**PRIVACY POLICY**

CodeFacts IT Solutions Pvt. Ltd. and our affiliates/partners/successors/permitted assigns

("CodeFacts," "we," "us," and "our") are fully committed to respecting your privacy and are
dedicated to safeguarding it through our adherence to this privacy policy ("Policy"). The term
"you" in this Policy pertains to the users of the CodeFacts Platform (as defined below),
irrespective of whether you access the services available on the Platform or complete a
transaction on the Platform ("Users"). This Policy delineates: (a) the categories of
information we may collect from you when you access or use our services (collectively, our
"Services") through our Platform, and (b) our procedures for gathering, utilizing, upholding,
protecting, and revealing that information.

The Website and GoArena App, either directly or via licenses granted by us, are collectively
referred to as the "Platform." By using or accessing this Platform and furnishing Information
(as defined below) or Confidential Personal Data (CPDI) (as defined below), you agree to
the terms and conditions set forth in this Policy. You also expressly approve of our utilization
and disclosure of your Information and/or CPDI in any manner as elucidated in this Policy
and further signify your concurrence with this Policy and the Terms of Use (incorporated
herein by reference). If you dissent from the terms and conditions of this Policy, kindly refrain
from proceeding further, using or accessing this Platform, or providing us with any
information.

**I. DEFINITIONS**

a. "Account" designates the password-protected account formulated by users to access and

engage with the Platform.

b. "Non-personal Identification Information" alludes to any non-personal data collected from

Users through their interactions on the Platform, including, but not restricted to, browser
specifications, computer type, and technical particulars concerning Users' means of
connecting to the Platform, such as the operating system and Internet service providers
used, among other akin data.

c. "Personal Identification Information" pertains to any data that identifies or has the potential
to identify, contact, or locate the individual to whom the information relates. This
encompasses instances when Users visit the Platform, register, complete a transaction,
participate in surveys, fill out forms, and partake in other activities, services, features, or
resources offered on the Platform. Users may be solicited for personal details, including, but
not limited to, their name, email address, phone number, and residential address, as
disclosed by you regarding the services available on the Platform. It's worth noting that
Users have the option to visit our site anonymously. CodeFacts will only collect Personal
Identification Information from Users if they voluntarily provide such information. Users
maintain the right to decline furnishing Personal Identification Information, although this may
limit their participation in specific activities or access to certain services available on the
Platform.
For the purposes of this Policy, Personal Identification Information and Non-personal
Identification Information shall collectively be termed "Information."

d. "Confidential Personal Data Or Information" (CPDI) or "Sensitive Data" encompasses

information pertaining to the following:

i. Passwords;

ii. Financial information, such as bank account details, credit card particulars, debit card
information, or other payment instrument data;

iii. Physical, physiological, and mental health status;

iv. Sexual orientation;

v. Medical records and medical history;

vi. Biometric data;

vii. Any information related to the above categories provided to a corporate entity for the
provision of services; and

viii. Any data received under the above categories by a corporate entity for processing,
storage, or handling under lawful contracts or otherwise.

e. "Third Party" denotes any individual or entity other than you or us.

**II. COLLECTION OF PERSONAL INFORMATION BY CODEFACTS**

Concerning the use of the Platform:

i. For the establishment of an Account on the Platform, Users will be asked to disclose
information, including personal contact details. The nature of Information collected from a
User fluctuates based on their interactions with the Platform.

ii. During the creation of User Accounts, we will gather data such as names, telephone
numbers, email addresses, residential or commercial addresses, and other Information. In
certain scenarios, we may also necessitate the disclosure of demographic particulars,
encompassing gender, age, education, and other data pertinent to the provision of Services.
Additionally, we may collect Information posted by Users in their offers, profiles,
requirements, feedback, or any other communication on the Platform.

iii. When Users employ our location-based services, we may collect and process information
regarding their mobile device's GPS location (including latitude, longitude, or altitude) and
the timestamp of this data. This information is employed to personalize the Services. We
may associate location data with device IDs and other information we have on Users. Users
can revoke consent for this feature by disabling location tracking on their devices.
iv. Furthermore, we may request access to Users' device contact lists to facilitate specific
features within our app, such as identifying acquaintances among their contacts and
connecting with them. By granting us permission to access their contact lists, Users
acknowledge that we may collect and use contact information from their contact lists,
encompassing contact names, phone numbers, and email addresses.

v. We also retain the right to oversee conversations between two Users facilitated by
CodeFacts through any mechanism on the Platform. This information may be used for
various purposes, including but not limited to monitoring and preventing misuse,
safeguarding Users' rights, and resolving any disputes that may arise.

b. From third-party platforms:

i. Users may also opt to register for an Account using their existing credentials from third-
party services such as Facebook, Google, Twitter, or other similar accounts ("Third-Party
Site Accounts"). As part of the Platform's functionality, Users can link their accounts with
Third-Party Site Accounts by either: (i) providing their Third-Party Site Account login details
to us through the Platform or (ii) authorizing us to access their Third-Party Site Account,
subject to the terms and conditions governing the use of each Third-Party Site Account. You
assert that you have the authorization to disclose your Third-Party Account login details to us
and grant us access to your Third-Party Site Account (including, but not limited to, purposes
described herein), without violating the terms and conditions governing your use of the
relevant Third-Party Site Account or imposing any fees or usage restrictions on us, as
stipulated by the applicable Third-Party Site service provider.

ii. Should you choose to register by logging in via a Third-Party Site Account through our
Platform, we will acquire Personal Information furnished by you to the pertinent Third-Party
Site service provider. This may include your actual name, email address, profile picture,
names of friends, group memberships, and other information you have made publicly
accessible via the Third-Party Site service provider or authorized us to access. Based on
your Third-Party Site Account selection and permissibility granted by you, we will access,
make accessible, and, if applicable and authorized by the Third-Party Site service provider
and you, store information from your Third-Party Site Account on your Platform account.

c. Cookies:

Cookies are diminutive data fragments saved by your browser. They retain various aspects
of your visit and support us in delivering uninterrupted service. Cookies also enable ad
networks to deliver targeted advertisements believed to

be of interest to you. Cookies may be placed in your browser either when you access the
Platform or visit Third-Party websites.

This anonymous information is segregated and not linked to the Information you provide us.
We utilize collected cookies to:

i. Authenticate your login information;

ii. Enable our security measures;
iii. Contextualize and display advertisements;
iv. Enhance and develop Platform features.

Please feel free to adjust your browser settings if you prefer not to accept cookies. It's
essential to note that modifying your browser settings may affect your Platform experience.
It's also noteworthy that this Policy does not encompass the use of cookies by advertisers.

d. Collection of CPDI:

For the purpose of establishing an Account on the Platform, Users will be prompted to reveal
specific CPDI, including credit card or debit card details necessary for transactions. It's
crucial to clarify that we do not access or store any CPDI related to financial transactions
conducted on our Platform. Such CPDI is acquired directly by payment gateways integrated
with our Platform. We ensure the use of reputable payment gateways equipped with
industry-recognized security protocols and measures. We commit not to transmit or disclose
your CPDI to a third party for any reason without your prior consent.

**III. USE OF PERSONAL INFORMATION BY CODEFACTS**

a. For the purpose of providing Services on the Platform, we may employ Information to:

i. Address and respond to User queries;

ii. Comprehend Users' needs;
iii. Troubleshoot technical issues;
iv. Deliver customer support;
v. Fulfill obligations arising from the contract between CodeFacts and Users, including billing
and collections;
vi. Enable Users to engage in interactive features offered through the Services;
vii. Pursue any other purpose specified by CodeFacts when soliciting information from
Users;
viii. For monetization and the generation of statistics for advertising, affiliate marketing, and
analytics;
ix. For any other purpose with the User's explicit consent.

b. Communication:

We may employ various forms of communication, including phone calls, emails, application
notifications, short message service (SMS), multimedia message service (MMS), or other
channels, to share information with Users about promotions, features, or offerings available
on the Platform. Users may receive such communications after registering as Users to
receive advertisements related to goods and services of potential interest. Should Users
wish to opt out of receiving non-transactional emails, instructions for unsubscribing are
provided at the end of each email, or Users may contact the relevant personnel.

c. We do not sell User-specific Information to Third Parties for the purposes mentioned
above, and all data shared with Third Parties for these purposes is done on an aggregate,
non-identifiable basis.
**IV. SHARING OF PERSONAL INFORMATION BY CODEFACTS**

a. General information disclosure:

We do not engage in the sale, trade, or rental of Users' Information to third parties. We may
share general aggregated demographic information about visitors and users with our
business partners, trusted affiliates, and advertisers for the previously delineated purposes.
Nevertheless, Personal Identification Information may be shared, as required, with (a) our
subsidiaries or affiliates, or (b) a purchaser or successor in the event of a merger,
divestiture, restructuring, reorganization, dissolution, or another sale or transfer of all or part
of CodeFacts's assets, whether as a going concern or as part of bankruptcy, liquidation, or
similar proceedings, in which Users' Information held by CodeFacts constitutes part of the
assets transferred.

b. Legal proceedings and law enforcement:

In situations necessitating responses to subpoenas, court orders, or other legal processes,

User Information may be disclosed pursuant to such legal mandates, potentially without prior
notice. We may also divulge User Information, including, but not limited to, names, cities,
states, telephone numbers, email addresses, and activity history on the Platform, to law
enforcement agencies, government officials, or other authorities if legally compelled to do so
or in cooperation with a government authority's investigation.

c. Third-Party service providers concerning the Platform:

To the extent necessary for the provision of services on the Platform, we may provide User
Information to Third-Party contractors working on our behalf or in conjunction with us to
deliver said services, facilitate communication with Users, or maintain the Platform.

d. With consent:

User Information and/or CPDI may be shared in any circumstance for which we possess
User consent.

**V. SECURITY**

We diligently endeavor to ensure the security, integrity, and confidentiality of User

Information and CPDI, employing measures to prevent unauthorized access, alterations,
disclosures, or destruction. We implement suitable physical, electronic, and managerial
procedures to protect and thwart unauthorized access, preserving data security. Our
payment gateway partners adhere to Payment Card Industry Data Security Standard (PCI
DSS) requirements and employ Secure Sockets Layer (SSL) secured communication
channels, encryption, passwords, and physical security measures to safeguard User
Information and CPDI.

However, it's important to recognize that absolute security cannot be guaranteed, as no

method of data transmission and protection is entirely impervious. We are not accountable
for any security breaches or actions by Third Parties who receive User Information.
Additionally, the Services may be linked to numerous other sites, and we disclaim
responsibility for their privacy policies and practices, as they are beyond our control.
Notwithstanding the provisions of this Policy or elsewhere, we shall not be held responsible
for any loss, damage, or misuse of User Information or CPDI resulting from events beyond
our reasonable control.

**VI. UPDATING, DELETING, AND AMENDING YOUR INFORMATION**

a. We will make reasonable efforts to accurately record the Information provided by you,
including any subsequent updates. You have the ability to review, update, and amend the
Information we maintain about you. Furthermore, you may request the deletion of
Information that is inaccurate, incomplete, or irrelevant for legitimate purposes or processed
in violation of applicable legal requirements.

b. Your right to review, update, amend, and delete Information may be restricted: (a) when
the rights or safety of another individual or individuals would be infringed upon, or (b) if the
information pertains to ongoing or anticipated legal proceedings between you and us, or
granting access to you would compromise negotiations between us or an investigation of
potential unlawful activity. Your right to review, update, amend, and delete Information is
also subject to applicable law, including any statutory retention obligations.

**VII. LINKS TO THIRD-PARTY APPLICATIONS AND WEBSITES**

The Platform, along with communications sent to you, may contain Third-Party
advertisements and links to other websites, products, and services. You acknowledge and
agree that these applications and websites are operated by Third Parties and are not
controlled by, affiliated with, or associated with us unless explicitly stated. Consequently, we
do not make representations regarding the privacy practices or policies of such Third Parties
or the terms of use of these websites or applications. Information provided by you to such
Third-Party websites will be subject to the privacy policies of those websites. We
recommend reviewing the privacy policy of any such websites and applications before using
them.

**VIII. AMENDMENT TO THE POLICY**

CodeFacts reserves the discretion to update this Policy at any time. In such instances, we
will modify the "Last Updated" date at the bottom of this Policy and may additionally notify
you via email. We encourage Users to regularly check this page to stay informed about any
changes to the Policy. You acknowledge and agree that it is your responsibility to
periodically review this Policy to remain informed of

any modifications. Your continued use of our Platform following any changes to the Policy
signifies your acceptance of those changes.

**IX. THIRD PARTY POLICIES**

As you access and utilize our services, we collect specific information from you, including but
not limited to your phone number, email address, device details, and IP address. By
accessing and utilizing our services, you expressly consent to the sharing and disclosure of
this collected information with our third-party service providers, business partners, and
agents. For instance, your information may be shared with third-party services such as
GetSimpl to ensure fraud prevention and facilitate PayLater checkout experiences. Please
refer to the privacy policies of third parties for further details.

**X. CONTACT US**

If you have any inquiries regarding the processing or use of Information or CPDI provided by
you, or regarding this Policy, you may reach out to us via email at info@codefacts.com or
send correspondence to the following address:

CodeFacts IT Solutions Pvt Ltd

ManiKonda,
Hyderabad, 500089,
Telangana, India