SMART ACCESS - PRIVACY POLICY

Effective Date: October 7, 2025

Smart Access ("we," "us," or "our") is committed to protecting the privacy and security of our users ("you"). This Privacy Policy describes how we collect, use, disclose, and safeguard your personal information when you use our mobile app (the "App") for society management, including features like member directories, event planning, and community communications.

By downloading, installing, or using the App, you agree to the terms of this Policy, including all protections for us outlined herein. This Policy applies to the App and its services but does not cover third-party websites or apps linked from ours.

We operate as the Data Fiduciary (as defined under the DPDP Act) under applicable laws. We process data based on lawful bases such as your consent, performance of our contract with you, or our legitimate interests in providing the service. To the fullest extent permitted by law, this Policy limits our liability and requires you to indemnify us, as detailed in Sections 4 and 10.

1. Information We Collect

We collect minimal data to enable App functionality, following data minimization principles under the DPDP Act. Before collecting any personal data, we provide this notice specifying the data, its purpose, your rights, and how to withdraw consent or file a grievance. Here's what we gather:

We do not collect sensitive data like full birth dates, financial info, health records, or precise geolocation without your separate, informed consent. For users under 18 (as per DPDP Act), we require verifiable parental or guardian consent before collecting any data. You agree that all data you provide is accurate and that you have the right to share it; we are not responsible for inaccuracies or unauthorized sharing by you.

2. How We Use Your Information

Your data powers the App's core features and is used solely for these purposes, as specified in our consent request:

Any use beyond these purposes requires your additional consent.

3. Data Sharing and Disclosure

We prioritize your privacy and do not sell, rent, or share your personal data with third parties for their commercial purposes, except as permitted under the DPDP Act. Sharing occurs only in limited, transparent cases, such as:

All shared data is minimized and anonymized where possible. We are not liable for disclosures required by law or resulting from your breach of this Policy.

4. Data Storage, Retention, and Security

Storage: Data is stored securely in encrypted databases on servers compliant with DPDP Act requirements (e.g., in India or with adequate safeguards for transfers).

Retention: We keep data only as long as needed for the specified purpose or legal obligations—typically while your account is active, plus 30 days post-deletion or withdrawal of consent. Inactive accounts auto-delete after 2 years unless you opt to retain.

Security: We use industry-leading measures including:

Breach Response: If a security incident occurs, we'll notify affected users and the Data Protection Board of India (if applicable) within the prescribed timelines.

Despite these efforts, no system is 100% secure. To the fullest extent permitted by law, we disclaim all liability for any unauthorized access, loss, or breach of data, including indirect, incidental, consequential, or punitive damages, except where directly caused by our gross negligence or willful misconduct.

5. Your Rights and Choices

As a Data Principal under the DPDP Act, you have the following rights, exercisable via in-App tools or by emailing support@primeonecorp.com:

We may deny or redact requests if exemptions apply (e.g., legal investigations) and will inform you of the reason. We are not obligated to fulfill requests that would impair App functionality or violate others' rights. For consents, you may use a registered Consent Manager under the DPDP Act.

6. Children's Privacy

If we learn we've collected data from a minor without guardian consent, we'll delete it promptly. Parents/guardians: Contact us to review or remove your child's info. Parents/guardians indemnify us for any unauthorized use by minors.

7. Cookies, Tracking, and Device Permissions

The App uses limited tracking for functionality (e.g., session cookies for logins). Manage permissions (e.g., camera for photos) in your device settings—we request only when needed. You assume responsibility for managing your device security.

8. Disclaimers and Warranties

The App and its services are provided "as is" and "as available" without warranties of any kind, express or implied, including but not limited to merchantability, fitness for a particular purpose, or non-infringement. We do not guarantee uninterrupted or error-free operation, and we disclaim liability for any interruptions, delays, or failures due to third-party actions, force majeure events, or your hardware/software.

9. Limitation of Liability

To the maximum extent permitted by law, our total liability to you for any claim arising from this Policy or the App is limited. We shall not be liable for indirect, incidental, special, consequential, exemplary, or punitive damages, including lost profits or data loss, even if advised of the possibility.

10. Indemnification

You agree to indemnify, defend, and hold harmless us, our affiliates, officers, directors, employees, and agents from and against any claims, losses, damages, liabilities, costs, and expenses (including reasonable attorneys' fees) arising from:

11. Dispute Resolution

Any disputes arising from this Policy shall be resolved exclusively through the courts in Bangalore, India. You waive any right to participate in a class action or representative proceeding.

12. Governing Law

This Policy is governed by the laws of India, without regard to conflict of laws principles.

13. Changes to This Policy

We may update this Policy to reflect App changes or legal needs, including DPDP rules. Significant updates will be notified via in-App alerts, email, or push notification at least 30 days in advance, with option to withdraw consent. Continued use post-changes implies acceptance.

14. Miscellaneous

15. Contact Us

For questions, support, rights requests, consent withdrawal, or grievances, contact:

Email: support@primeonecorp.com