Ayna AI Private Limited (referred to as “we”, “us”, “our” or “Ayna”) is the author and publisher of the internet resource, , products, services, or otherwise connected software and applications provided, developed and created by Ayna (collectively, the “Site/Platform”). Ayna is a software as a service platform/provider involved in the business of providing customizable image or visual generative artificial intelligence services in the form of artificial product photoshoots and AI fashion model generation for organizations involved in the e-commerce industry, offered through a subscription service made available at (“Services”). This privacy policy (“Privacy Policy”) explains how we collect, use, share, and protect the Personal Data of the users of the Services (referred to as “you”, “your”, or “User(s)”).

Carefully go through this Privacy Policy to be read along with the Terms of Service (“User Terms”) as they apply to your use of (and including access to) Ayna’s Services and Site. These Privacy Policy and the Terms of Service together constitute a legally binding agreement (“Agreement”) between you and Ayna. These terms shall apply to and govern your visit to and use of the Site and any of its products or services, whether accessed through a computer or a mobile phone. This includes all information, recommendations, and services provided to you on or through the Site.

BY CONFIRMING THAT YOU ARE BOUND BY THIS PRIVACY POLICY (BY THE MEANS PROVIDED ON THIS SITE), BY USING THE SERVICES OR BY OTHERWISE GIVING US YOUR INFORMATION, YOU AGREE TO THE PRACTICES AND POLICIES OUTLINED IN THIS PRIVACY POLICY. YOU HEREBY CONSENT TO OUR COLLECTION, USE, AND SHARING OF YOUR INFORMATION AS DESCRIBED IN THIS PRIVACY POLICY. WE RESERVE THE RIGHT TO CHANGE, MODIFY, ADD OR DELETE PORTIONS OF THE TERMS OF THIS PRIVACY POLICY, AT OUR SOLE DISCRETION, AT ANY TIME. IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY AT ANY TIME, PLEASE REFRAIN FROM USING ANY OF OUR SERVICES OR PROVIDING US WITH YOUR PERSONAL INFORMATION. IF YOU USE THE SERVICES ON BEHALF OF SOMEONE ELSE (SUCH AS YOUR CHILD) OR AN ENTITY, YOU REPRESENT THAT YOU ARE AUTHORISED BY SUCH INDIVIDUAL OR ENTITY TO ACCEPT THIS PRIVACY POLICY ON SUCH INDIVIDUAL’S OR ENTITY’S BEHALF.

1. LEGAL PROVISION FOR A PRIVACY POLICY

This Privacy Policy is published in compliance with inter alia (i) Section 43A of the Information Technology Act, 2000; (ii) Rule 4 of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information) Rules, 2011 (the “SPDI Rules”); (iii) Rule 3(1) of the Information Technology

(Intermediaries Guidelines) Rules, 2011 (“IG Rules”), and other applicable rules and regulations as amended from time to time.

This Privacy Policy states the following:

i. The types and categories of information collected from the Users, including sensitive personal data or information;

ii. The purpose, means, and modes of usage and processing of such information; and; iii. How and to whom we will disclose such information;

2. INFORMATION WE COLLECT AND PROCESS ON BEHALF OF THE USER

The processing of your Personal Data takes place either on the basis of your consent to this Privacy Policy, or to the extent as the legal regulations allow such data processing even without such consent. We collect and store personal information relating to you (“Personal Data”) as follows:

Generally, some of the Services require us to know who you are so that we can best meet your needs. When you access the Services, we may ask you to voluntarily provide us with certain information that personally identifies you or could be used to personally identify you. Without prejudice to the generality of the above, information collected by us from you may include (but is not limited to) the following:

A. Personal Data:

i. Contact details (such as your email address and phone number);

ii. Demographic data (such as your gender, your date of birth, your address, and your pin code);

iii. Commercial data, including the record of your subscription transactions;

iv. Professional details, such as the name of your business or company;

v. Derived information from other personal data provided to us, potentially encompassing your preferences, interests, and other details used to tailor your experience;

vi. Credentials for accessing your account, such as username and password and vii. Information our servers automatically collect when you access the Site, such as your IP address, your browser type, your operating system, your access times, and the pages you have viewed directly before and after accessing the Site.

viii. The information collected from you by Ayna may constitute ‘personal information’ or ‘sensitive personal data or information’ under the SPDI Rules.

Personal information is defined under the SPDI Rules to mean any information that relates to a natural person, which, either directly or indirectly, in combination with other information available or likely to be available with a body corporate, is capable of identifying such a person.

ix. Information that is freely available in the public domain or accessible under the Right to Information Act, 2005, or any other law will not be regarded as personal information or sensitive personal data or information.

B. Usage Data:

We collect usage data when you interact or subscribe to our Services. Usage data includes metrics and information regarding your use and interaction with Services such as what product features you use the most, your usual browsing behaviour on the Site, when an object (like a ticket) is opened and closed, and how often certain features are triggered by your account, etc.

C. Device Information:

This includes the name of the device, operating system, device identifiers, and browser you are using. Information collected may depend on the type of device you use and its settings.

D. Third-Party Integrations:

You may connect to third-party integrations to your account, for the purpose of sign-in or otherwise, which may ask for certain permissions to access data or send information to your account. We may collect information about what types of integrations you use in your account. It is your responsibility to review permissions and information collected by any third-party integrations you authorize. Any permissions granted by you that grant any third parties’ access to your data, which may include but is not limited to granting third-party applications access to view, store, and modify your account data, under no circumstances and events, shall Ayna be responsible for the acts or consequences arising from any third-party integration. Usage of third-party integrations on Ayna’s Site are subject to and exclusively governed by the privacy policies of the respective provider. Ayna reserves the right to integrate additional third-party providers at its sole discretion to improve or modify the website's functionality.

3. USE OF THE COLLECTED INFORMATION

All the information provided to us by a User, including sensitive personal information, is voluntary. You understand that Ayna may use certain information of yours, which has been designated as ‘sensitive personal data or information under the SPDI Rules’ (a) for the purpose of providing you with Services, (b) for commercial purposes, and in an aggregated or non-personally identifiable form for research, statistical analysis and business intelligence purposes, for (c) for sale or transfer of such research, statistical or intelligence data in an aggregated or non-personally identifiable form.

We may use the collected Personal Data for the following purposes:

i. To provide, manage, maintain, develop, and analyse our products and Services or in connection with business transactions;

ii. To enhance and improve our AI and for other research purposes;

iii. To help Ayna tailor the website browsing experience;

iv. For promotional and marketing purposes;

v. For contacting Users to take product and service feedback;

vi. Analysing software usage patterns for improving product design and utility; vii. Analysing anonymized information for commercial use;

viii. To adhere to legal requirements, protect our rights and interests, and ensure the safety and privacy of our affiliates, you, or other parties.

Collection of information that has been designated as ‘sensitive personal data or information’ under the SPDI Rules requires your express consent. By affirming your assent to this Privacy Policy, you provide your consent to such collection as required under applicable law. Although you reserve the right to withdraw such consent at any time in accordance with the SDPI Rules, by agreeing to this Privacy Policy, you also acknowledge that Ayna’s Services may be unavailable to you in the event such consent is withdrawn.

4. DISCLOSURE OF PERSONAL DATA

In certain circumstances we may provide your Personal Data to third parties without any notice to you unless required by the law:

a. Vendors and Service Providers: To support our business operations and perform specific services, we may share Personal Data with vendors and service providers.

This includes entities that provide hosting, customer service, cloud services, email communication, web analytics, payment gateways and other IT services. Any Personal Data shared by Ayna with third parties is limited strictly to necessary information for performing designated functions by such third parties. However, Ayna shall not be liable for any breach, misuse, or unauthorized access of Personal Data by such third parties, as compliance with applicable data protection obligations remains solely with the respective third parties. By using Ayna’s Services, you acknowledge and agree to these terms regarding the disclosure of your Personal Data.

b. Business Transfers: In the event of strategic activities such as mergers, reorganizations, bankruptcies, or changes in service providers, your Personal Data may be disclosed during due diligence and may be transferred to a successor or affiliate as part of the transaction, along with other business assets.

5. PRIVACY STATEMENTS

a. A condition of each User’s use of and access to our Services is their acceptance of the Terms of Service, which also involves acceptance of the terms of this Privacy Policy.

Any User who does not agree with any provisions of the same has the option to discontinue the Services provided by Ayna immediately.

b. Users’ personally identifiable information, which you choose to provide on the Site is used to help the Users describe/identify themselves. Other information that does not personally identify the Users as an individual, is collected by Ayna from Users (such as patterns of utilization described above) and is exclusively owned by Ayna.

We may also use such information in an aggregated or non-personally identifiable form for research, statistical analysis and business intelligence purposes, and may sell or otherwise transfer such research, statistical or intelligence data in an aggregated or non-personally identifiable form to third parties. In particular, we reserve with us the right to use anonymized User demographics information and anonymized User information for the following purposes:

(i) Analysing software usage patterns for improving product/service design and utility.

(ii) Analysing such information for research and development of new technologies, products or services.

(iii) Using analysis of such information in other commercial product or service offerings of Ayna.

(iv) Sharing analysis of such information with third parties for commercial use.

c. You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information provided as part of account registration. If your Personal Data changes, you may correct, delete inaccuracies, or amend information by making the change on your profile information page on the Sites or by contacting us at support@getayna.com. We will make good faith efforts to make the requested changes in our then active databases as soon as reasonably practicable. If you provide any information that is untrue, inaccurate, out of date or incomplete (or becomes untrue, inaccurate, out of date or incomplete), or Ayna has reasonable grounds to suspect that the information provided by you is untrue, inaccurate, out of date or incomplete, Ayna may, at its sole discretion, discontinue the provision of the Services to you.

d. Ayna may periodically ask Users to complete surveys asking about their experiences with features of the Site and Services. Our surveys may ask visitors for demographic information such as age, gender, and education. We use survey information for evaluation and quality improvement purposes, including helping Ayna to improve the information and services offered. In addition, Users giving feedback may be individually contacted for follow-up due to concerns raised during the course of such evaluation. Demographic information and web log data may be stored for future evaluation and quality improvement activities.

e. While using the Site, with your permission, we will use the geo-location feature of your device or the same or similar features of the device you are using to access the Site. Ayna may share your location information with other third parties to provide Services. You may opt out of sharing information regarding your location by sending an email to , however, this may affect the Services and lead to the discontinuation of Services.

f. Ayna takes your right to privacy very seriously and other than as specifically stated in this Privacy Policy will only disclose your Personal Data in the event it is required to do so by law, rule, regulation, law enforcement agency, governmental official, legal authority or similar requirements or when Ayna, in its sole discretion, deems it necessary in order to protect its rights or the rights of others, to prevent harm to persons or property, to fight fraud and credit risk, or to enforce or apply the User Terms.

g. Ayna may also disclose or transfer User’s personal and other information a User provides, to a third party as part of reorganization or a sale of the assets of Ayna.

Any third party to which Ayna transfers or sells its assets will have the right to continue to use the personal and other information that Users provide to us, in accordance with the User Terms.

h. To the extent necessary to provide Users with the Services, Ayna may provide their Personal Data to third-party contractors who work on behalf of or with Ayna to provide Users with such Services, to help Ayna communicate with Users or to maintain the Site. Generally, these contractors do not have any independent right to share this information. However, certain contractors who provide services on the Site, including the providers of online communications services, will have the right to use and disclose the Personal Data collected in connection with the provision of these Services in accordance with their own privacy policies.

i. Ayna has implemented security policies, rules and technical measures to protect the Personal Data that it has under its control from unauthorized access, improper use or disclosure, unauthorized modification and unlawful destruction or accidental loss.

However, for any data loss or theft due to unauthorized access to the User’s electronic devices through which the User avails the Services, Ayna shall not be held liable for any loss whatsoever incurred by the User.

6. CONSENT ON REGISTRATION

In order to have access to all the features and benefits on our Site, a User must first create an account on our Site. To create an account, a User is required to provide certain information, which such User recognizes and expressly acknowledges is Personal Data allowing others, including Ayna, to identify the Username, User ID, email address, address(es), date of birth, gender, phone number and password chosen by the User. Other optional information may be requested on the registration page. We may, in the future, include other optional requests for information from the User to help us to customize the Services to deliver personalized information to the User. The consent shall be obtained from the User during the time of the registration process for the information provided. Users can give, manage, review, and withdraw his/her consent by writing to .

7. TRANSACTION DETAILS

Ayna may require the User to pay with a credit card, debit card, net banking, UPI, or other online payment mechanisms for Services for which an amount(s) is/are payable. User’s credit card/debit card details are transacted upon secure sites of the approved payment gateways used by Ayna, which are digitally under encryption, thereby providing the highest possible degree of care as per current technology. User is advised, however, that internet technology is not foolproof safe and User should exercise discretion on using the same. Ayna shall not, under any circumstances, be held liable for any data breaches, unauthorized access, or losses that may arise by third-party payment gateways.

8. THIRD-PARTY WEBSITES AND CONTENT

This Privacy Policy applies to the Site and Services that are owned and operated by Ayna. We do not exercise control over the sites that may be displayed as search results or links from within the Services. These other sites may place their own cookies or other files on the Users’ computer, collect data or solicit Personal Data from the Users, for which Ayna is not responsible or liable. Accordingly, Ayna does not make any representations concerning the privacy practices or policies of such third parties or terms of use of such websites, nor does Ayna guarantee the accuracy, integrity, or quality of the information, data, text, software, sound, photographs, graphics, videos, messages or other materials available on such websites. The inclusion or exclusion does not imply any endorsement by Ayna of the website, the website's provider, or the information on the website. If you decide to visit a third-party website linked to the Website, you do this entirely at your own risk. Ayna encourages the User to read the privacy policies of such websites.

9. WEB BROWSER COOKIES

We use cookies to enable you to make the best possible use of the Site. These cookies are small text files used to store information including your preferences, the pages on the Site that you accessed or visited and additionally may allow customizing website to your interests and displaying interest-based advertising on other websites. The information is used to optimize your browsing experience by customizing our Site content based on Users’ browser type and/or other information.

We may utilize any or all of the following type of cookies in the operation of the Site including (but not limited to): (i) Strictly Necessary Cookies (which are necessary for certain features of the Site and cannot be turned off without affecting its basic functionality); (ii) Performance Cookies (which allows us to count visits, traffic sources, and user behaviour to measure and improve the Site); (iii) Functional Cookies (which enables the Site to provide enhanced functionality and personalization); and (iv) Targeting Cookies (which may be set through our site by our advertising partners).

The Site may therefore use cookies to store certain data (that is not sensitive personal data or information) that is used by us for the technical administration of the Site, research and development, and User administration. While serving advertisements or optimizing services to its Users, we may also allow authorized third parties to place or recognize a unique cookie on the User’s browser. The cookies, however, do not store any Personal Data of the User.

10. USE OF INFORMATION ON CANCELLATION OF ACCOUNT

If you wish to cancel your account or request that we no longer use your information to provide you Services, contact us at and we will retain your information for as long as your account with the Services is active and as needed to provide you with the Services. We shall not retain such information for longer than is required for the purposes for which the information may lawfully be used or is otherwise required under any other law for the time being in force. After a period of time, your data may be anonymized and aggregated and then may be held by us as long as necessary for us to provide our Services effectively or improve the Services.

11. EXCLUSION OF LIABILITY

The Services may enable a User to communicate with other Users or to post information to be accessed by others, whereupon other Users may collect such data. Such Users, including any moderators or administrators, are not authorized Ayna representatives or agents, and their opinions or statements do not reflect those of Ayna, and they are not authorized to bind Ayna to any contract. Ayna hereby expressly disclaims any liability for any reliance or misuse of such information that is made available by the User or visitors in such a manner.

12. CONFIDENTIALITY AND SECURITY

Your Personal Data is maintained by Ayna in electronic form (inter alia using servers) on its or its employee's and partners’ equipment. Such information may also be converted to physical form from time to time. We take necessary precautions to protect your Personal Data both online and offline and implement reasonable security practices and measures that are commensurate with respect to the information being collected and the nature of Ayna’s business. Ayna makes all User information accessible to its employees only on a need-to-know basis.

Notwithstanding the above, Ayna is not responsible for the confidentiality, security or distribution of your Personal Data by third parties outside the scope of our Agreement with any third parties. Further, Ayna shall not be responsible for any breach of security or for any actions of any third parties or events that are beyond the control of Ayna including but not limited to, acts of government, computer hacking, unauthorized access to computer data and storage device, computer crashes, breach of security and encryption, poor quality of internet service or telephone service of the User etc.

13. CASUAL VISITORS NOTE

a. No sensitive personal data or information is automatically collected by Ayna from any casual visitors of this website, who are merely perusing the site.

b. Nevertheless, certain provisions of this Privacy Policy are applicable to even such casual visitors, and such casual visitors are also required to read and understand the privacy statements set out herein, failing which they are required to leave the Site immediately.

c. If you, as a casual visitor, have browsed any page of this Site prior to reading the privacy statements set out herein, and you do not agree with them, we encourage you to use the “clear cookies” functionality of your browsers to ensure clearing/deletion.

However, Ayna cannot guarantee, predict or provide for the behaviour of the equipment of all the visitors of the Site.

d. You are not a casual visitor if you have willingly submitted any personal data or information to Ayna through any means, including email, post or through the registration process on the Site. All such visitors will be deemed to be and will be treated as Users for the purposes of this Privacy Policy, in which case, all the statements in this Privacy Policy apply to such persons.

14. CHANGE TO PRIVACY POLICY

Ayna may update this Privacy Policy at any time. In the event, there are significant changes in the way Ayna treats the User’s personally identifiable information, or in the Privacy Policy itself, Ayna will display a notice on the Site, so that you may review the changed terms prior to continuing to use the Services. If you object to any of the changes to our terms, and you no longer wish to use the Services, you may contact us at support@getayna.com to deactivate your account. Unless stated otherwise, Ayna’s current Privacy Policy applies to all information that Ayna has about you and your account.

If a User uses the Services or accesses the Site or uses the Site after a notice of changes has been sent to such User or published on the Site, such User hereby provides his/her/its consent to the changed terms.

15. ACCESS AND ERASURE

We process and retain your Personal Data only for as long as it is necessary to fulfil the specific purpose for which it was collected and to provide the Services. Once the data is no longer required for such purposes, it shall be permanently deleted, except where statutory retention obligations require otherwise. You may request confirmation regarding whether your Personal Data is currently being processed by Ayna by submitting a written request to support@getayna.com. However, Ayna reserves the right to decline such requests where permitted by applicable law or in cases involving legal or regulatory obligations.

Nothing in this regard shall apply to any Personal Data shared, processed, or stored by third-party integrations utilized during the course of availing the Services. Such interactions shall be governed exclusively by the Privacy Policies of the respective third-party providers, and Ayna disclaims all liability arising from the same.

16. INTERNATIONAL USER

By using our Service, you understand and acknowledge that your Personal Data will be processed and stored in our facilities and servers in India and may be disclosed to our service providers and affiliates in other jurisdictions.

17. CHILDREN'S AND MINOR'S PRIVACY

Ayna strongly encourages parents to supervise the online activities of their minor children and consider using parental control tools available from online services and software manufacturers to help provide a child-friendly online environment. These tools also can prevent minors from disclosing their name, address, and other personally identifiable information online without parental permission. Although express provision has been made under the Terms of Service that the Ayna Site and Services are not intended for use by minors.

18. LEGAL REQUIREMENTS

We may share your Personal Data, including information about your interaction with our Services, with government authorities, industry peers, or other third parties (i) if required to do so by law or in the good faith belief that such action is necessary to comply with a legal obligation, (ii) to protect and defend our rights or property, (iii) if we determine, in our sole discretion, that there is a violation of our terms, policies, or the law; (iv) to detect or prevent fraud or other illegal activity; (v) to protect the safety, security, and integrity of our products, employees, or users, or the public, or (vi) to protect against legal liability.

19. CONSENT TO THIS POLICY

You acknowledge that this Privacy Policy is a part of the User Terms of the Site and the other Services, and you unconditionally agree that becoming a User of the Site and its Services signifies your assent to this Privacy Policy. Your visit to the Site and use of the Services is subject to this Privacy Policy and the User Terms.

20. ADDRESS FOR PRIVACY QUESTIONS

Should you have questions about this Privacy Policy or Ayna’s information collection, use, and disclosure practices, you may contact our Privacy Officer at

Name: Mr. Vignesh Nagarajan,

Email: vignesh@getayna.com, and

Phone No.: +91 99622 33577.

We will make reasonable efforts to respond promptly to any requests, questions, or concerns that you may have regarding our use of your Personal Data.

21. CONTACT INFORMATION OF THE GRIEVANCE OFFICER

If you have any grievance with respect to our use of your information, you may communicate such grievance to: grievance@getayna.com

Address: Alankar Plaza, No. 45, Subaraju Layout, BK Circle Kothnoordinne Main Road, JP Nagar VIII phase, Bangalore, Bangalore South, Karnataka, India, 560076,