Kalmacure Private Limited ("Company", "we", "our", "us") respects an individual’s privacy and is committed to protecting the same. We are a company duly incorporated under the provisions of the Companies Act, 2013.

This Privacy Policy (“Policy”) describes how we collect, use, disclose and transfer Personal Information (as defined below), through https://trymanicule.com (“Website”) of the individuals who browse, or access the Website or provide information on or through the Website, or whose information the Company otherwise collects, receives or processes in connection with the offer and sale of its products (“Products”) (hereinafter, collectively referred to as “Customers”, “you”, “your”, “yourself”) and ensure its compliance with applicable laws and regulations. This Policy does not apply to Personal Information collected from you offline (unless otherwise specified), to Customers of countries other than India or to third-party websites to which the Website may link.

This Privacy Policy is a legally binding document between you and Kalmacure Private Limited (“Manicule”, terms defined below). The terms of this Privacy Policy become effective upon your access to or use of the Website. By accessing, browsing, or using the Website, or by providing any personal information through the Website, you acknowledge that you have read, understood, and agree to the practices described in this Privacy Policy.

By accessing the Website, or by seeking to avail of certain Products and Services (as defined in the Terms and Conditions), or by otherwise providing or accessing any information through the Website, you are required to agree to our Terms and Conditions (“Terms”) and acknowledge that your information will be stored, used and accessed in accordance with this Privacy Policy. For the purposes of this Privacy Policy, unless defined hereunder, all capitalised terms shall have the meaning ascribed to them under the Terms of Use.

This Privacy Policy (“Privacy Policy”) is an electronic record in the form of an electronic contract formed under the Information Technology Act, 2000 and the rules made thereunder and the amended provisions pertaining to electronic documents/records in various statutes as amended by the Information Technology Act, 2000. This Privacy Policy shall be construed in accordance with the provisions of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data of Information) Rules, 2011 under the Information Technology Act, 2000, that require publishing of the Privacy Policy for collection, use, storage and transfer of sensitive personal data or information. This Privacy Policy does not require any physical, electronic or digital signature.

This document is published in compliance with, inter alia:

• Section 43A of the Information Technology Act, 2000 (“IT Act”);
• Regulation 4 of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information) Rules, 2011 (“SPDI Rules”);
• The Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021 (“Intermediary Guidelines”);
• The Consumer Protection Act, 2019;
• The Consumer Protection (E-Commerce) Rules, 2020;
• The Digital Personal Data Protection Act, 2023 (“DPDP Act”); and
• The Digital Personal Data Protection Rules, 2025 (“DPDP Rules”).

This Privacy Policy explains: (i) what information we receive from you; (ii) how we collect and use that information; (iii) how you can provide information selectively, access and update the information; and (iv) how we process, share and protect your information.

Please read this Privacy Policy carefully. By using the Website, you indicate that you understand, agree and consent to this Privacy Policy. This Privacy Policy is applicable to all users accessing or using our Website. If you do not agree with the terms of this Privacy Policy, please do not use this Website. By accessing or using our Website or by otherwise giving us your information, you confirm that you have the capacity to enter into a legally binding contract under Indian law, in particular the Indian Contract Act, 1872, and have read, understood and agreed to the practices and policies outlined in this Privacy Policy and agree to be bound by it.

This Website is directed to be used by adults only who are above the age of 18 years. If you are not an adult, you may look at our Website, but you should not make a purchase, register, or submit personal information to us. We do not knowingly collect information from minors. Minors should not use this Website to submit any personal information. In the event of default by a minor, the parent or guardian will be liable to compensate for any damages arising out of such wrongful use by the minor.

If we become aware that personal data of a child has been collected without verifiable parental consent, we will take steps to delete such information.

You further agree and consent to receive all communications related to our services on the mobile number provided by you to the Company, even if such mobile number is registered under the DND/NCPR list under the Telecom Commercial Communications Customer Preference Regulations, 2018 (“TRAI Regulations”). Notwithstanding your registration with the National Do Not Call Registry (fully or partly blocked category under the National Customer Preference Register set up under the Telecom Regulatory Authority of India), you hereby express your interest and accord informed consent to receive communications (including commercial communications) in relation to the Company’s services. You further confirm that no communication to you from the Company or on behalf of the Company shall be construed as an Unsolicited Commercial Communication under Regulation 2(bw) of the TRAI Regulations, and that you have specifically opted to receive communications in this regard on the mobile number provided by you.

We review and may make changes to this Policy from time to time. When changes are made, the Policy link will include a notation “Last Updated (date)” indicating that you should review the new terms, which will be effective immediately upon posting, with an updated effective date. By accessing the Website after any changes have been made, you signify your agreement on a prospective basis to the modified Policy and any changes contained therein.

If you are accessing or using the Website from an overseas location, you do so at your own risk and shall be solely liable for compliance with any applicable local laws.

By providing us your information or by making use of the facilities provided by the Website, you hereby consent to the collection, storage, processing, use, sharing, disclosure and transfer of any or all of your Personal Information and Non-Personal Information by us as specified under this Privacy Policy. You further agree that such collection, use, storage and transfer of your information shall not cause any loss or wrongful gain to you or any other person.

Kalmacure Private Limited acts as a Data Fiduciary under the Digital Personal Data Protection Act, 2023.

If you do not agree with this Privacy Policy at any time, in part or as a whole, write to us at care@trymanicule.com. Please do not use the Website or the services provided on the Website, or provide us with any of your information.

1. How Do We Collect Your Personal Information?

We communicate with you through a variety of means and channels, including our Website, email, phone or text messaging on your mobile phone. Such communications may involve giving to you, as well as receiving information from you. We collect and receive Personal Information whenever you browse or use the Website, register an account, place an order, contact customer support, participate in a promotion or survey, or otherwise interact with us.

2. What Information Do We Collect?

The Company limits itself to collecting information which is necessary to ensure accurate services and is required to process your order of the Product or provide a refund, and to continually improve our Products and services. We collect and process the following information about you:

• your name, phone number, email address, postal address, PIN code;
• date of birth, sex, language preference, location;
• any open data and public records, such as information about you that is openly available on the internet;
• your occupation, interests, product interest information and, in certain circumstances, your opinions and individual preferences; and
• we may also verify your phone number or email address with the help of a one-time password sent to your phone number and email address.

For the purpose of this Policy, the term “Personal Information” shall mean any information that relates to you, which, either directly or indirectly, in combination with other information available or likely to be available with the Company, is capable of identifying you, which is submitted to and/or collected over the Website and maintained by the Company in an accessible form, 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 Policy.

The IT Act and the SPDI Rules regulate the collection, usage, retention and disclosure of personal information, which is defined under the SPDI Rules as any information that relates to a natural person, which, either directly or indirectly, in combination with other information available or likely to be available to a body corporate, is capable of identifying such person. The SPDI Rules further define sensitive personal data or information of a person as personal information about that person relating to:

• passwords;
• financial information such as bank accounts, credit and debit card details or other payment instrument details;
• physical, physiological and mental health condition;
• sexual orientation;
• medical records and history;
• biometric information;
• any detail relating to the above clauses as provided to the body corporate for providing services; and
• any of the information received under the above clauses by the body corporate for processing, stored or processed under lawful contract or otherwise.

You provide all information to us voluntarily. Collection, use and disclosure of Personal Information and SPDI requires your express consent. You are providing us with your consent to our use, collection and disclosure of the Personal Information and SPDI. You may choose not to provide us with Personal Information and SPDI, but in that event, we may be unable to provide you access to some aspects of our Website.

As we deal in health and wellness Products, certain order and support interactions may involve you voluntarily sharing information about your health, wellness goals or medical history (for example, when seeking product recommendations or raising a support query). Such information is collected only where you choose to share it, is used solely for the purpose of providing the relevant Product recommendation or resolving your support query, and is subject to the additional safeguards described in this Policy. We do not otherwise intentionally collect sensitive personal data such as biometric identifiers or sexual orientation through the Website.

For the purposes of the Digital Personal Data Protection Act, 2023, Kalmacure Private Limited acts as a “Data Fiduciary” with respect to personal data collected through the Website.

3. What Is the Use of This Information?

The information supplied by users enables us to improve our offerings and provide you with the most user-friendly experience. We may use your information for the following purposes:

• To operate, maintain, protect, and improve our Website, Products and services (including advertising services), develop new Products and services, deliver a user-friendly experience and improve our business as a whole;
• To enable your access to our Website to purchase Products and provide services;
• To verify your identity;
• To process and deliver your order with us;
• To communicate with you about your account and activities on the Website and to respond to your requests;
• To ask for ratings and reviews of the Products and to respond to reviews, comments, or other feedback provided to us;
• To administer a contest, promotion, survey or other site feature;
• To manage sign-ups for our newsletter, and respond to a survey or marketing communication;
• To follow up with you after correspondence (live chat, email or phone enquiries);
• To allow you to log in with a social media account and share activities on your social media pages;
• To help us learn more about your shopping preferences;
• To analyse data, track trends, build algorithms, and create databases for rating systems and recommendation engines;
• To conduct marketing and performance research to help us measure our customer service, benchmark our performance, and improve your Product and shopping experience;
• To conduct internal research on our customers’ demographics, interests and behaviour to better understand and serve you;
• To provide you with exclusive offers on the Website, tailor content and advertisements, and improve the Website;
• To analyse trends, track customers’ web page movements, and identify you and your shopping cart for aggregate use;
• For non-targeting reasons such as frequency capping, compliance, billing, ad reporting or delivery, and market research or product development purposes;
• To determine which offline locations carrying our Products may be closest to you, and to provide promotional offers;
• To comply with applicable law, legal obligations, policies and procedures, including relevant industry standards and enforcement of our Terms;
• To conduct audits and quality assessment procedures;
• To troubleshoot problems and improve our Products and services using information regarding your mobile device and software;
• To send communications related to order updates, offers and new Products or services through email, SMS and social media channels;
• To prevent, detect, investigate and take action against fraud, other illegal activities, or threats to the safety of any person, or violations of our Terms;
• To respond to your queries and communicate information to you, including notifications of promotions, alerts, and changes to the Website or its fees;
• To establish, exercise or defend legal rights in connection with legal proceedings and to seek professional or legal advice;
• To comply with any applicable law, regulation, legal process or enforceable governmental request; and
• To contact you by SMS, email and phone to record your feedback on our Products and services.

(Collectively, the above constitute “the Purposes”).

You can withdraw your consent as per this Policy, where applicable, and can also opt out of receiving non-essential communications such as promotional and marketing-related information regarding our Products and services. For either, please contact us at care@trymanicule.com.

We may also collect and/or generate anonymised and aggregated information from your use of the Website. Anonymised or aggregated information is not Personal Information since we are not able to re-identify you using any means available to us. We use such information for internal analysis, analytics and research, and may share it with third parties in an anonymised or aggregated form designed to prevent anyone from identifying you.

We maintain a social media presence, such as Facebook, Instagram, LinkedIn and X (Twitter). You can interact with us through social media, such as by entering our contests, posting content, sharing material from our Website, and using our social media plug-ins. When you interact with us using social media, we may receive information such as your user ID, profile picture, photos you post, and similar information, which is often determined by your privacy settings at the relevant social media site. Your use of social media sites is primarily governed by the site operators’ privacy policies and terms of service.

If you use the Website, you are responsible for maintaining the confidentiality of your access information and password and for restricting access to your computer or mobile device. We cannot secure any information that you release on your own or that is released through a third party to whom you have given access.

In case of our customer care support, we may record calls for quality and training purposes.

4. How Do We Share the Information?

Only persons authorised by us shall have access to your Personal Information. We do not rent or sell your Personal Information to any third party. We may disclose your Personal Information and SPDI to third parties in the manner and for the limited purposes specified below:

• We may disclose your Personal Information to our logistics partners for processing of orders placed by you on the Website;

• We may disclose Personal Information to service providers involved in order fulfilment or product delivery;

• We may disclose your Personal Information and SPDI to doctors and other qualified health and wellness experts, solely to help us improve our Products, services or the guidance we offer;

• We may disclose information to our partners, affiliates, investors, stakeholders or potential associates in an anonymised and aggregate manner, to help us create a better overall experience for you;

• We may share information within our group companies and their officers and employees for the purpose of processing personal information on our behalf, subject to appropriate confidentiality and security obligations;

• We may share aggregated, anonymous information about users with our clients, partners and other third parties so they may be aware of the nature and number of users, and to serve advertisements or marketing information relevant to you on our Website;

• Should we plan to merge or sell all or substantially all of our business, or undertake a similar transaction, we may transfer or disclose your Personal Information to the relevant business entity for the purposes of evaluating or operating that transaction;

• We may retain other companies and individuals to perform functions on our behalf consistent with this Policy, such as order processing, courier and logistics companies, data analysis firms, customer support specialists, email vendors, web-hosting companies and fulfilment companies;

• In some instances, you may be offered the opportunity to consent to sharing your information with a third party such as an event or promotion co-sponsor. If you consent, we will share your information with that third party for their own purposes, in accordance with their own policies; and

• We will disclose your Personal Information and SPDI if legally required to do so, pursuant to an order from a governmental entity, or in good faith to conform to legal requirements, protect our rights or property, prevent a crime or protect the personal safety of our users or the public.

Meta Business Tools: We share certain data with Meta Platforms, Inc. (“Meta”) through integrated Meta Business Tools, including the Meta Pixel and Conversions API. Data shared with Meta may include website event data (such as page views, purchases and add-to-cart actions), device and browser information, IP address, and hashed customer identifiers (such as email address and phone number), for the purposes of advertising measurement, optimisation, and audience targeting. This sharing is governed by Meta’s Platform Terms and Data Use Policy. You may control how Meta uses your data for advertising by visiting your Facebook Ad Preferences at https://www.facebook.com/adpreferences.

We may share personal data with trusted service providers who assist in operating our business, including:

• payment gateway providers;

• logistics and delivery partners;

• analytics and advertising platforms;

• cloud hosting providers; and

• customer service and communication platforms.

These parties process personal data only on our behalf and are contractually obligated to protect such data.

Personal data may be transferred outside India only in accordance with applicable Indian data protection laws, including the Digital Personal Data Protection Act, 2023 and any government notifications regarding permitted jurisdictions. Subject to applicable law, we may, at our sole discretion, transfer Personal Information and SPDI to any other body corporate (as defined under the Information Technology Act, 2000) that ensures at least the same level of data protection as is provided by us under this Policy, whether located in India or elsewhere.

By using our Website with Meta Business Tools enabled (such as the Meta Pixel), certain data may be transferred to Meta Platforms, Inc., which is headquartered in the United States. Such transfers are conducted in compliance with applicable data protection laws and Meta’s Data Use Policy. By continuing to use the Website, you consent to such transfers.

Any third party to which we transfer or sell our assets, or with which we merge or consolidate, will have the right to continue to use the Personal Information or SPDI provided to us by you, in accordance with the Terms and this Privacy Policy.

5. How Do We Store the Information?

We may store Personal Information using our own secure on-site servers or other internally hosted technology. Your Personal Information may also be stored by third parties, via cloud services or other technology, with whom the Company has contracted to support the Company’s business operations. These third parties do not use or have access to your Personal Information other than for cloud storage and retrieval, and the Company requires such parties to employ at least the same level of security that we use to protect your Personal Information.

6. Third Party Links

This Policy discloses the privacy practices for our own Website only. The Website may include hyperlinks to third-party websites, applications, content or resources (“Third Party Links”) that are beyond our control. We are not responsible for the collection or disclosure of your information by any external sites, applications, companies or persons. The presence of a Third Party Link on our Website cannot be construed as a recommendation or endorsement of it.

We are not liable for any loss or damage which may be incurred by you as a result of the collection and/or disclosure of your information via Third Party Links, or as a result of any reliance placed by you on the completeness, accuracy or existence of any advertising, products, services or other materials available via such Third Party Links. Such third-party websites and applications may have their own privacy policies governing the collection and use of your information, and we recommend that you review those policies before engaging with them.

If you post any comments or content on our Website, any information you choose to provide there may be read, collected, or used by third parties. We are not responsible for the information you choose to submit and cannot guarantee that third parties have not made copies of, or will not use, such information.

We use third-party analytics services to evaluate your use of the Website, compile reports on activity, collect demographic data, analyse performance metrics, and evaluate other information relating to the Website and mobile and internet usage. These third parties use cookies and other technologies to help analyse and provide us with this information, and, in some cases, connect it with other data held by us or by third-party environments. You consent to the processing of information about you by these analytics providers in the manner and for the purposes set out in this Policy.

7. Do We Use Cookies?

We may track your preferences and activities by utilising “cookies” and other tracking technologies, including session or local variables. A “cookie” is a small data file used to collect information about activity on the Website and transferred to your device’s hard drive by a web browser (if you allow it). Cookies keep a record of your activities on the Website, making subsequent visits more efficient.

Tracking technologies may record information such as internet domain and host names, internet protocol (IP) addresses, browser software and operating system types, stream patterns, and dates and times the Website is accessed. Your IP address does not identify you personally. We use this information to deliver our web pages to you, tailor the Website to the interests of our users, measure traffic within our site, and let advertisers know the geographic locations from which our visitors come.

Most browsers are designed to accept cookies by default, but they can be modified to block cookies. You may refuse all cookies on your browser by changing your settings to the extent permissible on your device. However, doing so may prevent you from using certain features of the Website or taking full advantage of its offerings; you will still be able to place orders.

Meta Pixel and Conversions API: We use the Meta (Facebook) Pixel and Conversions API to track interactions on our Website — such as page views, product views, add-to-cart actions, checkout initiation, and purchases. This data helps us measure advertising performance, personalise content, and improve your shopping experience.

Your Controls Over Meta Data: In addition to browser cookie controls, you can manage how Meta uses your data by: (i) adjusting your Ad Preferences on Facebook at https://www.facebook.com/adpreferences; (ii) opting out of interest-based advertising through the Digital Advertising Alliance at https://www.aboutads.info/choices; and (iii) adjusting your device-level advertising settings on your mobile device. Please note that opting out of interest-based advertising does not mean you will stop seeing advertisements; rather, the ads you see may be less relevant to your interests.

8. Changes to Your Information and Data Deletion

You may review, correct, update, change or delete your Personal Information relating to registration and order information by writing to us at care@trymanicule.com. We will comply with such requests within a reasonable time, unless we are required to keep certain information for legal purposes.

Should you choose to delete or modify your Personal Information or SPDI in a way that is not verifiable by us, or that renders it incorrect, we may be unable to provide you with access to our Website or Services, and such deletion or modification may be treated as your seeking to discontinue access to our Website and Services.

We reserve the right to verify and authenticate your identity and Personal Information to ensure accurate delivery of Products and Services. Access to, or correction, updating or deletion of, your Personal Information or SPDI may be denied or limited by us if it would violate another person’s rights or is not otherwise permitted by applicable law.

How to Request Deletion of Your Data: You may request deletion of your personal data at any time by emailing us at care@trymanicule.com with the subject line “Data Deletion Request.” Upon receiving your request, we will verify your identity and delete your personal data from our systems within 30 days, unless retention is required by applicable law or for legitimate business purposes (such as fulfilling a pending order or complying with tax and accounting obligations). Where we have shared your data with third parties (including Meta Platforms, Inc.), we will take reasonable steps to inform such third parties of your deletion request. You may also request deletion of data collected via Meta Business Tools by contacting Meta directly through your Facebook account settings.

9. Information Security

We take appropriate security measures to protect against unauthorised access to, or unauthorised alteration, disclosure or destruction of, data. These include internal reviews of our data collection, storage and processing practices, and appropriate encryption and physical security measures to guard against unauthorised access to systems where we store personal data.

We endeavour to maintain physical, technical and procedural safeguards appropriate to protect your information against accidental, unlawful or unauthorised access, disclosure, destruction, loss, alteration, misuse, copying or damage. We restrict access to Personal Information to employees and agents who need it to process it on our behalf, and who are subject to strict contractual confidentiality obligations. No employee or administrator of the Company will have knowledge of your account password.

We shall not be liable to any user for any loss or damage caused due to the unauthorised access or misuse of Personal or Sensitive Information by any third party, and we cannot guarantee that information you supply will not be intercepted while being transmitted to us over the internet. It is important that you protect against unauthorised access to your password and mobile phone. You must log off from the Website when you have finished using it. If you suspect any unauthorised use of your account, notify us immediately using the contact details in the Grievance Redressal section below.

In the event of any data breach affecting personal data, the Company will take appropriate steps to mitigate the breach and will notify affected individuals and relevant authorities where required under applicable law.

10. Information Retention and Disposal

We will retain your Personal Information only for as long as necessary to fulfil the purposes described in this Policy or as required by applicable law. Typical retention periods include:

• Order and transaction data: up to 8 years, for tax and accounting compliance;

• Customer account data: until account deletion or inactivity for an extended period;

• Marketing communication data: until you opt out; and

• Customer support records: up to 3 years.

We shall take reasonable steps to delete or permanently de-identify Personal Information that is no longer needed. Our SPDI is destroyed and/or anonymised as soon as it is reasonable to assume that the purposes for which it was collected have been fulfilled and retention is no longer necessary for any other reason.

If you wish to withdraw your consent for processing your Personal Information and SPDI, cancel your account, or request that we no longer use your Personal Information and SPDI to deliver our Products or Services, please contact us at care@trymanicule.com. Please note that your withdrawal of consent or cancellation of account may result in us not being able to deliver Products or Services to you, or in the termination of any existing relationship we may have with you.

11. Withdrawal of Consent

If you have consented to the collection, use and/or disclosure of your Personal Information as identified in this Policy, you have the right to withdraw this consent at any time by writing to us at care@trymanicule.com. Any processing carried out before withdrawal of your consent remains lawful. Notwithstanding such withdrawal, we may retain information to comply with our legal obligations, resolve disputes, and enforce our agreements.

If you do not wish to receive any promotional or marketing communications from us, you can write to us at the email above or click the “unsubscribe” link at the bottom of any promotional email you receive.

You can request removal of content you posted on a public space, such as a rating or review, by writing to us. We will endeavour to honour such requests, though our removal of information does not completely erase it from the internet — historical copies or “caches” may remain.

Under the Digital Personal Data Protection Act, 2023, you have the following rights with respect to your personal data:

• Right to access information about the personal data we process about you;

• Right to request correction or updating of inaccurate personal data;

• Right to request deletion of personal data where it is no longer necessary;

• Right to withdraw consent for processing personal data;

• Right to nominate another individual to exercise these rights in the event of your death or incapacity; and

• Right to raise grievances with the Data Protection Board of India.

You may exercise these rights by contacting us at the details provided below.

Grievance Redressal

If you are concerned about the handling of your Personal Information, or if you have any complaints or queries related to your Personal Information or this Policy, please contact:

Arpit Nema — Director, Grievance Officer

Kalmacure Private Limited

Unit-400A, 4th Floor, 12 Ajit, Green Park, New Delhi, South West Delhi – 110016, Delhi

Email: care@trymanicule.com

Phone: +91-9407852653

The Grievance Officer is identified above pursuant to the provisions of applicable laws, including the Information Technology Act, 2000, the Consumer Protection Act, 2019, the Digital Personal Data Protection Act, 2023, and the rules enacted thereunder. All grievances will be acknowledged within 48 hours of receipt and resolved within 30 days, in accordance with the Consumer Protection (E-Commerce) Rules, 2020.

Note on Meta Platform Compliance: This Privacy Policy complies with the Meta Platform Terms and Developer Policies. For questions regarding how Meta processes your data, please refer to Meta’s Data Policy at https://www.facebook.com/privacy/policy/. Our use of Meta Business Tools (including the Meta Pixel and Conversions API) is governed by the Meta Business Tools Terms at https://www.facebook.com/legal/terms/businesstools. If you have concerns about data shared with Meta through our Website, you may contact us at care@trymanicule.com or manage your Meta ad preferences directly at https://www.facebook.com/adpreferences.

Effective Date: 27 July 2026

Last Updated: 27 July 2026