Terms and Conditions of Use of Website

Introduction

Please read these Web Site Terms of Use carefully before using this Web Site (The "Web Site"). These Web Site Terms of Use (The "Terms of Use") govern your access to and use of the Web Site. The Web Site is available for your use only on the condition that you agree to the Terms of Use set forth below. If you do not agree to all of the Terms of Use, do not access or use the Web Site. By accessing or using the Web Site, you and the entity you are authorized to represent ("You" Or "Your") signify your agreement to be bound by the Terms of Use.

  1. User Eligibility: The Web Site is provided by Rivigo Services Private Limited and available only to entities and persons over the age of majority and who can form legally binding agreement(s) under applicable law. If You do not qualify, you are not permitted to use the Web Site.
  2. Scope of Terms of Use: These Terms of Use govern Your use of the Web Site and all applications, software and services (collectively, "Services") available via the Web Site, except to the extent such Services are the subject of a separate agreement. Specific terms or agreements may apply to the use of certain Services and other items provided to You via the Web Site ("Service Agreement(s)"). Any such Service Agreements accompany or are listed in association with or through a hyperlink associated with the applicable Services.
  3. Modifications: Rivigo Services Private Limited may revise and update these Terms of Use at any time. Your continued usage of the Web Site after any changes to these Terms of Use will mean You accept those changes. Any aspect of the Web Site may be changed, supplemented, deleted or updated without notice at the sole discretion of Rivigo service private Limited. Rivigo Services Private Limited may also change or impose fees for products and services provided through the Web Site at any time in its sole discretion.
  4. Rivigo Services Private Limited Privacy Policy: Rivigo Services Private Limited Privacy Policy governs the use of information collected from or provided by You at the Web Site. With respect to any individual whose personal information is provided by You to Rivigo Services Private Limited, You represent to Rivigo Services Private Limited that You have obtained all necessary consents for the processing of such personal information contemplated by the Services You are using and by Rivigo Services Private Limited Privacy Policy, including the transfer of such data to other countries whose laws may not provide the same level of protection for the personal data as the laws of the country of origin of such individual.
  5. License and Ownership: Any and all intellectual property rights ("Intellectual Property") associated with the Web Site and its contents (the "Content") are the sole property Rivigo Services Private Limited. The Content is protected by copyright and other laws in both the India and other countries. Elements of the Web Site are also protected by trade secret, unfair competition, and other laws and shall not be copied or imitated in whole or in part.
  6. Restrictions on Use of the Web Site: In addition to other restrictions set forth in these Terms of use, you agree that:
    1. You shall not disguise the origin of information transmitted through the Web Site.
    2. You will not place false or misleading information on the Web Site.
    3. You will not use or access any service, information, application or software available via the Web Site in a manner not expressly permitted by Rivigo Services Private Limited.
    4. You will not input or upload to the Web Site any information which contains viruses, or other computer programming routines that are intended to damage, interfere with, intercept or expropriate any system, the Web Site or Information or that infringes the Intellectual Property (defined below) rights of another.
    5. You will not input or upload to the Web Site any information which contains viruses, or other computer programming routines that are intended to damage, interfere with, intercept or expropriate any system, the Web Site or Information or that infringes the Intellectual Property (defined below) rights of another.
    6. Certain areas of the Web Site are restricted to customers of Rivigo Services Private Limited.
    7. You shall not use or access the Web Site in any way that, in Rivigo Services Private Limited's judgment, adversely affects the performance or function of the Rivigo Services Private Limited Systems, Services or the Web Site.
    8. You shall not frame or utilize framing techniques to enclose any portion or aspect of the Content or the Information, without the express written consent of Rivigo Services Private Limited.
  7. Submissions: Rivigo Services Private Limited does not accept ideas, concepts, or techniques for new services or products through the Web Site ("Comments"). If such Comments are received, you acknowledge that (a) they will not be considered confidential or proprietary, (b) Rivigo Services Private Limited and its affiliates are under no obligation to keep such information confidential, and (c) Rivigo Services Private Limited will have an unrestricted, irrevocable, world-wide, royalty free right to use, communicate, reproduce, publish, display, distribute and exploit such Comments in any manner it chooses.
  8. Termination: You agree that Rivigo Services Private Limited, in its sole discretion, may terminate or suspend Your use of the Web Site and its Content at any time and for any or no reason in its sole discretion, even if access and use continues to be allowed to others. Upon such suspension or termination, you must immediately (a) discontinue use of the Web Site, and (b) destroy any copies You have made of any portion of the Content. Accessing the Web Site, the Rivigo Services Private Limited, Information or Services after such termination, suspension or discontinuation shall constitute an act of trespass. Further, you agree that Rivigo Services Private Limited shall not be liable to You or any third party for any termination or suspension of Your access to the Web Site.
  9. Limitation of Liability: In No Event Shall Rivigo Services Private Limited, Its Affiliates, Its Licensors, Its Suppliers or Any Third Parties Mentioned at The Web Site Be Liable for Any Incidental, Indirect, Exemplary, Punitive and Consequential Damages, Lost Profits, Or Damages Resulting from Lost Data or Business Interruption Resulting from The Use of or Inability to Use the Web Site.
  10. Indemnity: You agree to defend, indemnify and hold harmless Rivigo Services Private Limited and its respective officers, directors, employees, agents and representatives from any and all claims (i) arising out of Your breach of any of these terms and conditions, and any of Your activities conducted in connection with this site.
  11. Jurisdiction: To The Fullest Extent Permitted by Law, You Hereby Expressly Agree That Any Proceeding Arising Out of or Relating to Your Use of the Web Site Shall Be Instituted in courts in Gurgaon, India.
  12. Severability: If any provision of these Terms of Use is found to be invalid by any court having competent jurisdiction, the invalidity of such provision shall not affect the validity of the remaining provisions of these Terms of Use, which shall remain in full force and effect.
  13. Complete Agreement: Except as Expressly Provided in Other Written Agreement Between You and Rivigo Services Private Limited These Terms of Use Constitute the Entire Agreement Between You AND Rivigo Services Private Limited with Respect to The Use of the Web Site.

Privacy Policy

We take your privacy seriously. Please read our privacy policy carefully to learn more.

If you have any questions about this Privacy Policy, please contact us using the contact information provided in your program materials or on the program website. We recognize the importance of privacy and have attempted to conform this Privacy Policy to applicable industry standards and practices existing at the time of its posting.

This Privacy Policy, which is a part of the Terms of Use and End User License Agreement and the Acceptable Use Policy (collectively, the "Agreement"), explains the types of information we collect through our Services and what we do with such information. "Services" are defined in the Terms of Use. Terms not defined in this Privacy Policy have the meaning defined elsewhere in the Agreement.

  1. Information we may collect, and whether this includes personally identifiable information: We may collect information in different ways:
    1. Information you Voluntarily Provide. Personally identifiable information you voluntarily provide may be collected if it is necessary to administer the Services. For example, when you sign up for an account or other Services that require registration, we ask you for personal information such as your name, address, billing information, account name or password. We DO NOT use your personal information other than to administer the Services. We may combine the information you submit under your account with information from other services or third parties in order to provide you with a better experience and to improve the quality of our Services. If.
      The information voluntarily provided by you during the registration process may also include or naturally entail other demographic information which is not personally identifying, such as gender, preferred language, age, occupation, household income, ZIP code or country.
    2. Information we may collect from your use of our Services:
      1. Community or Public Forums and Third Party Links. Our Service offers publicly accessible community services such as feeds, profiles, sharing and public links. You should be aware that any personal information or Content you provide in these areas may be read, collected, and used by others who access them. Your posts may remain even after you cancel your account and shared files cannot be un-shared or deleted.
        Our Site includes links to other third party websites whose privacy practices may differ from those of Rivigo. Rivigo has no control over the policies, actions or omissions of third party websites and is not responsible or liable for any such policies, acts or omissions. If you submit personal information to any of those websites, your information is governed by the applicable third party privacy policies and not by the Rivigo privacy policy. We urge you to carefully review the privacy policy of any website you link to, visit or share information with prior to doing so.
        If you are connected to a social network service user account such as Facebook®, we automatically receive and record anonymous data such as anonymous user identifiers provided by such social network service as well as information that you have made available publicly to everybody through such social network service.
        If you specifically allow us to access your social network user data such as your Facebook® user data, we automatically receive and record any information you have allowed us to access on your social network user account. As noted below, you can opt not to disclose such information to us.
      2. Server Logs. Our servers automatically record information that your browser sends and the Uniform Resource Locator ("URL") of the web page from which you came to us whenever you visit our websites. These server logs may include information such as your Internet Protocol ("IP") address, browser type, browser language, date and time of your request, search terms and may include a domain name and the date and time for each page you view. We also collect the name of and information about any advertisement or other link that brought you to us. This information does not personally identify you. We use IP addresses to diagnose problems with our servers and to administer our website. Your IP address also is used by us to gather broad demographic information, such as your general geographic location and internet service provider. IP addresses are further used to help determine the number of our users to maintain efficient administration of our Services. This demographic information may also be used by us to analyze aggregate usage behavior.
      3. Cookies: “Cookies” are small files that collect information that we use to track trends and patterns of how people search. We may send one or more cookies to your computer that uniquely identifies your user account or computer. We use cookies for such functions as verifying that you are one of our users, maintaining a history of services provided and enabling the fulfillment of our Services. Most browsers are initially set up to accept cookies, but you can reset your browser to refuse all cookies or to indicate when a cookie is being sent. However, many of our Services or features may not function properly if your receipt of cookies is disabled.
      4. Use of Remarketing with Google Analytics™: We collect and use cookies to enable basic web traffic analysis using Google Analytics™ to capture information about page visits (showing us which areas of the website are popular and those that are not often visited, this allows us to prioritize our enhancements to our website). This information is anonymous and we use this information only internally - to deliver the most effective content to our visitors. We use analytics data to serve ads based on a user's prior visits to our websites. Website visitors may opt out of the Google Analytics™ cookie by visiting the Google® advertising opt-out page or they may opt out of Google Analytics™ by visiting the Google Analytics™ opt-out page. Google® has additional information available about their Remarketing Privacy Guidelines, Policies, and Restrictions.
      5. Geo-Location Information: Some devices, mobile or otherwise, allow applications to access real-time location-based information (for example, GPS). Our mobile apps do not collect such information from your mobile device at any time while you download or use our mobile apps as of the date this policy went into effect, but may do so in the future with your consent to improve our Services. Some photos and videos you place in or on our Services may contain recorded location information. We may use this information to optimize your experience. If you do not wish to share files embedded with your geo-location information with us, please do not upload them. If you don’t want to store location data in your photos or videos, please consult the documentation for your camera, phone or other device to turn off that feature.
      6. Communications: If you email us, we may store copies of such email or similar communications between you and us. This can result in the collection of your email address or other personally identifiable information you may have in your email text, addresses, or other fields, as well as the collection of your IP address, the Internet or other routing of your communication, and the date and time of your communication. All transmissions between you and us, including emails, URLs, cookie identification numbers, usage paths, and any personally identifiable information they might contain, pass through many third party machines, operating systems, programs, browsers, web servers, networks, routers, Ethernet switches, ISPs, proxy servers, intranets, the public telephone systems, or other devices, any of which may create activity logs containing such transmissions, and many of which we cannot control. When you send email, feedback, comments or other communication to us, we may retain those communications in order to process your inquiries, respond to your requests, improve our Services, and may post or use such communications without any obligation to you.
  2. What we do with the information we collect/store and how we may share the information:
    • For your use. We will display your personal information on your account or profile page or elsewhere according to your preferences. Your profile page may be made public or shared with others according to your preferences, so we encourage you to carefully consider the information you choose to provide or make public with your account and profile preferences. We will display and make accessible the information and files, materials, and Content that you choose to share or make public using our Services. We use the information we collect for providing you with the Services that you select, and therefore, as a natural part of providing the Services, we may share this information with our employees, contractors and agents on an as needed basis in our sole discretion. We may contact you by email to respond to your Customer Service inquiries and to verify the quality of the Services provided.
    • Legal or Governmental Compliance. We may share your personal information, IP address or Content with persons outside of our company if we have a good faith belief that access, use, preservation or disclosure of such information or Content is reasonably necessary to (a) satisfy any applicable law, regulation, legal process or enforceable governmental request, (b) enforce agreements or resolve disputes between you and us, including investigation of potential violations thereof, (c) detect, prevent, or otherwise address fraud, security or technical issues, or (d) protect against imminent harm to the rights, property or safety of our company, its users or the public as required or permitted by law. We will disclose any information or Content we possess that is directly responsive to subpoenas, court orders, or other legal or governmental inquiries, and such information might be used by the receiving party to determine your identity.
    • Business Transfer. If we become involved in a merger, acquisition, or any form of sale of some or all of our assets, we will provide notice if such a transaction results in your information being subject to a different privacy policy.
    • Service Providers, Business Partners and Others. We may use certain trusted third party companies and individuals to help us provide, analyze, and improve the Service (including but not limited to data storage, maintenance services, database management, web analytics, payment processing, and improvement of the Service’s features). These third parties may have access to your information only for purposes of performing these tasks on our behalf and under obligations similar to those in this Privacy Policy and must apply appropriate confidentiality and security measures.
    • Non-Personal Information Disclosure. We may disclose or share non-personal or anonymous or aggregated information with third parties, such as usage statistics of our Services or IP addresses. Aggregated non-personally identifiable information is information recorded about users and collected into groups so that it no longer reflects or references an individually identifiable user. These third parties may collect information when users visit our Services. These third parties may use this aggregated information about your visits to this and other websites in order to provide advertisements on the other websites and other forms of media about goods and services of interest to you. For example, this is how anonymous data may contribute to or be used to improve our Services and your experience:
      • Advertising Research - non-personally identifiable data, which includes web use and demographic information, may be shared anonymously with third parties so they can understand if and how their advertising spending impacts the consumer journey and consumer decisions.
      • Media Use Analysis - non-personally identifiable data may be shared anonymously with clients so they can understand where consumers go online and how consumers interact with digital media which includes website content and advertising that is seen through web and mobile browsers.
      • Profile Building – third parties may use the data we have collected, either explicitly provided or collected from online behaviors, to obtain additional information from other public and private data sources. These third party data sources may provide information on the types of purchases relative to household and lifestyle information, and broader demographic details. We or third parties may then use the combined data to create non-personally identifiable profiles that are shared as consumer segments.
      • Addressable Marketing Segments - we may use non-personally identifiable data to identify certain consumer segments reachable with advertising.
    • Third-Party Applications. We may share your information with a third party application with your request or consent, for example when you choose to access our Services through such an application, for example through a mobile device application. We are not responsible for what those parties do with your information, so you should make sure you trust the application and that it has a privacy policy acceptable to you prior to accessing our Services using any third party applications.
  3. Security measures used to protect against the loss, misuse or alteration of information under our control:
    The security of your information and Content is important to us. If we collect information from your computer, we encrypt it while it’s being transferred to us. Once the information reaches our secure servers, as part of our security program, we employ procedures and safeguards, such as maintaining firewalls and having an intrusion detection system, to protect the confidentiality, security and integrity of the information we maintain. However, as with any information travelling over the internet and kept in servers, we cannot guarantee absolute security.
    When we work with third parties, we require that they maintain the confidentiality, security and integrity of the information and commit that the information is not used for any prohibited purpose. Additionally, we use commercially reasonable computer security safeguards to protect our databases and servers against risks of loss, unauthorized access, destruction, misuse, modification, or inadvertent or improper disclosure of data. These include internal reviews of our data collection, storage and processing practices and security measures, as well as physical security measures to guard against unauthorized access to systems where we store personal data. We restrict access to personal information to our employees, contractors and agents who need to know that information in order for us to provide, develop or improve our Services. Security risks, however, cannot be completely eliminated and we therefore cannot guarantee complete security.
    If you send us an email, you should know that email is not necessarily secure against interception. Therefore, if your communication will include sensitive information like your bank account, charge card, or social security number, and you prefer not to transmit it electronically, please contact us by postal mail or telephone rather than email. We do not send emails asking for a user's username and password or its Windows username and password or any other username or password.
  4. Choice and Correcting/ Updating/ Deleting/ Deactivating Personal Information: what information we collect and how it may be used, so that you can make meaningful choices. For example, you can:
    • Cancel your account at any time;
    • You can decline to submit requested information, however, it’s important to understand that the Services may not function properly or we may not be able to provide the requested service to you;
    • You can uninstall Inbox software at any time and discontinue use of our Services;
    • Control what information you post in public profiles and who you share information with;
    • Set your browser to block all cookies, including cookies associated with our services, or to indicate when a cookie is being set by us. However, it’s important to remember that many of our services may not function properly if your cookies are disabled. For example, we may not remember your language preferences.
    If we propose to use personal information for any purposes other than those described in this Privacy Policy, we will offer you an effective way to opt out of the use of personal information for those other purposes. If your personally identifiable information changes (such as ZIP code, phone, email or postal address), or if you no longer desire the Services, we provide a way to correct, update or delete/deactivate users' personally identifiable information. This can usually be done by emailing or calling Customer Support through our website.
  5. Changes to this Privacy Policy: This Privacy Policy may change from time to time and an updated Privacy Policy will be available and accessible on our website. You are responsible for periodically reviewing this Privacy Policy for any applicable changes.

Whistle Blower Policy

  1. Introduction: Section 177(9) of the Companies Act, 2013 mandates the following classes of Companies to maintain vigil mechanism:
    1. Every Listed company;
    2. Every such other company which accepts deposits from public;
    3. Every company which has borrowed money from Banks and Financial institutions in excess of Rs. 50 Crore.
  2. Objective: Rivigo Services Private Limited (hereinafter referred to as “Company”) believes in the conduct of it affairs in a fair and transparent manner by adopting higher standards of professionalism, honesty, integrity and ethical behaviour. Towards this end Company has adopted the Code of Conduct (“the Code”) which lays down the principles and standards that govern the action of Company and its employees. Any actual or potential violation of the Code, or violations of the law would be matter of serious concern for Company. The role of our employees in pointing out such violations is very important. Accordingly, this policy details the following:
    • Procedure to disclose any suspected unethical and/or improper practice taking place in the Company;
    • Protection available to the person making such disclosure in good faith;
    • Mechanism for actioning and reporting on such disclosures to the relevant authority within the Company; and
    • Relevant authority and its powers to review disclosures and direct corrective action relating to such disclosures.
    This Whistle Blower Policy is an extension of the Company’s Code of Conduct through which the Company seeks to provide a mechanism for its employees, directors, vendors or customers to disclose any unethical and/or improper practice(s) taking place in the Company for appropriate action and reporting. Through this policy, the Company provides the necessary safeguards to all Whistle blower for making disclosures in good faith.
  3. Definitions: The definitions of some of the key terms used in this policy are given below:
    1. "Company" means Rivigo.
    2. "Code of Conduct" means the Code of Conduct formulated by the Company for the employees.
    3. "Director" means any executive, non-executive, nominee or alternate director of the Company.
    4. "Disclosure" means any communication in writing in relation to an Unethical Practice (including anonymous disclosures) made in good faith by the Whistle blower to the designated personnel under this policy.
    5. "Employee" means any employee or officer of the Company.
    6. "Investigators" mean any person(s) duly appointed/consulted by the Vigil Mechanism Committee to conduct an investigation under this policy.
    7. "Subject Employee" means an employee against or in relation to whom a Disclosure is made under this policy.
    8. "Unethical Practice" means and includes, but not limited to, the following activities/ improper practices being followed in the Company:
      1. Manipulation of Company data / records;
      2. Abuse of authority at any defined level in the Company;
      3. Disclosure of confidential / proprietary information to unauthorized personnel;
      4. Any violation of applicable legal law and regulations to the Company, thereby exposing the Company to penalties/ fines;
      5. Any instances of misappropriation of Company assets;
      6. Activity violating any laid down Company policy, including the Code of Conduct;
      7. Any other activities whether unethical or improper in nature and injurious to the interests of the Company.
    9. "Whistle Blowers" shall have the meaning assigned under clause 4.
    10. "Whistle Blower Committee" means the committee consisting of Ms. Gazal Kalra as the first members of the committee. The committee may co-opt another member for any specific issue(s) at its discretion. The Managing Director would be the Chairman of the Whistle Blower Committee.
  4. Whistle Blowers: Whistle Blower shall mean and include the following categories of people in this Policy:
    1. Employees of the Company;
    2. Directors of the Company;
    3. Customers of the Company; and
    4. Vendors doing business with the Company.
  5. Procedure for Reporting:
    1. The Disclosures can be made as follows:
      • If the Disclosure is against an Employee up to the level of MB-4 the Disclosures can be made to the Whistle Blower Committee;
      • If the Disclosure is against an Employee in the level of Director or MB-5, the Disclosures can be made to the Managing Director of Company.
    2. Where a Disclosure is to the Whistle Blower Committee, it shall be addressed to Ms. Gazal Kalra her contact details are:
      Rivigo Services Private Limited
      Plot No. 90, Sector-44
      Gurgaon – 122002
      Email id: This email address is being protected from spambots. You need JavaScript enabled to view it.
      Alternatively, the Whistle Blowers can submit the Disclosure to the e-mail id: This email address is being protected from spambots. You need JavaScript enabled to view it.. This e-mail id shall be accessed by Ms. Gazal Kalra and the Chairman of Committee.
    3. Where a Disclosure is being made in relation to Nominee Director or above or a Director, the Disclosures can be made to the Managing Director of Company and it should be made to the following address:
      The Managing Director
      Rivigo Services Private Limited
      Unit No. 90, Sector-44,
      Gurgaon Haryana-12202
      Alternatively, Disclosure can also be made directly to the email id of managing Director of Company i.e. This email address is being protected from spambots. You need JavaScript enabled to view it.
    4. It is strongly advised that the Whistle Blowers discloses his/ her identity in the Disclosure for ensuring that adequate protection is granted to him/ her under the relevant provisions of this policy. However, anonymous Disclosures, though discouraged, may also be made.
    5. The Whistle Blowers must address the following issues, while reporting any disclosures under this policy:
      1. The Disclosures made should bring out a clear understanding of the issue being raised.
      2. The Disclosures made should not be merely speculative in nature but should be based on actual facts.
      3. The Disclosure made should not be in the nature of a conclusion and should contain as much specific and quantitative information with supporting documents to the extent possible to allow for proper conduct of the inquiry/ investigation.
      4. The Whistle Blowers is not required to give reasons for such Disclosure.
  6. Investigation of Disclosures:
    1. The Whistle Blowers Committee is duly authorized to investigate / oversee any Disclosures reported under this policy. The Whistle Blower Committee shall be assisted by the Chief People Officer on such terms as he may deem fit, for the implementation and reporting under this policy.
    2. All Disclosures made under this policy shall be recorded and duly actioned, if required, in accordance with the recommendation made by the Whistle Blower Committee.
    3. The Whistle Blower Committee may, at its discretion, conduct an investigation. However, an investigation shall be launched only after the review of the Disclosures prima facie establishes that:
      1. The Disclosure made, constitutes an unethical/ improper practice, as defined under this policy;
      2. The Disclosure made is supported by adequate information to support an investigation.
      Confidentiality of the Whistle Blower shall be maintained during the inquiry/ investigation process.
    4. Any inquiry/ investigation conducted against any Employee shall not be construed by itself as an act of accusation and shall be carried out as a neutral fact finding process, without presumption of any guilt.
    5. The inquiry/investigation shall be conducted in a fair manner and provide an equal opportunity for hearing to the affected party and a written report of the findings should be prepared.
    6. The Whistle Blower Committee Chairman and the Investigators shall have right to call for and examine any information / document and /or employees of the Company, as may be deemed necessary for the purpose of conducting inquiry/ investigation under this policy.
  7. Subject Employees:
    1. All Subject Employees shall be duly informed about the Disclosures of unethical practice(s) made against them at the commencement of the formal inquiry/investigation process and shall have regular opportunities for providing explanations during the course of the inquiry/ investigation process.
    2. No Employee shall directly/ indirectly interfere with the investigation process, till the completion of the inquiry/ investigation.
    3. The Subject Employee shall not destroy or tamper with any evidence,and shall have a duty to co-operate with the Whistle Blower Committee Chairman in the inquiry/ investigation process or with any of the Investigators appointed, till the time the inquiry/ investigation process is completed.
    4. During the course of the inquiry/investigation process, all Subject Employees shall have a right to consult any person(s) of their choice, other than the Investigators, and engage any legal counsel at their own cost to represent them in any inquiry/ investigation proceedings.
    5. All Subject Employees shall have a right to be informed about the results of the investigation process and shall be so informed in writing by the Company after the completion of the inquiry/ investigation process.
    6. All Subject Employees shall be given an opportunity to respond to results of the inquiry/ investigation as contained in an investigation report. No allegation of wrongdoing against any Subject Employee shall be considered as tenable, unless the allegations are duly supported by valid evidence in support of the allegation.
    7. Where the results of the inquiry/ investigation highlight that the allegations made against the Subject Employee are eventually dismissed as non-tenable, then the Company shall reimburse all such reasonable costs as shall have been incurred by the Subject Employee to defend him/her, during the process of inquiry/ investigation. In such cases, the Subject Employee will also be consulted whether a public disclosure of the investigation result should be in their best interest. The Whistle Blower Committee Chairman shall have the final discretion on whether such disclosure is necessary and if so, the scope and medium of such disclosure.
    8. Where a Disclosure gets substantiated, the Whistle Blower Committee shall forward its findings to:
      • For Subject Employees upto the level of General Manager: the Head of Human Resources and the respective Business Heads for consideration and taking further steps/action as may be deemed expedient and considered necessary.
      • For Directors: the Managing Director for consideration and taking further steps/action as may be deemed expedient and considered necessary.
  8. Protection to Whistle Blowers:
    1. The identity of the Whistle Blower, Subject Employee and any other Employee assisting the inquiry/ investigation, shall be kept confidential at all times, except during the course of any legal proceedings, where a Disclosure/ statement is required to be filed.
    2. The Company, as a policy, strongly condemns any kind of discrimination, harassment or any other unfair employment practice being adopted against the Whistle Blowers for Disclosures made under this policy. No unfair treatment shall be vetted out towards the Whistle Blowers by virtue of his/her having reported a Disclosure under this policy and the Company shall ensure that full protection has been granted to him/her against:
      1. Unfair employment practices like retaliation, threat or intimidation of termination/suspension of services, etc;
      2. Disciplinary action including transfer, demotion, refusal of promotion, etc;
      3. Director in direct abuse of authority to obstruct the Whistle Blower right to continue performance of his duties/functions during routine daily operations, including making further Disclosures under this policy.
  9. Management Action on False Disclosures: If an employee knowingly makes false disclosures under this policy, such employee shall be subject to disciplinary action on the terms deemed fit by the Whistle Blower Committee.
  10. Amendments: This policy may be amended or modified by the Company after due consultation with the management of the Company.
  11. Retention of Documents: All Disclosures made by the Whistle Blower or documents obtained during the course of inquiry/ investigation, along with the results of investigation relating thereto, shall be retained by the Company for a minimum period of 5 years.

FCPA Policy

  1. Introduction:
    The Foreign Corrupt Practices Act of 1977 (“FCPA”) prohibits the bribery of foreign officials. As a domestic concern of the United States, Warburg Pincus LLC, its portfolio companies, and joint ventures are subject to the FCPA. Additionally, as a company doing business in India through an investment in Rivigo Services Private Limited (“Company”), Warburg Pincus LLC, its portfolio companies and joint ventures are also subject to the (Indian) Prevention of Corruption Act 1988, as amended (“PCA”). Warburg Pincus LLC, its portfolio companies, and joint ventures must therefore abide by the FCPA and PCA by prohibiting corrupt and other unlawful payments by the Company, its employees and Third-Party Representatives (as defined below). The key provisions of the FCPA and PCA are summarized below.
  2. Scope:
    The Company shall abide by the provisions of the FCPA and PCA, summarized below, by prohibiting corrupt and other unlawful payments by the Company, its directors, officers and employees and all others subject to the Policy.
    This policy applies to all directors, officers and partners of the Group Companies, and any entity in which the Company has a greater than 50% interest, earns over 50% of the profits (or capital or beneficial interest), or holds over 50% of the seats on the board; any entity in which the Company has any other type of controlling power. This policy also applies to any other individual or entity acting for or on behalf of the Company. For entities in which the Company does not have a controlling interest, the Company should use its best efforts to implement this policy and the relevant procedures.
    The key provisions of the FCPA and PCA are summarized below.
  3. Bribery Provisions of the FCPA and PCA:
    Generally, anti-bribery laws like the FCPA and PCA prohibit paying, offering, authorizing or promising to pay Anything of Value with the intention of inducing or influencing a Government Official or political party to improperly use their position, in order to assist the Company in obtaining or retaining business, directing business to any person, or securing an improper advantage in the conduct of business.
    Likewise, it is prohibited to pay, offer, authorize or promise to pay, directly or indirectly, Anything of Value to any other person—such as a third-party representative—at the request of a Government Official or political party or while suspecting or having reason to believe that the payment or promise to pay will be offered or given to any Government Official or political party for the purposes of inducing or influencing a Government Official or political party to improperly use their position, in order to assist the Company in obtaining or retaining business, directing business to any person, or securing an improper advantage in the conduct of business.
    This policy prohibits payments described above, those made with a corrupt purpose, to any individual, regardless of whether such individual is a Government Official.

    Prohibited Payments
    “Anything of value” is a broad term. It can mean any transfer of value from one party to another, including of money, stocks, bonds or any other property, payment of expenses or providing services of any type. It can even include helping someone’s son get into university, assumption of a debt or release from the obligation to pay a debt, hiring individuals related to a Government Official or sponsored activities such as entertainment or travel. The payment need not actually be made to violate the FCPA – an offer or promise to provide a thing of value is a violation as well.
    Some examples of the type of payments which are prohibited include:
    • Payments to induce the issuance of any license, permit or other authorization.
    • Payments to a Government Official to induce the official not to disclose or prosecute activities by the Company that violates the law (e.g., payment to a transport official to allow vehicles to operate without government authorization).
    • Payments to a Government Official to obtain or expedite a negotiated agreement with a governmental agency.
    • Payments to a trade association or similar organization where there is reason to know that some or all of the payment will be passed to Government Officials to influence their decision making.
    • Payments or gifts given indirectly through a third party are also prohibited under these policies. Money or a gift to, without limitation, a third-party representative, consultant, independent contractor, distributor, sales representative, attorney or lobbyist, knowing that money or gift will be passed on to someone with whom the Company does or wants to do business would violate these laws.
    • Facilitation or “grease” payments to speed up routine actions such as licensing or permit processes are also not allowed.
    Government Officials
    For the purposes of this FCPA Policy, the term “Government Official” includes any officer, employee or other person acting in an official capacity on behalf of a government or any department or agency of the government. This includes elected officials, civil servants and military personnel. Children, spouses, siblings or parents of a Government Official can also be included in this definition. A Government Official may also be an officer or employee of a company or business that is owned or controlled by a government or any government department or agency. Political party officials or candidates are considered Government Officials. Individuals acting in an official capacity for or on behalf of a government even though he/she may not be an employee of such government or organization are also covered by this definition.

    Promotional and Marketing Expenses
    Under the FCPA, certain promotional or marketing expenses may be incurred in connection with Government Officials. These expenses must be incurred in connection with the sale, promotion or demonstration of Company’s services (e.g., demonstration or tour of a Company facility) or in connection with a particular contract. The Company may offer to pay for the reasonable cost of a meal, lodging or travel expenses for a Government Official only when:
    • The amount of the expense or reimbursement is nominal and reasonable in light of routine business travel and entertainment; and
    • The expense is directly related to either (a) the promotion, demonstration or explanation of Company’s services or (b) the execution of a contract.
    These expenses must also be accurately and fully recorded in the Company’s books and records.
    The PCA does not provide a specific exception for expenses of this nature.
  4. Third Party Representatives and Joint Ventures:
    Before entering into an agreement with a third party that will act on behalf of the Company or otherwise represent it before or with regard to a government entity or Government Official (“Third-Party Representatives”), the Company must seek to ensure under its contracts with the Third-Party Representatives that the: (i) Third-Party Representatives agree to abide by the FCPA and PCA, irrespective of whether those parties are subject to it; and (ii) Third-Party Representatives agree to refrain from engaging in any activity that the Company or its employees are prohibited from doing under the FCPA and PCA, including making any offer, payment or promise to pay anything of value to any Government Official with the intent or purpose of unlawfully influencing such Government Official in his official capacity or to do any act or take any decision in violation of FCPA and PCA.
    For the avoidance of doubt, notwithstanding anything to the contrary contained in this Agreement, the stipulations contained in this Schedule 8 are a policy directive under FCPA/PCA and nothing contained herein shall be deemed to impose a condition or obligation on the Company which is more extensive and/or or onerous than the stipulations prescribed under FCPA/PCA.nvestment in Rivigo Services Private Limited.

REFUND AND CANCELLATION POLICY

  1. POLICY
    This payment and refunds policy (the “Policy”) establishes the terms and conditions governing:
    1. the payments to be made to Rivigo Services Private Limited (“Rivigo”); and
    2. refunds in the form of credits for future matches (if any) required to be made to you, with respect to the Payment (as defined below) made by you to Rivigo, for the services provided by Rivigo. Rivigo may, from time to time, revise and amend this Policy.
  2. PAYMENT GATEWAY
    1. All payments to Rivigo online services will be made through an electronic and automated collection and remittance service (the “Payment Gateway”) hosted on the site through payment gateway service providers (the “Service Providers”).
    2. Rivigo makes no representation of any kind, express or implied, as to the operation of the Payment Gateway. You expressly agree that your use of the Payment Gateway is entirely at your own risk.
  3. TRANSACTION PROCESS AND REFUND POLICY
    The procedure adopted for payments to Rivigo is as follows:
    1. You will have to make a payment of the prescribed service fee to confirm your ‘interest’ for a deal / investment mandate provided by Rivigo. Upon the successful payment of the fee (“Payment”), a receipt containing the details of the Payment will be generated;
    2. Once the payment is complete, Rivigo does not Guarantee to provide refund, if you later decide to cancel the order.
      Our effort is to try and offer you the best possible service in a timely manner and to your satisfaction. Once order is confirmed, and the payment is made Rivigo reserves it right to hold that payment.
  4. LIMITATION OF LIABILITY
    1. In no event shall Rivigo be liable for any direct, indirect, incidental, special, consequential or exemplary damages, including but not limited to, damages for loss of profits, goodwill, data or other intangible losses arising out of or in connection with the access to, use of, or reliance on the Payment Gateway services.
    2. Rivigo assumes no liability whatsoever for any monetary or other damage suffered by you on account of:
      1. the delay, failure, interruption, or corruption of any data or other information transmitted in connection with use of the Payment Gateway; or
      2. any interruption or errors in the operation of the Payment Gateway.
    3. You agree, understand and confirm that personal data including without limitation details relating to debit card/credit card transmitted over the internet is susceptible to misuse, theft and/or fraud and that Rivigo has no control over such matters. Rivigo does not represent or guarantee that the use of the Payment Gateway will not result in theft and/or unauthorized use of data over the internet.
  5. BANKING DETAILS
    1. The records of Rivigo and/or the Payment Service Provider, generated by the transactions arising out of the use of Rivigo’ service, including the time the transaction is recorded, shall be conclusive proof of the genuineness and accuracy of the transaction.
    2. The details provided by you for use of the Payment Gateway will be correct and accurate and you shall not use a debit/credit card/ net banking which is not lawfully owned by you. You further agree and undertake to provide correct and valid debit/credit card / net banking details.
    3. In default of the above conditions, Rivigo shall be entitled to recover the amount of the transaction from you. Further, Rivigo also reserves the right to initiate any legal action for recovery of cost / penalty or any other measures, as it may deem fit.
  6. GOVERNING LAW AND JURISDICTION
    1. This Policy shall be governed by the laws of India, without giving effect to the principles of conflict of law provisions thereof. Further, the courts at Gurgaon shall have exclusive jurisdiction for all matters related to, arising out of or in connection with this Policy.
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