Your privacy is important to us. Stakeinfra Technologies Inc. (“Company” or “we”) takes the privacy of your information seriously. This global privacy notice (“Notice”) is in addition to, and does not relieve, remove or replace, our rights and responsibilities under Applicable Data Protection Laws. In case of a conflict between a provision or requirement of Applicable Data Protection Laws and a provision of this Notice, the former shall take precedence.

This Notice will be applicable to the Company’s collection of all Personal Data in the course of its business, including through the Company’s website at https://www.staderlabs.com/ or its mobile or web-based applications, as applicable (together, “Website”), in accordance with the Applicable Data Protection Laws. Please read the Notice carefully before engaging with the Company or using our Website. 

References in this Notice to “you”, “your” or “User”, as applicable, are references to individuals whose Personal Data the Company collects and processes. This Notice governs all collection and processing of Personal Data done by us in the course of our business, and your engagement with the Company or use of the Website signifies your voluntary and express acceptance of this Notice. If you do not agree with all the terms of this Notice, please do not use the Website. 

A “controller” is a person or organisation who alone or jointly determines the purposes for which, and the manner in which, any Personal Data is, or is likely to be, processed (“Controller”). This Notice is issued on behalf of the Company as the Controller. Unless we notify you otherwise the Company is the controller for your Personal Data.

We collect, use, store and transfer different kinds of Personal Data about you. We have provided below detailed categories of Personal Data collected and used by us –

• Contact Information includes the e-mail address. 
• Background Check Information includes name, address, country and passport details. 
• KYC Information includes passport details, e-mail address, phone number, government issued identification details, taxpayer identification details and photograph.  
• Social Media Data includes name, username, phone number, e-mail address and any other information available on social media platforms.
• Transaction Data includes transaction information sourced through the blockchain such as details of the wallet address, amount of investment, earning, quantum of assets and tokens, retention information related to such assets to a limited extent.
• Technical Data includes technical information such as your internet protocol (IP) address and geo-location. It also includes details of the content viewed including the device data and browser data including number of times content is viewed, patterns of page visits, time details per visits etc. 

Where we need to collect Personal Data by law (for instance, in relation “Know-Your-Customer” checks and employee provident fund obligations) or under the terms of a contract we have with you and you fail to provide the Personal Data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In this case, we may have to decline to provide or receive the relevant services, but we will notify you if this is the case at the time the Personal Data is collected. 

We will only use your Personal Data for the purposes for which we collected it as detailed in the Section V, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to receive an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at privacy@staderlabs.com

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The Company does not allow Minors to use the Company’s Website or services and does not knowingly collect Personal Data from Minors. Please note that Users must be at least 18 years of age to use the Website. If you are a Minor, please immediately stop using the Website.

We will not use your Personal Data to send you marketing materials if you have requested not to receive them. If you request that we stop processing your Personal Data for marketing purposes, we will stop processing your Personal Data for those purposes.

We would encourage you to make such requests via the forms and links provided for that purpose in the marketing materials we send you or by contacting us at ‘ramashis.biswas@staderlabs.com’.

Recipients

We may share your Personal Data with third parties if we believe that sharing your Personal Data is in accordance with, or required by, any contractual relationship with you or us, applicable law, regulation or legal process. We may share Personal Data with the following persons or in the following circumstances:

• Legal Authorities: We will disclose information about you to legal authorities and courts to the extent we are obliged to do so according to the law. We may also need to share your information in order to enforce or apply our legal rights or to prevent fraud. 
• Analytics service providers: We engage third parties for analysing Personal Data for a variety of purposes such as building User profiles, providing relevant offers and advertisements and to aid our marketing activities. We may need to share your Personal Data with them to help us measure traffic and usage trends for the Website and to understand more about the demographics of our Users. 
• Third party service providers – We share Personal Data of Independent Contractors with service providers providing medical insurance cover and human resource management system for managing payroll. In addition, we may use certain cloud storage services provided by third parties for storing your Personal Data.

We require any person or entity to whom we disclose Personal Data pursuant to this Section IX to respect the confidentiality and security of your Personal Data and to treat it in accordance with Applicable Data Protection Laws. In respect of such Personal Data, we will seek to, as may be required under Applicable Data Protection Laws, contractually require the receiving parties of the Personal Data to ensure the same level of data protection adopted by the Company is adhered to by the receiving party, subject to Applicable Data Protection Laws. We do not allow such recipients of your Personal Data to use it for their own purposes, and we only permit them to process your Personal Data for specified purposes and in accordance with our instructions. 

Disclosure and transfer of Personal Data outside the European Economic Area (“EEA”) 

Whenever we transfer your Personal Data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented: 

• we will only transfer your Personal Data to countries that have been deemed to provide an adequate level of protection for Personal Data by the European Commission (in the case of transfers out of the EEA); and/or
• where we use certain service providers or Independent Contractors, we may use specific contracts approved by the European Commission (in the case of transfers out of the EEA), in both cases which give Personal Data the same protection it has within the EEA.

Please contact us at privacy@staderlabs.com, if you would like further information about the specific mechanism used by us when transferring your Personal Data out of the EEA and/or the United Kingdom. 

The Company retains your Personal Data for as long as necessary to provide the access to and use of the Website, to fulfil the purposes described above or for other essential purposes such as complying with our legal obligations, resolving disputes and enforcing our agreements. Because these needs can vary for different data types and purposes, actual retention periods will vary. Even if we delete your Personal Data, it may persist on backup or archival media for audit, legal, tax or regulatory purposes. 

We determine the appropriate retention period for Personal Data, basis the amount, nature and sensitivity of the data, the potential risk of harm from unauthorised access, the purposes for which we process your Personal Data. 

You have the following rights in relation to the Personal Data we hold about you:

• Right of access – You can acquire confirmation from the Company as to whether the Personal Data concerning you is being processed. You can also obtain access to the Personal Data along with information such as the purpose of processing, categories of Personal Data concerned, recipients or categories of recipients to whom Personal Data has been / will be disclosed, etc. We may charge a reasonable fee for any further copies requested by you. 
• Right to rectification – You have the right to request us to rectify any inaccurate Personal Data concerning you and the right to have incomplete Personal Data completed.
• Right to erasure / right to be forgotten – You have the right to request erasure of your Personal Data in certain situations, including when you withdraw consent for the processing of Personal Data). 
• The right to withdraw your consent – Where your Personal Data is being processed on the basis of your consent, you have the right to withdraw your consent at any time. The withdrawal of your consent does not affect the lawfulness of processing based on consent before its withdrawal.
• Right to restriction of processing – You can restrict processing of your Personal Data in certain scenarios, such as (a) where accuracy of the Personal Data is contested by you, (b) if processing of Personal Data is unlawful (c) you oppose erasure and request restriction instead or if the Personal Data is no longer required by us but you require the Personal Data to be retained to establish, exercise or defend a legal claim or if you object to our processing of your data based on our legitimate interests, or where the processing is based on Art. 6(1) (e) GDPR. 
• Right to data portability – In certain situations, you will have the right to receive the Personal Data concerning you provided to you, in a structured, commonly used and machine-readable format.
• Right to object – You have the right to object to the processing of your Personal Data at any time and we will not process your Personal Data unless we are able to demonstrate compelling legitimate grounds for the processing override your interests, rights and freedoms. In such a situation, we will also not process your Personal Data for direct marketing purposes.
• Right not to be subject to automated individual decision-making – To the extent that decisions regarding your Personal Data are made through solely automated decision-making, you have a right to object to the same. 
• Your right to lodge a complaint with the supervisory authority - If you have a concern about any aspect of our privacy practices, including the way we've handled your personal information, you can report it to the relevant Supervisory Authority.

You may exercise any of your rights at any time using the contact details set out in Section XV. You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. 

We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. 

We try to respond to all legitimate requests within [one calendar month] (or earlier in accordance with Applicable Data Protection Laws). Occasionally it may take us longer than [one calendar month] if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

We are committed to protecting the security of your Personal Data. We will use reasonable security practices, including reasonable technical and organisational measures, to safeguard your Personal Data required under Applicable Data Protection laws. Technical and organisational measures include measures to deal with any suspected data breach.

To ensure that your Personal Data receives an adequate level of protection, we have also taken reasonable steps to put in place appropriate safeguards and procedures in relation to the third parties we share your Personal Data with. 

Our Website may, from time to time, provide links to other websites. We have no control over such websites and are not responsible for the content of these websites, the use of these websites or the practices employed thereon. This Notice does not extend to your use of such websites. You are advised to read the notice or statement of other websites prior to using them.

We may make changes to this Notice from time to time. To ensure that you are always aware of how we use your Personal Data we will update this Notice from time to time to reflect any changes to our use of your Personal Data. We may also make changes as required to comply with changes in Applicable Data Protection Law or regulatory requirements. We encourage you to review this Notice periodically to be informed of how we use your Personal Data.

If you have any concerns or would like to make a complaint about our processing of your Personal Data, you may raise your concerns with us and the Supervisory Authority directly. However, we would encourage you to contact us in the first instance as we aim to promptly, efficiently and satisfactorily resolve any concerns or complaints you may have in relation to the Company’s processing of your Personal Data.

If you wish to exercise your rights, you can get in touch with us by contacting:

The Grievance Officer

Name – Ramshis Biswas 

Email - ramshis.biswas@staderlabs.com

Our Website uses Cookies to enable, optimise and analyse site operations, as well as to provide personalised content and allow you to connect to social media. 

Cookies are usually small text files that are stored on your computer's browser directory or program data subfolders when you visit our Website and stored on your computer for the duration of your visit or for when you re-visit our Website at a later time. Cookies allow our Website to access or store information from your browser about you, your settings or your device. They are mainly used to ensure the Website’s expected functionality. As a rule, Cookies do not contain any information that could identify you directly. They do, however, make it possible to offer you a more personalised web experience.  

We distinguish the following categories of Cookies and associated data processing:

• Strictly Necessary
• Functionality and performance
• Analytics
• Marketing
• Unclassified

With the following information, we want you to be in a position to make an informed decision for or against the use of Cookies and the associated data processing which are currently not strictly necessary for the website’s technical features, i.e. categories (2), (3), (4) and (5) listed above. You can adjust your Cookie and associated data processing preferences any time in our Cookie Preference Manager on the Website. 

Consent  
Necessary Cookies will always be active on your device, but we ask for your consent to place functional, analytics and advertising Cookies and other similar technologies on your device. If at any time you want to change your cookie settings, including withdrawing your consent to this processing, we would encourage you to visit the Cookie Preference Manager on the Website. You may need to refresh the page before the changes to the settings take effect. 
 

Strictly Necessary, Functional and Unclassified - Currently we do not collect any strictly necessary, functional, or unclassified Cookies on our Website. However, it is important to note that in the future, we may consider adding these types of Cookies for improved website functionality and analysis. If any changes are made regarding the collection and usage of Strictly Necessary, functional, or unclassified Cookies, we will update this Privacy Policy accordingly and provide you with the option to manage your Cookie preferences through our Cookie Preference Manager on the Website. We are committed to maintaining transparency and ensuring that you have the ability to make informed decisions about the use of Cookies on our Website.

Advertising - Advertising Cookies help us and other third parties to provide content which may be of interest to you based on your browsing history.

Analytics – Analytics Cookies help improve the usability and layout of the Website, for example, to help us design a layout and/or create pages which are useful to our visitors to the Website.

How to block all cookies and the consequences of this

If you want to block all Cookies, you may be able to do this through the settings in your browser for each browser you use and each device you use to access the internet. Please be aware that some areas of our Website may not work if your browser does not accept Cookies. 

Help and complaints

If you have any questions about this notice or the information, we hold about you please contact ramashis.biswas@staderlabs.com

Aadhaar Information – means the Aadhaar number which is a 12 digit individual identification number issued by the Unique Identification Authority of India on behalf of the Government of India. The number serves as a proof of identity and address, anywhere in India;

Applicable Data Protection Laws – means EU’s General Data Protection Regulation (“GDPR”) as amended or substituted from time to time, any applicable law in India relating to the processing of Personal Data, including the Information Technology Act, 2000 and the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 (“SPDI Rules”), and any other applicable laws relating to data privacy and information security. 

Company - has the meaning given in the Preamble.

Controller – The GDPR uses the term ‘controller’ to refer to a natural or legal person which, alone or jointly with others, determines the purposes and means of processing of PD (“Data Controller”). 

Cookies – The small text files that are stored on your computer's browser directory or program data subfolders when you visit our website and stored on your computer for the duration of your visit or for when you re-visit our Website at a later time. 

Cookie Preference Manager – A pop-up available on the Website to manage the website's process of collecting and storing your consent preferences.

EEA – has the meaning given in Section IX.

European Commission – means the executive arm of the European Union. 

Independent Contractors - Independent contractors are self-employed persons or entity contracted to perform work for or provide services to the Company.

Investors – means the investors in the Company.

Minor – means a User, who is a child or a minor (i.e., a natural person below the age of 18 years)

Node Operators – The three types of node operators associated with the Company are (i) permissioned (ii) oracle and (iii) permission less operators. Wallet service providers are one kind of Node Operators

Notice - has the meaning given in the Preamble

PAN - Permanent Account Number abbreviated as PAN is a unique 10-digit alphanumeric number issued by the Income Tax Department to Indian taxpayers.

Personal Data – Personal Data includes any information relating to an identified or identifiable natural person. It does not include data that cannot be linked to an individual (anonymous data).

Special Categories of Personal Data - Special Categories of Personal Data includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data.

Supervisory authority - Means an independent public authority which is established pursuant to Art. 51 GDPR.

User – or “you” means the natural person who accesses the Website.

Website - has the meaning given in the Preamble