CAIRR Privacy Policy

CAIRR PLUS mobile application and www.ca2013.com
Last Updated: June 06, 2026

INTRODUCTION

CimplyFive Corporate Secretarial Services Private Limited (“CimplyFive”, “we”, “us”, or “our”) respects your privacy and is committed to protecting the information that is collected through your use of our products. This Privacy Policy (the “Policy”) explains the categories of information we collect, the purposes for which such information is used, the circumstances in which it may be shared, the security measures we adopt, your rights in relation to your information, and the manner in which you may contact us in respect of any concern or grievance.

1. SCOPE AND APPLICABILITY

This Policy describes how CimplyFive collects, uses, maintains, and discloses information collected from users (each, a “User”, “you”, or “your”) of:

  • the CAIRR PLUS mobile application, available on the Google Play Store (Android) and the Apple App Store (iOS) (the “App”); and
  • the website www.ca2013.com and its subdomains (the “Site”).

The App and the Site are together referred to as the “Services”. This Policy applies to all access to and use of the Services, whether on Android, on iOS, or through a web browser.

By accessing or using the Services, you acknowledge that you have read and understood this Policy and you consent to the collection, use, and disclosure of your information in accordance with it. Subject to applicable laws, the terms of this Policy (and any changes thereto) will become applicable to you retrospectively on and from the date of your first use of the App or the Site. If you do not agree to the terms of this Policy, please do not use our App or Site or access the Services. Further, by using the App or Site, you also confirm that you are either the owner of, or are duly authorized to use and share, the information that the App or Site may require, and that your use of the App or Site does not violate any applicable law or contract by which you may be bound or is otherwise prejudicial to any person. You agree to indemnify CimplyFive, its employees, directors, officers, agents, business associates, and affiliates from any loss, damage, expenses, or other adverse consequence they suffer as a result of your usage of the App, Site, or Services, unless such loss, damage, expenses, or other adverse consequence can be attributed to our act or omission.

2. DISCLAIMER — NO GOVERNMENT AFFILIATION

CAIRR PLUS is an independent platform developed and maintained by CimplyFive Corporate Secretarial Services Private Limited, a private company incorporated in India.

The App and the Site are not affiliated with, endorsed by, sponsored by, or representative of the Government of India, the Ministry of Corporate Affairs (MCA), the e-Gazette of India, the Insolvency and Bankruptcy Board of India (IBBI), the Securities and Exchange Board of India (SEBI), or any other governmental entity, authority, or body.

The legislative and regulatory material made available through the Services (including the Companies Act, 2013, the Insolvency and Bankruptcy Code, 2016, rules, regulations, and circulars) is sourced from publicly available government publications and is provided for informational reference only. It does not constitute legal advice and should not be relied upon as an authoritative or official source.

3. INFORMATION WE COLLECT

The CAIRR PLUS App does not require you to create an account or to log in, and may be used anonymously. We collect only the limited information described below.

3.1 Information you provide voluntarily (Site only)

Your name, email address, and phone number — collected only if you choose to contact us, subscribe to newsletters, or request a demonstration through the Site. The App contains no contact forms, account, or login features.

3.2 Information collected automatically by the App

  • Push notification token — if you grant notification permission, a unique token is generated by Google’s Firebase Cloud Messaging (FCM) service to enable delivery of content updates. This token is held by Google.
  • Basic device characteristics — limited to the application version, the operating-system platform (Android or iOS), and whether the device is a phone or a tablet. This information is used locally within the App for layout and version display and is not transmitted to our servers.
  • Local application preferences — small flags stored in your device’s private storage (such as your acknowledgement of the in-app Disclaimer screen and pending notification payloads). This data never leaves your device.

3.3 Information the App does not collect

The App does not collect: names, email addresses, or phone numbers; account, login, or authentication data; precise GPS or device location; contacts, calendar, photos, files, camera, or microphone data; payment or financial information; biometric or health data; advertising identifiers; analytics or behavioural tracking data; crash logs or diagnostic data; or children’s data.

3.4 Information processed through the in-app browser

When you view Site content within the App, your device communicates directly with the ca2013.com servers. The information processed in such cases is the same as if you had visited the Site through an ordinary web browser, and Sections 6 (Cookies) and 7 (Log Data) apply accordingly.

4. HOW WE USE YOUR INFORMATION

We use the limited information we collect to:

  • provide, operate, and maintain the App and the Site;
  • deliver push notifications, where you have enabled them;
  • respond to enquiries, demonstration requests, and newsletter subscriptions submitted through the Site;
  • send newsletters and product updates, where you have opted in (an unsubscribe facility is provided in every such communication);
  • comply with applicable laws, regulations, and lawful requests of competent authorities; and
  • troubleshoot software bugs and operational issues, conduct data analysis, testing, and research, and monitor and analyse usage and activity trends. Information collected may also be used to share communications with you about our products and services, provide additional features through cookies, and detect and/or prevent any fraudulent, criminal, or prohibited activity as permitted under applicable laws.

 

We do not sell or rent your personal information to any third party. We may share, transfer, or assign all of your information to any other business entity, including in the event of a merger, sale, re-organization, amalgamation, joint venture, assignment, restructuring of business, or transfer or disposition of all or any portion of our business.

5. HOW WE SHARE INFORMATION

We disclose information only in the following circumstances:

  • Service providers — such as Google (Firebase Cloud Messaging), which processes the push notification token on our behalf, subject to appropriate confidentiality obligations;
  • Legal and regulatory requirements — where disclosure is necessary to comply with applicable law, a court order, or legal process, or to protect the rights, property, or safety of CimplyFive, our Users, or others; and
  • Aggregated or anonymised data — non-identifying statistical information may be shared with partners.

We do not sell or rent your personal information to anyone.

6. COOKIES

The Site uses cookies and similar technologies to recognise you, remember your preferences, and understand how the Site is used. Cookies are small text files stored on your computer or device when you visit certain web pages, which record your preferences and actions. Most browsers accept cookies automatically; you may modify your browser settings to decline them, though doing so may limit your access to, or use of, certain features of the Site. The App does not use browser cookies.

7. LOG DATA

Whenever you use the Services, we may collect data from your device known as Log Data. This Log Data may include information such as your device’s Internet Protocol (“IP”) address, device name, operating-system version, the configuration of the application when using the Services, the date and time of your use of the Services, and other statistics.

8. DATA RETENTION

We retain information only for as long as is necessary for the purposes set out in this Policy, or for such longer period as may be required under applicable law:

  • Push notification tokens (FCM) — retained by Google for so long as the App is installed and notification permission remains granted, and removed upon uninstallation of the App or revocation of notification permission.
  • Newsletter and contact submissions (Site) — retained for the duration of the engagement and for a reasonable period thereafter for record-keeping (typically up to three years), unless earlier deletion is requested.
  • Local data on your device — cleared when you uninstall the App or clear the App’s data through your device settings.

9. DATA

We adopt reasonable security measures, including encryption in transit (HTTPS/TLS) and data minimisation, to protect the limited information collected through the Site. As the App requires no account or login and does not store personal data on our servers, the information at risk is minimal. However, no method of transmission over the internet or electronic storage is entirely secure, and we cannot guarantee absolute security.

10. YOUR RIGHTS AND CHOICES

Subject to applicable law, you may:

  • Access and correction — request access to, or correction of, the personal information we hold about you;
  • Deletion — request deletion of your personal information (see Section 12);
  • Notifications — disable push notifications at any time through your device’s notification settings; and
  • Marketing communications — unsubscribe from newsletters and product updates using the facility provided in each communication.

To exercise any of these rights, please contact us using the details in Section 15. We will respond to verified requests within the timelines prescribed by applicable law.

11. WITHDRAWAL OF CONSENT

You may withdraw your consent provided hereunder at any time. Such withdrawal of consent must be sent in writing to contact@cimplyfive.com. If you later withdraw your consent, we request that you not access the Services, and we reserve the right not to provide you any Services thereafter.

12. HOW TO DELETE YOUR DATA

As the App is anonymous and does not require an account, most App users have no personal data held by us that requires deletion. If, however, you have contacted us by email, subscribed to our newsletter, or shared personal information through the Site, you may request deletion by emailing contact@cimplyfive.com with the subject line “Data Deletion Request — CAIRR PLUS”. We will respond to verified requests within thirty (30) days.

You may also disable push notifications through your device’s notification settings; uninstall the App to stop all App-side data collection (including the FCM token); and clear the App’s data through your device settings to remove locally stored flags.

13. CHILDREN’S PRIVACY

The Services are intended for legal, corporate-secretarial, and compliance professionals and are not directed at children under the age of eighteen (18) years. We do not knowingly collect personal information from children. If you believe that a child has provided personal information to us, please contact us at contact@cimplyfive.com and we will take steps to delete such information promptly.

14. THIRD-PARTY LINKS AND SERVICES

The Services provide links to other websites and third-party platforms (including Google’s Firebase Cloud Messaging) (“Third-Party Platforms”). Such Third-Party Platforms may collect information about you. We are not responsible for the privacy practices or the content of those linked websites and Third-Party Platforms. We recommend that you review the privacy policies of such Third-Party Platforms.

15. GRIEVANCE REDRESSAL AND CONTACT

If you have any questions, concerns, or grievances regarding this Policy or the handling of your information, you may contact our Grievance Officer, appointed in accordance with applicable law:

Grievance Officer
Name: Eti Basaniwal
Address: 23 & 24, AMR Tech Park, Block 1, 1st Floor, Hosur Main Road, Hongasandra, Bengaluru, Karnataka 560068, India
Email: contact@cimplyfive.com

We will acknowledge and seek to resolve grievances within the timelines prescribed under applicable law.

16. GOVERNING LAW AND JURISDICTION

This Policy is governed by the laws applicable within the territory of India. By using the Services, you agree to the terms of this Policy and consent to the exclusive jurisdiction and venue of the courts at Bengaluru, India, in respect of all disputes arising out of or relating to the use of the Services or this Policy.

17. CHANGES TO THIS PRIVACY POLICY

This Policy may change from time to time. The “Last Updated” date at the top of this Policy indicates when the most recent modifications were made. We reserve the right to modify or amend the terms of this Policy at any time and will endeavour to post any changes on our webpage. While we will make reasonable efforts to keep you informed of any updates, we recommend that you review this Policy periodically to ensure you are aware of any changes. In the event we modify this Policy, your continued use of the Services will signify your acceptance of the modified Policy and will be adequate proof that you have expressly agreed to its terms, which shall apply from the date of your first use of the Services.




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