MYCLOTH INDIA ARMY : PRIVACY & DATA PROTECTION POLICY

 

MYCLOTH INDIA ARMY LONG-TERM SOCIAL MEDIA ACCOUNT OWNER & BRAND PARTNER PROGRAM

OFFICIAL PRIVACY & DATA PROTECTION POLICY

Commercial Model: 10% LOYALTY ANNUAL NET PROFIT SHARE
Brand: MYCLOTH INDIA
Official Website: MyCloth.in
Document Type: Official Privacy & Data Protection Policy
Version: 1.0
Effective Date: 19 September 2026
Last Updated: 19 September 2026

1. PURPOSE

This Policy explains how MyCloth India may collect, use, store, protect and disclose information in connection with:

  • MYCLOTH INDIA ARMY participation;

  • participant applications and verification;

  • social-media account information;

  • attribution and tracking;

  • orders and commercial records;

  • financial and payment administration;

  • fraud and integrity controls;

  • communications; and

  • operation of the Program.

The objective is:

COLLECT WHAT IS NEEDED → USE IT FOR A CLEAR PURPOSE → PROTECT IT → RETAIN IT APPROPRIATELY → DISCLOSE IT ONLY WHERE JUSTIFIED

This Policy does not repeat the Program's financial, attribution, advertising or fraud methodology.

2. DOCUMENT RELATIONSHIP

This Policy operates together with the other Program documents.

Document Main Function
Master Terms & Conditions Overall Program framework
Accounting Policy Annual financial calculation
PCF Policy Product contribution methodology
Attribution & Tracking Policy Attribution and tracking
Advertising & Content Policy Participant content
Fraud & Integrity Policy Fraud and artificial activity
Participant Agreement Participant-specific contractual terms
This Policy Privacy and data protection
Tax / Payment Policy Tax, withholding and payment

Where a participant-specific agreement contains applicable privacy/data provisions, the relevant order-of-precedence rules apply.

Nothing in this Policy overrides mandatory applicable law.

3. WHO THIS POLICY COVERS

This Policy may apply to information relating to:

  • applicants;

  • accepted participants;

  • Account Owners;

  • social-media accounts used for the Program;

  • customers where information is lawfully processed in connection with Program activity;

  • prospective participants;

  • service providers and professional advisers where relevant; and

  • persons communicating with MyCloth India regarding the Program.

4. INFORMATION THAT MAY BE COLLECTED

Depending on the Program activity, MyCloth India may collect information such as:

Participant Information

  • name;

  • contact details;

  • email address;

  • telephone/mobile number;

  • country and relevant location information;

  • date of birth or age information where legally required;

  • identity/verification information;

  • tax information where required;

  • payment/bank information where required for payment;

  • participant ID; and

  • agreement or application information.

Social-Media Information

  • platform name;

  • username/handle;

  • public profile information;

  • profile URL;

  • account ownership/verification information;

  • approved promotional links;

  • discount/coupon codes;

  • relevant public content; and

  • Program-related performance information.

Commercial / Attribution Information

Where required for Program administration:

  • order ID;

  • order date;

  • products/SKUs;

  • quantity;

  • selling value;

  • applicable discount;

  • attribution method;

  • participant ID;

  • return/refund status;

  • chargeback status;

  • qualification status; and

  • relevant contribution records.

The Company should collect only information reasonably required for the applicable purpose.

5. CUSTOMER INFORMATION

MyCloth India may process customer information where reasonably necessary for:

  • order processing;

  • attribution;

  • fraud prevention;

  • customer support;

  • accounting;

  • refunds/returns;

  • legal or statutory compliance; or

  • Program reconciliation.

Participants do not receive an unrestricted right to access customer personal information.

A participant must not independently collect, publish, sell, share or misuse customer personal information obtained through Program activity.

6. HOW INFORMATION MAY BE USED

Information may be used for:

    1. evaluating Program applications;

    2. verifying participant identity and account ownership;

    3. administering the participant agreement;

    4. assigning Participant IDs;

    5. tracking and reconciling attributable activity;

    6. calculating qualifying contribution;

    7. administering payments;

    8. complying with tax and statutory requirements;

    9. preventing fraud and artificial activity;

    10. communicating with participants;

    11. maintaining business and accounting records;

    12. protecting MyCloth India, participants and customers;

    13. resolving disputes and complaints;

    14. improving Program operations; and

    15. complying with applicable law.

7. TRACKING TECHNOLOGY

The Program may use approved tracking technologies and systems, including where applicable:

  • Shopify Collabs;

  • affiliate links;

  • discount/coupon codes;

  • Participant IDs;

  • platform reporting systems;

  • website analytics;

  • cookies or similar technologies; and

  • Company order/accounting systems.

Tracking is used for operational purposes such as attribution, measurement, security and reconciliation.

The Attribution & Tracking Policy governs the commercial attribution methodology.

8. SHOPIFY COLLABS AND THIRD-PARTY SERVICES

Where Shopify Collabs or another third-party service is used, relevant information may be processed through that service according to the applicable service provider's own terms and privacy practices.

Use of a third-party platform does not transfer responsibility for the Program's contractual financial methodology to that platform.

MyCloth India may use other service providers for:

  • website operation;

  • payments;

  • communications;

  • accounting;

  • analytics;

  • security;

  • fraud prevention;

  • verification; and

  • technical infrastructure.

9. PAYMENT AND TAX INFORMATION

Where payment is due or legally required, MyCloth India may collect and process information necessary to:

  • verify the recipient;

  • process payment;

  • comply with tax requirements;

  • apply withholding where required;

  • maintain accounting records; and

  • satisfy statutory reporting obligations.

Payment and tax information may be shared with authorised banks, payment providers, accountants, tax professionals, auditors, government authorities or other legally authorised parties where necessary.

10. FRAUD, SECURITY AND INTEGRITY

Information may be processed to detect or investigate:

  • fabricated orders;

  • artificial transactions;

  • manipulated attribution;

  • false identity information;

  • misuse of tracking systems;

  • suspicious activity;

  • unauthorised access;

  • payment irregularities; and

  • other Program integrity concerns.

The Fraud Prevention & Integrity Policy governs the substantive Program rules relating to such activity.

11. WHO MAY RECEIVE INFORMATION

Information may be disclosed where reasonably necessary to:

  • authorised MyCloth India personnel;

  • KRISHNA CREATOR VENTURE personnel responsible for Program administration;

  • technology/service providers;

  • payment providers;

  • accountants and auditors;

  • legal or professional advisers;

  • fraud/security providers;

  • tax professionals;

  • regulators or government authorities where legally required; or

  • other parties where disclosure is authorised or necessary under applicable law.

MyCloth India should not disclose personal information merely because another participant requests it.

12. PUBLIC INFORMATION

Some information may already be publicly available, including:

  • a participant's public social-media username;

  • public profile information;

  • public promotional content;

  • publicly visible Program participation where the participant chooses to disclose it.

Public availability does not mean that MyCloth India may use or disclose the information for every purpose.

13. CONFIDENTIAL PROGRAM INFORMATION

Participants may receive or encounter confidential information concerning:

  • customers;

  • internal systems;

  • attribution data;

  • financial records;

  • product economics;

  • PCF information;

  • internal investigations;

  • non-public business information; and

  • other confidential Company information.

Such information must be handled in accordance with the applicable confidentiality obligations.

14. DATA SECURITY

MyCloth India will use reasonable administrative, technical and organisational measures appropriate to the nature of the information and applicable legal requirements.

Security measures may include:

  • access controls;

  • restricted internal access;

  • authentication controls;

  • secure systems;

  • record monitoring;

  • data minimisation;

  • appropriate service-provider controls; and

  • incident-response procedures.

No online system can be guaranteed to be completely secure.

15. DATA RETENTION

Information may be retained for as long as reasonably necessary for:

  • Program administration;

  • contractual obligations;

  • accounting;

  • tax;

  • payment;

  • fraud prevention;

  • dispute resolution;

  • legal claims;

  • regulatory requirements;

  • security; or

  • other legitimate business purposes.

Different categories of information may have different retention periods.

Information that is no longer required should be deleted, anonymised or otherwise disposed of where appropriate and legally permissible.

16. DATA ACCURACY

Participants should provide accurate and current information.

Where relevant, participants should promptly notify MyCloth India of material changes to:

  • contact details;

  • social-media account information;

  • payment information;

  • tax information; or

  • identity/verification information.

The Company may request updated information where reasonably necessary.

17. PARTICIPANT REQUESTS

Subject to applicable law, a participant may contact MyCloth India regarding:

  • access to their personal information;

  • correction of inaccurate information;

  • deletion where legally available;

  • restriction or objection where legally available;

  • withdrawal of consent where consent is the applicable legal basis; or

  • other applicable privacy rights.

Some requests may be limited where retention or processing is required by law, contract, fraud prevention, accounting, tax, security or other lawful requirements.

18. IDENTITY VERIFICATION FOR PRIVACY REQUESTS

To protect personal information, MyCloth India may reasonably verify the identity of a person making a privacy request.

The Company should not disclose personal information to an unauthorised person merely because they claim to be the participant or Account Owner.

19. CHILDREN AND MINORS

The Program is intended to be administered in accordance with applicable age and legal-capacity requirements.

MyCloth India does not knowingly seek unnecessary personal information from children.

Where applicable law requires parental/guardian involvement or imposes additional requirements concerning minors, the Company will apply those requirements.

20. INTERNATIONAL DATA PROCESSING

Depending on the technology, service providers and location of participants or customers, information may be processed or stored in jurisdictions outside the person's home jurisdiction.

Where applicable, MyCloth India will apply the legally required safeguards for such processing.

21. COOKIES AND WEBSITE TECHNOLOGIES

MyCloth.in may use cookies, pixels, analytics tools or similar technologies for purposes such as:

  • website functionality;

  • security;

  • analytics;

  • performance measurement;

  • attribution;

  • remembering preferences; and

  • improving user experience.

Where legally required, applicable consent or cookie controls will be provided.

22. PARTICIPANT CONTENT AND PUBLIC POSTS

Where a participant publishes public content about MyCloth India, the Company may process that content where reasonably necessary for:

  • Program administration;

  • compliance review;

  • brand protection;

  • attribution;

  • responding to complaints;

  • fraud prevention; or

  • lawful business purposes.

The Advertising & Content Policy continues to govern the participant's obligations concerning such content.

23. DATA BREACH OR SECURITY INCIDENT

If MyCloth India becomes aware of a personal-data security incident, it may take reasonable steps to:

    1. investigate the incident;

    2. contain or mitigate the issue;

    3. secure affected systems;

    4. assess legal and operational impact;

    5. preserve relevant evidence; and

    6. provide notifications where required by applicable law.

24. NO SALE OF CUSTOMER INFORMATION FOR UNAUTHORISED PURPOSES

MyCloth India should not sell or disclose customer personal information for an unrelated purpose merely to benefit a Program participant.

Any permitted processing or disclosure remains subject to applicable law and the relevant privacy requirements.

25. PARTICIPANT RESPONSIBILITY

Participants must:

  • protect confidential information;

  • use customer information only as authorised;

  • avoid collecting unnecessary personal information;

  • not publish private customer information;

  • not sell or transfer customer information;

  • use approved Program systems where required; and

  • promptly report suspected privacy or security incidents where appropriate.

26. RELATIONSHIP WITH THE FINANCIAL POLICIES

Privacy controls do not replace the financial methodology.

The general operational flow remains:

Account Owner → Tracking → Order → Qualification → QNR → PCF → ACS → TACS → Annual Partner Pool → Individual Allocation

Personal information is processed only as reasonably necessary to administer these or related Program functions.

27. GOVERNANCE AND ACCESS

Access to Program information should be limited according to role and legitimate business need.

An employee, manager, contractor or service provider should not receive unrestricted access merely because they work with MyCloth India.

Access may be limited according to:

  • operational responsibility;

  • confidentiality;

  • security;

  • legal requirements;

  • data sensitivity; and

  • business necessity.

28. POLICY CHANGES

MyCloth India may update this Policy where reasonably required because of:

  • changes in law;

  • regulatory requirements;

  • technology changes;

  • new Program processes;

  • security requirements;

  • service-provider changes; or

  • improvements to privacy practices.

Material changes may be communicated through appropriate Program or website channels.

29. NO OVERRIDE OF MANDATORY LAW

Nothing in this Policy is intended to:

  • waive a mandatory privacy right;

  • remove a statutory protection;

  • permit unlawful processing;

  • restrict a legally protected remedy; or

  • exclude a liability that cannot lawfully be excluded.

Applicable law prevails where required.

30. PRIVACY PRINCIPLE

The MyCloth India Army should handle information according to five practical principles:

Principle Meaning
Necessary Collect what is reasonably required
Purposeful Use information for legitimate purposes
Secure Protect information appropriately
Limited Restrict access and disclosure
Accountable Maintain appropriate records and controls

31. CONTACT

Privacy-related questions or requests concerning the Program may be submitted through the official MyCloth India communication channels published by the Company.

Participants should use official channels rather than sending private customer information through unofficial accounts.

32. FINAL PRINCIPLE

Privacy is part of the integrity of the MYCLOTH INDIA ARMY.

The Program therefore aims to maintain:

RESPONSIBLE DATA COLLECTION
CLEAR PURPOSE
SECURE HANDLING
LIMITED ACCESS
LAWFUL PROCESSING


MYCLOTH INDIA ARMY

"BUILD WITH US

GROW WITH US"