PRIVACY POLICY

iSpear Africa Limited is committed to protecting the privacy and security of your Personal Information. Your privacy is important to us. This Privacy Policy (the "Privacy Policy" or "Policy") describes the Information that the Company collects via the Krish-e Smart Kit Application, which may be updated from time to time ("App"), which is an IoT and AI-powered solution consisting of a simple telematics GPS device and an Android application to, inter alia, help tractor owners accurately track daily farming, haulage, and fuel usage from or about the User(s). This Privacy Policy also describes how the Company may process your Information (as defined below) that is collected from the User(s).

By "we", "our" or "us", or the "Company", we mean, iSpear Africa Limited, and by "you", "your" or "User(s)", we refer to the users of the App.

The Company stores and processes User(s)' Information which may include sensitive financial information that is collected, if any, on devices that are protected by reasonable security practices and procedures, in accordance with the Information Technology Act 2000 and the Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011 made thereunder.

By using the App, the User(s) is/are consenting to the collection, processing, storage of User(s) Information in the manner as set forth in this Privacy Policy. This Privacy Policy is incorporated into and is subject to the Terms of Use of the App. This Policy explains how we collect, store, disclose, transfer, and use Information that personally identifies you when you use our App. We want you to be confident that we are looking after your interests and that is why we have set out our information practices in this Policy.

Before using our App, the User(s) is/are advised to carefully review this Privacy Policy and the Terms of Use. If the User(s) do not agree to be bound by this Privacy Policy or do not agree with any of the terms contained herein, the User(s) is/are asked to not access or use the App. By using the App, the User(s) is/are consenting to the terms of this Privacy Policy and to the processing and storage of the User(s) Information in the manner as set forth in this Privacy Policy.

Our Privacy Policy is subject to change at any time, from time to time, without notice, and such changes shall be effective immediately upon posting the updated or modified Privacy Policy on the App. To make sure you are aware of any such changes, please review the Privacy Policy periodically.

When User(s) use(s) the App, the App collects and stores Information which is provided by User(s) from time to time. The Company's primary goal in doing so is to provide an safe, efficient, smooth and customized experience to the User(s). This allows the Company to provide services and features that will most likely meet the User(s) needs, and enable to customize the App to make the User(s) experience safer and easier. We, therefore, collect personal information from User(s) through the App, that we consider necessary for achieving this purpose.

1. THE INFORMATION WE COLLECT AND HOW WE COLLECT IT

"Information" includes Personal Information, Non-Personal Information, Tractor Location Data, Log Data and Shared Information, each as defined below.

Collection of Personal Information and other Information:

Depending on what services you use, your Personal Information will be collected by us in different ways when you provide us with it. "Personal Information" is any information or combination of information that relates to you and can be used to identify you or any other natural persons such as your customers, if any, who are farmers who have rented your tractors. Personal Information may include, but will not be limited to the following:

• Information you make available to us when you register on the App or when you purchase the Krish-e Smart Kit Device ("the Device"), including but not limited to your name, mobile number, emergency contact number, gender, date of birth, residential address, email address, age, occupation, number of tractors owned, overall tractor usage and other assets.
• Information from one device to another in the event you sync multiple devices with the Device and/or the App.
• Information which you make available to us and information which we collect as you use our App, including but not limited to your Header, Name, Age, Phone Number, Gender, Birthdate, Tractor Model, Number of Tractors Owned, Tractor Serial Number, Tractor Last Service Date, Location, Tractor Identification, Number, Tractor Model and submodel, Driving Data, Location Data and Log Data.
• The Personal Information of your customers, if any, viz. the farmer's name, mobile number, farm details, job details.
• Your billing information, provided by you at the time of your purchase of the Device.

You hereby confirm that you shall share any personally identifiable information of your customer, viz. the farmers only after obtaining their prior written consent to disclose the same to us, for the purposes of this Policy.

Non-Personal Information:

"Non-Personal Information" is electronic data that does not contain any information that can be used to identify a natural person. The information that is collected includes work done on the farm in terms of area of the land and the time taken, diesel level.

Tractor Location Data:

"Tractor Location Data" is information that we collect regarding the location of your tractor, including your "Trip Route", the "Parked Tractor Location Information" of your Tractor, "Job Area and Location". Trip Routes allow you to review a particular route that you've driven, the distance and cost associated with that route, and the length of time the particular route takes to drive. Parked Tractor Location Information helps you to find your parked Tractor. Job Area and Location helps you locate where the job was performed, and the area and time taken for that job.

Any Location Data sampled and saved by us will be sent to our servers so that we may associate the information relating to your present location with content relevant to you, like localized suggestions for purchase of goods including but not limited to fertilizers, seeds, and other agriculture related products, third party insurance providers, etc., thereby providing you with a more customized experience with our services.

Location Data allows you to track your Tractor and see a live dashboard with your Tractor speed wherever you are. Your Location Data will also be used to provide you alerts for Geofence and alarms.

The Krish-e Smart Kit Mobile App uses your smartphone's location services (GPS, Wi-Fi, cell tower triangulation or other similar satellite services or sensors in your mobile device) to record its location as you drive. You may disable sharing of Location Data, by changing the settings on your Device, in which case You may not be able to access or use certain features within the Krish-e Smart Kit Mobile App.

In case if you have opted for a finance scheme for your Tractor at the time of purchase, we may share your Tractor Location Data with the financer during the term of finance of your Tractor as a part of our offering of analytics services to such financers.

Cookies and Web Beacons:

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. The cookies do not contain any of the User's personally identifiable information.

The Company uses data collection devices such as cookies on certain sections of the App to help analyse web page flow, measure promotional effectiveness, and promote trust and safety. We may offer certain features that are only available using cookies. The Company places both permanent and temporary cookies in the hard drive of the User's device.

We also use cookies to allow User(s) to enter your password less frequently during a session. Cookies can also help the Company to provide information that is targeted to User(s) interests. Most cookies are session cookies meaning that they are automatically deleted from User's hard drive at the end of a session. User(s) are always free to decline our cookies if User's browser permits, although in that case User(s) may not be able to use certain features on the App and User(s) may be required to re-enter your password more frequently during a session.

Additionally, User(s) may encounter cookies or other similar devices on certain pages of the App that are placed by third parties. The Company does not control the use of cookies by third parties.

Web beacons are electronic image files or other technologies that may be embedded within the App or email to keep count of visitors, record when and if an email or App is accessed, or access certain cookies.

Log Data:

"Log Data" is certain technical information that is automatically collected and logged by our servers when you use our App, whether through the use of cookies, web beacons and log files or otherwise, including:

• Technical information such as your mobile carrier, configuration information made available when you access the App, your IP address and your device's version and identification number; and
• Information about the state of your device if the App crashes such as device model and built, device orientation, whether location services are active, operating system version, amount of memory free, amount of storage free and the amount of battery percentage.

Shared Information:

"Shared Information" is information about you or relating to you that is voluntarily shared by you. For example, if you choose, you can share your Tractor's location with the people with whom you share the Tractor, in which case we will collect such Shared Information.

2. PURPOSE OF COLLECTION OF YOUR PERSONAL INFORMATION & USE

The use of your Personal Information is subject to the Privacy Policy in effect at the time of our use. We will process your Personal Information for the following purposes:

• To provide and maintain our services;
• To provide an efficient, smooth and customized User(s) experience;
• To provide services and features that will most likely meet the User(s) needs and enable customization of the App to make the User(s) experience easier.
• To better understand how you access and use our App, for the purposes of trying to improve our services and to respond to your desires and preferences, including language and location customization, personalized help and instructions, or other responses to your and other customers' usage of our App;
• To help us develop new services and features;
• To send communication/notifications/offers based on User(s) previous interaction on the App/orders and interests
• To resolve disputes, provide customer support and troubleshoot problems as permitted by law.
• To improve the quality and design of our existing services;
• To suggest third party services based on your location and in line with your preferences;
• To investigate and prevent the misuse of any of our services;
• To allow you to participate in surveys about our products and services. If you participate in a survey, we may request certain Personal Information from you. Participation in these surveys is voluntary and you therefore have a choice whether to disclose your Personal Information. We may use a third-party service provider to conduct these surveys and such third-party service provider will be prohibited from using your Personal Information for any purpose other than for conducting the survey;
• To help us research and create and sell industry reports and give interesting insights such as "usage patterns of tractors". Such reports are created using aggregated, anonymized data of driving patterns and Tractor performance, and will never contain any of your Personal Information; and
• In connection with any legal proceedings pertaining to the Company, the User(s) or the App.

3. BASIS FOR PROCESSING YOUR PERSONAL INFORMATION

We process your Personal Information provided by you only if we have the following legal basis for doing so:

• To fulfil a contract, we have concluded with you or to take steps at your request prior to entering into such an agreement with you; or
• To pursue our prevailing legitimate interests to achieve the purposes set out in this Policy.
• On the basis of the necessity to comply with legal obligations to which we are subject.

If we process your Personal Information based on your consent, we will ask for your consent in a separate process.

We endeavor to collect only such Information that is reasonably necessary for us to perform the desired function.

By using the App and/or by providing your Personal Information, you consent to the collection and use of your Personal Information that is disclosed on the App, or the information created while using the App in accordance with this Privacy Policy, including but not limited to consent for sharing information as per this Privacy Policy.

4. SHARING/DISCLOSURE OF PERSONAL INFORMATION

The Company may share Personal Information with any third party including but not limited to our affiliates, group companies, agents, contractors, service providers to help detect and prevent identity theft, fraud and other potentially illegal acts; correlate related or multiple accounts to prevent abuse of our services; and to facilitate joint or co-branded services that User(s) request where such services are provided by more than one corporate entity. Those entities and affiliates may not market to User(s) as a result of such sharing unless User(s) explicitly opt-in.

User(s) may disclose Personal Information if required to do so by law or in the good faith belief that such disclosure is reasonably necessary to respond to summons, court orders, or other legal process. The Company may disclose Personal Information to law enforcement agents, third party rights owners, or others in the good faith belief that such disclosure is reasonably necessary to enforce our Terms of Use or Privacy Policy; respond to claims that an advertisement, posting or other content violates the rights of a third party; or protect the rights, property or personal safety of our User(s) or the general public.

The Company and its affiliates may use or share some or all of User(s)' Personal Information with another business entity should the Company (or our assets) plan to merge with, or be acquired by that business entity, or re-organization, amalgamation, restructuring of business. Should such a transaction occur, that other business entity (or the new combined entity) will be required to follow this Privacy Policy with respect to User(s)' Personal Information.

5. DATA RETENTION

We will retain your Personal Information which we have collected for as long as we reasonably consider it necessary for achieving the above mentioned purposes and as is permissible under applicable law, subject to appropriate safeguards. This is determined on a case-to-case basis. We will delete your Personal Information whenever you request us to do so. However, we may be required to archive and/or retain your Personal Information for as long as there are statutory retention obligations or potential legal claims are not yet time barred.

6. LINKS TO OTHER THIRD-PARTY SITES OR ADVERTISEMENTS ON THE APP

The App may contain links to other websites, that are beyond the Company's control, that may collect personally identifiable information about User(s). Should User(s) choose to browse/visit such websites, the Company shall not be responsible for the privacy practices or the content of those linked websites. We encourage you to be aware when you leave our App to read the privacy policies of other third-party sites that may collect your Personal Information.

The Company uses third-party advertising companies to serve ads when User(s) visit the App. These companies may use information (not including your name, address, email address, or telephone number) about User(s) visits to this and other websites to provide advertisements about goods and services of interest to the User(s). The Company is not responsible for the terms of use/privacy policies/notices/statements or the content of such third-party advertising companies or third-party social media sites even if:

• You accessed the third-party site using links from our App; or
• You accessed our App using links from a third-party site.

7. SECURITY MEASURES

We are committed to protecting your Personal Information and privacy online and accordingly, we have implemented technical and organizational security measures in relation to all the data or information including Personal Information that is processed by us to protect against a breach of security leading to accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, Personal Information transmitted, stored, or otherwise processed.

8. YOUR RIGHTS IN CONNECTION WITH YOUR PERSONAL INFORMATION

We respect your right to access and control your Personal Information, and we will respond to requests for information and, where applicable, will correct, amend, or delete your Personal Information. These rights can be exercised by you, as per the Data Protection Law that is applicable to your region.

Please note that applicable law might require that we cannot comply with every request. For example, we will be required to retain your Personal Information due to statutory retention requirements despite your request for erasure.

You have the following rights:

• Right to access: You have the right to confirm if we hold any Personal Information about you and obtain a copy of the Personal Information about you that is held with us.
• Right to withdraw consent: If you have consented to our processing of your Personal Information, you may revoke that consent at any time, effective going forward, by contacting us. This includes cases where you wish to opt out from marketing messages that you receive from us via the App. However, opting out will result in immediate cessation of services and no further collection of data will be done on a going forward basis.
• Right to rectification: You have the right to have information held about you corrected if it is not accurate or complete.
• Right to erasure: You can also request to erase the Personal Information that is no longer necessary for the purpose for which it was processed unless retention is necessary for a legal purpose.
• Right to restriction of processing: You have the right to restrict processing of your information, however exercising this right may not enable the Company to fulfil your service requests and ensure service performance.
• Right to object: You have the right to object to receive marketing communications from the Company by choosing to opt out of all marketing communications.
• Right to lodge a complaint: You have the right to complain about the processing activities carried out by us before the competent data protection authorities, as applicable under your region-specific Data Protection Law.

For exercising any of your rights mentioned above, you can write to us at support@carnot.co.in

However, please note that:

• We will need you to respond with proof of your identity before you can exercise these rights.
• The Company may not be able to process any requests made in the event the user fails to identify themselves or if the Company is unable to authenticate such a user.

The Company may also decline to process requests that are unreasonably repetitive, requiring disproportionate effort, jeopardizing the privacy of others, or would be extremely impractical.

• The Company shall not charge you for fulfilling any of the above requests. However, if the fulfilment of any such request leads to certain costs being incurred by the Company, then the Company will notify you of such costs prior to processing such request.

9. CHOICE/OPT-OUT

The Company provides all User(s) with the opportunity to opt-out of receiving non-essential promotional or marketing-related communications from its partners, and from the Company in general, after setting up an account.

If User(s) want to opt-out and remove their contact information from the App lists and newsletters, then please write to us at hello@ispear.co.tz. Please remember that even if you opt out of receiving marketing emails, we may still send you important service information related to your accounts and subscriptions, if any, unless you delete your account.

10. OUR CONTACT DETAILS

If you have any questions or comments regarding this Privacy Policy or want to express your grievances regarding the processing of your Personal Information, please contact the Grievance Officer by writing in at the following address:

This Privacy Policy was last updated on 28^th December, 2023.

11. DISCLAIMER

Kindly note that the Company does not collect Personal Information about individuals except when such individuals specifically provides such information on a voluntary basis. Upon such voluntary disclosure of Personal Information, we may further verify, collate or receive information about you from publicly and commercially available sources (as permitted by law), which we may combine with other information we receive from you. We may also receive information about you from third-party social networking services, if you are already connected with those services. The Company shall, at all times, ensure to implement reasonable security practices and procedures (such as managerial, operational, physical and technical) for the purpose of protection and safeguarding of your personal data and information as the same is of vital importance to the Company. At the Company, we are strongly committed to protecting the personal and financial information that you submit to us. Personal Information of individual users will not be sold or otherwise transferred to unaffiliated third parties without your approval at the time of collection. However, please note that although we take reasonable steps to protect your information, no website, internet transmission, computer system or wireless connection is completely secure.

The Company shall ensure to safeguard the security and confidentiality of any Personal Information you share with us. Any of your personally identifiable information obtained by us shall not be used or shared other than for the purposes to which you consent. However, despite our utmost efforts to protect your Personal Information, the Company cannot warrant the security of any information you transmit to us through our online services/applications. By accepting this Privacy Policy, you accept that such transmission of your Personal Information is done at your own risk.

Your information/inputs/queries as a registered user are required to serve you better and the same shall not be shared with anyone without your consent. However, we may disclose your Personal Information to agents or contractors of the Company and/or its group companies/affiliates to enable processing of transactions or communications with you "on need" basis. Your aforesaid information may be further used for assessment and analysis of our market, customers, products, and services and to understand the way people use our services so that we can improve them and develop new products and services. However, it shall be on the basis that the agents are required to keep the information confidential and will not use the information for any other purpose other than to carry out the services they are performing for the Company and/or its group companies/affiliates.