Privacy Policy

The web application and the associated website www.pi42.com and any of our associated websites or mobile/web applications (collectively, the “Platform”) are owned, operated and managed by LIGHTNINGNODES TECHNOLOGIES PRIVATE LIMITED (CIN: U62099GJ2023PTC143842), having its registered office at 1328, Gala Empire, Drive-in-Road, Memnagar, Thaltej Road, Ahmedabad City, Ahmedabad-380054, Gujarat (hereinafter referred to as “Pi42.com” or “Company” or “Us” or “We” or “Our”, which term shall mean and include our affiliates and group entities).

The Company operates the Platform to enable customers to engage in Crypto trading and related services. This privacy policy (“Privacy Policy”) explains how personal data is collected, used, shared, stored, and protected when you access or use the Platform. It also describes your rights in relation to your personal data and how you may exercise them. For the purposes of this Privacy Policy, “personal data” means any data about an individual who is identifiable by or in relation to such data, and includes information that you provide directly, that is provided on your behalf, or that is generated through your use of the Platform.

This Privacy Policy applies to third parties using the Platform and any other individual whose personal data may be processed through the Platform (“Users” or “you” or “your”).

This Privacy Policy covers personal data processed through the Platform operated by the Company. Please carefully read this Privacy Policy before registering on, or accessing any information, content, products, services, applications, tools, and features on the Platform or using our services. This Privacy Policy (i) shall be considered an electronic record under applicable Indian laws, including the Information Technology Act, 2000 and the rules made thereunder; and (ii) does not require any physical, electronic, or digital signature by the Company. By clicking “I Agree”, you agree that you have read, understood, and accepted each of the terms contained herein and agree to be bound by the same. This Privacy Policy does not apply to independent actions or decisions taken by users outside the Platform, nor does it apply to third-party websites, applications, or services that are not operated by the Company. Where the Platform integrates or links to third-party services, the handling of personal data by such third parties is governed by their respective privacy policies.

GUIDING PRINCIPLES

1. Pi42.com adheres to the following principles to protect your privacy.
2. Pi42.com does not share your contact information with another user of the Platform, without your consent.
3. Any personal data that you provide will be secured by industry standard protocols and technology in compliance with applicable law.

1. INTRODUCTION

1.1 This Privacy Policy specifies the manner in which your personal data is collected, received, stored, processed, disclosed, transferred, dealt with or otherwise handled by us and our affiliates in offering the Platform. This Privacy Policy will only be applicable in case Pi42.com Platform is fulfilling the role of a data fiduciary i.e., where it’s determining the means and purpose of processing of personal data. This Privacy Policy explains inter alia (i) what personal data we collect; (ii) sources from which such data may be obtained; (iii) how we use it; (iv) with whom we share it; (v) your rights and how you may exercise them; and (vi) the measures that we undertake to protect your personal data; when you use our Platform. By clicking “I Agree” you agree to the collection, use, storage and dissemination of your personal data as set out below in this Privacy Policy. The Privacy Policy does not apply to entities that Pi42.com Platform does not own or control. You should review this Privacy Policy every time you provide us with personal data. We reserve the right to change, add, amend, modify the Privacy Policy terms hereof at our discretion from time to time.

2. WHAT PERSONAL DATA WE COLLECT AND GROUNDS OF PROCESSING

2.1. This Section provides a general overview of the categories of personal data that may be collected by Pi42.com Platform and the broad purposes for which such data may be processed. A more specific notice containing the details required under applicable law, including the exact nature of personal data collected, the purpose of processing, the manner of sharing (if any), and information regarding your rights, may be provided at or before the time of collection of your personal data by Pi42.com Platform. We acknowledge and accept that the personal data that you impart to us, is to be kept in strict confidentiality and to use the personal data only in the manner which enables us to provide the services. We consider our relationship with you as invaluable and strive to respect and safeguard your right to privacy. We shall protect the personal data received from you with a reasonable degree of care, to prevent the unauthorised use, dissemination, or publication of this data. We have put in place reasonable security measures and safeguards to protect your privacy and personal data from misuse, unauthorised access, disclosure, destruction etc. in compliance with applicable laws.

2.2. As noted above, personal data is information which can be used to identify you as an individual. This includes your:

a. Personal Details, means any information including personally identifiable information that relates to you, which, whether directly or indirectly, in combination with other information available or likely to be available with us, is capable of identifying you e.g. name, age, gender, date of birth, trading preferences, etc.;

b. Contact Details, e.g. email, phone and permanent address etc.;

c. KYC Details, e.g. identification documents, viz PAN, Driving License, Identity and Address Proof, Passport or AADHAAR information, photograph, IPV (in-person verification) video, bank account details etc, other sensitive personal data received for opening of a User account;

d. Location Data: This may include information about the location of the IP address or the location details provided by you; we may collect and process your location information (such as IP-based location or device GPS data, where enabled), along with certain device identifiers and related technical information (including device ID), to verify your jurisdiction, comply with applicable laws and legal requirements, enhance platform security, and prevent fraud or misuse. e. Account Details: This may include information such as your login details, encrypted password profile information, or the details of your interaction with our platform; and

f. Transaction Details: This may include information about the transactions you undertake on the Platform such as transaction ID, amounts, wallet address, details of the source of the virtual digital assets, bank account details.

2.3. Other Details

a. Device and Network Data: This may include information such as your browser details, the operating system of your device, meta-data, app settings, device information, the date and time of your visit pages on our website, number of pages viewed etc.

b. Usage and Analytics Data: This includes information such as the Platform usage pattern, user analytics or other similar data points.

2.4. The collection of all the personal data described herein is necessary for your use of the services and functionality of the Platform. We receive personal data any time you use any service or functionality of the Platform, including the function that allows you to continue as a guest.

2.5. We also gather and store non-personal information to get page view statistics, to analyse trends and for better understanding of the usage of the site, and for system administration purposes. This information cannot and does not identify you personally.

2.6. We may collect or receive your personal data in the following ways:

a. Personal data you provide us: You may provide us with your personal data so as to enable us to provide you the services. b. Personal data we generate: We may use in-house or third-party analytics tools to help us track the usage of our services or interactions with our Platform after your explicit consent. c. Personal data we receive: We may receive your personal data from select third parties including our subcontractors and vendors; or other websites or applications we operate or the other Pi42.com services we provide subject to your consent to such sharing.

2.7. Where the Company collects personal data directly from Users, it determines the purpose for which such personal data is processed. In these situations, personal data is processed in accordance with applicable laws. In most cases, processing will be carried out on the basis of your prior consent, which may be obtained through in-app consent mechanisms or other affirmative actions at the time of collection. You have the right to withdraw consent at any time using the mechanisms provided within the Platform or by contacting us. Withdrawal of consent will not affect the lawfulness of processing undertaken prior to such withdrawal. Please note that certain categories of personal data may be necessary for providing specific features or completing transactions. If you choose not to provide such personal data, or withdraw consent for its processing, we may be unable to provide the relevant feature or service. In certain circumstances permitted under applicable law, personal data may be processed without obtaining consent. This includes situations where you have voluntarily provided personal data for a specified purpose and have not indicated any objection to its use for that purpose, or where processing is necessary to comply with a legal obligation, or where personal data is required pursuant to a judgment or order under applicable law, where personal data is necessary to respond to a medical emergency or public health situation, or where personal data is required to ensure safety or provide assistance during disasters or breakdowns of public order, or where personal data is necessary for employment-related purposes, or where personal data is required for the prevention, detection, investigation, or prosecution of an offence or contravention of law. Any such processing will be undertaken strictly within the scope permitted under applicable law.

2.8. All the personal data you share with us must be accurate and complete. You shall promptly inform Pi42.com in case of any change to your data which may impact the provision of our services. We shall not be responsible or held liable for any loss or damage that may occur to you or other third parties on account of provision of incorrect data provided by you.

2.9. We may ask you to provide us with your personal data if and when: (i) you register and make an account on the Platform; (ii) you transfer any funds from/to your linked bank account; (iii) you correspond with us by phone, e-mail chat or otherwise; (iv) you place an order on the Platform; (v) you subscribe to Pi42.com’s newsletter, if applicable, (vi) we troubleshoot problems reported by you; or (vii) you respond to a survey or fill out a form on the Platform.

3. HOW WE USE YOUR PERSONAL DATA

3.1. We primarily use the personal data we collect to provide the services to you and for your use of the services. This includes using your personal data: a. For the provision of our services: ● To provide Pi42.com services and to enable you to undertake transactions on the Platform. ● To verify your identity, fulfil your trading requests, process and complete transactions, and to carry out settlement of your obligations, including sending text messages and email notifications to you; send administrative information to you, such as changes to our terms, conditions, and policies. ● To personalise your experience on the Platform regarding offers and promotions that we deliver, contact you about new features, products etc. and perform other activities; develop new products, identify usage trends, determine the effectiveness of our promotional campaigns, and operate our business. ● To improve the Platform or the features of the Platform. ● To improve customer service. b. For verification and security purposes: ● To verify and process transactions on the Platform. ● To update and back-up our records. ● To enhance the security of our Platform and keep the same safe and secure. ● To conduct data analysis and audits, undertake financial/regulatory/management reporting. ● To analyse usage and generally improve the services; ensure the security of the services, prevent fraud and enforce our policies. c. For the purpose of our internal operations: ● To run our Platform and for other internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes. ● To detect and protect against error, fraud and other criminal or illegal activity, collect fees owed, enforce our terms and conditions; prevent abuse of our services, prevent violation of the rights of third parties, other users or the general public. d. For the purpose of communications and marketing: ● To notify you about changes to our services or Platform. ● To understand the effectiveness of advertising we provide and carry out. ● To send you information and updates pertaining to your orders. ● To send you occasional news, updates, and related information about the Platform. ● To send you relevant marketing material, if applicable. e. For legal purposes: ● To comply with any statutory or regulatory requirement. ● To prevent and identify suspicious or other illegal transactions and to mitigate risks relating to money laundering and other illegal activities.

3.2. Your personal data, whether public or private, will not be sold, exchanged, transferred, or given to any other entity except as set out in this Privacy Policy. You hereby acknowledge that Pi42.com may share your personal data for the following purposes: a. for delivering the services requested by you from the Platform; b. for carrying out know-your-customer verification and client due diligence; c. in connection with a promotion, survey or other feature; d. for sending periodic emails and other communications; and e. for the disclosure or transfer of personal data as required by, or in furtherance of our compliance with applicable laws or any judicial or governmental proceeding.

4. WITH WHOM WE SHARE IT

4.1. We may host, transfer and process data, including personal data in Indian servers.

4.2. We do not sell, trade, or otherwise transfer your personal data to third parties for profit. However, we may share the information we collect on an as-needed basis with trusted third parties and subcontractors who assist us in operating the Platform, conducting our business, or servicing you after obtaining your explicit consent. We seek to ensure that such third parties agree to keep this personal data confidential and that they ensure the same level of data protection that is adhered to by Pi42.com.

4.3. Accordingly, we may share your personal data with:

a. Law Enforcement Authorities: We may share your personal data with governmental agencies and regulatory bodies, prevention of money-laundering authorities and any other authority as required or requested for due fulfilment of legal and regulatory compliance. Where permitted under applicable law, such disclosures may be made without prior notice to the concerned individual.

b. Transaction Facilitators: We may also share the personal data so collected with third parties in connection with providing services, products and features accessed by you and where we feel they can contribute to add value and improve the quality of services offered to you. We may share your personal data with transaction facilitators who authenticate KYC and other details as provided by you, commercial banks which provide banking facilities; payment processing companies and other exchanges we may work with for providing our services. Where required under applicable law, such sharing will be undertaken on the basis of your consent obtained through clear and affirmative mechanisms. Once personal data is shared with a third-party service provider for the purpose of delivering a requested service, the subsequent processing of such personal data by that third party is governed by their respective privacy policies and terms.

c. Cloud Platforms: We may use third-party cloud service providers to store and process your personal data, including but not limited to Google Cloud platform, Microsoft Azure & Amazon Web Services.

d. Analytics Platforms: We may use certain third-party applications to perform analytics-related tasks. Such platforms include, but are not limited to Google Analytics, Microsoft Azure & Amazon Web Services.

e. Internal Disclosures: Personal data may be accessed by authorized employees, affiliates, and entities under common ownership with Pi42.com Platform strictly on a need-to-know basis for the purpose of operating the Platform, providing services, ensuring compliance with applicable law, conducting internal audits, or managing corporate operations.

4.4. We may share non-personally identifiable information with other parties. We also use certain information in an irreversible aggregated or anonymised form across users to compile statistical and demographic profiles for our business and marketing activities.

4.5. Third Party Links: Occasionally, at our discretion, we may include or offer third party products or services on the Platform. These third party sites may have separate and independent privacy policies. We have no responsibility or liability for the content and activities of these third party sites. Nonetheless, we seek to protect the integrity of the Platform and welcome any feedback about these third party sites.

4.6. Change of Control: In the event of a merger, acquisition, restructuring, reorganization, sale of assets, or other corporate transaction involving Pi42.com Platform, personal data may be disclosed or transferred to a successor entity, investor, or acquiring party, subject to appropriate confidentiality obligations and applicable legal requirements.

5. HOW WE PROTECT YOUR PERSONAL DATA

5.1. We follow applicable industry standards and best practices to reasonably secure your personal data. We use firewalls and SSLs to help protect the personal data we collect from you when it is being communicated to us. Our policies restrict access to your personal data to only those employees and service providers who need to know the information in order to provide you the services. We maintain physical, electronic and procedural safeguards that comply with applicable privacy and data security laws and regulations.

5.2. Pi42.com Platform implements reasonable technical and organisational security measures and safeguards, as noted above, to protect personal data from loss, misuse, unauthorised access, disclosure, alteration, or destruction, in compliance with applicable laws, including the DPDPA.

5.3. On becoming aware of any personal data breach, Pi42.com Platform shall, to the best of its knowledge, intimate each affected Data Principal in relation to the same with the details required under the DPDP Framework, in a concise, clear, and plain manner and without undue delay, through the User’s account on the Platform or through any mode of communication deemed appropriate by Pi42.com.

5.4. Pi42.com Platform shall also notify the Data Protection Board of India of such personal data breach, where required, in the manner prescribed under applicable law.

6. DATA RETENTION

6.1. We retain your personal data only for as long as is necessary to fulfil the purposes for which it was collected.

6.2. Where you have not approached us for the performance of the purpose for which your personal data was collected, nor exercised your rights in relation to such processing, we will erase your personal data upon expiry of the applicable retention period, unless retention is required for compliance with any law for the time being in force. Before we do so, we will notify you at least 48 hours in advance, giving you the opportunity to log into your account, contact us, or exercise your data principal rights, failing which your personal data will be erased upon completion of such period.

6.3. However, we may retain your personal data for a duration of three years from the date on which you last approached us for the performance of the purpose for which your personal data was collected or exercising your rights, or the commencement of the Digital Personal Data Protection Rules, 2025, whichever is latest.

6.4. We also retain your personal data, associated traffic data, and processing logs for a minimum period of one year from the date of processing. Upon expiry of this period, such data and logs will be securely erased, unless further retention is required under applicable law.

6.5. Regardless of the retention periods provided in this section 6, we may retain and process your personal data for a longer period where required under applicable law.

6.6. Where your personal data is no longer required for any lawful purpose, we will take reasonable steps to ensure that it is securely erased or anonymised in a timely manner.

7. YOUR RIGHTS

7.1. Where personal data is processed on the basis of your consent obtained by Pi42.com Platform, you always have the right to refuse or withdraw your consent to provide/share/disseminate your personal data and such a request must be made to us in writing. However, in such an event, you will no longer be able to avail our services. You can configure your browser or phone settings to reject all cookies, or to notify you when a cookie is set. Each browser is different, so you need to check the Help menu of your browser to learn how to change your cookie and privacy preferences. However, if you reject cookies, your use of services may be impaired, restricted or stopped. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal. In certain cases, withdrawal of consent may result in deletion or anonymization of the relevant personal data, subject to applicable legal or contractual retention requirements.

7.2. You can ask us for a summary of your personal data being processed or retained by us. You may also request details regarding the categories of personal data processed, the purposes of processing, and the identities of third parties with whom such data has been shared, subject to limitations prescribed under applicable law.

7.3. You can ask us to correct, update, or complete inaccurate or outdated personal data. In many cases, you may review and update certain profile information directly within the Platform, including contact details such as your name, email address, or phone number. If certain information cannot be modified through the Platform, you may submit a correction request to [email protected]. You are responsible for ensuring that the information you provide is accurate and up to date. Pi42.com Platform shall not be responsible for any loss arising from inaccurate or outdated information provided by you.

7.4. In accordance with applicable law, you have the right to nominate another individual who may exercise your rights in relation to your personal data in the event of your death or incapacity. The mechanism for such nomination may be prescribed by applicable law and will be implemented by Pi42.com as required.

7.5. You can close your Account. Even though your account is closed, we still may retain and use your personal data to prevent fraud, resolve disputes, assist with any investigations, and otherwise comply with applicable law for a specific period as required by any law.

7.6. If you choose not to provide your personal data or to withdraw your consent, our ability to provide you the services may be affected and we may not be able to provide you the access to our Platform or the services therein.

7.7. In order to exercise any of your rights you may send us an email at [email protected] detailing your request. We may undertake additional measures to confirm your identity.

8. YOUR DUTIES

8.1. In addition to the rights described above in Section 6, applicable law also prescribes certain duties that individuals must observe in relation to the exercise of their rights and the provision of personal data.

8.2. While using the Platform or exercising your rights under this Privacy Policy, you are required to comply with all applicable laws for the time being in force. You must not impersonate another person while providing personal data or while exercising any rights in relation to personal data.

8.3. You must not suppress any material information while providing personal data for any document, unique identifier, proof of identity, or proof of address issued by the State or any of its instrumentalities. Any information provided by you in connection with the use of the Platform or while exercising your rights must be accurate, complete, and verifiably authentic.

8.4. You must not register false or frivolous grievances or complaints with Pi42.com or with any regulatory authority, including the Data Protection Board of India. Where you exercise your right to erasure or any other statutory right, you are required to furnish only authentic and verifiable information in support of such request.

8.5. Failure to comply with the above duties may result in appropriate action as stipulated under applicable law.

9. PERSONAL DATA OF CHILDREN AND PERSON WITH DISABILITIES

9.1. The Platform is not intended to be used independently by children, being individuals below 18 (eighteen) years of age. Pi42.com Platform does not knowingly collect personal data directly from children for features that it operates independently.

9.2. Where Pi42.com becomes aware that the personal data collected relates to a child, Pi42.com Platform will take appropriate steps in accordance with applicable law, including obtaining verifiable consent from the parent or lawful guardian or discontinuing processing where required.

9.3. Pi42.com does not knowingly undertake tracking, behavioural monitoring, or targeted advertising directed at children in violation of applicable law.

9.4. If you believe that personal data relating to a child has been provided to Pi42.com without appropriate authorization, please contact us at [email protected] we will take appropriate steps in accordance with applicable law.

9.5. The Platform and Services are designed to be inclusive and accessible to all individuals, including persons with disabilities. For the purposes of this Privacy Policy, a person with disability refers to an individual with a long-term physical, mental, intellectual, or sensory impairment that may hinder full and effective participation on an equal basis with others, while being legally competent to contract.

9.6. If you are a User with a disability and require assistance in accessing or using the Platform, you may contact us at [email protected], and we will make reasonable efforts to provide necessary support to facilitate access to the Services.

10. DISCLAIMER

10.1. We do not make any express or implied warranties about the Platform, including but not limited to implied warranties of merchantability, fitness for a particular purpose, or non-infringement. The Platform is made available to you “as is” and “as available” and we do not warrant that any defects or inaccuracies will be corrected.

10.2. We do not warrant that the Platform will meet your needs, or that the Platform or access to it will be uninterrupted, timely, secure, or error-free. We also provide no warranty that the results obtained from the use of the Platform will be accurate or reliable, or that the quality of any products, services, information, or other material obtained by you through the Platform will meet your expectations.

11. GRIEVANCES

11.1. If you have any grievance, related to your data privacy, and/or objection or complaint about Pi42.com or any incident concerning these Privacy Policy, you may contact our grievance officer, Mr Prajwal B by sending an email to [email protected] and in furtherance thereto, provide us with all the necessary/relevant assistance, information and/or documents concerning such matter. We will undertake reasonable/fair/appropriate efforts to investigate and resolve your complaint.

11.2. By lodging a complaint, you agree to provide complete support to the grievance redressal officer, and such reasonable information as may be sought from you. We aim to resolve the complaints as soon as possible.

11.3. The grievance redressal officer shall acknowledge your grievances, or complaints or concerns with respect to the Platform or the Services, within 120 hours of receipt of the same and shall endeavour to respond to the same at the earliest, but not later than 90 (ninety) days.

11.4. If you have exhausted your opportunity of redressing your grievances concerning your personal data with us and you are not satisfied with the resolution, you may raise your concern to the Data Protection Board of India, once formed and effective.

11.5. While you have the right to raise complaints with both Pi42.com Platform and the Data Protection Board of India, please note that registering false or frivolous complaints with the Data Protection Board is a punishable offence.

Last updated on: 28th August, 2026