PRIVACY POLICY

This Privacy Policy takes effect from [date] (“ Effective Date”) consolidates the website privacy policy and the personal data privacy policy which were posted on www.startv.com at [link] and [link] prior to [date].

Version 1.0

Star India Private Limited, Novi Digital Entertainment Private Limited, Asianet Star Communications Private Limited and Mashal Sports Private Limited (each a “Star Entity”) (all the Star Entities collectively, the “Star Group”), (also referred to as “ We” or “Us” or “Our”), value your trust and are committed to the responsible collection, use, transfer and retention your information, including your personal information.

This Privacy Policy (“Privacy Policy”) describes the practices and governs the use, handling, processing, storage, transfer and retention of: (i) information shared or received via the website www.startv.com; and (ii) your personal data or information (“Personal Information”) and/ or sensitive personal data or information (“ Sensitive Personal Information”) as defined by the Information Technology Act, 2000, and the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, as amended from time to time (“ IT Law”) that is collected or received by Star India Private Limited and other Star Entities in India or outside India, through email, via the corporate website of Star India Private Limited www.startv.com or any other mode of electronic communication or physical mode or otherwise, excluding information collected or received on the Hotstar Platform (defined below). This Privacy Policy should be read in conjunction with the Terms of Use available on www.startv.com/legal-terms-policies/ .

All Personal Information collected, received, stored, used, transferred or otherwise handled by Novi Digital Entertainment Private Limited (“Novi”) on or via www.hotstar.com (“Website”) and/or any associated mobile sites, applications and/or the services provided by the Platform on the Website is not covered by this Privacy Policy, and is subject to the privacy policy located at https://www.hotstar.com/privacy-policy .

Information including Personal Information you provide to us via a third-party site or third party platform, may be separately collected by such third party site or platform and is subject to the third-party site or platform’s privacy policy.

At the outset, please note you are under no obligation to provide any information including Personal Information to the Star Group. If you do opt to share your information including Personal Information with the Star Group, such information including Personal Information will be dealt with in accordance with this Privacy Policy. However, if you choose not to provide your Personal Information, you may not be able to: (i) enter into a relationship with the relevant Star Entity; or (ii) be provided the full extent of services, or benefits that the Star Group could have provided to you, had you provided your information including Personal Information, as applicable.

Purpose

Our primary purpose in collecting your information, including Personal Information, is for a lawful purpose connected with various functions, business, and activities of the relevant Star Entity.

Who is covered by this Privacy Policy?

Natural persons whose information, including Personal Information is either collected/ received/ possessed/ stored/ dealt with or in/ handled by the relevant Star Entity are covered by this Privacy Policy. This may include third parties, contestants, talent, vendors, suppliers, service providers, customers and other individuals with whom we deal. If you are an employee or prospective employee of a Star Entity, please refer to the Addendum to this Privacy Policy(“Addendum”), which modifies this Privacy Policy, only to the extent applicable to individuals who are applying for a job, position or internship with or already employed with a Star Entity. In the event of any inconsistency between this Privacy Policy and the Addendum, the Addendum will prevail.

What is Personal Information and Sensitive Personal Information?

Personal Information means any information which relates to you, either directly or indirectly, in combination with other information available or likely to be available with the relevant Star Entity, which is capable of identifying you and that you may have provided to the Star Group and/or which Star Group may collect. Some examples of Personal Information are your name, email address, location, phone number.

Sensitive Personal Information has the meaning ascribed to such term under IT Law, i.e. Personal Information which consists of information relating to: (i) passwords; (ii) financial information such as bank account details, or credit card details, or debit card or other payment instrument details; (iii) physical, physiological and/or mental health condition; (iv) sexual orientation; (v) medical records and history; and (vi) biometric information.

Provided that any information that is freely available or accessible in the public domain or furnished under the Right to Information Act, 2005 or any other law for the time being in force, shall not be regarded as Personal Information for the purposes of this Privacy Policy.

Unless specifically solicited by the relevant Star Entity, you must not provide Sensitive Personal Information as defined under IT Law. Any such unsolicited disclosure of Sensitive Personal Information shall be at your sole risk and liability. The relevant Star Entity hereby disclaims all liability in relation to the receipt of any such unsolicited Sensitive Personal Information.

Consent

You hereby consent to the collection, storage, use, disclosure, processing, transfer and retention of your Personal Information by the relevant Star Entity in accordance with, and for the purposes set out in this Privacy Policy. You hereby agree and acknowledge that the collection, storage, use, disclosure, processing, transfer and retention of the Personal Information by the Star Entity under the terms of this Privacy Policy is for a lawful purpose and is necessary for the business relationship between the relevant Star Entity and you. In case you are under the age of eighteen (18) years, then please do not share any Personal Information with us without having your parent or legal guardian accept this Privacy Policy on your behalf.

You may, at any point in time, withdraw your consent to the collection, storage, use, disclosure, processing, transfer and retention of the Personal Information by Star Entity, by addressing a written communication to this effect to the contact address of the Grievance Officer specified below and we will take appropriate steps to address the same within a reasonable time. However, please note that the Star Group may not be able to continue its relationship with you in the event of such withdrawal.

Disclosure and Processing Information

Your information including Personal Information may also be shared by the Star Entity with: (i) its affiliates; and (ii) third party service providers to perform functions or services on its behalf for the Star Group’s business operations. Such service provider may have limited access to your information including Personal Information needed to perform such functions, but are restricted from using your information including Personal Information for purposes other than providing services to the said Star Entity. Such Star Entity shall ensure on reasonable commercial efforts’ basis that its service providers that have access to information including Personal Information to provide the services or perform their functions for or to the Star Group, are subject to privacy protection as is required by the relevant IT Laws.

Email or any other mode of Electronic Communication or otherwise and your Information

To manage business operation of the relevant Star Entity, Star Group may need to process, store, retain or transfer your information including Personal Information on, or to a service provider’s infrastructure or cloud platform which the said Star Entity has subscribed to. Therefore, the relevant Star Entity informs you that your information including Personal Information, if collected by the said Star Entity, which you have provided to the Star Entity or that it otherwise acquired in the course of its ordinary activity, through e-mail or any other mode of electronic communication or otherwise may be processed, stored, retained or transferred to a service provider’s infrastructure or cloud platform and you expressly authorize such process, transfer, retention or storage, in India and outside India.

Disclosures to Government/ Regulatory Agencies

The Star Group cooperates with mandated government and law enforcement agencies or with any third parties pursuant to an order under law, for the time being in force, to enforce and comply with such law. We will disclose information including Personal Information to government, law enforcement officials or private parties in accordance with applicable laws as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process, to protect the property and rights of the relevant Star Entity, or a third party, to protect the safety of the public or any person, or to prevent or stop any illegal, unethical or legally actionable activity.

Mergers & Acquisitions

The Star Group may transfer or otherwise share some or all of its assets, including Your information including Personal Information including any Sensitive Personal Information, in connection with or pursuant to a merger, acquisition, reorganization or sale of assets or in the event of insolvency or bankruptcy and You consent to the same. Should such a sale or transfer occur, we will endeavour to ensure that the information including Personal Information including any Sensitive Personal Information You have provided is stored and used by the transferee in a manner that is no less stringent than under this Privacy Policy.

Retention and Accuracy of Personal Information

Personal Information provided by you is retained till the later of: (i) as long as required for the purposes for which it was collected; or (ii) for such period so as to satisfy legal, regulatory, tax and/ or accounting requirements or to protect the relevant Star Entity’s or the Star Group’s interests.

Please note that the accuracy of the Personal Information provided to us is essential and you undertake to ensure the accuracy and completeness of all Personal Information disclosed, shared, exchanged or otherwise update and notify our Grievance Officer mentioned below.

Reasonable Security Practices and Procedures

The relevant Star Entity uses ordinary industry standard technology designed to help keep your information including Personal Information safe. The secure server software (SSL) encrypts all information including Personal information you submit before it is sent to us. Furthermore, all the customer data we collect is protected against unauthorized access. To prevent unauthorized access, maintain data accuracy, and ensure correct use of information, We will employ commercially reasonable and practicable security practices and procedures and security methods and technologies. We will also ensure on reasonable commercial efforts’ basis that any agent or third party that we employ complies with the same security standards as us for the protection of your information including Personal Information.

Your Personal Information may be transferred to or maintained on computers, computer systems and computer resources located outside of your state or country where the privacy laws may not be as protective as those where you live. If You are located outside India and choose to provide Personal Information to us, please be aware that the relevant Star Entity keeps or transfers Personal Information to India and processes it there. Your submission of such Personal Information represents your agreement to that transfer.

Unfortunately, the transmission of information including Personal Information over the Internet is not completely secure. Although We strive to protect your information including Personal Data, We cannot guarantee the security of your information including Personal Data while it is being transmitted to our site; any transmission is at your own risk. Once we have received your information, we have commercially reasonable procedures and security features in place to reasonably endeavour to prevent unauthorized access.

Star Group shall exercise reasonable commercial endeavours for the prevention of the unauthorised disclosure of the information including Personal Information provided by you, but cannot guarantee security against all risks.

Changes

This Privacy Policy may be changed from time to time. You can determine when this Privacy Policy was last revised by referring to the "UPDATED ON" legend at the top of the Policy. Any changes to our Policy will become effective upon our posting or distribution of the revised Policy.

Contact Us/ Grievances

If you have any questions, grievances or complaints about this Privacy Policy or if you wish to delete or modify your Personal Information, you may contact Mr. Ketan Saitwadekar at it.security@startv.com, who is the Grievance Officer for the purposes of this Privacy Policy.

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