Terms of Use

1. Acceptance of Terms

By accessing or using the Service, you agree to be bound by these Terms of Use and our Privacy Policy.
If you do not agree to these Terms, you must not access or use the Service.

2. Definitions

• “Service” means the website, platform, applications, software, and related services provided by the Company.
• “User”, “you”, or “your” means any person or entity accessing or using the Service.
• “Company”, “we”, “us”, or “our” means Apply Gateway Ltd.
• “Personal Data” means any information relating to an identified or identifiable natural person.
• “Applicable Law” means all laws, regulations, and binding regulatory requirements applicable to the Service, including data protection and information security laws.

3. Compliance Framework

We maintain an information security and privacy compliance program designed to support recognized
security and privacy standards and legal requirements, including:

• ISO/IEC 27001-aligned information security management practices;
• SOC 2-aligned security, availability, confidentiality, processing integrity, and privacy controls, as applicable;
• The General Data Protection Regulation (GDPR), where applicable; and
• The Digital Personal Data Protection Act, 2023 (DPDP Act), where applicable.

Our controls are designed to support the confidentiality, integrity, availability, and protection of data
processed through the Service.

4. Eligibility and Authorized Use

You may use the Service only if you have the legal capacity to enter into a binding agreement and
only in compliance with these Terms and Applicable Law.

If you use the Service on behalf of an organization, you represent and warrant that you are authorized
to bind that organization to these Terms.

5. Acceptable Use and Security Obligations

You agree that you will not:

• Attempt to gain unauthorized access to the Service, accounts, networks, or systems;
• Probe, scan, test, or exploit vulnerabilities without prior written authorization;
• Introduce malware, ransomware, spyware, viruses, or other malicious code;
• Reverse engineer, decompile, disassemble, copy, scrape, or otherwise misuse the Service;
• Circumvent authentication, access restrictions, encryption, or other security controls;
• Use the Service in a manner that is unlawful, fraudulent, abusive, or infringes the rights of others; or
• Upload or transmit data that you do not have the right to process or disclose.

You agree that you will:

• Use the Service only for lawful and authorized purposes;
• Follow reasonable technical, administrative, and organizational security requirements communicated by us;
• Maintain appropriate safeguards over credentials and devices used to access the Service; and
• Promptly report any suspected security incident, vulnerability, misuse, or unauthorized access involving the Service.

6. Account Security and Access Control

You are responsible for maintaining the confidentiality of your login credentials and for all activities
conducted through your account.

• You must provide accurate and complete account information.
• You must not share credentials except as expressly authorized.
• You must enable multi-factor authentication where available, if required by us or by your organization.
• You must notify us immediately of any suspected unauthorized access or compromise of your account.

We reserve the right to suspend, restrict, or terminate access where necessary to protect the Service,
Users, data, or compliance obligations.

7. Data Protection and Privacy

We process Personal Data in accordance with our Privacy Policy and Applicable Law. Depending on the
context of processing, we may act as a data controller, business, processor, or service provider.

7.1 GDPR

Where GDPR applies, we process Personal Data on an appropriate lawful basis, including where relevant:

• Consent;
• Performance of a contract;
• Compliance with legal obligations;
• Legitimate interests; and
• Other lawful bases recognized under GDPR.

Subject to applicable conditions and limitations, data subjects may have rights including:

• Right of access;
• Right to rectification;
• Right to erasure;
• Right to restriction of processing;
• Right to data portability;
• Right to object; and
• Rights related to withdrawal of consent and complaints to a supervisory authority.

7.2 DPDP Act

Where the DPDP Act applies, we process digital personal data in accordance with lawful purposes, including consent or other recognized legitimate uses under Applicable Law.

Data principals may have rights including:

• Right to access information about personal data processing;
• Right to correction and erasure;
• Right to grievance redressal; and
• Right to nominate, where applicable under law.

7.3 User Responsibilities for Data

You agree that you will not upload, submit, or otherwise process through the Service:

• Personal Data without proper notice, consent, or other legal basis where required;
• Special category, sensitive, or restricted data unless expressly authorized by us in writing and legally permitted;
• Data obtained unlawfully or in violation of third-party rights; or
• Excessive, irrelevant, or unnecessary personal data for the intended use of the Service.

8. Confidentiality

You agree to protect all non-public, confidential, proprietary, or restricted information accessed
through the Service using reasonable safeguards and at least the same degree of care you use to
protect your own confidential information, but no less than a reasonable standard of care.

You must not disclose such information except:

• As authorized in writing by the Company;
• As necessary for permitted use of the Service; or
• As required by law, provided that legally permitted notice is given where appropriate.

These confidentiality obligations survive termination of your use of the Service.

9. Security Monitoring, Logging, and Incident Response

To maintain the security and integrity of the Service, we may monitor, log, review, and analyze system,
account, access, and usage activity to detect threats, investigate misuse, enforce these Terms, and
meet legal, regulatory, and audit obligations.

We maintain incident response procedures designed to identify, contain, assess, remediate, and document
security incidents. Where required by Applicable Law, we may notify affected parties or authorities.

You must promptly notify us if you become aware of:

• A security vulnerability affecting the Service;
• Unauthorized access or disclosure of data;
• Misuse of an account; or
• Any other event that may materially affect the security, confidentiality, integrity, or availability of the Service.

10. Data Processing and International Transfers

Where required, the parties may enter into a separate Data Processing Agreement (DPA) governing the
processing of Personal Data.

If Personal Data is transferred across borders, we may rely on appropriate safeguards as required under
Applicable Law, including contractual protections such as Standard Contractual Clauses where relevant.

11. Service Availability and Security Disclaimer

We implement reasonable technical and organizational safeguards designed to protect the Service and data
processed through it. However, no method of transmission, storage, or security control is completely secure.

Accordingly, the Service is provided on an “as is” and “as available” basis, and
we do not guarantee that the Service will be uninterrupted, error-free, or immune from unauthorized access,
downtime, or other security events.

12. Intellectual Property

The Service, including its software, design, text, graphics, logos, trademarks, databases, and other
content, is owned by or licensed to the Company and is protected by intellectual property and other laws.

You may not, without our prior written consent:

• Copy, reproduce, distribute, modify, create derivative works from, or publicly display the Service;
• Reverse engineer, decompile, or attempt to extract source code, except where prohibited by law from restricting such rights; or
• Use our trademarks, branding, or proprietary materials in a misleading or unauthorized way.

13. Third-Party Services and Subprocessors

The Service may integrate with or rely upon third-party services, infrastructure providers, subprocessors,
or external platforms. We are not responsible for third-party services except as expressly stated by us.

Where applicable, we may use vendors or subprocessors that support our security and privacy obligations,
subject to appropriate diligence and contractual safeguards.

14. Suspension and Termination

We may suspend, restrict, or terminate your access to the Service immediately, with or without notice,
if we reasonably determine that:

• You have violated these Terms;
• Your use creates a security, privacy, legal, or operational risk;
• We are required to do so by law, regulation, court order, or governmental authority; or
• Your actions may harm the Service, other users, or the Company.

Upon termination, your right to use the Service will cease immediately, but provisions that by their nature
should survive termination will remain in effect.

15. Indemnification

You agree to defend, indemnify, and hold harmless the Company, its affiliates, officers, directors,
employees, and agents from and against any claims, liabilities, damages, losses, costs, and expenses,
including reasonable legal fees, arising out of or related to:

• Your use or misuse of the Service;
• Your breach of these Terms;
• Your violation of Applicable Law; or
• Your infringement of any third-party right.

16. Limitation of Liability

To the maximum extent permitted by Applicable Law, the Company and its affiliates, officers, directors,
employees, agents, licensors, and service providers will not be liable for any indirect, incidental,
special, consequential, exemplary, or punitive damages, or for any loss of profits, revenues, data,
goodwill, or business opportunities, arising out of or related to the Service or these Terms.

To the maximum extent permitted by Applicable Law, the total aggregate liability of the Company for all
claims arising out of or relating to the Service or these Terms shall not exceed the greater of:
(a) the amount paid by you to the Company for the Service during the twelve (12) months preceding the event
giving rise to the claim; or (b) INR 10,000 / USD 100, unless otherwise agreed in writing.

Nothing in these Terms excludes or limits liability to the extent such exclusion or limitation is prohibited by law.

17. Changes to the Terms

We may modify these Terms from time to time to reflect changes in the Service, legal requirements,
regulatory obligations, security measures, or business practices.

Updated Terms will be posted on this page with a revised “Last Updated” date. Your continued use of the
Service after updated Terms become effective constitutes your acceptance of those changes.

18. Governing Law and Jurisdiction

These Terms shall be governed by and construed in accordance with the laws of [Insert Jurisdiction],
without regard to conflict of laws principles.

Subject to mandatory legal rights under Applicable Law, the courts located in [Insert Jurisdiction]
shall have exclusive jurisdiction over disputes arising out of or relating to these Terms or the Service.

19. Miscellaneous

• If any provision of these Terms is found unenforceable, the remaining provisions will remain in full force and effect.
• Our failure to enforce any provision of these Terms shall not constitute a waiver of that provision.
• You may not assign or transfer these Terms without our prior written consent. We may assign these Terms as part of a merger, acquisition, reorganization, or sale of assets.
• These Terms, together with any incorporated policies or agreements, constitute the entire agreement between you and the Company regarding the Service, unless superseded by a separate written agreement.