Privacy Policy

1Introduction

P9e Microsystems Private Limited (“P9e”, “we”, “us” or “our”) respects individual privacy and is committed to handling personal data lawfully, transparently and securely.

This Privacy Policy explains what personal data we collect, how and why we collect it, how we use it, when and with whom we share it, how long we retain it, how we protect it, and the rights and choices available to you.

It applies to personal data handled by P9e in connection with our websites, applications, software products, platforms, services, business relationships, recruitment activities and other interactions where P9e determines the purposes and means of processing.

Where P9e processes personal data solely on behalf of a customer under a contract, the customer primarily determines how that data is processed. Section 15 explains this distinction.

2About P9e

P9e Microsystems Private Limited is an Indian private limited company engaged in technology, engineering, software, electronics, research, product development and related business activities.

Depending on the context, P9e acts as a Data Fiduciary under the Digital Personal Data Protection Act, 2023 (the “DPDP Act”), as a data controller, body corporate or data processor under other applicable laws, or as a service provider processing personal data on a customer’s documented instructions.

3Scope of this Policy

This Policy applies when you:

• visit a P9e website or contact us through any channel;
• request information about, register for, or use a P9e product, service, platform or application;
• create an account with us, or communicate with our sales, support or engineering teams;
• participate in demonstrations, trials or pilot programmes;
• enter into a business relationship with us, or act as a representative of one of our customers, vendors or partners;
• attend an event organised or attended by P9e, or subscribe to communications from us;
• apply for employment, internship, consultancy or another engagement with P9e;
• visit our offices or facilities; or
• otherwise provide personal data to P9e.

This Policy does not govern processing for which another organisation independently determines the purposes and means.

4Key Terms

“Personal Data” means information relating to an identified or identifiable natural person, such as name, contact details, identification or account details, employment information, online identifiers (including IP address), or any other information that identifies or can reasonably be linked to an individual.

“Data Principal” means the individual to whom personal data relates — referred to in this Policy as “you”.

“Processing” means any operation performed on personal data, including collection, recording, storage, use, disclosure, transfer and erasure.

Information that cannot reasonably identify an individual — including appropriately anonymised or aggregated information — is not personal data.

5Personal Data We Collect

The categories of personal data we collect depend on how you interact with us.

6Sensitive Personal Data

Certain categories of information attract additional safeguards under applicable law, including passwords; financial information such as bank-account and payment-instrument details; health and medical information; biometric information; and other categories recognised as sensitive, including under the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011.

We collect sensitive information only where reasonably necessary for a legitimate and lawful purpose, and we restrict access to it.

7How We Collect Personal Data

Directly from you — when you complete a form, communicate with us, create an account, request a quotation, sign a contract, use a product, submit a support request, attend a meeting, apply for a role or provide information during a commercial relationship.

Automatically — certain technical information is generated when you use our websites, software or systems.

From your organisation — for example, when your employer designates you as an authorised user or project contact.

From service providers and business partners — such as recruitment, payment, identity-verification and event providers, channel partners and consultants, where lawful and necessary.

From publicly available sources — professional or business information from legitimate public sources, where reasonably necessary for business purposes.

8Why We Use Personal Data

9Lawful Grounds for Processing

We process personal data only where a lawful ground exists.

Under the DPDP Act, these grounds are: (a) your consent, given for a specified purpose after notice; and (b) certain legitimate uses recognised by the Act, including personal data you voluntarily provide for a specified purpose, employment-related purposes, compliance with law or with a judgment or order, responding to medical emergencies or threats to life or health, and other uses the Act permits.

Under other applicable laws, grounds may include performance of a contract, compliance with a legal obligation and legitimate interests.

Where processing is based on consent: we provide appropriate notice of the purpose; you may withdraw consent at any time, and withdrawing consent will be as easy as giving it; withdrawal applies prospectively and does not affect processing lawfully undertaken before withdrawal; and withdrawal may limit our ability to provide the relevant service. Some processing may continue after withdrawal where required or otherwise permitted by law.

Where applicable law provides for registered Consent Managers, we will honour consents and withdrawals validly communicated through them.

10Data Minimisation

We collect only the personal data reasonably necessary for the stated purpose, and we design our forms, systems, products and workflows to avoid collecting personal information merely because it might be useful at some future time.

Where practical, we use anonymisation, aggregation, pseudonymisation and limited identifiers to reduce unnecessary exposure of identifiable information.

11Cookies and Similar Technologies

Our websites and applications may use cookies and similar technologies for:

• Essential functions — website operation, authentication, security, session management and user preferences;
• Analytics — understanding website traffic, feature usage, performance, errors and general interaction patterns; and
• Preferences — remembering selected settings.

Where legally required, non-essential cookies are deployed only with appropriate notice and consent. You can control cookies through browser settings or a cookie-preference interface where available; disabling certain cookies may affect functionality.

We do not use behavioural-advertising or third-party advertising trackers. If that ever changes, we will update this Policy and implement any legally required choice mechanism before doing so.

12When We Share Personal Data

We do not disclose personal data indiscriminately. Personal data may be shared only in the circumstances described below.

13No Sale of Personal Data

We do not sell or rent personal data to third parties for their independent direct-marketing purposes. If this practice ever materially changes, we will update this Policy and satisfy any consent or other legal requirements applicable to such processing before implementing it.

14International Data Transfers

We may use technology infrastructure, service providers or business partners operating in jurisdictions outside India. Accordingly, certain personal data may be processed or stored outside India where applicable law permits.

We do not transfer personal data to any country, territory or recipient to which transfer is restricted by the Central Government or otherwise prohibited by applicable law, and we apply contractual protections, security controls and purpose limitation to cross-border processing.

15Customer Data Processed by P9e

A customer may provide information to P9e, or permit P9e systems to process information, relating to that customer’s employees, customers, suppliers, contractors, users or other individuals.

Where the customer determines why and how such personal data is processed and P9e processes it only on the customer’s documented instructions, P9e acts as a processor or service provider rather than independently determining the purposes of processing. In such cases:

• the customer’s privacy notice governs its relationship with the relevant individuals;
• P9e processes the information in accordance with its contractual obligations;
• P9e does not use the information for unrelated purposes unless legally permitted;
• requests concerning the information may need to be directed to the relevant customer; and
• P9e assists the customer in responding to legitimate privacy requests where contractually or legally required.

P9e enters into Data Processing Agreements or equivalent contractual data-protection provisions with enterprise customers where appropriate.

16Artificial Intelligence and Automated Processing

P9e develops, evaluates and uses artificial-intelligence and automated technologies. Where personal data is used in connection with such technologies, that use is purpose-bound, lawful, proportionate, subject to suitable access controls and consistent with our contractual obligations.

We do not use customer personal data or customer confidential data to train unrelated or general-purpose AI models merely because we have technical access to it. Where an AI-enabled product processes customer-controlled data, the applicable agreement, product documentation and any product-specific privacy notice provide additional information.

Where automated processing has a material effect on individuals and applicable law requires additional safeguards, human review or disclosure, we implement those requirements.

17Children’s Personal Data

Under the DPDP Act, a “child” is an individual under 18 years of age. Our corporate websites, engineering services and business-to-business services are not directed at children, and we do not knowingly collect children’s personal data except where required for a legitimate product or service.

Where a product or service is intended to process children’s personal data, we obtain verifiable parental or guardian consent where required, provide appropriate notice, and do not undertake tracking or behavioural monitoring of children, or advertising targeted at children, where prohibited by applicable law.

If you believe a child has supplied personal data to P9e inappropriately, contact us using the details in this Policy.

18Information Security

We use reasonable technical, organisational, administrative and physical safeguards appropriate to the nature of the information and the risks involved, including: access controls and multi-factor authentication; encryption in transit and, where appropriate, at rest; network and endpoint security; secure software-development practices; logging and monitoring; vulnerability management; backups; restricted privileged access; personnel confidentiality obligations and awareness; incident-response procedures; and vendor-security controls.

Access to personal data is limited to personnel and authorised parties who require it for legitimate purposes.

No electronic transmission, network, storage environment or security system can be guaranteed to be completely secure. While we take reasonable measures to protect personal data, absolute security cannot be guaranteed.

19Personal Data Breaches

We maintain procedures for identifying, assessing and responding to suspected personal-data and information-security incidents. Where a personal-data breach occurs, we contain the incident; investigate its scope and cause; preserve relevant evidence; mitigate foreseeable harm; remediate affected systems; and notify affected individuals and the Data Protection Board of India, or other competent authority, in the form and within the timelines required by applicable law.

If you become aware of a suspected compromise involving P9e information, contact: privacy@p9e.in.

20Data Retention

We do not retain identifiable personal data indefinitely without a continuing reason. Retention periods depend on the purpose of collection; contractual and statutory requirements, including tax and accounting requirements; the nature of the business relationship; security, dispute-resolution and litigation considerations; intellectual-property protection; and legitimate business requirements.

When personal data is no longer reasonably required and no legal or contractual obligation requires its retention, we securely delete, destroy or anonymise it, or otherwise place it beyond ordinary use. Backup copies persist for limited periods under our backup and disaster-recovery schedules before normal deletion cycles remove them.

21Accuracy of Personal Data

We seek to keep personal data accurate where it is used for decisions or operational purposes. Please inform us when material personal information you have supplied changes or is incorrect.

22Your Privacy Rights

Depending on the law applicable to the processing and the provisions in force, you may have the right to:

• obtain a summary of the personal data being processed and the related processing activities, and, where required, the identities of other data fiduciaries and data processors with whom it has been shared;
• request correction, completion and updating of your personal data;
• request erasure of personal data where its retention is no longer necessary or permitted;
• withdraw consent where processing is consent-based;
• raise a grievance through our grievance-redressal mechanism;
• nominate another individual to exercise your rights in the event of death or incapacity; and
• exercise any other rights provided by applicable law — for example, rights of access, objection or portability under the laws of other jurisdictions where they apply.

These rights are not absolute. Information may be retained where required for legal compliance, contractual obligations, taxation, fraud prevention, security, legal claims or another legally permitted purpose.

23Exercising Your Rights

Privacy requests may be submitted to: privacy@p9e.in.

Please include enough information for us to understand the request, identify the relevant information or account, and reasonably verify your identity where necessary. We will not request substantially more personal information than reasonably necessary to verify and process the request; we may seek clarification where the scope of a request is unclear; and we will respond within the timelines required by applicable law.

24Withdrawal of Consent

Where processing is based on consent, you may withdraw it through the mechanism we make available or by contacting the Privacy Contact. Withdrawing consent will be as easy as giving it.

Withdrawal applies prospectively. It may mean we cannot continue providing a service for which the relevant personal data is necessary; we will explain material consequences where appropriate.

25Marketing Preferences

You may opt out of non-essential promotional communications using an unsubscribe mechanism where provided, or via the privacy contact specified in this Policy. Opting out does not prevent communications concerning your account, service delivery, contracts, invoices, system security, important product or legal notices, or other non-promotional business matters.

26Grievance Redressal

Privacy grievances may be sent to:

Grievance Officer / Privacy Contact — Name/Designation: Praveen Pusapati, Director; P9e Microsystems Private Limited; Address: 5-3/1/R/195, Road no:3, Phase 2, RNS Colony, Boduppal, Hyderabad; Email: privacy@p9e.in.

Please provide sufficient information for us to investigate the issue. We will acknowledge, investigate and resolve grievances within the timelines required by applicable law.

If your grievance remains unresolved after our process, you may approach the Data Protection Board of India or another competent authority as provided by law.

27Third-Party Websites and Services

Our websites and products may link to websites, applications or services operated by third parties. We do not control their privacy practices, and the presence of a link does not mean P9e assumes responsibility for them. Please review the applicable third party’s privacy policy before providing personal data.

28Third-Party Integrations

Certain P9e products integrate with third-party systems such as cloud services, payment providers, identity providers, communication platforms, mapping services, analytics providers and external APIs. Information transmitted directly to a third-party service is also governed by that provider’s terms and privacy practices. We identify material integrations where appropriate.

29Business Contact Information

We frequently interact with individuals acting in their professional capacity on behalf of organisations. We may retain business contact information for reasonable relationship-management purposes, including after completion of a particular project. You may request that non-essential communications cease.

30Recruitment Data

Candidate information is used principally for recruitment and related administration. We may retain information about unsuccessful candidates for a reasonable period to maintain recruitment records, comply with applicable law, defend potential claims or consider the candidate for future roles, subject to applicable law and appropriate retention controls.

Candidates may contact the Privacy Contact regarding the handling of their recruitment data.

31Employee Data

Employees and long-term personnel are covered by a separate Employee Privacy Notice and Internal Data Protection Policy, which address employment-specific processing such as payroll, attendance, benefits, statutory compliance, access control, performance, security, asset management and workforce administration. This public Policy does not replace any more specific employee notice provided by P9e.

32Confidential, Technical and Industrial Data

Not all information handled by P9e is personal data. We also process technical, engineering, machine and industrial data, source code, telemetry, specifications, intellectual property, trade secrets, and confidential commercial and customer information. Such information is protected under contracts, intellectual-property law, confidentiality obligations and our information-security policies even where it is not personal data. This Policy primarily addresses information relating to identifiable individuals.

33Research and Analytics

We may generate aggregated, statistical or anonymised information from product or business data for analytics, engineering research, benchmarking, reliability analysis, capacity planning, cybersecurity, product improvement and business intelligence. Where information has been genuinely anonymised so that individuals cannot reasonably be identified, we may use it for legitimate business and research purposes, subject to applicable law and contractual restrictions.

34Changes to this Policy

We may update this Policy to reflect changes in law, our products, processing activities, organisation, security practices or business operations. The revised version will indicate its updated effective or revision date. Where a change materially affects how personal data is processed and applicable law requires additional notice or consent, we will take appropriate measures. Please review the current version periodically.

35Applicable Law

This Policy is interpreted in accordance with applicable Indian law, as and to the extent the relevant provisions are in force, including:

• the Information Technology Act, 2000;
• the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011;
• the Digital Personal Data Protection Act, 2023;
• the Digital Personal Data Protection Rules, 2025; and
• other applicable rules, notifications, directions and regulatory requirements.

Where P9e processes personal data subject to the laws of another jurisdiction, additional requirements may apply. Nothing in this Policy reduces any right that cannot lawfully be waived or restricted.

36Contact Us

Questions, concerns, complaints or requests relating to this Policy or P9e’s handling of personal data may be directed to:

P9e Microsystems Private Limited

Registered Office: 5-3/1/R/195, Road no:3, Phase 2, RNS Colony, Boduppal, Hyderabad

Privacy / Grievance Contact:

Email: info@p9e.in

Website: www.p9e.in

Privacy Commitment

P9e’s approach to privacy rests on the following principles:

• Collect only what is reasonably necessary.
• Use personal data for defined legitimate purposes.
• Provide appropriate transparency.
• Restrict access according to need.
• Protect information through reasonable security safeguards.
• Do not retain identifiable information without a continuing reason.
• Respect applicable individual rights.
• Never treat access to customer data as permission for unrelated use.
• Build privacy and security into system design, not as an afterthought.