Privacy Policy

1. Introduction

This Privacy Policy ("Policy") is published by COZ CLUB CONSULTING PRIVATE LIMITED, a company incorporated under the laws of India and having its registered office at Vadodara, Gujarat ("COZ CLUB", "we", "us" or "our"). COZ CLUB operates a business ecosystem comprising various verticals and initiatives, including its Connect, Consult, CoServe and Capital initiatives, and provides its members with access to the website available at www.cozclub.com and the associated member portal (together, the "Website").

We respect the privacy of every person who visits the Website or uses the member portal, and we are committed to handling personal data responsibly, transparently and in accordance with applicable Indian law, including the Information Technology Act, 2000 and the rules made under it, and the Digital Personal Data Protection Act, 2023 ("DPDP Act") together with the Digital Personal Data Protection Rules, 2025, as and when their provisions are brought into force.

This Policy explains what information we collect, how we collect and use it, with whom we share it, how long we keep it, how we protect it, and the rights and choices available to you. Please read this Policy together with the COZ CLUB Website Terms of Use and, if you are a member, your COZ CLUB Membership Agreement.

2. Applicability

This Policy applies to: (a) visitors to the Website; (b) persons who register on, or are provided access to, the member portal, including members of the COZ CLUB ecosystem and their authorised representatives, employees and contact persons ("Members", "you" or "your"); and (c) any other person whose personal data is submitted to us through the Website.

This Policy applies to personal data collected in digital form or digitised after collection. Where a Member is a company, firm or other entity, this Policy applies to the personal data of the individuals connected with that entity (such as its directors, partners, employees or representatives) whose details are provided to us. By providing another individual's personal data to us, you confirm that you are authorised to do so and have made this Policy available to that individual.

If you have signed a Membership Agreement or any other agreement with COZ CLUB, this Policy supplements that agreement. In case of any conflict between this Policy and a signed agreement, the signed agreement will prevail to the extent of the conflict, except where applicable data protection law requires otherwise.

3. Information We Collect

We collect only such information as is reasonably necessary for membership administration, Website and portal access, profile creation, ecosystem participation, networking, events and other lawful business purposes. The categories of information we may collect are:

• Identity and contact information, your name, designation, organisation, business email address, business phone number, business address, city and, where you choose to provide it, your photograph.
• Business and professional information, details of your company or firm, industry and sector, nature of business, products and services, business interests, and materials you choose to upload such as company profiles, logos, brochures and presentations.
• Account information, your Login ID, Membership Number, account settings and communication preferences.
• Usage and technical information, IP address, device and browser type, log records, pages visited, and similar technical data collected when you use the Website.
• Event and participation information, details of your registration for and participation in COZ CLUB events, meetings, initiatives and programmes.
• Communications, correspondence, queries, feedback and grievances that you send to us.

It may be noted that COZ CLUB does not require, and Members should not upload to the Website, financial records, bank or payment credentials, client-confidential information, information protected by professional privilege, trade secrets, or any sensitive personal information that is not necessary for the purposes described in this Policy. If any such information is inadvertently submitted, you may write to us at contact@cozclub.com and we will take reasonable steps to remove it.

4. How We Collect Information

We collect information in the following ways:

• Directly from you, when you register on the Website, create or update your member profile, upload content, register for events, participate in ecosystem initiatives, or correspond with us.
• From your organisation, when the entity you represent, or its authorised representative, provides your details to us in connection with its membership or participation in the COZ CLUB ecosystem.
• Automatically, through cookies, log files and similar technologies when you use the Website, as described in Section 10.
• From other Members or ecosystem participants, for example, where a Member refers or introduces you to COZ CLUB, in which case we will inform you and seek your consent before creating your account or profile.

5. Purpose of Processing

We use your information only for the following purposes:

• to create, administer and manage your membership, Login ID, Membership Number and access to the Website and member portal;
• to create, host and display your member profile within the member portal in accordance with Section 7;
• to facilitate business networking, introductions, referrals, collaboration and ecosystem visibility among Members;
• to organise, manage and communicate about COZ CLUB events, meetings, programmes and initiatives, including the Connect, Consult, CoServe and Capital initiatives;
• to send you ecosystem updates, newsletters, announcements and service communications relating to your membership;
• to maintain the security and integrity of the Website, prevent fraud, misuse and unauthorised access, and investigate suspected violations of the Website Terms of Use;
• to respond to your queries, requests and grievances;
• to improve the Website and our services, including through aggregated and anonymised analytics; and
• to comply with applicable law, and to establish, exercise or defend legal claims.

We will not use your personal data for any purpose that is incompatible with the purposes described above without informing you and, where required by law, obtaining your consent.

6. Consent and Withdrawal of Consent

We process your personal data on the basis of consent, your consent will be free, specific, informed, unconditional and unambiguous, and given through a clear affirmative action, for example, by ticking the consent checkbox at the time of registration. You may review the consent you have given at any time through your account or by writing to us.

You may withdraw your consent at any time, with effect for the future, by using the option provided in the member portal or by writing to contact@cozclub.com. Withdrawing consent is as simple as giving it. Withdrawal will not affect the lawfulness of processing carried out before withdrawal, and will not affect processing that we are permitted or required to carry out under applicable law without consent.

Certain information is necessary for us to provide you access to the Website and member portal. If you withdraw consent for such processing, we may be unable to continue providing you with a Login ID, member profile or related services, and your access may be deactivated after reasonable notice to you.

7. Member Profile and Visibility Settings

For clarity, information on the Website is handled at four levels:

• Information used internally by COZ CLUB for membership administration, records, security and compliance (such as your contact details, account information and correspondence) is not displayed to other Members.
• Your member profile, typically your name, designation, organisation, industry, business description and content you upload, is visible to other logged-in Members of the COZ CLUB ecosystem. This visibility is the core purpose of the member portal, and by creating or maintaining a profile you consent to it.
• We do not display your personal profile on publicly accessible pages of the Website without your consent. Where you expressly agree (for example, to be featured as a speaker, participant or success story), the specific information you approve may be displayed publicly.
• Where COZ CLUB facilitates an introduction, referral or business opportunity, we share only such of your business contact and profile details as are reasonably necessary, and only with your consent or in accordance with your Membership Agreement.

You may edit your profile, request a change in its visibility, or ask us to remove specific content from it at any time through the member portal or by writing to us.

8. Sharing of Information within the COZ CLUB Ecosystem

COZ CLUB operates through affiliates, verticals, authorised representatives and ecosystem initiatives. We may share your information within this ecosystem strictly on a need-to-know basis for the purposes described in Section 5, for example, with the vertical relevant to your industry, with event partners for an event you have registered for, or with an authorised representative coordinating an introduction you have requested or consented to. All such recipients are required to handle your information consistently with this Policy.

9. Sharing with Service Providers and Third Parties

We may engage service providers to operate the Website and support our activities, such as website hosting and maintenance vendors, technology and software providers, communication and email service providers, analytics providers, event management partners and professional advisers. These providers process information only on our instructions, only to the extent necessary to perform their services, and under obligations of confidentiality and data protection.

We may also disclose information: (a) where required by law, or pursuant to an order or direction of a court, tribunal, government agency or regulator; (b) to enforce our Website Terms of Use or Membership Agreements, or to protect the rights, property or safety of COZ CLUB, its Members or the public; and (c) in connection with a bona fide reorganisation, merger or transfer of COZ CLUB's business, subject to the successor honouring this Policy.

COZ CLUB does not, at any point, rent or trade Members' personal data to any third party.

10. Cookies, Analytics and Website Technologies

The Website uses cookies and similar technologies. Essential cookies are necessary for the Website to function, for example, to keep you logged in securely. Analytics and preference cookies help us understand how the Website is used and improve it; these are used on the basis of your consent, which you may give or decline through the cookie notice displayed on the Website and may change at any time through your browser or cookie settings. Disabling certain cookies may affect the functioning of parts of the Website. Analytics data is used in aggregated form and is not used to make decisions about individual Members.

11. Data Retention

We retain personal data only for as long as it is needed for the purposes described in this Policy. In general: (a) profile and account information is retained for the duration of your membership and for a reasonable period thereafter to close out the relationship; (b) records that we are required to retain under applicable law (including tax, corporate and information technology laws) are retained for the periods prescribed by such law; and (c) usage logs are retained for the periods required or permitted under applicable law for security and legal purposes.

When personal data is no longer required and no legal retention obligation applies, we will delete it or irreversibly anonymise it. If you withdraw consent or your membership ends, we will erase your personal data within a reasonable time, subject to legal retention requirements and our legitimate need to preserve records of concluded transactions and communications.

12. Data Security

We adopt reasonable security safeguards, appropriate to the nature of the data we hold, to protect personal data against unauthorised access, disclosure, alteration, loss and misuse. These include access controls, secure hosting arrangements, periodic review of security practices, and contractual security obligations on our service providers, consistent with the standards contemplated under the Information Technology Act, 2000 and the DPDP Act.

No method of transmission or storage over the internet is completely secure, and we cannot guarantee absolute security. In the event of a personal data breach that affects you, we will notify you and the relevant authority in the manner and within the timelines required under applicable law.

Your Login ID and One Time Passwords are personal to you. You are responsible for keeping your login credentials confidential, for all activity under your account, and for notifying us promptly at contact@cozclub.com if you suspect any unauthorised access to or use of your account.

13. Rights of Members and Users

Subject to applicable law, you have the following rights in relation to your personal data:

• Right to access, to obtain a summary of the personal data we hold about you and of the processing activities undertaken with respect to it;
• Right to correction and updating, to have inaccurate or incomplete personal data corrected, completed or updated;
• Right to erasure, to have your personal data erased where it is no longer necessary for the purpose for which it was collected, subject to legal retention requirements;
• Right to withdraw consent, as described in Section 6;
• Right to grievance redressal, to raise a grievance at contact@cozclub.com, and thereafter, if unresolved, with the Data Protection Board of India in accordance with the DPDP Act once the relevant provisions are in force; and
• Right to nominate, to nominate another individual to exercise your rights in the event of your death or incapacity, in the manner prescribed under applicable law.

You may exercise these rights through the member portal or by writing to contact@cozclub.com, quoting your Membership Number or registered email address. We may verify your identity before acting on a request, and we will respond within the timelines prescribed under applicable law.

14. Children's Privacy and Age Restriction

The Website and member portal are intended solely for use by individuals who are at least 18 years of age and are engaged in business or professional activities. We do not knowingly collect personal data of persons under 18 years of age. If we become aware that such data has been collected, we will delete it. If you believe that a person under 18 has provided personal data to us, please write to contact@cozclub.com.

15. Changes to this Privacy Policy

We may update this Policy from time to time to reflect changes in law, technology or our practices. The updated Policy will be published on the Website with a revised "Last Updated" date, and where the changes are material, we will notify Members through the member portal or by email. Your continued use of the Website after an update takes effect will signify your acceptance of the updated Policy, except where applicable law requires us to obtain your fresh consent.