PRIVACY POLICY

1. INTRODUCTION –

We, Xenon Strodum LLP, a Limited Liability Partnership, registered under Limited Liability Partnership Act 2008, having it’s registered office at C-02, Mahindra Park, Narayan Nagar, LBS Road, Ghatkopar West, Mumbai (“Boliyee”/ “we”/ “our”/ “us”).

We offer services through our platform, “boliyee.com, ” designed to support individuals seeking to share their problems and dilemmas with an empathetic listener. Our Empathetic Listeners provide compassionate and attentive listening over the phone, helping clients find relief. We are accessible under our brand name “Boliyee” through website

www.boliyee.com(“Platform”).

We respect the privacy of everyone who visits or uses the Platform. This privacy policy (“Privacy Policy”) describes the procedures for collecting, using, and disclosing Your information which You share with us for availing Service or accessing the Platform (“Personal Information”). This Privacy Policy shall be governed by the Terms of Use of the Platform as updated from time to time available on the Platform. We recommend You to read this Privacy Policy so that You understand our approach towards the use of Your Personal Information.

We will not knowingly disclose Your Personal Information to third parties, except as provided in this Privacy Policy. We will take reasonable steps to protect the Personal Information we collect from You.

When You visit the Platform, You are not required to provide any Personal Information unless and until You choose to avail the services provided over the Platform. By accepting this Privacy Policy, You authorize the Platform to collect, store, use, disclose, retain and transfer Your Personal Information in accordance with this Privacy Policy. You also authorize us or our service providers to collect such information and to call/e-mail/text message You in connection with Your interest in the Services.

If You do any or all or any of the following, You indicate that You have read, understood, and agree to this Privacy Policy: explicitly accepting this Privacy Policy by providing consent; OR accessing the Platform; OR creating an account on the Platform; OR accessing an account on the Platform; OR sharing personal details and mobile number as requested by Platform in order to access the Service; OR booking an appointment for call over the Platform; OR undertaking any other action that involves interacting with the Platform.

1. DEFINITIONS –

“Platform” shall mean the website boliyee.com owned, operated and managed by us.“Service” shall mean the online empathetic listening services provided by Boliyee, which involve patiently listening and extending an empathetic ear to the User.

“User” or “You” or “Your” or “Yourself” shall mean individual who register on the Platform to avail the Service.

“Empathetic Listeners” shall mean trained individuals who interact with User on the Platform, providing attentive and compassionate listening services.

“Visitor” shall mean any individual accessing, scrolling or browsing the Platform without availing any Service.

1. INFORMATION WHICH IS COLLECTED AND STORED –

When a User avails the Service or register over the Platform, this Privacy Policy comes into immediate effect with respect to User’s Personal Information collected by us. We collect Personal Information from You that we consider necessary for achieving the purpose of providing You the Service. In case You wish to simply browse through the Platform, we do not ask You for any Personal Information. However, any Visitor who accesses the Platform by means of browsing, scrolling, without sharing any Personal Information, shall also immediately come under the purview of this Privacy Policy and all the legal obligations mentioned hereunder this Privacy Policy will be applicable to him unless otherwise specifically excluded.

When You subscribe to avail Service or register with us, to serve You in our best capacity, we may collect Your Personal Information if required. (“Personal Information”) means and includes any information or data which includes but not limited to:

Full Name

E-mail ID

Date of Birth

Age

Mobile Number

Gender

Payment details

Personally identifiable information if any, shared by the User to Empathetic Listener during the course of conversation on call Any additional communication data including messages exchanged or chat conversation with customer support Social media profile information, if You choose to log in to the Platform using social media credentials

We may collect Personal Information about Your activity, such as date and time You logged in, features of our Platform that You’ve been using, searches, clicks and pages visited by You.

User understands that User shall be solely responsible for the accuracy and truthfulness of the Personal Information

shared with us. In the event the User is sharing any Personal Information on behalf of a third person, the User represents and warrants that he has the necessary authority to share such Personal Information with us and we shall not be responsible for verifying the same. The User understands and acknowledges that such Personal Information shall be subject to the terms and conditions of this Privacy Policy.

If the User shares any personal issues or problems during their interaction with us, such disclosure is made voluntarily and at the User’s own risk. The User acknowledges that we may record and retain such information in accordance with ourprivacy practices. The User represents and warrants that they have the necessary authority to share such Personal Information with us. The User understands that we assume no responsibility for any consequences arising from the disclosure of their personal issues or problems.

1. COLLECTION OF NON-PERSONAL INFORMATION –

When You use, or access the Platform, we may also collect and store additional information which may or may not personally identify You or be identifiable with other information collected. Such information includes, without limitation, Your internet protocol address, Your usage and log in information, browser types, domain name, device locations, geographic locations, type of operating system, browser type and version, operating system, identifiers associated with cookies or other technologies that may uniquely identify Your device or browser and other statistical data involving Your use of the Platform and/or our Service. This information is collected passively using various technologies or may be provided by You through communications with us. We may also aggregate details which You have submitted to the Platform (for example, Your age, feedback provided in the comment box, (which does not attribute any Personal Information) for verification and Your requirements). You cannot be identified from this information, and it is only used to assist us in providing an effective service on this Platform. We may from time to time supply third parties with this non-personal or aggregated Information in connection with the Platform.

The information You provide on the Platform will be aggregated for our reference. However, the details of individual

information shall not be used by us. For example –we may analyze the data to identify your preferences, frequency of Service use, requirements, and related complaints. However, this information, along with Your preferences and choices regarding the Service, will not be used by us for any other commercial purposes.

1. ACCESS AND PERMISSIONS –

You shall give permission to this Platform in order to access Your Contact number: For the distinct purpose of contacting You for conversation over the call with our Empathetic Listener.

Email address: For the purpose of communicating confirmation of Your appointment for proving Service over the Platform and for other necessary diverse purposes.

1. HOW WE USE PERSONAL INFORMATION

The Personal Information is collected and used to:

i. ii. iii. Create and administer Your account (login/registration credentials). provide and improve the Service database. monitor Your activity, such as keyword searches or number of appointments booked by You and more effectively manage traffic on the Platform.

iv. customize Your experience.

v. assist You with technical difficulties.vi. occasionally send promotional emails, messages or contact You to communicate about existing Services, special offers, benefits or other information which we think You may find interesting using the email address, contact details which You have provided.

vii. ix. x. manage our relationship with You.

viii. maintain and update our records. monitor suspected fraud, misconduct and unlawful activities on the Platform. comply any requirement of applicable laws.

You agree that we may also use the Personal Information to contact You and deliver information to You that, in some cases, are targeted to Your interest, such as targeted User advertisements, offers, promotions, and communications relevant to Your use of the Platform. Nevertheless, we will provide an option to decline the services relating to promotional emails and advertising notifications as well. The information collected by the Platform maybe used for purposes as maybe permissible by the applicable law such as for providing personalized browsing experience, research purposes, improving marketing, promotional efforts, improve the content of website, all will keep anonymity of the User.

Also, we may share with third-party service providers certain information, such as Your browser capabilities or operating system, that we have collected in order to better understand which advertisements and Service may interest You. We will retain Your Personal Information including recorded call sessions, as long as it is reasonably necessary or otherwise permitted or required by applicable law or regulatory requirements, even after Your account is terminated. We may also retain Your Personal Information so long as it is necessary to fulfil the purposes for which it was collected including meeting any legal, administrative, accounting, or other reporting requirements or as evidence in case of any unreasonable claims, allegations, legal action or accusations against us. We endeavor, Your Personal Information is safeguarded against inappropriate access and disclosure, as per this Privacy Policy. Please refer to our “Data Retention” clause for more information regarding retention of information shared by You.

1. CHILDREN’S PRIVACY –

The Platform is not directed at anyone under the age of 18, nor do we collect any Personal Information from anyone who we know to be under the age of 18. If You are under the age of 18 years, please do not use the Service and do not submit any Personal Information to us.

1. DISCLAIMER –

The empathetic listening services provided through this Platform are intended for listening purpose only. We do not provide professional mental health advice, diagnosis or treatment. This Platform is not suitable for individuals struggling with mental health issues, including those experiencing suicidal thoughts, self-harm, or related concerns. We strongly recommend that such individuals refrain from using the Platform, and if You are currently engaging with it, we advise You to discontinue immediately. Continuing to use the Platform will be done at Your own risk.While we strive to ensure the privacy and confidentiality of Your Personal Information, please be aware that online communications may not be completely secure. The Platform does not guarantee the confidentiality of Personal Information shared during sessions and is not responsible for any unauthorized access or misuse of your Personal Information. For mental health services, please consult a professional medical therapist or counselor. The services provided by this Platform should not be used as a substitute for medical consultation or relief.

1. COOKIES –

A “Cookie” is a small piece of information stored by a web server on a web browser so it can be later read back from that browser. Cookies are useful for enabling the browser to remember information specific to a given user. We may place both permanent and temporary cookies in Your computer, any electronic devices such as mobile phone, iPads or tab’s hard drive while using our Service. These Cookies do not contain any of Your personally identifiable information. You may choose to disable the Cookies using the settings in Your operating system of the device. However, if You do so, You may not be able to use the full functionality of our Platform. Cookies may be used for any or all the following purposes:

i. ii. iii. iv. Customize Your experience on Our Platform For obtaining information regarding use of the Platform and assess which pages do You visit the most in order to provide You with services that may be of interest to You To obtain information regarding Your IP address, location and other demographic information such as age range and gender in order to ascertain user’s internet behavior

For allowing us to provide You with personalized services by remembering the choices made by You with respect to language You prefer, geographical location where You are etc.

The Platform uses IP tracking details and cookies solely to enhance Your experience and facilitate Your use of the site. Any sensitive information collected will not be shared with third parties without Your consent.

1. DISCLOSURES –

With due regards to the rules incorporated in the Privacy Policy, we may send, rent, share, distribute, lease, or otherwise provide or disclose User’s Personal Information to third parties in the following circumstances – Administrators – We may provide access to User’s Personal Information to any of our authorized administrators for an internal business purpose, who shall be under confidentiality obligations towards the same. Joint Marketing Arrangements: Where permitted by law, we may provide Personal Information that we collect to joint marketers with whom we have a marketing arrangement, if any. We shall require all joint marketers to have written contracts with us that specify appropriate use of Your Personal Information, require them to safeguard Your Personal Information, and prohibit them from making unauthorized or unlawful use of Your Personal Information. Persons Who Acquire Our Assets or Business: We may transfer Your Personal Information if we are acquired by / we acquire or merge with another entity or transfer a part of our business, including the Platform to a third party. Any third party or resultant entity that receives Your Personal Information pursuant to a merger, demerger or business transfer shall have the right to continue to use Your Personal Information. In the event of such a sale or transfer, we reasonably notify You. Legal and Regulatory Authorities: We may be required to disclose Your Personal Information due to legal or regulatory requirements. In such instances, we reserve the right to disclose Your Personal Information as requiredin order to comply with our legal obligations, including but not limited to complying with court orders, warrants, or discovery requests. We may also disclose Personal Information about our Users to law enforcement officers or others, in the good faith that such disclosure is reasonably necessary to enforce this Privacy Policy; respond to claims that any Personal Information violates the rights of third parties; or protect the rights, property, or personal safety of Platform, our Users or the general public. You agree and acknowledge that we may not inform You prior to or after disclosures made according to this section. Service providers or business partners – We may use certain trusted third party and individuals to help us to provide, analyze, and improve the services or provide marketing, development or consulting services, data storage, payment processing and other features related to the Service. These third parties may have access to Your Personal Information only for the purposes of performing their respective tasks and are under obligations similar to those in this Privacy Policy. We may disclose Your Personal Information to service providers who perform hosting services on our behalf.

Testimonials – We may publish any testimonials that You have provided about the Platform or Services and such testimonials and other marketing, promotions and advertisements may include Your Personal Information that You have provided to us. Notwithstanding anything mentioned hereinabove, we shall not be responsible for the actions or omissions of the parties (including but not limited to the entities listed above) with whom the Personal Information is shared, nor shall we be responsible and/or liable for any additional information which User may choose to provide directly to any third party.

1. DATA RETENTION –

We will retain Your Personal Information as needed to provide You the best User experience. We may retain and use Your Personal Information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Consistent with these requirements, we will try to delete Your Personal Information, on (case to case basis on our discretion), upon reasonable request. We may also need to retain certain data for recordkeeping purposes, and there may also be residual information that will remain in our databases and on other records, which will not be removed. Please note, however, that there might be a latency in deleting Personal Information from our servers. Data may still reside on backed-up versions after deletion. In addition, we do not delete from our servers’ files that You have in common with other users.

1. SECURITY –

We value Your Personal Information; we will ensure an adequate level of protection. We have therefore implemented technology and policies with the objective of protecting Your Personal Information from unauthorized access and improper use and will update these measures as new technology becomes available, as appropriate. As a matter of security, we take back-up of systems periodically. Although we provide appropriate firewalls and protections, our systems are not hack proof or error free. Data pilferage due to unauthorized hacking, virus attacks, technical issues is possible, and we take no liabilities or responsibilities for it.

1. INTERACTION BETWEEN YOU AND PLATFORM –We are interested in Your views, and we value the Feedback (defined below) we receive from You. However, we do not have control or are responsible for any such Feedback or the Personal Information which You make available through the Platform. We encourage You to be careful regarding the Personal Information You disclose in this way. Subject to any applicable law, any communication or feedback sent by You to the Platform (including without limitation testimonials, reviews, comments, contents, feedback etc. collectively “Feedback”) is on a non-confidential basis, and we are under no obligation to refrain from reproducing, publishing or otherwise using it in any way or for purpose. We can use the Feedback including without limitation any ideas, inventions, concepts, techniques or know-how disclosed therein, for any purpose including without limitation developing, manufacturing and/or marketing services. You agree that You will not assert any ownership right of any kind in the Feedback (including without limitation copyright, patent, trademark, unfair competition, moral rights, or implied contract) and You hereby irrevocably waive the right to receive any financial or other consideration in connection with the Feedback, including without limitation acknowledgment of You as the source of the Feedback.

1. ACCESSING AND MODIFYING PERSONAL INFORMATION –

In the event that You choose to avail services under the Platform, and in case You need to access, remove, review, and/or make changes to the Personal Information that You have provided to us, You can directly do the changes by Yourself at the time of next use of the Service by adding or changing Your name/address/mobile number etc.as the case may be.

1. THIRD PARTY LINKS –

If there happens to be any links to other Platform or You are referred to our Platform through a link from another platform, we shall not be responsible for the privacy policies and practices of other platforms. Such content is subject to their terms of use and any additional guidelines and privacy information provided in relation to that use on their platform. We recommend that You check the policy of each platform You visit to better understand Your rights and obligations especially when You are submitting any type of content on those third-party platform. Please contact the owner or operator of such platform if You have any concerns or questions.

1. SOCIAL MEDIA –

You may wish to participate in the digital media/social media campaign hosted by us which we make available to You. You may note that personal information shared by You on social media may be open and available to the public at large and the Platform will not have any control on its viewership. However, we cannot be held responsible if You share Personal Information on Social Media platform that is subsequently used, misused or otherwise appropriated by another user.

1. INDEMNIFICATION –In addition to the indemnification commitment provided in Terms of Use, User agrees to indemnify us, our partners, affiliates, officers, agents and employees and hold us harmless from and against any claims and demand, including reasonable attorney’s fees, made by any third party due to arising out of or relating to:

i. ii. iii. accuracy and correctness of Personal Information and contents that User submits or shares through the Platform; User’s violation of this Privacy Policy; User’s violation of any rights of another User.

1. RESERVATION OF RIGHTS –

All rights not expressly granted in this Privacy Policy are reserved by us. Nothing contained in this Privacy Policy shall be construed as conferring by implication, estoppels or otherwise any license or right under any copyright, patent, trademark or other intellectual property right of Boliyee.com or any other person or to User.

1. LIMITATION OF LIABILITY –

Platform will not be liable for any damages, direct or indirect, incidental or consequential, and all liabilities (including for negligence, loss or damage such as loss of revenue, unavailability of system or loss of data and loss of Your Personal Information) and for use of or inability to use Service of any kind that is offered or to provide indemnity or any other remedy to You or any third party. We make reasonable efforts to ensure that the Platform is free from defects or viruses. It is Your responsibility to ensure that You use the correct devices for accessing and using the Platform and to protect Your credentials.

1. GOVERNING LAW AND DISPUTES –

This Privacy Policy is governed by the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules 2011 and other applicable laws of India, which is designed to protect Personal Information, other relevant laws, and policies of Platform. This Privacy Policy is governed by and construed according to the laws of India, the acceptance of the Privacy Policy shall be deemed to have been given at Mumbai and the Courts in Mumbai shall have exclusive jurisdiction to entertain any proceedings in any way relating to or concerning this Privacy Policy or any rights, duties, obligations or liabilities arising there under to the exclusion of all other Courts in India.

1. CHANGES TO THIS POLICY –

From time to time we may make changes to this Privacy Policy. If we make any substantial changes to this Privacy Policy and the way in which we use Your Personal Information, we will post these changes on this page and it shall be Your responsibility to be aware of any significant changes. Please check our Privacy Policy on a regular basis.

1. CONTACT US –If You have questions or concerns or grievances regarding this Privacy Policy, You can email us regarding any grievance at

boliyee07@gmail.com at Contact no. .

 

I ACCEPT