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Personal Identifiable Information Policy.

Effective April 1, 2026.

Personal Identifiable Information Policy


1.   Introduction

TraCarta is committed to protecting Personal Identifiable Information (PII) collected or processed through its website, professional services, and technology platforms including SkyBoard.

This policy establishes the principles and safeguards adopted by TraCarta to ensure that personal data is collected, processed, stored, and protected responsibly and in accordance with applicable laws and industry best practices.

For the purposes of this policy, “TraCarta” refers to TraCarta, its affiliates, technology platforms, employees, partners, and authorized representatives involved in delivering services and operating digital platforms.


2.   Definition of Personal Identifiable Information

Personal Identifiable Information (PII) refers to any information that can identify an individual either directly or indirectly.

PII may include, but is not limited to:

- Full name
- Email address
- Phone number
- Residential or business address
- Identification numbers
- Professional details such as designation and organization
- IP address or device identifiers associated with an individual user
- Login credentials or account identifiers

The definition of personal data is aligned with the principles under the Digital Personal Data Protection Act, 2023.


3.   Scope of the Policy

This policy applies to all PII collected through:

- The TraCarta website
- Client onboarding processes
- Professional service engagements
- The SkyBoard SaaS platform
- Communication with clients, partners, or users

It also applies to TraCarta employees, consultants, vendors, and partners who may process personal data as part of their roles.


4.   Collection of Personal Information

TraCarta collects PII only where necessary for legitimate business purposes.

Information may be collected when:

- Users contact TraCarta through the website
- Clients engage TraCarta for services
- Users register for access to the SkyBoard platform
- Information is required for service delivery, authentication, or communication

TraCarta aims to collect only the minimum information necessary for the relevant purpose.


5.   Purpose of Processing PII

Personal information may be used for purposes including:

- Delivering professional services to clients
- Providing access to TraCarta technology platforms such as SkyBoard
- User authentication and account management
- Communication related to service delivery
- Compliance with legal or regulatory requirements
- Improving platform functionality and user experience

PII will not be used for unrelated purposes without appropriate authorization.


6.   Consent and Legal Basis

Where required under applicable law, TraCarta processes personal information based on consent provided by the individual or the organization that provides such information.

Processing may also occur where necessary for:

- Performance of contractual obligations
- Compliance with legal requirements
- Legitimate operational purposes related to service delivery

These principles align with obligations under the Digital Personal Data Protection Act, 2023.


7.   Protection of Personal Information

TraCarta implements appropriate technical and organizational safeguards to protect PII from unauthorized access, misuse, alteration, or loss.

Security measures may include:

- Role based access controls
- Secure authentication systems
- Data encryption where appropriate
- Monitoring and logging of platform access
- Secure infrastructure for hosting and storage

These safeguards apply to both internal systems and the SkyBoard platform.


8.   Access to Personal Information

Access to PII is restricted to authorized personnel who require such access for legitimate operational purposes.

Employees, consultants, and service providers are required to adhere to confidentiality and data protection obligations when handling personal information.


9.   Data Retention

Personal information is retained only for as long as necessary to fulfill the purpose for which it was collected or to comply with legal and regulatory obligations.

Once the information is no longer required, TraCarta will securely delete or anonymize the data where feasible.


10.   Disclosure of Personal Information

TraCarta does not sell or commercially distribute personal data.

Personal information may be disclosed only in the following circumstances:

- To authorized employees or service providers involved in delivering services
- Where required by law, regulatory authorities, or court orders
- Where necessary to protect the legal rights or security of TraCarta or its clients

Appropriate safeguards are applied to any such disclosures.


11.   Rights of Individuals

Subject to applicable law, individuals may have the right to:

- Request access to personal information held by TraCarta
- Request correction of inaccurate information
- Request deletion of personal information where appropriate

Requests related to personal data may be submitted through the contact channels provided on the TraCarta website.


12.   Data Breach Response

In the event of a suspected data breach involving personal information, TraCarta will take appropriate steps to investigate, mitigate potential impact, and comply with any legal reporting obligations.

13.   Policy Updates

TraCarta may update this policy periodically to reflect legal, operational, or technological developments.

Any updates will be published on the TraCarta website.


14.   Contact

Questions regarding this Personal Identifiable Information Policy or requests relating to personal data may be directed to TraCarta through the contact information available on the website.

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