Privacy Policy

This Privacy Policy of 1E9 Advisors Private Limited (“1E9,” “we,” “us,” or “our”) is effective as of February 23, 2026. It describes how 1E9 collects, uses, retains, processes, transfers, and discloses information in connection with EnineSites and related website infrastructure, hosting environments, software systems, and services (collectively, the “Platform”).

This Policy applies when you access or use the Platform, communicate with us, or otherwise interact with EnineSites. Where you or the organization with which you are affiliated (“Organization”) have entered into a separate written agreement with 1E9, that agreement shall govern to the extent its terms conflict with this Policy.

Depending on the context, 1E9 may act either as a Data Fiduciary determining the purposes and means of processing, or as a Data Processor processing personal data on behalf of a Customer pursuant to contractual instructions. Where 1E9 acts solely as a Data Processor with respect to data submitted by a Customer through the Platform, the Customer remains responsible for compliance with applicable data protection laws, including the Digital Personal Data Protection Act, 2023, and data principals should direct inquiries to the relevant Customer.

1E9 collects information that you provide directly when you create an account, subscribe to services, request support, correspond with us, or otherwise submit information through the Platform. This may include your name, email address, phone number, organization details, and billing information.

We also collect information generated in connection with your use of the Platform, including technical and usage data such as IP address, browser type, device information, access timestamps, log files, and interaction data necessary to operate, secure, and improve our systems.

Where Customers use the Platform to host websites and collect personal data from their own website visitors, such data is processed by 1E9 as infrastructure provider and, in certain cases, for internal analytics as described below.

1E9 processes information to provide, operate, secure, and improve the Platform; to perform contractual obligations; to administer accounts and process payments; to communicate with you; to prevent fraud or misuse; and to comply with applicable law.

In addition to acting as a Data Processor for hosting services, 1E9 may process identifiable usage and behavioral data as an independent Data Fiduciary for internal service improvement, performance optimization, security monitoring, and fraud prevention. Such processing is limited to internal operational purposes. 1E9 does not sell personal data and does not use personal data collected through Customer websites for cross-customer profiling or unrelated marketing activities.

Payment transactions are processed through authorized third-party payment gateways. 1E9 does not store full card details and retains only limited billing identifiers as necessary for accounting and compliance.

Information may be processed in India or in other jurisdictions in which 1E9 or its service providers, including cloud infrastructure providers such as Amazon Web Services, operate. Where information is transferred across borders, 1E9 implements reasonable safeguards consistent with applicable law. Such transfers shall be conducted in compliance with Section 10 of the DPDP Act 2023, and 1E9 shall restrict transfers to any territories as may be notified by the Central Government of India from time to time.

1E9 retains information only for as long as necessary to fulfill the purposes described in this Policy, to comply with legal obligations, resolve disputes, and enforce agreements. Retention periods vary depending on the nature of the information and the context in which it was collected. Upon termination of services, Customer Data may be deleted in accordance with the applicable Terms of Use unless otherwise required by law.

Individuals may request access to, correction of, or deletion of personal information held by 1E9, subject to applicable law and contractual obligations. Individuals may also withdraw consent where processing is based on consent and seek grievance redressal. Where 1E9 processes information solely on behalf of a Customer, such requests should be directed to the relevant Customer.

By using the Platform, you agree to: (a) comply with all applicable laws while exercising your rights; (b) not furnish any false particulars or suppress any material information; and (c) not register any false or frivolous grievances. 1E9 reserves the right to take appropriate legal action for any breach of these duties as permitted under the DPDP Act. You may exercise your rights under this Policy directly through our Platform or through a Consent Manager duly registered with the Data Protection Board of India.

1E9 does not sell personal information. We may share information with service providers engaged to support hosting, infrastructure, payment processing, or security functions, who are authorized to process information only as necessary to provide services to 1E9 and who are subject to appropriate confidentiality and security obligations. We may also disclose information where required by law or where necessary to protect the security or integrity of our systems or the rights, property, or safety of 1E9, our customers, or others.

1E9 implements administrative, technical, and organizational safeguards designed to protect information against unauthorized access, disclosure, alteration, and destruction, consistent with industry standards appropriate to the nature of the services provided. While no system can guarantee absolute security, 1E9 maintains safeguards proportionate to the risks presented by the processing of information.

If required personal information is not provided where necessary to create an account, verify identity, or deliver services, 1E9 may suspend or refuse access to the Platform.

The Platform is not directed to individuals under the age of eighteen, and we do not knowingly collect personal information from such individuals.

1E9 may amend this Policy from time to time. If a revision is material, we may provide notice prior to the change becoming effective. Continued use of the Platform after the effective date constitutes acceptance of the revised Policy.

Questions, requests, or grievances regarding this Privacy Policy or the processing of personal data may be directed to privacy@eninesites.com with the subject line “Privacy Grievance.”

We will acknowledge and address grievances in accordance with the timelines and requirements prescribed under applicable law, including the Digital Personal Data Protection Act, 2023. Where we act as a Data Processor on behalf of a Customer, we will coordinate with the relevant Customer as necessary to facilitate appropriate resolution.