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GLOBAL PRIVACY POLICY

[currently relevant to US and India]

This Privacy Policy describes how 360 World, Inc. and its affiliates including 360 World Innovations India Private Ltd. (collectively "360 World") collect and process your personal information through 360 World websites, devices, products, services, online marketplaces and applications that reference this Privacy Policy (together "360 World Services").

By using 360 World Services you agree to our use of your personal information (including sensitive personal information) in accordance with this Privacy Policy, as may be amended from time to time by us at our discretion. You also agree and consent to us collecting, storing, processing, transferring, and sharing your personal information (including sensitive personal information) with third parties or service providers for the purposes set out in this Privacy Policy.

Personal information subject to this Privacy Policy will be collected and retained by 360 World, with registered offices at:

  • US address: 39899 Balentine Drive, Suite 200, office 210, Newark, California 94560
  • India address: Flt No-10 Shanti Hgt PLT, No. 9 10 Sr No 297/2, Pathardi, Nashik, Nashik- 422010, Maharashtra, India.

What Personal Information About Customers Does 360 World Collect?

We collect your personal information in order to provide and continually improve our products and services.

Here are the types of personal information we collect:

Information You Give Us: We receive and store any information you provide in relation to 360 World Services. You can choose not to provide certain information, but then you might not be able to utilize certain 360 World Services or services features.

You provide information to us when you, for example:

  • search or shop for products or services in our marketplace;
  • provide information in your account (you are expected to have only one user account with 360 World) or your profile;
  • talk to or otherwise interact with our AI Chatbot service;
  • configure your settings on, provide data access permissions for, or interact with a 360 World Services;
  • communicate with us by phone, e-mail, or otherwise;
  • complete a questionnaire, a support ticket, or a contest entry form;
  • upload or stream images, videos or audio or other files while using 360 World Services;
  • participate in discussion boards or other community features;
  • provide and rate the 360 World Services or other users of 360 World Services with whom you have had a services-related interaction.

As a result of those actions, you might supply us with such information as:

  • identifying information such as your name, address and phone numbers;
  • payment information;
  • your age;
  • your location information;
  • your IP address;
  • e-mail addresses of your friends and other people;
  • content of reviews and e-mails to us;
  • the personal description and photograph in your profile;
  • prompt content when you interact with our AI Chatbot;
  • images, videos and other content collected or stored in connection with 360 World Services;
  • information and officially valid documents regarding identity and address information, including PAN numbers and Aadhaar Card numbers;
  • licenses, certifications or other authentications of your background, expertise or professional qualifications;
  • credit history information;
  • corporate and financial information; and
  • device log files and configurations, including Wi-Fi credentials.

Automatic Information: We automatically collect and store certain types of information about your use of 360 World Services, including information about your interaction with content and services available through 360 World Services. Like many websites, we use cookies and other unique identifiers, and we obtain certain types of information when your web browser or device accesses 360 World Services and other content served by or on behalf of 360 World on other websites.

Examples of the information we collect and analyze include:

  • the internet protocol (IP) address used to connect your computer, phone or other access device to the internet;
  • login, e-mail address, and password;
  • the location of your device or computer;
  • device metrics such as when a device is in use, application usage, connectivity data, and any errors or event failures;
  • 360 World Services metrics (e.g., the occurrences of technical errors, your interactions with service features and content, your settings preferences and backup information, location of your device running an application, information about uploaded images and files such as the file name, dates, times and location of your images);
  • version and time zone settings;
  • purchase and content use history, which we sometimes aggregate with similar information from other customers to offer certain 360 World Services, such as live feeds;
  • the full Uniform Resource Locator (URL) clickstream to, through, and from our websites, including date and time; products and content you viewed or searched for; page response times, download errors, length of visits to certain pages, and page interaction information (such as scrolling, clicks, and mouse-overs);
  • phone numbers used to call our customer service number; and
  • images or videos when you participate in our marketplace using 360 World Services.

We may also use device identifiers, cookies, and other technologies on devices, applications, and our web pages to collect browsing, usage, or other technical information.

Information from Other Sources: We might receive information about you from other sources, such as updated delivery and address information from our carriers, which we use to correct our records and deliver your next purchase more easily.

Examples of information we receive from other sources include:

  • updated delivery and address information from our carriers or other third parties, which we use to correct our records and deliver your next purchase or communication more easily;
  • account information, purchase or redemption information and page-view information from some merchants with which we operate co-branded businesses or for which we provide technical, fulfillment, advertising or other services;
  • information about your interactions with products and services offered by our affiliates;
  • search results and links, including paid listings (such as Sponsored Links);
  • information about internet-connected devices;
  • identity verification and other personal background information; and
  • credit history information from credit bureaus, which we use to help prevent and detect fraud and to offer certain credit or financial services to some customers.

For What Purposes Does 360 World Use Your Personal Information?

We use your personal information to operate, provide, develop, and improve the products and services that we offer our customers. These purposes include:

  • Delivery of products and services. We use your personal information to take and fulfill service requests, deliver products and services, process payments, and communicate with you about service requests, products and services, and promotional offers.
  • Provide, troubleshoot, and improve 360 World Services. We use your personal information to provide functionality, analyze performance, fix errors, and improve the usability and effectiveness of the 360 World Services.
  • Recommendations and personalization. We use your personal information to recommend features, products, and services that might be of interest to you, identify your preferences, and personalize your experience with 360 World Services.
  • Provide voice, image and camera services. When you use our voice, image and camera services, we use your voice input, images, videos, and other personal information to respond to your requests, provide the requested service to you, and improve our services.
  • Referrals. If you choose to use our referral service to tell a friend about the 360 World Services, we may collect your friend's name and email address. We will automatically send your friend an email, SMS or other message inviting them to visit our Services.
  • Sweepstakes, Contests & Promotions. We may offer sweepstakes, contests, and other promotions that may require providing your personal information to register. By participating, you agree to official rules that may allow sponsors to use your name, voice and/or likeness in advertising or marketing.
  • Comply with legal obligations. In certain cases, we collect and use your personal information to comply with applicable laws, such as collecting establishment information and financial account information for identity verification.
  • Communicate with you. We use your personal information to communicate with you in relation to 360 World Services via different channels (e.g., by phone, e-mail, chat).
  • Advertising. We may use your personal information to display interest-based ads for features, products, and services that might be of interest to you. We don't use information that personally identifies you to display interest-based ads.
  • Fraud Prevention and Credit Risks. We use personal information to prevent and detect fraud and abuse to protect security. We may also use scoring methods to assess and manage credit risks.

Our use of Cookies and Other Identifiers

To enable our systems to recognize your browser or device and to provide and improve 360 World Services, we use cookies and other identifiers. We use cookies, pixels, and other technologies (collectively, "cookies") to recognize your browser or device, learn more about your interests, and provide you with essential features and services and for additional purposes, including:

  • Recognizing you when you sign-in to use our services. This allows us to recognize you as a validated, signed-in 360 World user, provide you with product recommendations, display personalized content, and provide other customized features and services.
  • Keeping track of your specified preferences. This allows us to honor your preferences, such as whether or not you would like to see interest-based ads. You may set your preferences through your account.
  • Keeping track of pending and fulfilled services requests.
  • Conducting research and diagnostics to improve 360 World's content, products, and services.
  • Preventing fraudulent activity.
  • Improving security.
  • Delivering content, including ads, relevant to your interests on 360 World sites and third-party sites.
  • Reporting. This allows us to measure and analyze the performance of our services.

Approved third parties may also set cookies when you interact with 360 World services. Third parties include search engines, providers of measurement and analytics services, social media networks, and advertising companies. Third parties use cookies in the process of delivering content, including ads relevant to your interests, to measure the effectiveness of their ads, and to perform services on behalf of 360 World.

Does 360 World Share Your Personal Information?

Information about our users is an important part of our business and we are not in the business of selling our customers' personal information to others. We share customers' personal information only as described below and with 360 World, Inc. and subsidiaries that 360 World, Inc. controls that either are subject to this Privacy Policy or follow practices at least as protective as those described in this Privacy Policy.

  • Transactions involving Third Parties: We make available to you services, products, applications, or skills provided by third parties for use on or through 360 World Services. For example, the services you engage through our marketplace are from third parties, and you can enable third-party skills through 360 World services. We may also offer services or sell product lines jointly with third-party businesses, such as credit providers or providers of professional services.
  • Third-Party Service Providers: We may employ other companies and individuals to perform functions on our behalf. Examples include sending e-mail, removing repetitive information from customer lists, analyzing data, providing marketing assistance, providing search results and links (including paid listings and links), processing payments, transmitting content, scoring, assessing and managing credit risk, and providing customer service. Such third-party service providers have access to personal information needed to perform their functions, but may not use it for other purposes. Further, they must process the personal information in accordance with applicable law.
  • Business Transfers: As we continue to develop our business, we might sell or buy other businesses or services. In such transactions, customer information generally is one of the transferred business assets but remains subject to the promises made in any pre-existing Privacy Policy (unless, of course, the customer consents otherwise). Also, in the event that 360 World, Inc. or any of its affiliates, or substantially all of their assets, are acquired, customer information will of course be one of the transferred assets.
  • Protection of 360 World and Others: We release account and other personal information when we believe release is appropriate to comply with the law; enforce or apply our Terms of Use and other agreements; or protect the rights, property, or safety of 360 World, our users, or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction.

Other than as set out above, you will receive notice when personal information about you might be shared with third parties, and you will have an opportunity to choose not to share the information.

How We Secure Information About You

We design our systems with your security and privacy in mind.

  • We work to protect the security of your personal information during transmission by using encryption protocols and software.
  • We follow industry-standard measures to secure personal and financial data when handling payment-related data.
  • We maintain physical, electronic, and procedural safeguards in connection with the collection, storage, processing, and disclosure of personal customer information.
  • Our security procedures mean that we may occasionally request proof of identity before we disclose personal information to you.
  • It is important for you to protect against unauthorized access to your 360 World account information, your password and to your computers, devices and applications. Be sure to sign off when finished using a shared computer or device.

Advertising in connection with our Services

Third-Party Advertisers and Links to Other Websites: 360 World Services may include third-party advertising and links to other websites and apps. Third-party advertising partners may collect information about you when you interact with their content, advertising, and services.

What Choices Do I Have?

If you have any questions as to how we collect and use your personal information, please contact our Grievance Officer by sending an email to contact@360world.com.

  • As described above, you can always choose not to provide certain information, but then you might not be able to take advantage of many of the 360 World Services or particular features of such services.
  • You can add or update certain information on pages such as your account profile. When you update information, we usually keep a copy of the prior version for our records
  • If you do not want to receive e-mail or other communications from us, please adjust your User Communication Preferences. If you don't want to receive in-app notifications from us, please adjust your notification settings in the app or device
  • The Help feature on most browsers and devices will tell you how to prevent your browser or device from accepting new cookies or other identifiers, how to have the browser notify you when you receive a new cookie or how to block cookies altogether. Because cookies and identifiers allow you to take advantage of some essential features of 360 World Services, we recommend that you leave them turned on. For instance, if you block or otherwise reject our cookies, you may not be able to use certain 360 World Services that require you to be signed in.

Are Children Allowed to Use 360 World Services?

360 World does not facilitate services for purchase or use by children. Individuals under the age of majority in their respective countries should not create 360 World Services user accounts or use the 360 World Services directly or indirectly under anyone else's 360 World Services user account.

Conditions of Use, Notices, and Revisions

If you choose to use 360 World Services, your use and any dispute over privacy is subject to this Privacy Policy and our Terms of Use , including limitations on damages, resolution of disputes, and application of the prevailing law in your country of residence. If you have any concern about privacy at 360 World, please contact us with a thorough description, and we will try to resolve it. Our business changes constantly, and our Privacy Policy will change also. You should check our policies frequently to see recent changes.

Unless stated otherwise, our current Privacy Policy applies to all information that we have about you and your account. We stand behind the promises we make, however, and will never materially change our policies and practices to make them less protective of customer information collected in the past without the consent of affected customers.

Jurisdiction-Specific Provisions.

India. In this Policy, “applicable law” includes the Digital Personal Data Protection Act (“DPDPA”). Further, the term “data controller” includes “data fiduciaries,” and the term “data subject” includes “data principal,” both as defined in the DPDPA.

In some cases, and as permitted under the DPDPA, we may rely on “legitimate use” as a legal basis. For example, we might do so when you voluntarily provide your personal data to us. Where we are required to obtain your explicit and informed consent, we will do so on a case by case basis. “Consent Managers” as defined under the DPDPA may submit a request to revoke or provide consent using the methods described in the Contact Us section below, or as set out in the following paragraph, or via other means made available by 360 World in the future. We may ask for proof of authorization and identity before processing such a request.

You have the right to contact 360 World to nominate another individual, who may, in the event of your death or incapacity, exercise your rights under this Privacy Policy and under the DPDPA and implementing regulations.

In certain cases, you may be asked to consent to the collection and processing of your Aadhaar number by 360 World Innovations India Private Ltd. and/or its third party verification partner(s). The purpose of this collection is to facilitate the identification verification process as required under applicable laws. Your provision of Aadhaar details is purely voluntary, and you may provide other identification documents as may be accepted by us from time to time. You will not be denied service merely for not submitting Aadhaar details.

If you have any questions or complaints regarding the processing of your Personal Data in India, or if you want to receive this Policy or communicate with us about privacy in one of India’s official languages, please contact our Grievance Officer.

Grievance Officer
Name: Manojkumar Pawar
Designation: Grievance officer
e-mail: grievance-officer@360world.com
Address: Flt No-10 Shanti Hgt PLT, No. 9 10 Sr No 297/2, Pathardi, Nashik, Nashik- 422010, Maharashtra, India.

Alternatively, you may contact our DPO at dpo@360World.com. If we are unable to address your complaint or grievance, you have the right to escalate the matter to the Data Protection Board of India.

United States. If you are a consumer located in the United States (“US”), we process your personal information in accordance with US federal and state privacy laws. For additional details, please review the information below and see our additional U.S. Privacy Disclosures here. 360 World uses cookies, including advertising cookies, as described above concerning our use and management of cookies.

Your Rights and Choices. As a US consumer and subject to certain limitations under US privacy laws, you may have choices regarding our use and disclosure of your personal data. In addition to the above rights, you may also have the rights listed in this section. Please see our Privacy Center to learn more about data subject rights metrics and learn more about the laws under which these rights may apply.

  • Exercising the right to know: You have a right to request additional information about the categories of personal information collected, sold, disclosed, or shared; purposes for which this personal information was collected, sold, or shared; categories of sources of personal information; and categories of third parties with whom we disclosed or shared this personal information.
  • Exercising the right to opt-out from a sale or sharing: We do not transfer your personal data to third parties in exchange for payment. However, as noted above, we may provide the data to third party partners, such as advertising partners, analytics providers, and social networks, who assist us in advertising our products and services to you. Because these third parties may use the data 360 World provides for their own purposes, 360 World's provision of data to these parties may be considered a data “sale” or “sharing” (for behavioral advertising) as those terms are defined under the CCPA and other applicable US privacy laws. You can opt out of targeted advertising and any related data “sales” or “sharing” (for behavioral advertising) here.
  • Exercising the right to limit the use or sharing of Sensitive Personal Information: We do not sell or share (for behavioral advertising) Sensitive Personal Information as defined by US privacy laws and have not done so in the past 12 months. Learn more about our collection and use of Sensitive Personal Information over the last 12 months here.
  • Profiling with legal or similarly significant effects: In the event that we engage in profiling or automated decision making for which applicable law entitles you to an opt out we will provide you with notice of how to exercise that opt-out right.
  • Appeal: If you wish to appeal any of our decisions regarding a rights request under US privacy laws, you may do so by contacting 360 World’s Data Protection Officer (“DPO”) at dpo@360world.com
  • To submit a request to exercise any of the rights described above, please contact us using the methods described in the Contact Us section below. Please note that rights under some U.S. state laws do not apply to Personal Data we collect, process, and disclose when you act as a consumer to obtain financial products or services from 360 World for personal, family, or household purposes. See our US Consumer Privacy Notice below for more information.
  • We will verify your request by asking you to send it from the email address associated with your account or requiring you to provide information necessary to verify your identity, including name, address, transaction history, photo identification, and other information associated with your account.
  • You may designate, in writing or through a power of attorney, an authorized agent to make requests on your behalf to exercise your rights under the CCPA and other applicable US privacy laws. Your agent may submit a request on your behalf by contacting us using the methods described in the Contact Us section below. We may still require you to directly verify your identity and confirm that you gave the authorized agent permission to submit the request.

US Consumer Privacy Notice

The following Consumer Privacy Notice applies to you if you are an individual who resides in the United States and utilizes the financial transaction services supported by 360 World primarily for your own personal, family, or household purposes.

FACTSWHAT DOES 360 WORLD DO WITH YOUR PERSONAL INFORMATION?
Why?Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.
What?

The types of personal information we collect and share depend on the product or service you have with us. This information can include:

  • Social Security Number
  • Contact details
  • Account balances and transaction history
  • Credit history
  • Payment, transaction, and purchase information and history

When you are no longer our customer, we may continue to share your information as described in this notice.

How?All companies supporting financial transaction services need to share customers' personal information to run their everyday business. In the section below, we list the reasons companies supporting financial transaction services can share their customers' personal information; the reasons 360 World chooses to share; and whether you can limit this sharing.
Reasons we can share your personal informationDoes 360 World Share?Can you limit this sharing?
For our everyday business purposes - such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureausYesNo
For our marketing purposes - to offer our products and Services to youYesNo
For joint marketing with other financial services companiesYesNo
For our affiliates' everyday business purposes - information about your transactions and experiencesYesNo
For our affiliates' everyday business purposes - information about your creditworthinessNoWe don't share
For our affiliates to market to youNoWe don't share
For nonaffiliates to market to you (for data not collected through Financial Connections)YesYes
For nonaffiliates to market to you (for data collected through Financial Connections)NoWe don't share
To Limit our Sharing

Login to your 360 World account in the app and toggle off data sharing from the "Legal" menu in the profile section.

Please note: If you are a new customer, we can begin sharing your information 30 days from the date we sent this notice. When you are no longer our customer, we continue to share your information as described in this notice.

However, you can contact us at any time to limit our sharing.

What we do
How does 360 World protect my personal information?To protect your personal information from unauthorized access, destruction, loss, alteration, or misuse we use security measures to comply with federal law. These measures include computer safeguards and secured files and buildings. We impose access controls along with ongoing monitoring to prevent data misuse, and we require our service providers to take similar steps to protect your information.
How does 360 World collect my personal information?

We collect your personal information, for example, when you

  • open a Link account;
  • ask 360 World to process a payment for goods or services;
  • provide bank account information to 360 World using Financial Connections

We also collect your personal information from others, such as affiliates or other companies.

Why can't I limit all sharing?

Federal law gives you the right to limit only

  • sharing for affiliates' everyday business purposes — information about your creditworthiness
  • affiliates from using your information to market to you
  • sharing for nonaffiliates to market to you.

State laws and individual companies may give you additional rights to limit sharing. See the Other Important Information section below for more information on your rights under state law.

Definitions
Affiliates

Companies related by common ownership or control. They can be financial and nonfinancial companies.

• Our affiliates include companies operating under the 360 World name, such as 360 World Innovations India Private Ltd.

Nonaffiliates

Companies not related by common ownership or control. They can be financial and nonfinancial companies.

• Nonaffiliates with which we share personal information include service providers that perform services or functions on our behalf, Business Users with which you choose to transact, partners with which we share data to provide you with services, and advertising partners, analytics providers, and social networks, who assist us in advertising our Services to you.

Joint Marketing

A formal agreement between non-affiliated financial companies that together market financial products or services to you.

• Our joint marketing partners include financial companies we partner with to provide you with financial services.

Other Important Information

Vermont: If your account with us is associated with a Vermont billing address, we will not disclose information about your creditworthiness to our affiliates and will not disclose your personal information, financial information, credit report, or health information to nonaffiliated third parties to market to you, other than as permitted by Vermont law, unless you authorize us to make those disclosures. For joint marketing, we will only disclose your name, contact information, and information about your transactions. Additional information concerning our privacy policies can be found in our Privacy Policy and Privacy Center.

California: If your account with us is associated with a California billing address, we will not disclose Personal Data we collect about you except to the extent permitted under California law. For instance, we may disclose your Personal Data as necessary to process transactions or provide products and services you request, at your instruction, as required for institution risk control, and to safeguard against fraud, identity theft, and unauthorized transactions.