Effective Date: 09-09-2026

This privacy policy document is a written agreement and an electronic record, valid and enforceable under the Information Technology Act, 2000 (as applicable in the Republic of India) and the rules made thereunder, including amended provisions pertaining to electronic records under applicable Indian statutes. This electronic record is generated by a computer system and does not require any physical or digital signature. Your use of the Solutions constitutes deemed acceptance of this Privacy Policy and any modifications or updates to it.

At Soliton Technologies Pvt. Ltd., we respect your privacy. This Policy, together with our Terms of Use (www.solitontech.com/terms-of-use) and our Cookie Policy (www.solitontech.com/cookie-policy), describes how we collect, use, share, and protect your Personal Information, and the choices available to you. IF YOU DO NOT AGREE, PLEASE DO NOT USE OR ACCESS THE SITE.

This Policy covers information Soliton Technologies Pvt. Ltd. ("Soliton," "we," "us," "our") collects from users of www.solitontech.com, whether or not registered with us, and applies to the "Services" as defined in our Terms of Use.

Definitions

“Controller” means the natural or legal person, public authority, agency, or other body which alone or jointly with others, determines the purposes and means of the processing of Personal Data.

“Customer” means the natural or legal person that has subscribed to the Service(s) by agreeing to the Terms of Service or entering into an agreement for subscription to the Service(s).

"Personal Data" means any information relating to an identified or identifiable natural person — one who can be identified, directly or indirectly, by reference to an identifier such as a name, identification number, location data, online identifier, or to one or more factors specific to their physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

"Processing" means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, including collection, recording, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, destruction or erasure.

"Users" or "You" means users of our Services, Solutions, and/or website(s).

“Processor” means a natural or legal person, public authority, agency, or other body which Processes Personal Data on behalf of the Controller.

“Service(s)” means Our cloud-based proprietary service which enables enterprises to track sales commission and other incentive compensation schemes and any new services that We may introduce as a Service to which You may subscribe to, and any updates, modifications or improvements thereto, including individually and collectively, the API and any Documentation.

“Terms of Service” means the binding contract between Us and You which governs the access and use of the Service(s) by You.

“Website(s)” means the websites that We operate.

How We Collect, Use And Share Your Personal Data

Personal Data that You provide Us

Personal Data That We Collect Not Provided Directly By You

If You provide Us with any Personal Data relating to other individuals, You represent that You have the authority to do so, and where required, have obtained the necessary consent, and acknowledge that it may be used in accordance with this Policy. If You believe that Your Personal Data has been provided to Us improperly, please contact Us by using the information in the Notice clause below.

In addition to the details provided in the table above, We may also share Your Personal Data with‍

·        an entity to which we divest all or a portion of Our business, or otherwise in connection with a merger, consolidation, change in control, reorganisation or liquidation of all or a portion of Our business.

·        law enforcement authorities, government authorities, courts, dispute resolution bodies, regulators, auditors, and any party appointed or requested by applicable regulators to carry out investigations or audits of Our activities.

·        professional advisors who advise and assist Us in enforcing Our contracts and policies, handling Our claims, effective management of Our company and in relation to any disputes We may become involved in.

We will not be sharing the mobile numbers of US mobile subscribers with any third parties for marketing/promotional purposes.

How We Use Cookies

Our Site uses cookies and similar technologies to operate correctly, understand how visitors use the Site, and — where you consent — support marketing and advertising activities. You can update or withdraw your cookie consent at any time using the "Cookie Settings" link in the Site footer.

Cookies are text files that are placed on Your computer to collect standard internet log information and visitor behaviour information by Us. When You visit the Website(s), We may collect Personal Data automatically from You through cookies or similar technology.

When You access Our Website: We also set cookies to collect information that is used either in aggregate form to help Us understand how our Website(s) are being used or how effective Our marketing campaigns are, to help customize the Website(s) for You or to make advertising messages more relevant to You.

When You access and/or use Our Services: We set cookies when You access Our Services to provide the features You have requested in the Services, for instance, remembering that You have logged in; make the Services more tailored to You; improve the functionality of the Services, or analyze which features of the Services that You interact with the most and how You engage with them;

Essential Cookies: We set essential cookies that enable core functionality such as security, network management, and accessibility. You may not opt out of these cookies. However, You may disable these by changing Your browser settings, but this may affect how the Website(s) functions.

Analytics, Customisation and Advertising Cookies: We set these cookies to help Us improve Our Website(s) and Services by collecting and reporting information on how You use them. Where You visit the Website, the cookies collect information in a way that does not directly identify anyone.

When You visit the Website or access the Platform, a cookie banner will be displayed providing additional information about cookies and options to opt out of non-essential cookies as required by applicable laws.

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How We Store Your Information

Your information is primarily stored electronically, though certain data may also be stored in physical form. We may store, process, and use your data in countries other than India, always in compliance with applicable law. Where we engage third parties to store or process your data, we require them to adopt reasonable security standards on a commercially reasonable basis.

We retain the Personal Data collected where an ongoing legitimate business requires retention of such Personal Data.

In the absence of a need to retain Personal Data under legitimate business purposes as mentioned above, We will either delete it or aggregate it, or, if this is not possible then We will securely store Your Personal Data and isolate it from any further Processing until deletion is possible.

How We Protect Your Information

We use industry-standard security measures, at minimum those mandated under the Information Technology Act, 2000 and the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, to safeguard your data. No transmission over the internet is completely secure, and any transmission to our Site is at your own risk. We retain Personal Information only as long as necessary to fulfil the purposes for which it was collected, or as required by law.

Soliton does not knowingly collect Personal Information from children under 18 without parental or guardian consent. If we learn we have done so, we will delete that information promptly.

Your Rights

You are entitled to the following rights:

(a)    You can request Us for access and correction of Your Personal Data.

(b)   If We have collected and processed Your Personal Data with Your consent, then You can withdraw Your consent at any time. Withdrawing Your consent will not affect the lawfulness of any processing We have conducted prior to Your withdrawal, nor will it affect processing of Your Personal Data conducted in reliance on lawful processing grounds other than consent.

(c)    You have the right to complain to a data protection authority about Our collection and use of Your Personal Data. For more information, please contact Your local data protection authority as specified by the applicable data protection laws.

(d)   You have the right to opt out of marketing communications We send You at any time. You can exercise this right by clicking on the “unsubscribe” or “opt out” link in the marketing e-mails We send You.

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(e)    If You are a resident of the EEA, UK, or Switzerland, You are also entitled to the following rights.

·        You can request Us for deletion and erasure of Your Personal Data.

·        You can object to the processing of Your Personal Data, ask Us to restrict the processing of Your Personal Data, or request portability of Your Personal Data.

(f)    If You are a resident of India, You are also entitled to the following rights:

·        You can request Us for deletion and erasure of Your Personal Data.

·        You can nominate any other individual, who shall, in the event of Your death or incapacity, be allowed to exercise Your rights as prescribed under the Digital Personal Data Protection Act, 2023.

·        You are entitled to provide, manage, review or withdraw Your consent through a consent manager.

·        You can contact Us at the details provided in the Notice clause below to register any grievance that You may have in respect of Our collection and use of Your Personal Data.

(g)   If You seek to exercise Your rights under this clause, please contact Us at the details provided in the Notice clause below. We will verify any requests before acting on the request and respond to all requests We receive from individuals wishing to exercise their data protection rights within a reasonable timeframe in accordance with applicable data protection laws.

Lawful Basis for Processing (GDPR)

Where GDPR applies, we process your Personal Information on the following legal bases: (i) your consent; (ii) performance of a contract with you; (iii) compliance with a legal obligation; and (iv) our legitimate interests in operating and improving our business, provided these are not overridden by your rights and interests.

‍EEA REGION

If You are a data subject from the European Economic Area, Our legal basis for collecting and using the Personal Data described above will depend on the Personal Data concerned and the specific context in which We collect it.

We will normally collect Personal Data from You only where it is needed to perform a contract with You, where the processing is in Our legitimate interests and not overridden by Your data protection interests or fundamental rights and freedoms, or where We have Your consent. In some cases, We may also have a legal obligation to collect Personal Data from You. If We process Personal Data with reliance on Your consent, You may withdraw Your consent at any time.

India

If You are a data principal from India, Our legal basis for collecting and using the Personal Data described above will depend on the Personal Data concerned and the specific context in which We collect it.

We will normally collect Personal Data from You only where We have Your consent, except in the scenarios described in ‘Personal Data that You provide Us’ table above, in which case we will rely on legitimate use for processing of such Personal Data. If We process Personal Data with reliance on Your consent, You may withdraw Your consent at any time.

If You have questions or need further information concerning the legal basis on which We collect and use Your Personal Data, please contact Us using the contact details provided under the Contact Information clause below.

‍International Transfer

We mainly Process Personal Data in the United States of America. However, We may transfer Personal Data outside the United States of America for the purposes referred to in table above. We will ensure that the recipient of Your Personal Data offers an adequate level of protection that is at least comparable to that which is provided under applicable data protection laws.

If You are a resident of the European Economic Area and when Your Personal Data is processed outside EEA, We will ensure that the recipient of Your Personal Data offers an adequate level of protection, for instance by entering into standard contractual clauses for the transfer of Personal Data as approved by the European Commission (Article 46 General Data Privacy Regulation, 2016), or We will ask You for Your prior consent to such international data transfers.

If You are a resident of India, and where We intend to process Your Personal Data outside India, We will ensure that We do not transfer the Personal Data to any country that is notified as restricted by any applicable regulations or the Government of India from time to time.

Notice To End User And Other Exclusions

Our Service(s) are intended for use by enterprises. This Policy is not applicable to Our processing of any Personal Data forming a part of the Customer Data. We may receive End Users’ Personal Data as a part of the Customer Data for which We will only act as a Processor and such processing will be governed by the Terms. In such a case, the End User’s data privacy questions and requests should be submitted to the Customer in its capacity as the End User’s Controller. If We are not responsible for Customers’ privacy or security practices which may be different from this notice.

Our Website(s) contain links to other websites. Our Policy applies only to Our Website(s), so if You click on a link to another website, You should read their privacy policy. We encourage You to review the privacy statements of any such other websites to understand their Personal Data practices.

Communication Preferences

You control which communications you receive from us. To opt out of marketing communications, follow the unsubscribe instructions in any email, or contact [email protected]. Please allow a reasonable period for your opt-out to take effect.

Changes to This Policy

We may update this Policy from time to time. Continued use of our Solutions after changes are posted constitutes acceptance of the updated Policy. We encourage you to review this page periodically.

Contact Us

For questions about this Policy or to exercise your privacy rights, contact us at [email protected].

Kind Attention: Grievance Officer: Santhosh Kumar Velumani

Email Address: [email protected]

Contact: 0091- 9843005286

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Effective Date: 09-09-2026

CCPA Rights and Choices

Applicable to California residents under the California Consumer Privacy Act of 2018 ("CCPA"), as amended by the California Privacy Rights Act ("CPRA")

Your Rights and Choices

This page describes the rights available to California residents under the CCPA and explains how to exercise them, in addition to our Privacy Policy at www.solitontech.com/privacy-policy. We collect as Business. “CCPA” means the California Consumer Privacy Act of 2018 as amended by the CPRA. “CPRA” means the California Privacy Rights Act. For the purposes of this section, the terms “Business”, “Business Purpose”, “Consumer” “Personal Information”, “Sale/Sell”, “Service Provider” and “Sensitive Personal Information” and “Share” shall have the meaning given to them under the CCPA.

The categories of Personal Information We have collected in the twelve (12) months prior to the Effective Date and that We may collect include:

·        Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, social security number, passport number, or other similar identifiers;

·        Signature, physical characteristics or description, telephone number, state identification card number, insurance policy number, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information;

·        Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet Website, application, or advertisement;

·        Geolocation data;

·        Audio, electronic, visual, thermal, olfactory, or similar information.

Disclosure of Personal Information

We have disclosed the categories of Personal Information listed in the clause above for a business purpose in the twelve (12) months prior to the Effective Date and may disclose such Personal Information to service providers or contractors or to any other third parties who support our business provided (a) they do not Sell or Share such Personal Information or (b) retain, use or disclose such information for any purpose other than for the specific purpose of performing the services specified in our contract with them or (c) combine such information with any other information received directly by them. We do not Sell or Share (as the terms are defined in the CPRA) the Personal Information We collect without providing You a right to opt out. We do not Sell or Share Personal Information of minors of at least the age of thirteen (13) but less than sixteen (16) years without receiving such minor’s consent or the consent of the minor’s guardian if the minor is less than thirteen (13) years. We have not Sold or Shared any Personal Information in the twelve (12) months prior to the Effective Date. We shall not disclose further the Personal Information collected for verification of a consumer’s request or retain it longer than it is necessary for the purpose of verification.

You are entitled to the following rights under the CCPA:

a.        You can request Us to disclose details and categories of Your Personal Information collected by Us.

b.       You can request Us to disclose Your Personal Information collected twelve (12) months prior to the Effective Date, this right shall apply only to personal information collected after January 1, 2022.

c.        You can request Us to disclose (a) Your Personal Information Sold or Shared and (b) the service provider or contractor, or a third-party (as defined in the CPRA) to whom such information is Sold or Shared.

d.       You can request Us to correct Your inaccurate Personal Information.

e.        You have the right to request the deletion of your personal information held by Us or by Our service provider, contractor, or any other third party to whom We have disclosed personal information to. We shall hold a confidential record of all deletion requests for the purpose of preventing the selling of such personal information for which You have submitted a deletion request.

f.        You have the right to opt out of any Sale or Sharing of Your Personal Information if any such sale or sharing occurs.

g.       You can request us to limit the use of Your Sensitive Personal Information.

h.       You can request the transfer of specific pieces of Your Personal Information to any other entity.

i.         You have the right to not be discriminated against for exercising Your rights under CCPA.

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Right to Delete

You may request that we delete Personal Information we have collected from you, subject to certain exceptions, including where retention is necessary to: complete a transaction you requested; detect security incidents or fraud; debug functionality; comply with a legal obligation; or make other internal, lawful uses compatible with the context in which you provided the information.

Right to Correct

You may request that we correct inaccurate Personal Information we hold about you.

Sale / Sharing of Personal Information

"We do not sell Personal Information for money. We do use cookies and similar technologies that may constitute 'sharing' under the CCPA for cross-context behavioral advertising purposes. You can opt out of this sharing at any time via the 'Cookie Settings' link in our Site footer, or by emailing [email protected] with 'California Privacy Rights — Opt-Out' in the subject line."

How to Exercise Your Rights

To submit a verifiable consumer request, email [email protected] with "California Privacy Rights" in the subject line, and include:

•     A description of your request

•     Your name and contact details

•     Sufficient information for us to verify your identity

You may only make a request to know or for data portability twice within a 12-month period. You may designate an authorized agent registered with the California Secretary of State to submit a request on your behalf, or submit a request on behalf of your minor child.

Response Timing

We will confirm receipt of your request within 10 business days and respond within 45 calendar days. If we need more time (up to an additional 45 days), we will notify you of the reason and extension period. We do not charge a fee to process requests unless they are excessive, repetitive, or manifestly unfounded, in which case we will explain why before proceeding.

Non-Discrimination

We will not deny you goods or services, charge you different prices, or provide a different level of service because you exercised your CCPA rights.

Shine the Light

Under California Civil Code Section 1798.83, California residents may request information about our disclosure of Personal Information to third parties for their direct marketing purposes. Submit such requests to [email protected].

Effective Date: 09-09-2026