PRIVACY POLICY

1. USER'S CONSENT

We collect, use, store, share or otherwise process your personal information shared with us only based on your explicit consent expressed electronically to us for the purposes set out in this Privacy Policy.

By accessing the Application and using it, you indicate that you understand the terms and expressly consent to this Privacy Policy of the Application. If you do not agree with the terms of this Privacy Policy, please do not use this Application.

Your continued use of this Application shall confirm that you have provided your unconditional consent and confirmation to the terms of this Privacy Policy as regards collecting, maintaining, using, processing and disclosing your personal and other information in accordance with this Privacy Policy.

This Privacy Policy is to be read along with the terms of use or other terms and conditions as provided on the Application.

Additional Clause (for GCC countries)

For Users accessing the Application from the United Arab Emirates, Kingdom of Saudi Arabia, State of Qatar, or State of Kuwait, continued use of the Application also constitutes consent under the applicable regional data protection laws, including:

• UAE Federal Decree Law No. 45 of 2021 (Personal Data Protection Law);
• Saudi Arabia Personal Data Protection Law (PDPL 2023) issued by SDAIA;
• Qatar Law No. 13 of 2016 on the Protection of Personal Data;
• Kuwait Law No. 20 of 2014 on Electronic Transactions.

2. INFORMATION WE COLLECT

Any information qualifies as personal in nature when the information collected identifies a specific User, either on its own or in combination with other information. We collect such personal information from you through the Application during the following actions:

• When you create your account to access the Application, we collect your full name, phone number, gender, location, photograph, email address and any other detail required on the Application during registration. In the absence of registration, the Application and the services therein will not be accessible to such unregistered User.
• When you use the Application, we may access and transmit the information you provide to other Users you select.
• When you grant the Application the permission to use your device's microphone, it allows our Application to capture the sound of your voice as audio and convert it into digital data that we can process.
• When you register on the Application and use the Application, we may collect information such as geographical location, type of browser used to access the Application, log files, session data, device data, internet service provider, telecom service provider, IP address and information that is stored by your browser on your computer's hard drive through cookies.
• When Users deposit money into Muthyam wallet or avail paid services, or Eligible Users participate in monetization features on the Application, we may collect related information such as the amounts to be deposited/held in or withdrawn (only Eligible Users can withdraw) from the Muthyam wallet, IP (Internet Protocol) address, and any other information that such User may provide in connection with booking a paid service or withdrawing earnings from the Muthyam wallet. An Eligible User is an expert User who is eligible to earn and/or withdraw money from the Application as per the applicable payment terms. Please note that our payment aggregators and payment service providers may collect, process and transfer your information (including payment instrument details) directly during your use of the Application.
• We also collect details including but not limited to User feedback, comments, etc. that may be disclosed/informed/mentioned on any article/blog or groups/forums or other pages which the User may have access to while visiting the Application. For such information which is in public domain and accessible to all the Users and visitors of the Application, the User is advised to exercise its discretion before disclosing it as this information is susceptible to misuse.

We also collect any other information which may be mandatory to be disclosed and further may receive any other information via email or other methods with regard to specific services availed from the Application or any products bought from the Application, such information may not be made part of the User's profile but shall be used only for addressing the specific need or concern of the User.

THE USER HEREBY REPRESENTS AND CONFIRMS THAT THE INFORMATION PROVIDED TO THE APPLICATION IS AUTHENTIC, CORRECT, CURRENT AND UPDATED. WE, THE APPLICATION AND ALLIED ENTITIES SHALL NOT BE RESPONSIBLE FOR THE AUTHENTICITY OF THE INFORMATION THAT THE USER MAY PROVIDE. THE USER SHALL BE PERSONALLY LIABLE AND INDEMNIFY US FOR ANY LOSSES ARISING FROM ANY BREACH OF THIS POLICY ARISING FROM USER'S ACTS OR OMISSIONS.

Additional Clause (for GCC countries)

To comply with local know your customer (KYC), taxation, and financial transaction regulations applicable in GCC countries, we may collect limited additional data points such as country code, nationality or payment verification details. Such information will be used only for lawful processing under the applicable local regulations and never for profiling or marketing without consent.

3. PURPOSE AND USE OF INFORMATION

The information we collect from you may be used for the below purposes as may be permissible under the applicable law:

• To provide the Application, securing and validating the registration of the User, securing the User profile, managing the access and use of the services in the Application and providing a personalised experience.
• To enable Users to use the Application and the features.
• To administer and operate our business in relation to the Application, including purposes such as processing payments, maintaining payment logs and transaction data for Application and the services, and sending transactional communications to you (such as notification of terms and conditions, confirmation of subscription start date or information about changes to your account), responding to your inquiries and requests, managing your grievances and resolution of disputes, and assisting you with operational requests such as password resets.
• To review User's compliance with applicable laws and our policies/terms (including on content).
• To enforce the terms of use and other terms and conditions for use of the Application.
• To manage the Application, troubleshoot issues, enhance security of the Application and detect fraud and moderate the content.
• To research, analyze, and improve our Application and services, such as analyzing and understanding our audience to improve our services, analyse usage of and traffic to the Application, better understand User engagement, gather demographic information, analyse the average length of visits, pages viewed during a visit, improve the content of the Application and product offering, improve performance of the Application and for customising the Application's layout for suiting the needs of the Users.
• To evaluate and improve the marketing and promotional efforts and display advertisements in line with User's preferences.
• To ensure a seamless experience at the Application for you and to ensure your maximum benefit and comfort, the Application may use the data collected through cookies, log file, device identifiers, location data and clear gifs information to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the site; (b) provide custom, personalized content and information, including advertising; (c) provide and monitor the effectiveness of services offered by Application; (d) monitor aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns on the Application and its services; (e) diagnose or fix technology problems; and (f) otherwise to plan for and enhance the service.
• To cooperate with law enforcement officers and activities, and comply with applicable statutory or legal obligations, tax laws and evidentiary requirements.

Additional Clause (for GCC countries)

In addition to the purposes stated above, for users in the UAE, Saudi Arabia, Qatar, and Kuwait, personal information may also be used to:

• meet local VAT/tax reporting obligations (e.g., UAE 5%, KSA 15%);
• prevent fraudulent or prohibited transactions in compliance with local e-commerce laws; and
• Respond to verified requests from local regulators such as FTA (UAE), ZATCA (KSA), MoTC (Qatar), and CITRA (Kuwait).

For GCC users, certain anonymized transaction details may be shared with tax or regulatory bodies solely to satisfy local VAT and e-commerce reporting obligations. No audio, message, or private call content is shared for such purposes.

4. COOKIES

The Application may store temporary or permanent 'cookies' on the User's computer. Cookies would allow the web server to recognize the User's computer each time the User returns to the Application including the time and date of the visit, viewing of page, length of time, verify registration or password information etc. It further automatically logs generic information about the User's computer connection to the Internet i.e. session data. Such cookies are usually only read by the server placed and the User may choose to block these cookies on their computers. Please note that if the cookies are turned off, the User may be prevented from using certain features of the Application. The Application uses the cookies to personalize the User's experience on the Application and to display an advertisement according to the User's preferences.

5. THIRD PARTY TOOLS

The Application uses certain third-party analytics tools to measure traffic and usage trends for the Services. These tools collect information, which is not personal or sensitive in nature sent by the User's device, including the web pages visited, add-ons, and other information that assists the Application in improving the Services. Such information is collected from Users in the form of anonymized logs, so that it cannot reasonably be used to identify any particular individual User.

6. CONFIDENTIALITY

The Application aspires to take care of all the information provided to it by its Users which may be termed as confidential. The confidential information of the User shall not be disclosed or shared by the Application, its employees, its agents or any third-party contractors including the experts either orally or in writing except for the following circumstances:

Additional Clause (for GCC countries)

Muthyam complies with the respective national authorities governing personal data and digital content regulation in each GCC country. Where disclosure is legally required by a competent authority within UAE, KSA, Qatar, or Kuwait (e.g., tax, telecom, or cyber-crime investigations), the Application may disclose limited personal information as mandated, ensuring due process and minimum data sharing. Such sharing may also be done if:

• the Application believes that there is a significant/ real/ imminent threat or risk to User's health, safety or life or to the health, safety or life of any other person or the public.
• such confidential information must be shared in accordance with the law inclusive of any investigation, court summons, judicial proceedings etc.
• to protect and defend the rights or property of the Application.

7. SECURITY MEASURES

We implement reasonable security standards and appropriate technical and organisational measures to secure your personal information in accordance with applicable laws.

While we will endeavour to take all reasonable and appropriate steps to keep secure any personal information which we hold about you and prevent unauthorized access, you acknowledge that the internet or computer networks are not fully secure and that we cannot provide any absolute assurance regarding the security of your personal information.

Additional Clause (for GCC countries)

In compliance with GCC data protection laws, any data breach incident affecting users from these jurisdictions shall be notified to the relevant authority and the affected User within:

• 72 hours in UAE and KSA;
• 7 days in Qatar; and
• As soon as reasonably practicable in Kuwait.

8. CHILDREN'S PRIVACY

The Application requires that the User visiting the Application and using the services are above 18 years of age. However, it is stressed upon that Application is not designed or intended to be attractive to be used by children under the age of 18 and no personal identifiable information of children below the age of 18 is collected knowingly. IF YOU ARE UNDER 18 YEARS OF AGE, PLEASE DO NOT USE ANY OF THE SERVICES PROVIDED BY THE APPLICATION AT ANY TIME OR IN ANY MANNER. If it comes to the knowledge of the concerned parent regarding sharing of any information of a child under the age of 18 with the Application, contact the Application immediately. We will take appropriate steps and delete the data from the Application's systems.

Additional Clause (for GCC countries)

Under the applicable laws of UAE, KSA, Qatar, and Kuwait, the Application does not knowingly collect information from children below 18 years of age and specifically prohibits use by those under 13 years of age without verified parental consent.

9. DISCLOSURE AND TRANSFER OF INFORMATION

We may share your information with our business partners and with our trusted service providers who work on our behalf, including partners and service providers situated outside India, who ensure the same level of data protection that we follow.

We may use and may transfer/disclose/share your information to third parties who support our business such as hosting and maintaining our servers and the Application, database storage and management, e-mail management, storage marketing, credit card processing, customer service and fulfilling orders for products and services you may purchase through the Application.

We may share your information with our payment aggregators and payment service providers who may further transfer your information to the extent necessary to provide payment services.

We may share portions of our log file data, including IP addresses, for analytics purposes with third parties such as web analytics partners, application developers, and ad networks. We may also share certain information with third party service providers and third party advertisers for measure the overall effectiveness of the Application's online advertising, content, programming and for other bonafide purposes as required.

Such third party entities do not have an independent use of your information that Muthyam discloses to them, and do not further transfer or publish the information we share with them. They have agreed to adhere to the rules set forth in this Privacy Policy and under applicable laws, including providing adequate security measures for the information that Muthyam shares with them.

Further, notwithstanding anything to the contrary contained herein, you may at any time choose to revoke your consent to share your information with third parties who are working with Muthyam. Upon revocation of such consent, we may not be able to provide you with access to the Application. Please note that Muthyam shall not be responsible or liable in any manner whatsoever for any actions of any third parties that receive your information.

We may also share your information with our current and future affiliated companies and business partners, and if we are involved in a merger, asset sale or other business reorganization, we may also share or transfer your information to our successors-in-interest.

We may share your information in furtherance of our obligations under any applicable laws. We may further share your information to respond to a court order or summons. We may also share your information upon request from a government agency or investigatory body requests or when we are investigating potential fraud. We reserve the right to disclose your information when required to do so by law or regulation, or under any legal obligation or order under law or in response to a request from a law enforcement or governmental agency or judicial, quasi-judicial or any other statutory or constitutional authority or to establish or exercise our legal rights or defend against legal claims.

We may also share your information with such third parties to whom we believe it is necessary to do so in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of various terms and conditions or our policies.

However, please note that mobile information will not be shared with third parties/affiliates for marketing/promotional purposes, including text messaging originator opt-in data and consent. This information will also not be shared with any third parties.

Additional Clause (for GCC countries)

By using the Application, Users in GCC expressly consent to the transfer and processing of their personal data outside their country of residence, including transfer to India, in accordance with these laws. Cross-border data transfer will follow applicable and adequate safeguard measures (contractual clauses or equivalent) as mandated by:

• Article 22 & 23 of UAE PDPL;
• Article 29 of Saudi PDPL;
• Article 14 of Qatar Data Protection Law; and
• Article 28 of Kuwait Electronic Transactions Law.

10. DATA DELETION

Delete Profile: If you wish to delete your entire Muthyam profile, including personal information associated with it, you might find an option to "Delete your account" on the Application. Click on this setting option inside the menu and follow the instructions and complete the account deletion process. You can also write to our grievance officer at the details provided below or at support@muthyam.live

Provided, however, any requests for erasure will be acted upon in accordance with applicable law and may adversely impact Muthyam's ability to provide Application or services to You.

Additional Clause (for GCC countries)

Requests for data or account deletion from UAE, KSA, Qatar, or Kuwait residents will be honoured in accordance with local data-retention timelines.

Tax related transaction data may be retained for up to 7 years as required under GCC VAT frameworks, after which it will be securely erased.

11. YOUR RIGHTS IN RELATION TO YOUR INFORMATION

Please note that you may exercise the following rights under this Privacy Policy in relation to your personal information by contacting our grievance officer whose details are mentioned subsequently in Section 15 below:

• Right of access and modification: You may access your information at any time to review any personal information that you have provided us, and may modify any inaccurate information.
• Right to withdraw consent: You may withdraw your consent provided to us for the processing of your Personal Information by sending a mail to our grievance officer using the details mentioned below, except to the extent the processing of your personal information to verify this request and process it. This will impact our ability to provide services and Application to you.

12. DISCLAIMER FOR THIRD PARTY SERVICES/APPLICATIONS

Some of the services provided by the Application may direct the User to the platform(s) of third parties. Any information provided by the User on such platforms may be dealt by them in the manner provided by the privacy policy formulated by such third-party platforms. The Application in this regard fully disclaims any liability(ies) or claim(s) which may arise by use/misuse of such information shared by the User, to any third party or any party not known to the Application. The Application would not be liable for the misuse of such information shared by the User or by any third party.

Further, we shall not be held liable for such usage made only because a link to the third-party application was provided on the page of the Application.

13. COMMUNICATIONS AND NOTIFICATIONS

By using the Muthyam Application, you consent to receive important account, transactional, and service-related communications from us. These communications may be sent via:

• SMS
• WhatsApp
• RCS (Rich Communication Services)
• Phone Calls
• In-app notifications
• IVR (Interactive Voice Response)

These notifications may include OTPs, login alerts, subscription updates, payment reminders, content updates, customer support responses, and promotional messages (only if you have opted in).

You may opt out of non-essential promotional messages at any time by contacting our support team or using available settings within the app (where applicable). Essential communications, such as OTP, account security, payment status, or subscription validity, cannot be opted out of.

14. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time. The revised Privacy Policy will be posted in the Application and on our website. We encourage you to review this policy periodically.

15. GRIEVANCE OFFICER

If you have any concerns or questions in relation to this Privacy Policy, or wish to exercise any of your rights mentioned in Section 11 above, you may address them to our grievance officer whose details are as follows:

Grievance Officer: Muthyam Support Team (support@muthyam.live)

Address: 1257/37, 2nd & 3rd Floor, Hanto Orion Center, 14th Main St, Sector-7, HSR Layout, Bengaluru Karnataka 560102

Regional Contact Emails (for GCC users)

• UAE – support.uae@muthyam.live
• Saudi Arabia – support.ksa@muthyam.live
• Qatar – support.qa@muthyam.live
• Kuwait – support.kw@muthyam.live

Users residing in the above countries may reach out to these contacts for exercising rights under their respective data protection laws or to raise region specific privacy concerns.