emailing [support@mandirpath.com] with the subject line “Privacy Appeal”. We will respond in writing within the period required by applicable law (generally 45 to 60 days) and will explain the reasons for our decision. If you are not satisfied with the outcome, you may contact your state attorney general or, in California, the California Privacy Protection Agency, or file a complaint with the Federal Trade Commission.

11.5 Marketing emails and text messages

We send service-related and transactional messages, including one-time passcodes, to your mobile number and email address. [Include if applicable: We send promotional emails or text messages only where you have opted in or as otherwise permitted by law. You may unsubscribe from promotional emails using the link in each message, and reply STOP to any text message to opt out. Message and data rates may apply. Consent to receive promotional messages is not a condition of any purchase.] [Include if applicable: We do not share mobile information, including phone numbers and text-message opt-in data and consent, with third parties or affiliates for their marketing or promotional purposes. Our promotional emails include our postal address and an unsubscribe link, as required by the CAN-SPAM Act.]

12. ACCOUNT DELETION

You may stop using the Platform and request deletion of your account through any account-deletion mechanism made available in the App or by contacting us at [support@mandirpath.com]. We will process a valid request in accordance with applicable law and Section 11.

Account deletion may affect access to the Platform and associated features. Certain information may be retained where required or permitted by law, including transaction records, information needed to resolve disputes, prevent fraud, comply with legal obligations or establish or defend legal claims.

Deleting the App from your device does not by itself delete your account. Account deletion is also separate from subscription cancellation. If you have an active subscription purchased through an App Store, you should manage or cancel it through the relevant App Store settings.

Before voluntary account deletion, the Company may inform you of unused Reward Coins, Purchased Coins and Bricks and the consequences of deletion, in accordance with the Terms and Conditions and applicable law. The treatment of Virtual Units is governed by the disclosed purchase terms, the Terms and Conditions, the Refund and Cancellation Policy and applicable law.

13. ADDITIONAL INFORMATION FOR RESIDENTS OF CERTAIN STATES

13.1 California

• The categories of Personal Information we collect, their sources, our purposes, the categories of recipients and our retention periods are described in Sections 3, 4, 6 and 9.
• We have not sold or shared Personal Information in the preceding 12 months (Section 6.1).
• We use sensitive personal information only for the purposes described in Section 5.1, which the CCPA regulations treat as permitted purposes.
• Shine the Light (Civil Code § 1798.83). California residents may request, once a year, information about the Personal Information we have disclosed to third parties for their direct marketing purposes. We do not make such disclosures.
• https://reportaproblem.apple.com/https://support.google.com/googleplay/CalOPPA. See Section 7 for how we respond to Do Not Track signals, and Section 16 for how we notify you of changes to this Policy.

13.2 Nevada

Nevada law allows consumers to opt out of the “sale” of certain covered information as defined in Nevada law. We do not sell covered information. You may nevertheless submit a request to [support@mandirpath.com].

13.3 Other states

Residents of states with comprehensive privacy laws, such as Colorado, Connecticut, Indiana, Kentucky, Oregon, Rhode Island, Texas and Virginia, have the rights described in Section 11 and the right to appeal under Section 11.4. Oregon and Minnesota residents may also ask for a list of the specific third parties to which we have disclosed Personal Information. We obtain your consent before processing sensitive information, as described in Section 5.1.

We offer the rights described in Section 11 to all users in the United States, whether or not the law of their state requires it.

14. THIRD-PARTY SERVICES AND LINKS

The Platform may link to or integrate with third-party websites, App Stores, payment providers, authentication services, content providers or other services. Those third parties may collect or process information under their own terms and privacy policies. We do not control independent third parties’ privacy practices. Please review their policies where you interact with their services.

15. TRANSFERS OUTSIDE THE UNITED STATES

Mandir Path is based in India. Personal Information you provide through the Platform will be transferred to, stored and processed in India and in other countries where we or our service providers operate. Those countries may have data-protection laws that differ from those of your state or country. We apply the protections described in this Policy to your Personal Information wherever it is processed. Personal Information processed in India may be accessible to Indian courts and government authorities in accordance with Indian law. [Confirm before publishing: We do not store or process Personal Information through vendors located in, or controlled by persons from, countries of concern under the U.S. Department of Justice rule on bulk sensitive personal data (28 C.F.R. Part 202).]

16. CHANGES TO THIS POLICY

We review this Policy at least once every 12 months and may update it from time to time to reflect changes to the Platform, our data practices or applicable law. We will publish the updated Policy on the Platform and revise the “Last Updated” date. For material changes, we will notify you through the App or by email before the change takes effect. Where required by law, we will obtain your consent before using Personal Information in a materially different way, including any new use of sensitive information. Earlier versions are available on request.

17. COMPLAINTS AND CONTACT DETAILS

For any complaint relating to our handling of Personal Information, please contact us using the details below. Complaints may also be sent to grievance@mandirpath.com, as described in the Terms and Conditions. Complaints about the handling of Personal Information will be handled within the periods described in Section 11.

MANDIR PATH PVT. LTD.

Registered Office: H-8 F, Hauz Khas, New Delhi – 110016, India

[Privacy Contact Email: support@mandirpath.com]

Complaints Email: grievance@mandirpath.com

[Telephone: ____________________]

Please include your name and contact details, a description of your concern, and relevant account, transaction or supporting information. Do not include unnecessary sensitive information in your complaint.

18. RELATIONSHIP TO OTHER TERMS AND YOUR LEGAL RIGHTS

This Policy forms part of the Terms and Conditions. The governing-law and dispute-resolution provisions of the Terms and Conditions apply to this Policy.