Privacy Policy

1.1 This Privacy Policy ("Privacy Policy") is an electronic record in accordance with the provisions of the Information Technology Act, 2000, the rules framed thereunder, the Digital Personal Data Protection Act, 2023, and other applicable laws in force in India. This electronic record is generated by a computer system and does not require any physical or digital signatures.

1.2 The mobile application, website, software platform, APIs, and related services operating under the name TradeBooks (collectively referred to as the "Platform") are owned, operated, managed, and maintained by CropWings Technologies Private Limited, a company incorporated under the provisions of the Companies Act, 2013 and having its registered office at Ten Madhapur, 4A Road, HUDA Techno Enclave, HITEC City, Hyderabad, Telangana 500081, India (hereinafter referred to as the "Company").

For the purpose of this Privacy Policy, CropWings Technologies Private Limited, including its affiliates, subsidiaries, successors, permitted assigns, directors, officers, employees, representatives, and service providers, shall wherever the context so requires be referred to as "TradeBooks", "Company", "We", "Us", or "Our".

The terms "You", "Your", "User", "Customer", "Trader", "Buyer", "Seller", "Institutional Buyer", "Broker", "Agent", "Business Entity", or any person accessing, registering, interacting with, or using the Platform shall collectively refer to the individual, partnership, company, proprietorship, organization, institution, association, or legal entity using the Platform.

1.3 TradeBooks is a technology-enabled digital trade management and ledger platform designed to facilitate the recording, maintenance, organization, synchronization, tracking, reconciliation, and management of trade transactions, commercial records, trade histories, settlement information, due-date tracking, ledger management, business communications, and related activities between traders, buyers, sellers, institutional buyers, brokers, and other commercial entities.

1.4 At TradeBooks, We recognize the importance of privacy, confidentiality, and information security. We are committed to protecting the information entrusted to Us by Users and to processing such information in a lawful, transparent, fair, secure, and responsible manner.

1.5 This Privacy Policy explains how We collect, receive, access, use, process, store, maintain, organize, disclose, transfer, retain, protect, and otherwise handle information provided by Users or collected through the Platform.

1.6 By accessing, browsing, registering on, downloading, installing, or using the Platform, You acknowledge that You have read, understood, and agreed to the collection, use, storage, disclosure, transfer, retention, and processing of information as described in this Privacy Policy.

1.7 If You do not agree with any provision of this Privacy Policy, You should discontinue access to and use of the Platform immediately.

2.1 For the purpose of this Privacy Policy, unless the context otherwise requires:

Account

means a registered account created by a User on the Platform for accessing and utilizing the Services provided by TradeBooks.

Applicable Laws

means all laws, statutes, regulations, ordinances, notifications, rules, guidelines, directions, circulars, governmental orders, judicial decisions, and regulatory requirements applicable to the Platform, the Company, or the User.

Business Information

means information relating to a business entity, organization, trade activity, commercial operation, trade record, transaction, ledger, settlement, commercial arrangement, or other business-related data maintained through the Platform.

Counterparty

means any buyer, seller, trader, broker, commission agent, institutional buyer, supplier, distributor, processor, aggregator, logistics provider, transporter, or any other party associated with a trade transaction recorded on the Platform.

Personal Data

means any information relating to an identified or identifiable individual and shall include any information classified as personal information under applicable laws.

Services

means all products, services, functionalities, features, modules, software, APIs, websites, applications, and related offerings made available through TradeBooks.

Trade Record

means any trade-related information, transaction record, commercial entry, ledger entry, settlement record, due date, payment information, trade note, trade confirmation, commodity information, quantity information, pricing information, or other information maintained through the Platform.

3.1 This Privacy Policy applies to all Users accessing or using the Platform, including individual traders, buyers, sellers, Farmers, brokers, institutional buyers, commission agents, business representatives, organizations, partnerships, proprietorships, private limited companies, public limited companies, cooperatives, associations, and other legal entities.

3.2 This Privacy Policy governs information collected through:

• Mobile Applications
• Websites
• Web Portals
• APIs
• Software Platforms
• Customer Support Channels
• Communication Channels
• Third-Party Integrations
• Electronic Communications

3.3 This Privacy Policy applies regardless of the device, location, operating system, browser, network, or technology used to access the Platform.

3.4 This Privacy Policy shall apply to all information collected by TradeBooks in connection with the provision of Services and shall continue to apply for so long as such information remains under the possession, custody, or control of the Company.

4.1 Information Provided by Users

When You create an Account, use the Platform, communicate with Us, upload information, record trades, create ledgers, or otherwise interact with the Services, We may collect information including:

• Full Name
• Mobile Number
• Email Address
• Username
• Password
• Profile Photograph
• Business Name
• Trade Name
• Business Address
• Registered Address
• Designation
• GST Number
• PAN Number
• Tax Registration Information
• Company Registration Information
• Business Licenses
• Authorized Representative Details

4.2 Trade and Commercial Information

TradeBooks is designed to facilitate trade record management and commercial record keeping.

Accordingly, We may collect:

• Trade Entries
• Trade Records
• Trade Confirmations
• Trade Histories
• Commodity Details
• Product Information
• Quantity Information
• Quality Information
• Trade Rates
• Pricing Information
• Delivery Information
• Due Dates
• Settlement Information
• Outstanding Balances
• Buy-Back Information
• Payment Information
• Trade Notes
• Commercial Correspondence
• Ledger Information
• Party-Wise Transaction Records

4.3 Counterparty Information

Users may provide information relating to counterparties involved in trade transactions, including:

• Buyer Information
• Seller Information
• Broker Information
• Agent Information
• Supplier Information
• Distributor Information
• Institutional Buyer Information
• Customer Information
• Vendor Information
• Transporter Information

4.4 Documents Uploaded by Users

The Platform may permit Users to upload and manage documents including:

• Invoices
• Purchase Orders
• Agreements
• Contracts
• Trade Confirmations
• Delivery Challans
• Tax Documents
• Settlement Records
• Trade Statements
• Ledger Statements
• Business Correspondence

4.5 Device Information

When You access the Platform, We may automatically collect:

• Device Type
• Device Model
• Operating System
• Browser Information
• Device Identifiers
• Application Version
• Network Information
• IP Address
• Mobile Carrier Information
• Device Language Settings

4.6 Usage Information

We may collect information relating to Platform usage, including:

• Login Activity
• Session Activity
• Feature Usage
• Search Activity
• Clickstream Data
• Navigation Information
• Access Logs
• Error Logs
• Crash Reports
• System Events

4.7 Device Permissions and Access

TradeBooks may request access to certain device features and permissions in order to provide Platform functionality and improve user experience.

(a) Contact Access

We may request access to Your device contacts to:

• Allow You to invite traders, buyers, sellers, brokers, commission agents, transporters, and other business contacts to the Platform.
• Enable faster selection of counterparties while creating trade records or ledgers.
• Facilitate business networking and trade-related communications.

TradeBooks only accesses contacts with Your permission and does not upload or store contact information unless specifically required for a Platform feature initiated by You.

(b) Camera Access

We may request access to Your device camera to:

• Capture profile photographs.
• Scan invoices, bills, receipts, purchase orders, delivery challans, and other business documents.
• Upload trade-related images and supporting documents.
• Enable document verification and record management features.

(c) Microphone Access

We may request access to Your device microphone to:

• Enable voice notes and voice-based trade record creation.
• Support voice search and voice-enabled features.
• Facilitate customer support interactions where applicable.

Audio recordings are only captured when You actively use such features.

(d) Location Information

We may request access to Your device location information, including precise or approximate location, to:

• Display nearby traders, buyers, sellers, commission agents, warehouses, logistics providers, and other business entities.
• Improve trade discovery and marketplace functionality.
• Detect fraudulent activities and secure user accounts.
• Provide location-based services and recommendations.

Location access can be managed through Your device settings.

(e) Permission Controls

You may grant, deny, revoke, or modify permissions at any time through Your device settings. However, certain Platform features may not function properly if the required permissions are denied or withdrawn.

4.8 Subscription and Payment Information

Where Users purchase a paid subscription plan or in-app feature, We may collect and process information relating to such transactions, including:

• Subscription Plan Selected
• Subscription Amount and Billing Frequency
• Transaction ID and Payment Reference Number
• Payment Status (Successful, Failed, Refunded)
• Subscription Start Date, Renewal Date, and Expiry Date
• Invoice and Billing History

All payments for subscriptions made through the Platform are processed through authorized third-party payment processors and payment gateways. TradeBooks does not collect, store, or have access to full payment card numbers, CVV numbers, UPI PINs, net-banking credentials, or other sensitive payment credentials, as these are collected and processed directly and exclusively by the respective payment processor in accordance with applicable payment industry security standards.

Information relating to subscription amount, billing frequency, and payment status received from the payment processor is used solely to activate, manage, renew, and provide Users with visibility into their subscription, and to maintain accurate billing and accounting records.

5.1 We may collect information directly from Users when:

• Creating an Account
• Updating a Profile
• Recording Trade Information
• Uploading Documents
• Creating Ledger Entries
• Communicating with Support
• Participating in Surveys
• Responding to Notifications
• Providing Feedback

5.2 We may automatically collect information through:

• Cookies
• SDKs
• Device Identifiers
• Analytics Tools
• System Logs
• Application Monitoring Tools
• Usage Tracking Technologies

5.3 We may receive information from third parties including:

• Service Providers
• Technology Partners
• Analytics Providers
• Verification Partners
• Business Partners
• Government Databases where permitted by law

6.1 Account Creation and Management

To create, authenticate, manage, maintain, support, administer, and secure User Accounts.

6.2 Trade Management Services

To facilitate creation, maintenance, synchronization, tracking, management, and reconciliation of trade records.

6.3 Ledger Management

To generate, maintain, organize, and manage party-wise ledgers, outstanding balances, trade histories, and settlement records.

6.4 Due Date Tracking

To generate reminders, alerts, notifications, and communications relating to trade obligations, due dates, settlements, and outstanding transactions.

6.5 Trade Verification and Record Maintenance

To maintain reliable digital records of trade transactions and related commercial activities for future reference and dispute management.

6.6 Customer Support

To provide technical assistance, support services, grievance handling, complaint resolution, and customer communication.

6.7 Security and Fraud Prevention

To detect, prevent, investigate, mitigate, and respond to:

• Fraud
• Cybersecurity Threats
• Unauthorized Access
• Abuse of Services
• Policy Violations
• Illegal Activities

6.8 Analytics and Platform Improvement

To improve Platform performance, enhance user experience, develop new features, conduct research, generate insights, and improve service quality.

6.9 Compliance with Legal Obligations

To comply with:

• Applicable Laws
• Regulatory Requirements
• Court Orders
• Government Directions
• Tax Obligations
• Audit Requirements
• Legal Proceedings

6.10 Subscription and Billing Management

To process subscription purchases, receive and record subscription amounts, manage billing cycles, generate invoices and receipts, track renewals and expirations, and communicate with Users regarding their subscription and payment status.

6.11 Device Permission Usage

• To facilitate contact discovery and invitations.
• To capture and upload business documents and images.
• To enable voice-based functionality.
• To provide location-based trade services and security features

7.1 By creating an Account, accessing the Platform, recording trade information, uploading documents, sharing information with counterparties, or otherwise using the Services, You expressly acknowledge and consent to the collection, storage, processing, use, disclosure, transfer, retention, and handling of information as described in this Privacy Policy.

7.2 You acknowledge that the information provided by You is necessary for the operation of the Platform and for enabling the Services offered through TradeBooks.

7.3 Where required under applicable law, TradeBooks shall obtain appropriate consent prior to processing Personal Data.

7.4 You may withdraw consent at any time by contacting the Company through the channels specified in this Privacy Policy. Withdrawal of consent shall not affect the lawfulness of processing undertaken before such withdrawal.

7.5 The Company may continue to process information where such processing is required for legal compliance, dispute resolution, fraud prevention, security purposes, contractual obligations, or other lawful grounds permitted under applicable laws.

8.1 TradeBooks is a technology platform designed to facilitate the recording, organization, synchronization, management, tracking, reconciliation, storage, retrieval, and maintenance of trade-related records and commercial information.

8.2 Users may create and maintain trade records containing trade terms, commodity details, quantity information, pricing information, settlement details, payment obligations, due dates, counterparty information, and other commercial records.

8.3 All trade records maintained on the Platform originate from information entered, uploaded, synchronized, or otherwise provided by Users.

8.4 TradeBooks does not independently verify, validate, audit, certify, endorse, or guarantee the accuracy, completeness, reliability, authenticity, legality, or enforceability of any trade record.

8.5 Users acknowledge that TradeBooks functions solely as a technology platform and does not act as a buyer, seller, broker, commission agent, financier, warehouse operator, logistics provider, payment intermediary, or contracting party to any transaction.

9.1 The Platform enables Users to record and maintain information relating to counterparties involved in trade transactions.

9.2 Such counterparties may include buyers, sellers, traders, brokers, commission agents, distributors, suppliers, processors, aggregators, institutional buyers, transporters, and other business entities.

9.3 Users represent and warrant that they have obtained all necessary permissions, authorizations, consents, notices, and legal rights required to provide information relating to counterparties through the Platform.

9.4 TradeBooks shall not be responsible for obtaining or verifying such permissions on behalf of Users.

10.1 Users shall ensure that all information submitted, uploaded, maintained, synchronized, shared, or otherwise made available through the Platform is accurate, complete, current, lawful, and not misleading.

10.2 Users shall not upload, store, transmit, or share information that:

• Violates applicable law;
• Infringes intellectual property rights;
• Violates privacy rights;
• Is fraudulent, misleading, or deceptive;
• Contains malicious software or harmful code.

10.3 Users shall be solely responsible for maintaining the confidentiality and security of their login credentials.

10.4 Users shall immediately notify TradeBooks of any suspected unauthorized access or security incident affecting their Account.

11.1 TradeBooks may disclose information to counterparties where necessary to facilitate trade synchronization, ledger maintenance, transaction tracking, settlement management, and related functionalities.

11.2 The Company may share information with service providers engaged to support the operation, maintenance, improvement, security, hosting, analytics, communication, and administration of the Platform.

11.3 Information may be disclosed to legal authorities, government agencies, regulators, courts, law enforcement authorities, and other competent bodies where required by law or where reasonably necessary to protect legal rights.

11.4 The Company may disclose information in connection with mergers, acquisitions, investments, restructuring transactions, asset sales, corporate reorganizations, financing activities, or transfers of business operations.

11.5 No Sale of Personal Data

TradeBooks does not sell, rent, or trade Personal Data to third parties for their own independent marketing or advertising purposes. Information is shared only in the limited circumstances described in this Section 11, or otherwise with the User’s consent

12.1 TradeBooks may engage third-party service providers, contractors, consultants, auditors, technology vendors, hosting providers, cloud infrastructure providers, analytics providers, communication providers, customer support providers, security providers, and business partners.

12.2 Such service providers shall be granted access to information only to the extent necessary to perform their respective services and shall be subject to appropriate confidentiality and security obligations.

13.1 TradeBooks may use cookies, software development kits (SDKs), pixels, tags, device identifiers, local storage technologies, web beacons, analytics tools, and similar technologies to collect information regarding the use of the Platform.

13.2 These technologies may be used for the following purposes:

• User authentication;
• Session management;
• Account security;
• Platform performance monitoring;
• Fraud prevention;
• Usage analytics;
• Personalization of user experience;
• Troubleshooting and debugging;
• Product improvement and feature enhancement.

13.3 The information collected through such technologies may include device identifiers, browser information, operating system details, usage patterns, session information, navigation behavior, and technical diagnostic information.

13.4 Users may manage certain cookie preferences through device or browser settings. However, disabling certain cookies or technologies may affect the availability or functionality of certain Platform features.

14.1 TradeBooks recognizes the importance of protecting information and implements reasonable administrative, technical, organizational, and physical safeguards designed to protect information from unauthorized access, disclosure, misuse, alteration, destruction, loss, or accidental disclosure.

14.2 Security measures implemented by Trade Books may include:

• Encryption of sensitive information where appropriate;
• Access control mechanisms;
• Multi-level authentication procedures;
• Role-based access restrictions;
• Secure infrastructure environments;
• Security monitoring systems;
• Network protection mechanisms;
• Audit logging systems;
• Backup and recovery procedures;
• Incident response processes.

14.3 Access to information is restricted to authorized personnel, contractors, and service providers who require such access for legitimate business purposes.

14.4 While Trade Books strives to implement industry-standard security practices, no method of electronic transmission, storage, or processing can be guaranteed to be completely secure. Accordingly, Trade Books cannot guarantee absolute security of information.

14.5 Users are responsible for maintaining the confidentiality of their login credentials and for securing devices used to access the Platform.

15.1 To ensure security, compliance, operational integrity, and dispute resolution, TradeBooks may maintain and process:

• Login records;
• Access logs;
• Device logs;
• Audit trails;
• Transaction logs;
• Activity histories;
• Error logs;
• Security logs;
• Administrative records.

15.2 Such information may be used for:

• Monitoring platform usage;
• Detecting suspicious activity;
• Investigating fraud;
• Resolving disputes;
• Conducting internal audits;
• Ensuring legal compliance;
• Maintaining system integrity.

15.3 TradeBooks reserves the right to review platform activities where reasonably necessary to protect users, investigate misconduct, prevent fraud, ensure compliance, or protect legal rights.

16.1 TradeBooks shall retain information for as long as necessary to fulfill the purposes described in this Privacy Policy, provide Services, maintain trade histories, preserve ledger records, comply with legal obligations, resolve disputes, enforce agreements, prevent fraud, and protect legal rights.

16.2 Trade records, transaction histories, ledger entries, settlement records, audit logs, and related commercial information may be retained for extended periods where required for business continuity, regulatory compliance, taxation, auditing, accounting, legal proceedings, or dispute resolution.

16.3 Following account closure or deletion requests, certain information may continue to be retained in archived systems, backups, disaster recovery environments, audit repositories, or legal compliance records for a reasonable period.

16.4 Where information is no longer required, TradeBooks may delete, anonymize, aggregate, archive, or otherwise de-identify such information in accordance with applicable laws and internal policies.

17.1 Subject to applicable laws, Users may have the right to:

• Access information relating to them;
• Request correction of inaccurate information;
• Update information maintained on the Platform;
• Request deletion of information;
• Withdraw consent where applicable;
• Seek information regarding processing activities;
• Lodge complaints or grievances;
• Exercise any additional rights available under applicable law.

17.2 TradeBooks may require verification of identity before acting upon requests relating to personal information.

17.3 TradeBooks may decline requests where permitted by law, including where such requests would adversely affect the rights of others, compromise security, violate legal obligations, or interfere with legitimate business interests.

17.4 Permission Withdrawal

Users may withdraw camera, microphone, contacts, or location permissions at any time through device settings. Withdrawal of such permissions may limit certain Platform functionalities.

18.1 Users may request deletion of their Account through available Platform mechanisms or by contacting TradeBooks.

18.2 Account deletion may result in the removal of access to trade records, transaction histories, notifications, ledger information, reports, and related Services.

18.3 TradeBooks may retain certain information notwithstanding account deletion where necessary to:

• Comply with legal obligations;
• Prevent fraud;
• Resolve disputes;
• Enforce agreements;
• Protect legal rights;
• Maintain audit records;
• Preserve business continuity.

18.4 Information retained following account deletion shall continue to be protected in accordance with this Privacy Policy.

19.1 TradeBooks may store, process, transfer, access, or maintain information in jurisdictions outside the User's state, region, or country through affiliates, service providers, cloud infrastructure providers, or business partners.

19.2 Where information is transferred across jurisdictions, TradeBooks shall take reasonable measures designed to ensure that such information receives an appropriate level of protection consistent with applicable laws.

19.3 By using the Platform, Users acknowledge and consent to such transfers where permitted by applicable law.

20.1 TradeBooks may send communications relating to:

• Product announcements;
• New features;
• Platform updates;
• Service enhancements;
• Educational content;
• Promotional campaigns;
• Business insights;
• Industry updates.

20.2 Users may opt out of receiving promotional communications by following the instructions provided in such communications or by contacting TradeBooks.

20.3 Notwithstanding such preferences, Users may continue to receive essential service-related communications necessary for the operation of their Accounts and the provision of Services.

21.1 TradeBooks is intended for commercial and business use and is not designed for or directed toward children.

21.2 TradeBooks does not knowingly collect Personal Data from children except where expressly permitted by applicable law.

21.3 If TradeBooks becomes aware that information relating to a child has been collected in violation of applicable laws, appropriate steps may be taken to remove such information.

22.1 Users acknowledge that trade records, pricing information, commercial arrangements, settlement information, contracts, invoices, purchase orders, counterparty details, transaction histories, ledger entries, and related business records maintained through the Platform may constitute confidential commercial information.

22.2 TradeBooks implements reasonable measures designed to safeguard such information from unauthorized access, disclosure, misuse, or alteration.

22.3 TradeBooks shall not be responsible for disclosure of confidential information resulting from:

• User actions;
• Counterparty disclosures;
• Third-party misconduct;
• User negligence;
• Unauthorized credential sharing;
• Security incidents beyond the reasonable control of the Company.

23.1 TradeBooks acts solely as a technology platform facilitating trade record management, ledger maintenance, trade synchronization, notification services, and related functionalities.

23.2 TradeBooks does not independently verify, validate, certify, audit, guarantee, endorse, or warrant:

• Trade records;
• Commercial terms;
• Trade conditions;
• Pricing information;
• Settlement details;
• Payment obligations;
• Counterparty information;
• Delivery information;
• Business documents.

23.3 Users remain solely responsible for all information submitted through the Platform and for all business, commercial, financial, legal, and operational decisions made based on such information.

23.4 To the maximum extent permitted by law, TradeBooks shall not be liable for indirect, incidental, consequential, special, exemplary, punitive, or economic losses arising from the use of the Platform.

24.1 In accordance with applicable laws, TradeBooks shall designate a Grievance Officer responsible for addressing complaints, concerns, requests, and grievances relating to privacy, information security, and data processing.

Name: Sai Vignesh Email: sai.vignesh@cropwings.com Address: Ten Madhapur, 4A Road, HUDA Techno Enclave, HITEC City, Hyderabad, Telangana 500081, India

24.2 Users may submit grievances through the contact information provided above.

For any questions, requests, complaints, concerns, or communications relating to this Privacy Policy or the processing of information, Users may contact:

CropWings Technologies Private Limited TradeBooks Platform

Email: sai.vignesh@cropwings.com Website: https://tradebooks.cloud Phone: 7997711557 Address: Ten Madhapur, 4A Road, HUDA Techno Enclave, HITEC City, Hyderabad, Telangana 500081, India

26.1 TradeBooks reserves the right to modify, amend, update, replace, or revise this Privacy Policy at any time in order to reflect changes in business practices, legal requirements, technological developments, operational requirements, or service offerings.

26.2 Updated versions of this Privacy Policy shall be published on the Platform and shall become effective from the date specified therein.

26.3 Continued access to or use of the Platform following publication of an updated Privacy Policy shall constitute acceptance of such revised Privacy Policy.