Last updated: September 13, 2025

This privacy notice for SwaLay Digital (doing business as SwaLay) ("SwaLay," "we," "us," or "our") describes how and why we might collect, store, use, and/or share ("process") your information when you use our services ("Services"), such as when you:

• Visit our website at https://swalay.in, or any website of ours that links to this privacy notice.

• Engage with us in other related ways, including any sales, marketing, or events.

Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you don't agree with our policies and practices, please don't use our Services. If you still have any questions or concerns, please contact us at swalay.care@talantoncore.in.

SUMMARY OF KEY POINTS

This summary provides key points from our privacy notice. You can find more details by using our table of contents below to find the section you're looking for.

• What personal information do we process? We may process personal information that you provide to us, as well as some information automatically, depending on how you interact with our Services.

• Do we process any sensitive personal information? We may process sensitive personal information when necessary, with your explicit consent, or as otherwise permitted by law.

• Do we receive any information from third parties? We may receive information from third-party services that you link to your account or from our business partners, but we do not purchase data from third parties.

• How do we process your information? We process your information to provide, improve, and administer our Services, to communicate with you, for security and fraud prevention, and to comply with legal obligations. We only process your information when we have a valid legal reason to do so.

• In what situations and with which types of parties do we share personal information? We may share your information with vendors, service providers, and business partners in specific situations to help us operate our business.

• What are your rights? Depending on your geographical location and applicable privacy laws (such as GDPR, CCPA, and India's Digital Personal Data Protection Act, 2023), you have certain rights regarding your personal information.

• How do you exercise your rights? You can exercise your rights by contacting us. We'll consider and act upon your request in accordance with applicable data protection laws.

TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?

2. HOW DO WE PROCESS YOUR INFORMATION?

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

6. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

7. HOW LONG DO WE KEEP YOUR INFORMATION?

8. WHAT ARE YOUR PRIVACY RIGHTS?

9. CONTROLS FOR DO-NOT-TRACK FEATURES

10. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

11. DO RESIDENTS OF INDIA HAVE SPECIFIC PRIVACY RIGHTS?

12. DO WE MAKE UPDATES TO THIS NOTICE?

13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you voluntarily provide to us.

We collect personal information that you provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, participate in activities on the Services, or when you contact us.

The personal information we collect may include:

• names

• phone numbers

• email addresses

• mailing addresses

• usernames

• contact preferences

• billing addresses

Sensitive Information: We may process the following categories of sensitive information when necessary, with your explicit consent, or as otherwise permitted by applicable law:

• student data

• demographic data (e.g., age, gender)

Payment Data: If you make purchases, we collect data necessary to process your payment, such as your payment instrument number (like a credit card number) and the security code associated with it. This payment data is processed and stored securely by our third-party payment gateways, Razorpay and Paytm. You can find their privacy notices here: https://razorpay.com/privacy/ and https://paytm.com/privacy-policy.

Social Media Login Data: We may give you the option to register with us using your social media account details. If you choose this option, we'll collect the information described in the "HOW DO WE HANDLE YOUR SOCIAL LOGINS?" section.

All personal information you provide to us must be true, complete, and accurate, and you must notify us of any changes.

Information automatically collected

In Short: Some information, such as your IP address and device characteristics, is collected automatically when you visit our Services.

We automatically collect certain information when you visit or use our Services. This information doesn't reveal your specific identity but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This data is primarily needed to maintain the security and operation of our Services and for internal analytics and reporting.

Like many businesses, we also collect information through cookies and similar tracking technologies. The information we collect automatically includes:

• Log and Usage Data: Service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services. This may include your IP address, browser type, and information about your activity on the Services.

• Device Data: We collect information about your computer, phone, tablet, or other device used to access the Services. This may include your IP address, device and application identification numbers, hardware model, operating system, and system configuration information.

• Location Data: We collect location data about your device's location, which can be either precise or imprecise. You can opt out of this by disabling the location setting on your device.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, and for security and fraud prevention.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To facilitate account creation and authentication: To allow you to create and log in to your account.

• To deliver services: To provide you with the requested services.

• To respond to user inquiries/offer support: To respond to your questions and solve any potential issues.

• To send administrative information: To send you details about our products, services, and changes to our terms and policies.

• To fulfill and manage your orders: To process your orders, payments, returns, and exchanges.

• To enable user-to-user communications: If you choose to use features that allow communication with other users.

• To protect vital interests: To save or protect an individual's vital interests, such as preventing harm.

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?

In Short: We only process your personal information when we have a valid legal reason to do so under applicable law.

We may rely on the following legal bases to process your personal information:

• Consent: We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time.

• Performance of a Contract: We may process your personal information when it's necessary to fulfill our contractual obligations to you.

• Legal Obligations: We may process your information when it's necessary for us to comply with a legal obligation, such as cooperating with a law enforcement body.

• Legitimate Interests: We may process your information when we believe it's necessary to achieve our legitimate business interests, provided those interests do not outweigh your rights and freedoms.

• Vital Interests: We may process your information when it's necessary to protect your vital interests or the vital interests of a third party.

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information with third parties in specific situations to operate our business.

We may share your data with third-party vendors, service providers, contractors, or agents ("third parties") who perform services for us or on our behalf. The categories of third parties we may share personal information with include:

• Cloud computing services

• Payment processors

• Data analytics services

• Website hosting service providers

• User account registration & authentication services

• Business partners and affiliates

We may also need to share your personal information in the following situations:

• Business Transfers: In connection with any merger, sale of company assets, financing, or acquisition.

• With Affiliates: We may share your information with our affiliates, and we will require them to honor this privacy notice.

• With Business Partners: We may share your information with our business partners to offer you specific products, services, or promotions.

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: Yes, we may use cookies and other tracking technologies to collect and store your information.

We use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. You can find more details about how we use these technologies and how you can refuse certain cookies in our Cookie Notice.

6. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

In Short: If you choose to log in with a social media account, we may access certain information from that account.

Our Services may offer you the ability to register and log in using your social media account details. When you do this, we receive profile information from your social media provider, which may include your name, email address, and profile picture. We use this information only for the purposes described in this privacy notice. We are not responsible for how your social media provider uses your personal information; we recommend you review their privacy notice.

7. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice.

We will only keep your personal information for as long as it is necessary for the purposes set out in this notice, unless a longer retention period is required or permitted by law (such as for tax or accounting purposes).

When we no longer have a legitimate business need to process your personal information, we will either delete or anonymize it. If that's not possible, we will securely store your information and isolate it from any further processing until deletion is possible.

8. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: In some regions (like the EEA, UK, and Canada), you have rights that allow you greater access to and control over your personal information.

Depending on your location, you may have the right to:

• Request access to your personal information.

• Request correction or erasure of your data.

• Object to the processing of your personal information.

• Request data portability.

• Withdraw your consent at any time.

You can make a request by contacting us using the details provided below. We will consider and act upon any request in accordance with applicable data protection laws.

Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional emails at any time by clicking the "unsubscribe" link in the emails or by contacting us directly.

Account Information: If you would like to review, change, or terminate your account, you can log in to your account settings or contact us. Upon your request to terminate, we will deactivate or delete your account, though we may retain some information for legal or security purposes.

9. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems offer a Do-Not-Track ("DNT") feature that you can enable to signal your privacy preference not to have your online browsing activities monitored. At this time, no uniform technology standard has been finalized for DNT signals. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online.

10. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: Yes, if you are a resident of California, you have specific rights regarding the collection, use, and disclosure of your personal information.

Under California law, you have the right to:

• Request to Know: Request that we disclose what personal information we collect, use, and share about you.

• Request to Delete: Request the deletion of your personal information.

• Right to Opt-Out: Request to opt out of the sale of your personal information. (Note: We do not sell your personal information.)

• Non-Discrimination: Not be discriminated against for exercising your privacy rights.

To exercise these rights, please contact us using the details below. We will verify your identity before processing your request.

11. DO RESIDENTS OF INDIA HAVE SPECIFIC PRIVACY RIGHTS?

In Short: Yes, under the Digital Personal Data Protection Act, 2023 (DPDP Act), residents of India have specific rights and obligations regarding their personal data.

As a Data Fiduciary operating in India, we are committed to upholding your rights under the DPDP Act. These rights include:

• Right to Access: You have the right to request information about your personal data being processed by us.

• Right to Correction and Erasure: You can request the correction of inaccurate data or the erasure of your personal data.

• Right to Grievance Redressal: You have the right to have your grievances addressed by our designated Data Protection Officer.

• Right to Nominate: You can nominate an individual to exercise your rights on your behalf in the event of your death or incapacity.

We will process your data only for the purposes for which it was collected and will not retain it longer than necessary. We will also implement reasonable security safeguards to protect your data from unauthorized access or breaches. For any requests or grievances, please contact our Data Protection Officer.

12. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws and reflect changes in our services.

We may update this privacy notice from time to time. The updated version will be indicated by an updated "Last updated" date and will be effective as soon as it is accessible. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may contact our Data Protection Officer (DPO) by email at swalay.care@talantoncore.in, by phone at +917303630201, or by post to:

SwaLay Digital

Data Protection Officer

TC HO, C-4, 4/19, Sector-2, Ghaziabad, Uttar Pradesh 201005

India