Ultimaa Resources Private Limited, a private limited company incorporated under the

provisions of the Companies Act, 2013 having its registered address at 201, Kanta

Apartment, 181, East Avenue Road, Near Anand Bhuvan, Santacruz (West), Mumbai-

400054 (“Us”, “We”, or “Our”) operates the website i.e. www.changewealth.in (“Website”).

By accessing or using the Website, the user (“You” or “Your”) expressly acknowledges and

agrees to be bound by this Privacy Policy (“Privacy Policy”), which governs the manner in

which We collect, receive, store, process, disclose, transfer, and otherwise handle Your

personal data and other information. The Terms & Conditions governing the use of the

Website available at [Insert the link for the Terms & Conditions] are incorporated by

reference into this Privacy Policy and should be read in conjunction with this Privacy Policy.

Please read this Privacy Policy carefully before accessing or using the Website.

This Privacy Policy sets forth the procedures adopted by Us, including Our affiliates, in

relation to the handling of personal and non-personal information. However, it does not apply

to any data or information that You may share with, or that may be collected by, third parties

(other than Us or Our affiliates) through the Website. This includes any third-party websites

or services that You may access or use in connection with the use of the Website.

COLLECTION, USAGE & STORAGE OF INFORMATION:

When You use or access the Website, We collect certain personal information from You

(“Personal Information”, as defined below).

This Privacy Policy is applicable to the information that We collect from You for the purpose

of enabling and improving Your use and access to the Website:

a. Information You Voluntarily Provide: When You use or access the Website, You

voluntarily provide Us with personal information, which may include but is not limited

to:

• Your full name, email address and mobile number;

• If You are accessing the Website on behalf of a corporate entity, the name of the

corporate entity;

• Further, You will be asked to select from the below-options as to what describes

You the best: (i) Wealth Manager; (ii) Family Office (Principal or Staff); (iii)

Individual Investor; (iv) Institutional Investor; or (v) Other;

• Such other personal information as shall be requested from time to time.

(collectively referred to as the “Personal Information”).

We may additionally ask for certain non-personal information from You. All

information provided by You is deemed to be disclosed voluntarily and without

coercion. The Company shall not be liable for any misrepresentation, inaccuracies,

fraud, or omissions in the information provided by You.

b. Information We Collect Automatically: When You use or interact with the Website,

We automatically collect technical and usage data such as:

• Details of Your usage including pages visited, time spent on the Website, and

navigation patterns;

• Device-specific data like IP address, location data, device type, operating system,

browser version, crash reports, and system activity;

• Date and time of Your interactions with the Website and referral URLs.

This information helps Us to personalize Your experience and improve Website

performance. You may choose to disable location-tracking features on Your device;

however, this may restrict access to certain functionalities on the Website.

Use of Collected Information

We use the information collected from You to enhance and personalize Your experience on

the Website. This allows Us to tailor the Website’s content and features to better align with

Your preferences and needs.

In addition to Personal Information, while You browse, access, or use the Website, We may

collect certain non-personal information that does not directly identify You. This may

include, but is not limited to:

• Your device’s operating system;

• Internet Service Provider (ISP);

• Internet Protocol (IP) address;

• Browser type and version;

• Uniform Resource Locator (URL) of access;

• Software and hardware characteristics;

• Cookie data;

• Web requests;

• Pages accessed;

• Aggregate user behaviour and traffic patterns.

(collectively referred to as the “Non-Personal Information”).

This Non-Personal Information helps Us monitor usage trends, administer the Website more

efficiently, and improve user experience. It may also be used for analytics, system

diagnostics, or in the development of new features and functionalities.

Use of Personal and Non-Personal Information

We use the Personal Information and Non-Personal Information collected from You for the

following purposes:

a. To enhance and improve the performance of the Website;

b. To promote the safety, integrity, and security of the Website;

c. To communicate with You, including marketing communications, promotional offers,

services, and important updates;

d. To personalize Your experience on the Website by tailoring content to Your

preferences;

e. To enforce our Terms & Conditions and provide related information;

f. To troubleshoot issues, respond to Your queries, and resolve disputes;

g. To detect, prevent, and defend against errors, fraud, unauthorized activities, or any

other illegal or prohibited conduct;

h. To allow Our affiliates and partners to send You customized communication updates;

i. To notify You of significant changes to Our terms, policies, or features of the Website;

j. For analytics, promotions, project planning, and market research;

k. To invite You to participate in voluntary online surveys, for which We may request

contact and demographic information. We use this data to personalize the Website

experience for You;

l. To process and retain feedback or content You post on our message boards, chat rooms,

or communication sections to enhance user experience, customer support, and address

user concerns;

m. To handle correspondence, including communications from You or third parties related

to Your activity on the Website;

n. To collect and analyze technical data, including IP address, browser type, and usage

patterns, to diagnose server issues, manage the Website, and generate demographic

insights;

o. To conduct internal research on user behaviour, demographics, and interests to better

serve and understand Our users. This research is carried out in aggregated form,

without identifying You personally;

p. To utilize cookies: We use both temporary and permanent cookies to enhance Website

functionality and remember Your preferences. While You may browse the Website

without revealing Your identity, cookie-based features may be restricted if You choose

not to share Personal Information. When You first visit the Website, You will be

presented with a pop-up screen informing You of Our use of Cookies and asking You

to provide Your consent for such use. The pop-up screen may not reappear for all Your

subsequent visits to Our Website, but You may adjust Your web browser software if

You do not with to receive cookies or web beacons, but this may prevent You from

taking advantage of some of the features of Our Website.

We may collect and retain Your information for as long as necessary to fulfill the purposes

outlined above and as permitted by applicable law.

Third-Party Sharing & Consent

• We do not disclose Your Personal Information to other users or third parties unless You

specifically authorize us to do so or when required for Your use or access of the

Website.

• We may share Personal Information with trusted third parties only to comply with legal

obligations.

• You expressly consent to Our use, processing, storage, and sharing of Your information

(including Personal Information) with such third parties, only for the limited and

necessary purposes related to Your use of the Website.

Communication Preferences

• While You will have the option to opt out of receiving promotional emails, We may

still contact You for non-promotional purposes such as customer service, legal notices,

and updates related to the Website.

Disclosure and Sharing of Information

1. With Affiliates

We may share Your Personal and Non-Personal Information with Our affiliates in order

to enable Your use of the Website. This Privacy Policy shall apply to all such shared

information.

2. With Third Parties

Your Personal Information may also be shared with Our consultants and other third

parties. These parties are contractually obligated to:

a. Maintain the confidentiality of Your Personal Information;

b. Use the information solely under Our instructions and for legitimate business

purposes.

3. With Consent or as Required by Law

We will never disclose Your Personal Information to third parties for their independent

marketing or advertising purposes without Your express consent. However, we may

share Your information without notice or consent when:

• Required by applicable law or legal process;

• Necessary to protect Our rights, property, users, or others (e.g., enforcing the

Terms & Conditions);

• In the event of a merger, acquisition, reorganization, joint venture, asset sale, or

business transfer, subject to compliance with applicable data protection laws.

Data Security Measures

We are committed to safeguarding Your Personal and Non-Personal Information with the

highest level of security:

1. Encryption & Access Controls

• Your data is encrypted using bank-grade TLS encryption protocols;

• Website access is secured via Multi-Factor Authentication (MFA);

• All information is stored in a Company-controlled database, protected by

firewalls and password-protected servers, with limited access only to authorized

personnel.

2. Cloud-Based Services

We use secure cloud-based tools to perform various business functions, such as:

• Server and database hosting;

• Processing communications (calls, chats, messages, emails);

• Marketing analytics and CRM.

The security of the Server and database hosting is not handled by the Company, it is handled

by the Cloud Service Providers and hence the Company absolves itself of all the liabilities in

relation thereto. The role of the Company is limited to configure the security requirements.

Limitations of Security

While We use state-of-the-art security systems, no data transmission or storage method is

100% secure. Therefore:

• We cannot guarantee that Our security measures will prevent all unauthorized access,

breaches, or data interception during transmission over the Internet;

• Any data or content You post in public sections (e.g., forums or discussion boards) of

the Website is accessible by anyone with internet access.

We recommend that You take precautions in handling and disclosing Your Personal

Information and avoid transmitting sensitive data through unsecured channels.

DATA ACCESSED FROM GOOGLE

We will never rent or sell Your information or data to anyone. The Company ensures that it is

always in compliance with the restricted scope defined under Google OAuth API policies.

1. The Company limits use of data to providing or improving Your user experience.

Connecting Your Gmail account with the Website is completely optional and based on

Your explicit consent for only specific use cases as has been described in this Privacy

Policy. You can choose to de-link Your Gmail account with the Website at any time

and/ or You can delete Your information by writing to founders@changewealth.in.

Alternatively, You can remove access to the Company from Google Mail’s permission

settings located at: https://myaccount.google.com/permissions.

2. We only transfer the data to others if necessary to provide or improve user-facing

features that are prominent in the requesting application's user interface. We may also

transfer data as necessary to comply with applicable law or as part of a merger,

acquisition, or sale of assets with notice to users. All other transfers or sales of the user

data are prohibited.

3. We don't use or transfer the data for serving ads, including retargeting, personalized, or

interest-based advertising and We do not allow and We prohibit access to any of the

third-party analytics providers.

4. We don't allow humans to read the data, unless:

• We first obtain Your affirmative agreement for specific messages;

• It is necessary for security purposes (such as investigating a bug or abuse);

• It is necessary to comply with applicable law; or

• Our use is limited to internal operations and the data (including derivations) have

been aggregated and anonymized.

These prohibitions of use of data apply to the raw data obtained from Restricted Scopes and

data aggregated, anonymized, or derived from them. Our employees, agents, contractors, and

successors comply with the “Google API Services: User Data Policy”.

ACCESSING AND UPDATING PERSONAL INFORMATION

1. Access and Correction Requests:

When You use the Website (including any sub-sites), We make good faith efforts to

provide You with access to Your Personal Information upon request. Where feasible,

We will also correct or amend any Personal Information or sensitive personal

data/information that is found to be inaccurate or deficient, subject to:

• Legal or regulatory obligations requiring retention;

• Legitimate business purposes.

To process such requests, We may require You to:

• Verify Your identity;

• Clearly specify the information You wish to access, correct, or delete.

We reserve the right to decline requests that are:

• Repetitive or unreasonable;

• Require disproportionate technical effort;

• Jeopardize the privacy of others;

• Impractical (e.g., requests related to backup systems or archival data); or

• Not legally mandated.

When permitted, We provide this service free of charge, unless the effort required is

excessive.

2. Data Persistence and Deletion:

Due to system architecture and operational processes:

• Residual copies of Your Personal Information may remain in Our backup systems

for a period even after You delete or request deletion of data;

• Some records may continue to be stored despite withdrawal of contact consent.

3. Right to Update or Delete:

You are encouraged to regularly review, update, and correct the Personal Information

We hold. You may request the deletion of data that is:

• Inaccurate, incomplete, or irrelevant;

• Processed in violation of any applicable legal standards.

All such requests will be considered in accordance with Our data retention policies,

applicable laws, and statutory obligations.

4. Retention Obligations

• We will retain Your records in compliance with all applicable laws, including

data retention periods stipulated by regulatory bodies;

• If any legal or regulatory proceedings are pending, We may retain relevant data

for a longer duration as required.

5. Data Storage and Security

All information and records are stored in servers owned by Us or Our group companies,

located in India.

• Data may be stored in various forms including electronic, magnetic, or

documentary format.

THIRD-PARTY SITES AND COLLECTION OF INFORMATION

Our Website may contain links or direct You to other websites and digital Websites operated

by third parties (“Third-Party Sites”). These Third-Party Sites may collect and store certain

Personal Information about You, including but not limited to Your IP address, browser type,

and operating system.

Please note:

• We do not control the privacy practices, security standards, or content of these

Third-Party Sites, and shall not be held liable in any manner for any actions,

omissions, or data processing activities carried out by such sites;

• When accessing these Third-Party Sites, You may encounter “cookies” or similar

technologies. The use of such tools by third parties is outside Our control, and the

handling, storage, or usage of Your data on these Third-Party Sites is governed by

their respective privacy policies, not this Privacy Policy.

We strongly encourage You to carefully review the privacy policies of each Third-Party Site

You visit, to understand how Your Personal Information may be collected, stored, and

processed by them.

Additionally:

• Certain third-party advertising partners may display ads on Our Website. These

third-party advertisers may use non-personally identifiable information

(excluding Your name, address, email address, or phone number) about Your

visits to Our Website and other websites to show You advertisements for products

and services that may be of interest to You;

• You agree and acknowledge that We shall not be responsible for the publication,

accuracy, or legality of any material, content, or advertising found on such Third-

Party Sites.

SECURITY MEASURES:

In accordance with applicable laws, including the Information Technology Act, 2000 and the

Information Technology (Reasonable Security Practices and Procedures and Sensitive

Personal Data or Information) Rules, 2011, We have implemented appropriate physical,

electronic, and managerial safeguards to protect Your Personal Information from

unauthorized access, loss, misuse, disclosure, alteration, or destruction.

However, despite Our best efforts, no method of data transmission or storage is completely

secure. Therefore:

• We do not guarantee the absolute security of Your Personal or Non-Personal

Information;

• We cannot ensure or warrant that unauthorized third parties will never be able to

bypass Our security measures or those of Our third-party service providers.

You are also responsible for taking adequate steps to safeguard Your Personal Information.

While We strive to preserve Your privacy, We disclaim liability for any unauthorized

disclosures of information by third parties not under Our control.

Your Right to Access Personal Information

As per Regulation 5 of the Information Technology (Reasonable Security Practices and

Procedures and Sensitive Personal Data or Information) Rules, 2011, You have the right to

request a readable copy of the Personal Information that You have provided to Us. To

exercise this right, You may write to Us at: founders@changewealth.in.

CONSENT TO, WITHDRAWAL OF CONSENT TO AND MODIFICATION OF

THIS PRIVACY POLICY:

You agree to the terms of the Privacy Policy by accessing the Website.

Withdrawal of consent: You may decide to revoke the consent You have given in

accordance with this Privacy Policy. Written notice of this withdrawal of consent must be

given to : founders@changewealth.in

We ask that You refrain from using the Website in the event that You do not give Your

consent or subsequently withdraw it. In this case, We have the option of deleting Your

information (personal or otherwise) or de-identifying it so that it is anonymous and cannot be

traced back to You.

This Privacy Policy is published on the Website in compliance with Regulation 4 of the

(Indian) Information Technology (Reasonable Security Practices and Procedures and

Sensitive Personal Information) Rules, 2011, as amended, read with Rule 3(1) of the

provisions of Information Technology (Intermediary Guidelines and Digital Media Ethics

Code) Rules, 2021, as amended. We retain the unrestricted right to alter, amend, supplement,

or delete any part of this Privacy Policy at any time without directly informing You of such

modifications. Any upgrades or modifications shall be effective immediately and You shall

solely be responsible to check this Privacy Policy, on regular basis for updates. Your

acceptance of the amended Privacy Policy shall signify Your consent to such changes and

agreement to be legally bound by the same.

GRIEVANCE OFFICER:

If You have any grievance with respect to the Website or questions about the accuracy or

safety of Your Personal Information , please feel free to reach out to the grievance officer, the

name and contact details of this officer have been provided below:

Name: Mr. Param Agarwal

Email: founders@changewealth.in