PRIVACY POLICY

Effective Date: 29/08/2025

At Across Assist Private Limited (“Across Assist”, “AAPL”, “we”, “our”, or “us”), we respect your privacy and are committed to protecting the personal information you share with us. This Privacy Policy explains how we collect, use, store, share, and protect your information when you use our website, mobile applications, and other services (collectively, “Services”).

1. SCOPE OF THIS POLICY

a. This Policy applies to personal information collected or processed by AAPL in connection with:

i. customers and users of AAPL's products and services;

ii. individuals who contact or interact with AAPL's customer support, assistance centres or representatives;

iii. individuals whose information is provided to AAPL by its corporate clients, business partners, distributors or other authorised persons for the purpose of providing services;

iv. visitors to AAPL's websites and users of its applications and digital platforms; and

v. other individuals whose personal information is processed by AAPL in connection with its business operations.

b. Where AAPL processes personal information on behalf of a corporate client or business partner, such processing may also be governed by the terms of the relevant agreement between AAPL and that entity.

2. INFORMATION WE COLLECT

Depending upon the nature of the service or interaction, we may collect the following categories of information:

a. Personal and Contact Information: This may include your name, age or date of birth, gender, mobile number, email address, residential or correspondence address and other contact details as required for provision of service.

b. Service and Transaction Information: This may include information relating to products or services availed, membership or plan details, service requests, assistance requests, bookings, transactions, communications with us and other information necessary to administer and provide the relevant service.

c. Vehicle, Device, Asset and Technical Information: For relevant services, we may collect information such as vehicle registration number, make and model, vehicle location, device make and model, serial number, IMEI or other identifiers and information necessary to identify or service the relevant vehicle, device or asset. Where location or device permissions are required through an application or device, the relevant permissions may be controlled through the device or application settings, although disabling such permissions may affect the availability or functionality of certain services.

d. Location Data: Where required for providing, facilitating an assistance service, or for verification and security purposes, we may collect location information, including information provided by you or obtained through your device or application, such as GPS location or approximate location.

e. Payment Information: Where applicable, we may collect information relating to payments, billing, invoices, refunds and transactions. Payment information may be processed through authorised payment service providers and other third parties engaged for transaction processing.

f. Communication and Service Records: We may maintain records of communications with you, including telephone calls, emails, messages, service requests, complaints, feedback and other interactions with AAPL. Calls to our assistance or customer support centres may be recorded or monitored for quality, training, security and operational purposes, subject to applicable law.

g. Technical and Usage Data: When you use our websites, applications or digital platforms, we may collect information such as IP address, browser type, operating system, device information, application usage information, login credentials, access logs, preferences, feedback, interactions with our Services, and other technical information necessary for security, administration, analytics and improvement of our platforms.

h. Information Relating to Health or Emergencies: For certain medical, travel, emergency or assistance services, it may be necessary to collect information concerning an individual's health, medical condition, emergency circumstances or other information relevant to providing the requested assistance.

Clarification: AAPL does not knowingly collect or process personal information of children except where permitted by applicable law and where the relevant service requires such processing through a parent, guardian or other authorised person. Where applicable, we will take reasonable steps to comply with the additional requirements relating to children's personal information under applicable law.

3. HOW WE COLLECT INFORMATION

a. We may collect information:

i. directly from you when you register, purchase or use a service, submit a request, contact us or otherwise interact with AAPL;

ii. through our websites, applications, digital platforms and assistance systems;

iii. from our corporate clients, business partners, distributors, agents and other authorised third parties;

iv. from service providers engaged to provide assistance to you;

v. automatically through cookies, logs, device information and similar technologies; and

vi. from publicly available sources or other lawful sources, where permitted under applicable law.

b. We seek to collect only such information as is reasonably necessary for the relevant purpose.

4. PURPOSE OF COLLECTION & USE

We use your information for the following purposes –

a. to register, administer and provide products and services;

b. to verify identity, eligibility, membership or entitlement to services;

c. to receive, process and fulfil assistance or service requests;

d. to coordinate with service providers, hospitals, garages, technicians, travel providers, emergency responders and other relevant parties;

e. to communicate with customers and users regarding their services, requests, transactions, appointments, alerts and other operational matters;

f. to process payments, refunds, reconciliations and other financial transactions;

g. to provide customer support and resolve complaints or disputes;

h. to maintain records and comply with applicable legal, regulatory, contractual and reporting requirements;

i. to prevent, detect and investigate fraud, misuse, unauthorised access and other unlawful activities;

j. to protect the security and integrity of our systems, platforms and services;

k. to analyse and improve our products, services, systems and customer experience;

l. to conduct internal audits, quality assurance, training and operational monitoring;

m. to send information about products, services or offers where permitted by applicable law and subject to applicable consent or opt-out requirements; and

n. for any other purpose disclosed to you at the time of collection or otherwise permitted under applicable law.

5. SHARING AND DISCLOSURE OF INFORMATION

a. AAPL does not sell or commercially trade personal information.

b. We may, however, share personal information where reasonably necessary for providing our services, operating our business or complying with law, including with:

i. corporate clients, business partners and entities through whom the relevant service has been offered or made available;

ii. service providers and assistance partners, including third parties such as garages, technicians, hospitals, medical service providers, travel service providers, logistics providers, emergency responders or any other vendors / persons;

iii. payment processors, banks and financial service providers;

iv. technology, hosting, cloud, communication, analytics and customer-support service providers;

v. professional advisers, auditors, consultants and insurers;

vi. government authorities, regulators, law enforcement agencies or courts where required or permitted by law; and

vii. any other person or entity where such disclosure is necessary to provide the requested service, protect the rights or property of AAPL or others, prevent fraud or misuse, or comply with a legal obligation.

c. Third parties receiving personal information from AAPL are expected to process such information in accordance with applicable law and, where appropriate, contractual confidentiality and data protection obligations.

6. COOKIES AND SIMILAR TECHNOLOGIES

a. Our websites and applications may use cookies, pixels, tags, log files and similar technologies to operate the platform, remember preferences, understand usage, improve performance, maintain security and analyse traffic and where required, we will seek the permissions or provide the choices required under applicable law.

b. You may manage or disable cookies through your browser or device settings. Certain features of our websites or applications may not function properly if some of the choices are not selected by you or when cookies are disabled.

7. DATA SECURITY

a. We take reasonable technical, organisational and administrative measures to protect your data against unauthorised access, loss, misuse, disclosure, destruction or alteration.

b. These measures may include access controls, authentication mechanisms, role-based access, secure data transmission, monitoring, logging, backups, storage in encrypted formats with industry-standard security practices, and other safeguards appropriate to the nature of the information and the risks involved.

c. Access to personal information within AAPL is restricted to persons who require such access for legitimate business or service purposes.

8. DATA RETENTION

Data is retained only for as long as reasonably necessary for the purposes for which it was collected, including providing Services, maintaining business and transaction records, resolving disputes, preventing fraud and complying with applicable legal, regulatory, contractual or accounting requirements. The applicable retention period may therefore vary depending upon the nature of the information and the purpose for which it is processed. When personal information is no longer required, AAPL will take reasonable steps to delete, anonymise or otherwise dispose of it in accordance with applicable law and its internal retention practices.

9. USER RIGHTS

a. Subject to applicable law, individuals may have rights in relation to their personal information, including the right to:

i. obtain information regarding the processing of their personal information;

ii. request correction or updating of inaccurate or incomplete information;

iii. withdraw consent where processing is based on consent;

iv. request deletion of personal information where permitted by law; and

v. raise a grievance concerning the processing of personal information.

b. Requests may be submitted using the contact details provided in this Policy. AAPL may require reasonable information to verify the identity of the person making the request before acting upon it. Withdrawal of consent or deletion of information may affect AAPL's ability to provide certain products or services where the relevant information is necessary for such services.

10. THIRD-PARTY WEBSITES AND SERVICES

a. Due to the nature of services, our websites, applications or communications may contain links to websites, applications or services operated by third parties.

b. AAPL is not responsible for the privacy practices, security or content of such third parties. Users are advised to review the applicable privacy policies before providing personal information to them.

11. UPDATES AND CHANGES TO PRIVACY POLICY

a. We may amend or update this Privacy Policy from time to time to reflect changes in our services, technology, business practices or legal requirements.

b. The updated Policy will be published on our website and mobile application. The “Last Updated” date at the beginning of this Policy indicates when the Policy was most recently revised.

c. Where required by applicable law, AAPL will provide additional notice or obtain consent in respect of material changes.

12. GOVERNING LAW AND ITS COMPLIANCE

a. This Privacy Policy shall be governed by and construed in accordance with the laws of India, including applicable data protection and privacy laws and regulations.

b. Across Assist complies with the Information Technology Act, 2000 and relevant Rules under the Act of 2000.

c. “Sensitive Personal Data or Information” (SPDI) includes financial data, health-related data, biometric details, and other sensitive records as may be provided under Aadhaar (Targeted Delivery of Financial and Other Subsidies, Benefits and Services) Act, 2016 or any other law. Such data will be collected and processed only with your consent.

d. Users may withdraw consent at any time, though this may limit access to certain Services.

13. GRIEVANCE REDRESSAL

In accordance with the IT Act, 2000 and SPDI Rules, 2011, the following officer has been designated as the Grievance Officer:

Grievance Officer

Across Assist Private Limited

1st Floor, Plot No. 91, Sector-44, Gurugram, Haryana-122003

Email: contact@acrossassist.com

Phone: +91-120-4501-400

By using or signing up on AAPL's websites, applications or services, or otherwise providing personal information to AAPL, you acknowledge that you have read and understood this Privacy Policy and, where required under applicable law, provide consent to the processing of your personal information in accordance with this Policy.