EQUATION INTERNET PRIVATE LIMITED

PRIVACY POLICY

1. Introduction

1.1. Welcome to pep.live (“Website”) and Pep Application (“Application”), a platform owned and managed by Equation Internet Private Limited (“Company”/ “We”/ “Our”/ “Us”) that brings together customer engagement, content delivery and administration tools in one place. We are focused on providing an online marketplace to content creators, domain experts and instructors to offer their content in various categories such as finance, fitness, entertainment, lifestyle, etc. to users through interactive sessions and pre-recorded videos (“Service”). The Website and Application are hereinafter collectively referred to as “Platform”.

1.2. We are committed to protect the privacy and security of personal data, belonging to and/or provided by any person who accesses or uses the Platform (hereinafter referred to as “You”, “Your” or “User”). This Privacy Policy (“Policy”) applies to Your use of Our Services, content, features, technologies, or functions accessible through Our Platform. The Company, being in charge of managing the Platform, respects Your privacy, and seeks to comply with all the Applicable Laws and other statutory requirements in India in respect of data collection, processing and transfer.

1.3. This Policy outlines the type of Personal Data (defined below) We may collect, how We use it, and the choices You have regarding Your Personal Data. By using Our Platform, You agree to the terms of this Policy. This Policy is incorporated into and subject to Our Terms of Use (“Terms”) and shall be read harmoniously and in conjunction with the Terms. In the event of any conflict between the Terms and this Policy, the provisions of the Terms shall supersede this Policy to the extent of procedural requirements, business practices etc., and subject to the Applicable Laws. Capitalised terms used but not defined herein shall have the meaning as ascribed in the Terms.

1.4. This Policy does not apply to any Personal Data or information that You provide to, or that is collected by: (i) any third-party through Our Website; and (ii) any third-party websites that You access or use in connection with the Services offered through Our Platform. The Company shall not be liable for and has no control over the practices and content of any such third parties.

1.5. You consent that the collection, storage, processing, disclosure and transfer of any Personal Data or information shared by You with Us shall not cause any wrongful loss to You, if it is done in accordance with the provisions of this Policy. We shall not be liable for any loss that may happen to You or any other person providing Us with wrong information. Please read the Policy carefully before using Our Platform or accessing any material, information or availing any Services through the Platform. By agreeing to this Privacy Policy you also agree to give your consent as per the notice accessible here.

1.6. This Policy is an electronic record in the form of an electronic contract formed under the Information Technology Act, 2000, rules made thereunder, and any other applicable statutes, as amended from time to time. This Policy does not require any physical, electronic or digital signature.

2. Your Approval

2.1. You can accept this Policy only if:

(a) You are a natural person of the legal age to consent in your jurisdiction and of sound mind to form a binding contract with Us pursuant to Your use of the Platform; or

(b) You are a juristic person, lawfully existing that has all the authorizations, permits and allowances to enter into this Policy and form a binding contract; and

2.2. You understand that We want You to not use the Platform if You do not understand, approve of or accept this Policy in entirety. Hence, You are requested to read this Policy carefully and understand this Policy before You accept it and agree to be bound by the Policy. If You do not agree to this Policy, please do not use or access the Platform and/or Services.

3. Definitions and Interpretations

3.1. Unless otherwise defined elsewhere in this Policy or the Terms, the following terms shall have the meanings assigned to them as herein below for the purposes of this Policy:

(a) “Applicable Laws” mean all laws, statutes, common law, regulations, ordinances, codes, rules, guidelines, orders, permits, tariffs and approvals, of any governmental, judicial, quasi-judicial, statutory or regulatory authorities, particularly those relating to the internet technology and data privacy that apply to the Company including Digital Personal Data Protection Act, 2023.

(b) “Cookies” shall mean small data files stored on your device (computer or mobile device). Cookies are files with a small amount of data which may include an anonymous unique identifier. The term “Cookie” shall be construed accordingly.

3.2. Any reference to the singular includes a reference to the plural and vice versa, and any reference to one gender includes a reference to other gender(s), unless explicitly provided for.

3.3. Headings and captions are used for convenience only and not for interpretation of the Policy.

4. Personal Data that We Collect

4.1. Our Platform may collect the following personal data for, inter alia, providing Services to You. All types of data mentioned in this Section 4.1 will be collectively referred to as “Personal Data”

(a) Personal Data: Personal data shall mean and include any or all information that is listed out below:

(i) Name of the User;

(ii) Contact details (mobile number, postal address, email address) of the User;

(iii) Gender;

(iv) Date of birth and age;

(v) Billing and payment-related information (mode of payment, transaction reference numbers; no storage of card details);

(vi) Order details of the User;

(vii) Feedback, complaints, and service preferences of the User;

(viii) Name and contact details of proprietors/authorised representatives; and

(ix) place of birth, telephone number (work, mobile), details of documents on education, qualification, professional training, number, photograph, information regarding Your transactions on the Platform, (including purchase history), Your financial information such as bank account information or credit card or debit card or other payment instrument details and other data.

We shall ask You to provide only such Personal Data which is for lawful purpose and necessary to be collected by Us to provide Our Services.

(b) Location and Log Information: When You interact on Our Platform, We may automatically collect such information that shall include (i) your IP address, (ii) Your geolocation information, (ii) time zone, (iv) access dates and times, (v) information about Your activity on Our Platform which shall include the sites from where You have accessed Our Platform, (vii) type of browser, and (ix) mouse clicks.

(c) Device Information: When you use or interact on our Platform, we may collect information about Your mobile device including for example operating system and version, software and file names, preferred language, geolocation information, unique device identifiers, browser type, unique device identifier, diagnostic data, browser language, and other transactional information, etc.

(d) Information shared through free will: We may collect additional information at other times, when You provide feedback(s), or email preferences, respond to surveys, participate in contests or special offers, or asking Us a question through Our e-mail.

(e) Market Research: We may collect Personal Data from You in connection with voluntary surveys conducted by Us. Data may be collected through the Platform, on the phone or through the mail. The information You provide may be shared, but only in the aggregate, with advertisers and partners unless we notify You otherwise at the time of collection.

(f) Local Storage Objects: We may use local storage objects to store content information and preferences. Third parties with whom We partner to provide certain features on Our Platform or to display advertising based upon Your web browsing activity.

(g) Third Parties: Certain aspects of Our Services are enabled through third-party service providers and platforms that support Our business operations (collectively, “Third Parties”). In the ordinary course, We may disclose Personal Data to such Third Parties strictly on a need-to-know basis and for lawful purposes connected with delivery of Our Services, internal operations and compliance requirements. The Third Parties may include but are not limited to: billing system providers, payment gateway and banking partners, marketing and promotional service providers, and customer feedback / grievance platforms. This description of Third Parties is intended to provide a transparent overview of common categories of Third Parties engaged by Us. It is not exhaustive and, depending on operational requirements and lawful purposes, We may engage additional Third Parties from time to time. These Third Parties may place or recognize Cookies, web beacons or other technology to track certain non-personal information about Our Website Users. For example, in the course of serving certain advertisements, an advertiser may place or recognize a unique Cookie on Your browser in order to collect certain information about Your use of the Platform. For another example, an advertiser or advertisement server may also be able to collect Your device’s unique identifier in the course of serving an advertisement. In many cases, this information could be used to show You advertisements on other websites based on Your interests. Further, We may receive Personal Data about You from such third party social media entities, including commercially available sources and business partners. If you access the Platform through a connected service on the Platform, the information we collbect may include your Personal Data available through such connected services.

(h) Other Information: Any content You choose to make public on our Platform such as comments, ratings, images, or other submissions may be viewed and used by others and by Us for promotional or commercial purposes. We are not responsible for any information, including Personal Data, You voluntarily disclose through such public activities on our Platform, which may also appear on third-party websites or connected social media accounts and will be deemed shared by You. We may also collect Personal Data when You participate in sweepstakes, or special offers; if You do not wish such Personal Data to be shared, please do not participate.

5. Consent and Withdrawal of Consent

5.1. Collection and processing of Your Personal Data by Us is subject to Your free, specific, informed, unconditional and unambiguous consent. We agree that the Company will not collect or process Your Personal Data unless You specifically consent to this Policy. If You do not agree with Our practices regarding Your Personal Data as set out in this Policy, please do not use Our Platform and/or the Services in any manner.

5.2. You may inquire as to the nature of Personal Data stored or processed by Us. You will have the right to review Your Personal Data and make corrections or updates and request erasure of Personal Data. You also have the right to withdraw Your consent, if necessary, to the collection, use, retention, and disclosure of Your Personal Data.

5.3. To the extent that the legal basis for Our processing of Your Personal Data is consented, You have the right to withdraw the consent at any time. Withdrawal will not affect the lawfulness of processing of Personal Data before the withdrawal. You further understand that withdrawal of consent for processing of Personal Data will be implemented as soon as practicable. You also confirm that We, while accepting Your request for withdrawal of consent, will be allowed to keep such Personal Data as required by the Applicable Laws and regulations for history and record keeping purposes for a specified period of time.

5.4. If You need to withdraw Your consent with respect to usage of Your Personal Data under Our purview, excluding the Personal Data which has already been shared with the authorities, regulators or business associates and was outside Our control at that time, You will inform Us by clicking here.

6. How We Use Your Personal Data

6.1. We collect, use, process, store, disclose or transfer Your Personal Data in compliance with the Applicable Laws, in such circumstances, where We need to:

(a) perform the Services that You have contracted with Us for, including but not limited to availing of Our Services, or accessing or viewing the content on the Platform;

(b) provide other ancillary services on the Platform, including facilitating the creation of User profiles, viewing and accessing content, processing of offer coupons/vouchers, and related customer support and engagement;

(c) contact You via email or phone call or SMS/WhatsApp and offer You Our Services, make suggestions/recommendations in relation to Our Services, impart product knowledge, offer promotional offers running on Platform, for which reasons Personal Data collected may be used;

(d) create and maintain an online account with the Platform, notify You about changes to Our Services, allow You to participate in interactive features of our Services when You choose to do so; monitor Your usage of Our Platform and Services;

(e) provide You with notices about Your account and/or subscription, including expiration and renewal notices, email-instructions, etc.;

(f) furnish Your Personal Data to service providers to the extent necessary for delivering the relevant Services to You;

(g) dispatch transaction-related communications such as welcome letters, billing reminders, and purchase confirmations;

(h) aggregated and individual, anonymized and non-anonymized data may periodically be transmitted to service providers to help Us improve the Platform and Our Services;

(i) maintain and operate internal business systems and records, including storage, maintenance and retrieval of records in physical and/or digital formats, and implementing role-based access and internal access controls;

(j) provide aggregate statistics about Users, traffic patterns, and other related information to reputable third parties, however this information when disclosed will be in an aggregate form and does not contain any of personally identifiable information;

(k) engage third-party service providers as sub-processors to support Our Services and/or business operations (including payment partners, IT/cloud vendors, customer feedback systems and professional advisors), to the extent necessary for the purposes described in this Policy;

(l) provide an enhanced and personalised User experience;

(m) analysis to improve relationships with our Users;

(n) comply with contractual, legal or regulatory obligations;

(o) manage User communications, including responding to queries, feedback, complaints and service requests received through Our Platform, email;

(p) development in products offered, which allows Us to improve and enhance the safety and security of Our Services, develop new features and products;

(q) improve Platform analytics, user experience, and optimize Our Services; or

(r) check any account activity in order to prevent fraudulent transactions and ensure the security.

7. How We Share Your Personal Data

We may share Your Personal Data in the following events in relation to your use of our Services:

7.1. Third-Party Service Providers: We may share Your Personal Data for business purposes with service providers (including sub-processors) for all or any of the following reasons:

(a) billing system providers;

(b) payment gateway and banking partners;

(d) anti-fraud;

(e) marketing / promotional service providers for monitoring, advertising, marketing, and analytics of use of our Services;

(f) customer feedback and grievance management platforms;

(g) update and automation services for the development process of our Platform;

(h) remarketing services to advertise on third party websites to Users after Users have visited our Platform; and

(i) Services from consultants, lawyers, accountants, auditors, and other professional services.

Our service providers may use Cookies to inform, optimise and serve advertisements based on your past visits to our Platform. The use of Your Personal Data will improve the Platform and better tailor them to meet Your needs, so as to provide You with an efficient, safe and customized experience while using the Platform. It is clarified that the third-party service providers shall not have right with respect to Personal Data and shall use the Personal Data for the limited purpose for which it has been provided or retain the same for purposes of compliance of Applicable Laws or in complete anonymize form for analytical purposes. Such third-party service providers may store the Personal Data in the servers located in India or outside India.

If you prefer that We do not share your Personal Data with third party service providers, You may opt-out by emailing us at support@pep.live.

Please include Your personal details like name and phone number in the body of Your email or letter and include “Opt-out” in the subject line.

7.2. In connection with a business transfer: We may transfer Your Personal Data in connection with a substantial corporate transaction in which Personal Data is among the assets to be transferred.

7.3. For legal reasons: We may disclose Your Personal Data when it is necessary to protect rights and comply with Our legal obligations under Applicable Laws.

7.4. Consent: We may share Your Personal Data for other purposes pursuant to Your consent or at Your direction.

7.5. Personal Data is depersonalized: We may share aggregated or otherwise anonymized information which is no longer personally identifying You.

8. Tracking Cookies Data

8.1. We use Cookies and similar tracking technologies to track the activity on Our Platform. Cookies are sent to Your browser from a website and stored on Your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyse our Services.

8.2. We may store temporary or permanent Cookies on Your computer/device to store certain Personal Data which will aid Us in to enhancing Your browsing experience, analyse usage patterns, and personalize content. You can manage Cookie preferences through Your browser settings or erase or choose to block these Cookies from Your computer, but disabling Cookies may impact certain features of Our Platform. You can configure Your computer’s browser to alert You when We attempt to send You a Cookie with an option to accept or refuse the Cookie. If You have turned Cookies off, You may be prevented from using certain features of the Platform. We do not control the use of Cookies by third parties.

8.3. Examples of Cookies we use:

(a) Session Cookies: We use session Cookies to operate our Service.

(b) Preference Cookies: We use preference Cookies to remember your preferences and various settings.

(d) Advertising Cookies: Advertising Cookies are used to serve you with advertisements that may be relevant to You and Your interests.

9. Retention of Personal Data

We will retain your Personal Data only for as long as is necessary for the purpose of providing our Services, and other purposes as set out in this Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with Applicable Laws), resolve disputes, and enforce our legal agreements and policies. When We process Your Personal Data to provide the Services, We keep the Personal Data until Your account is deleted or as per timelines prescribed under Applicable Laws, whichever is earlier.

10. Disclosure of Data

We may disclose Personal Data that we collect, or you provided on our Platform as follows:

10.1. Disclosure for Law Enforcement and other legal necessities: We may use or disclose your Personal Data to law enforcement authorities, regulators, government or public bodies, to comply with any statutory or legal requirements or as otherwise required by Applicable Laws when responding to summons, notices, court orders and other legal processes, including for the purpose of national security or other issues of public importance.

We reserve the right to use or disclose your Personal Data and other information if we believe that disclosure is necessary or appropriate to protect rights, property and safety of the Company, its users, customers, service providers, officers and shareholders. We may also in good faith share Personal Data and information with other organizations and entities for the purposes of fraud protection and credit risk reduction.

10.2. Disclosure to Affiliates: We may share Your Personal Data with Our parent or subsidiary companies, if any, for internal reasons, including business and operational purposes.

10.3. Disclosure by the User: When You use certain features on the Platform like the discussion forums and you post or share your Personal Data as comments, messages, files, photos on such discussion forums on the Platform, which is freely accessible to group of other Users and/or the public, the same will be available to all such Users and/or public. All such sharing of Personal Data will be done at your own risk. Please keep in mind that if you disclose any Personal Data in posting as comments, messages, files, photos on the discussion forums on the Platform, such information may become publicly available.

11. Data Security Practice and Procedure

11.1. The security of your Personal Data is important to Us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use reasonably acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

11.2. We maintain strong security safeguards to ensure the security and confidentiality of the Personal Data, protect against any anticipated threats to the security of your Personal Data, protect against unauthorized access to your Personal Data, and ensure the proper disposal of your Personal Data. We have in place appropriate safeguards and security measures to protect the Personal Data you provide on Our Platform against accidental or any other unlawful forms of processing.

11.3. We use third party service providers for the purposes of payment collections and information shared by You in relation to payments, shall be governed by privacy policy adopted by such service providers. In the event of disruption of Services or security breach, We will use reasonable efforts to restore Services and mitigate any adverse effects as per Applicable Laws. In the unfortunate event of data breach, We shall immediately inform You as per the provisions of Applicable Laws.

12. Your Rights and Choices

12.1. Your rights with respect to data protection and privacy under this Policy are as follows:

(a) The right to access Personal Data;

(b) The right to correction or updating of Personal Data;

(d) The right to restrict processing;

(e) The right to object to processing;

(f) The right to complain to a regulatory authority;

(g) The right of grievance redressal;

(h) The right to data portability;

(i) The right to withdraw consent; and

(j) The right to nominate.

13. Grievance Redressal

13.1. If You want to request access, correction, or deletion of Your Personal Data, You may write to Us at support@pep.live with the subject “Data related Grievance”. Upon receipt of Your complaint, the Grievance Officer will acknowledge the complaint within 24 (twenty-four) hours and will make best efforts to resolve the matter within 15 (fifteen) business days of receiving the complaint or as per timelines mentioned in the Applicable Laws of India.

13.2. In accordance with Applicable Laws, contact details of the Grievance Officer are provided below:

Name: Nav Sarvesh

Email: nav@pep.live

14. Transfer of Data

14.1. The information, including Personal Data, we obtain from or about You may be maintained, processed and stored by Us on the systems situated in the territory of India.

14.2. However, subject to Applicable Laws, Your Personal Data, may be transferred to and maintained on computers located in the countries other than India where the data protection laws may differ from those of the Applicable Laws in India.

14.3. If you are located outside India and choose to provide Personal Data to Us, please note that we transfer the Personal Data, to India and process it there.

14.4. Your consent to this Policy followed by Your submission of such Personal Data represents your agreement to that transfer.

14.5. The Company will take all the steps reasonably necessary to ensure that your Personal Data is treated securely and in accordance with this Policy and no transfer of your Personal Data will take place to an organisation or a country unless there are adequate controls in place including the security of your Personal Data.

15. Governing Law and Jurisdiction:

15.1. The Platform may be controlled and operated through any country and may be subject to the laws of that country in which they are controlled and operated. If You use the Platform from any location, then, You are responsible for compliance with the local laws applicable to You.

15.2. This Policy shall be governed by and shall be construed in accordance with the laws of India. Subject to Section 15.3 and Section 15.4 below, the courts of Bangalore, Karnataka shall have exclusive jurisdiction.

15.3. In the event of any dispute or difference between the You and Us (“Dispute”), then such Dispute shall first be resolved amicably through good faith negotiations by You and Us. In the event that a resolution of the Dispute is not achieved within 30 (thirty) days from the date such Dispute arises, as notified in writing by any party to the other party, then any of the parties to the Dispute, shall have the right to refer such Dispute to arbitration by issuing a written notice (“Arbitration Notice”) for final resolution in accordance with the provisions of this Section.

15.4. Upon the issuance of an Arbitration Notice, the Dispute shall be referred to a single arbitrator mutually appointed by the parties. If an arbitrator is not appointed within 30 (thirty) days of the Arbitration Notice, either party may refer the matter to the President of the Mumbai Centre of International Arbitration (“MCIA”) in accordance with the rules of the MCIA (“MCIA Rules”) for appointment of the arbitrator. The arbitral proceedings shall be administered by MCIA and shall be governed by the MCIA Rules, which are deemed to be incorporated by reference to this Section. The seat of arbitration shall be Bangalore. The arbitration shall be conducted in English.

15.5. The award of arbitral tribunal in respect of a Dispute shall be final and binding on the parties and shall be enforceable in accordance with its terms and shall be substantiated in writing. You and Us shall submit to the award of the arbitral tribunal and such award shall be enforceable in any competent court of law. The arbitral tribunal shall also decide on the costs of the arbitration proceedings. Prior to or pending arbitration, nothing in this Policy shall preclude either You or Us from seeking an interim or injunctive relief from courts of competent jurisdiction.

16. Changes to This Privacy Policy

16.1. We reserve the right to withdraw or amend our Services, and any service or material We provide via the Platform, in our sole discretion. We will not be liable if for any reason all or any part of Our Services is unavailable at any time or for any period. From time to time, we may restrict access to some parts of the Platform or the Services, or the entire Platform, to Users, including registered Users.

16.2. We may amend this Policy at any time by posting the amended terms of the Policy on the Platform. Your continued use of the Platform following the posting of revised Policy means that You accept and agree to such changes in the Policy.

16.3. By continuing to access or use our Platform and the Services, after any revisions to the Policy become effective, you agree to be bound by the revised Policy. If You do not agree to the new terms of the Policy, you may opt out of using the Platform and the Services.

Last updated in: April 2026