Setthi — Legal Documents & Policies Compendium

Welcome to the Setthi Legal & Statutory Compliance Hub. This compendium establishes the binding Privacy Policy, Terms of Service, DPDP Statutory Consent Notice, and statutory regulatory schedules governing your access to and utilization of the Setthi mobile software application, web services, and associated cloud APIs.

TABLE OF CONTENTS & NAVIGATION INDEX

1. Statutory Framework & Preamble
2. General Information & Entity Metadata
3. Document 1 — Privacy Policy
   • 1. About This Policy & Statutory Applicability
   • 2. Who This Policy Applies To
   • 3. Personal Data We Collect (Classification Matrices)
   • 4. Explicit Non-Collection of Sensitive Banking Credentials
   • 5. Sensitive Personal Data or Information (SPDI) under Rule 3
   • 6. Purpose of Processing & Legal Basis Mapping
   • 7. AI Processing & Zero Foundation Model Training Guarantee
   • 8. Authorized Third-Party Sub-Processors Schedule
   • 9. Storage Architecture: Local Sandbox vs. Encrypted Cloud
   • 10. Data Retention & Deletion Schedule
   • 11. Technical, Operational & Organizational Security Safeguards
   • 12. Protection of Children's Personal Data (Strict 18+ Mandate)
   • 13. Statutory Data Principal Rights under DPDP Act 2023
   • 14. Designated Grievance Officer & Statutory Redressal Mechanism
4. Document 2 — Terms of Service
   • 1. Agreement to Terms & Eligibility
   • 2. Description of the Application & Architecture
   • 3. Mandatory Regulatory & Financial Disclaimer (SEBI Non-Advisory Exemption)
   • 4. Artificial Intelligence Accuracy & Hallucination Clause
   • 5. User Account Security & Two-Factor Confidentiality
   • 6. Acceptable Use Policy & Prohibited Conduct
   • 7. Intellectual Property Rights & Data Ownership
   • 8. In-App Subscriptions, Invoicing & Billing Terms
   • 9. Account Suspension & Immediate Termination
   • 10. Disclaimer of Warranties ("AS IS" & "AS AVAILABLE")
   • 11. Limitation of Liability & Absolute Monetary Liability Cap
   • 12. Mutual Indemnification
   • 13. Governing Law, Amicable Dispute Resolution & Forum Jurisdiction
5. Document 3 — DPDP Statutory Consent Notice
6. Appendix A — Entity & Technical Configuration Schedule
7. Appendix B — Statutory Concordance Index

General Information & Entity Metadata

• Application Name: Setthi ("App" or "Application")
• Operating Entity / Licensor: Setthi Technologies / Santosh Patil ("we," "us," or "our")
• Founder & Statutory Signatory: Santosh Patil
• Grievance & Legal Officer: Santosh Patil
• Official Compliance Electronic Mail: setthi2003@gmail.com
• Corporate Seat & Judicial Jurisdiction: Bangalore, Karnataka, Republic of India
• Primary Cloud Infrastructure Region: AWS / Supabase Mumbai Region (ap-south-1)
• Governing Enactments: Information Technology Act, 2000 ("IT Act"); Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 ("SPDI Rules"); Digital Personal Data Protection Act, 2023 ("DPDP Act"); Reserve Bank of India Master Directions on Non-Banking Financial Company - Account Aggregators.

Statutory Framework & Preamble

This Legal Policies & Statutory Compliance Compendium ("Compendium") constitutes a binding legal agreement and electronic contract executed in conformance with:

1. The Information Technology Act, 2000 (Act No. 21 of 2000), including amendments thereto;
2. The Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 ("SPDI Rules"), promulgated under Section 43A of the IT Act;
3. The Digital Personal Data Protection Act, 2023 (Act No. 22 of 2023) ("DPDP Act 2023");
4. The Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021, as amended;
5. Master Directions and circulars issued by the Reserve Bank of India (RBI) regarding Non-Banking Financial Company - Account Aggregator (NBFC-AA) networks; and
6. App distribution compliance standards, including the Apple App Store Review Guidelines (Schedule 2) and Google Play Developer Distribution Agreement.

This document is published in conformance with Rule 3(1) of the Information Technology (Intermediaries Guidelines) Rules, 2011, and Rule 4 of the SPDI Rules, which mandate the publication of rules, regulations, privacy policies, and terms of service for access to or usage of digital applications.

Document 1 — Privacy Policy

Effective Date: September 24, 2026
Version: 1.0
Grievance Officer: Santosh Patil (setthi2003@gmail.com)
Jurisdiction: Bangalore, Karnataka, Republic of India

1. About This Policy & Statutory Applicability

This Privacy Policy describes how Setthi collects, processes, stores, protects, and discloses your personal data and Sensitive Personal Data or Information (SPDI). This Policy is published in strict compliance with:

• Rule 4 of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 (SPDI Rules); and
• Section 5 of the Digital Personal Data Protection Act, 2023 (DPDP Act).

By downloading, installing, registering, accessing, logging expenses, uploading transaction receipts, querying the AI personal finance assistant, or syncing financial feeds via Account Aggregator gateways, you acknowledge that you have read, understood, and agreed to the practices outlined in this Policy.

2. Who This Policy Applies To

This Policy applies to all natural persons who register, access, or utilize the Setthi mobile application and associated web portals ("you," "User," or "Data Principal" as defined under Section 2(j) of the DPDP Act 2023).

3. Personal Data We Collect (Classification Matrices)

Setthi collects and processes distinct categories of personal data strictly for legitimate, proportionate, and user-authorized financial budgeting and analytical purposes.

3.1 Account & Identity Data (Registration & Authentication)

3.2 Financial & Transactional Data

3.3 AI Prompts & Assistant Interaction Data

3.4 Technical & Device Telemetry Data

4. Explicit Non-Collection of Sensitive Banking Credentials

[!CAUTION]
Strict Zero-Knowledge Policy for Banking Passwords and Credentials

Setthi does NOT collect, access, transmit, or store:

1. Net banking login credentials (User IDs, Passwords, Security Questions);
2. Mobile Banking Personal Identification Numbers (MPIN);
3. Card Security Codes (CVV / CVC);
4. Automated Teller Machine (ATM) PINs;
5. One-Time Passwords (OTPs) generated by banks for payment authorization;
6. Full 16-digit Primary Account Numbers (PAN / Debit / Credit Card Numbers);
7. Biometric credential records (fingerprint or Face ID data remains strictly within your device's hardware Secure Enclave);
8. Continuous GPS background geolocation or device address book contacts.

Any financial connection established via the Account Aggregator framework operates strictly under the Reserve Bank of India Master Directions - Non-Banking Financial Company - Account Aggregator (Reserve Bank) Directions, 2016. In such cases, authentication occurs exclusively within your banking institution or the licensed Account Aggregator client interface. Setthi never intercepts, views, or handles access credentials.

5. Sensitive Personal Data or Information (SPDI) under Rule 3

Pursuant to Rule 3 of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, the following categories of information processed by Setthi are expressly classified as Sensitive Personal Data or Information ("SPDI"):

1. Passwords & Cryptographic Hashes: Salted, hashed user authentication secrets managed by Supabase Auth; never accessible to or readable by us in plaintext;
2. Financial Information:
   • Income figures, monthly budget thresholds, and granular expense records;
   • Bank account balances, transaction narrations, and ledger feeds synced via Account Aggregator gateways;
   • User-uploaded retail invoices and receipts containing transactional financial data.

All SPDI collected is processed strictly subject to the enhanced consent and security mandates articulated in Rules 5, 6, 7, and 8 of the SPDI Rules and the statutory safeguards of the DPDP Act 2023.

6. Purpose of Processing & Legal Basis Mapping

In compliance with Section 4, Section 5, and Section 6 of the DPDP Act 2023 and Rule 5(3) of the SPDI Rules 2011, the processing of personal data and SPDI is mapped to specific legal bases:

7. AI Processing & Zero Foundation Model Training Guarantee

Setthi incorporates generative artificial intelligence and Large Language Models (LLMs) to deliver automated budgeting summaries, spending insights, and natural language query handling.

7.1 Zero-Training Guarantee for AI Processing

1. Stateless API Inference: User chat prompts and contextual financial aggregates submitted to third-party AI inference engines (such as OpenAI, Anthropic, or Google Cloud Vertex AI) are processed ephemerally over encrypted TLS 1.3 channels.
2. Zero Training Commitment: Setthi contractually mandates and strictly covenants that user prompts, financial figures, transaction descriptions, and budget balances are NEVER used by our third-party AI sub-processors to train, retrain, fine-tune, or improve foundational public machine learning models. All AI API endpoints operate under enterprise Data Protection Agreements (DPAs) enforcing strict Zero Data Retention (ZDR).
3. Data Minimization & Redaction: Prior to injecting transaction records into an AI context window, client-side and server-side sanitation filters strip direct personal identifiers, including names, email addresses, phone numbers, permanent account numbers (PAN), and Aadhaar numbers.

8. Authorized Third-Party Sub-Processors Schedule

In accordance with Section 8(2) of the DPDP Act 2023, Setthi engages trusted third-party Data Processors ("Sub-Processors"). Written data processing agreements ensure equivalent data protection safeguards:

Cross-border transfers of personal data are conducted in full compliance with Section 16 and Section 17 of the DPDP Act, 2023, ensuring contractual equivalence of security standards.

9. Storage Architecture: Local Sandbox vs. Encrypted Cloud

1. Client-Side (Local Device Storage):
   • To ensure instant loading and offline budget tracking, Setthi stores a locally encrypted database (e.g., SQLite via SQLCipher) on your device containing cached transaction entries, budget categories, offline calculation queues, UI preferences, and temporary session tokens.
   • This local database is sandboxed within your operating system's private storage (iOS Keychain on iOS and EncryptedSharedPreferences / KeyStore on Android).
   • Clearing App storage or uninstalling the App completely purges this local database from your physical device.
2. Server-Side (Cloud Infrastructure):
   • Primary cloud storage is maintained in AWS / Supabase India Region (Mumbai ap-south-1).
   • Multi-tenant data segregation is implemented at the database engine level via PostgreSQL Row Level Security (RLS). Every database query executes strictly within the authenticated context of the User's cryptographic UUID (auth.uid() = user_id), ensuring zero unauthorized cross-user access to financial rows.

10. Data Retention & Deletion Schedule

In compliance with Section 8(7) of the DPDP Act 2023, Setthi retains personal data only for as long as necessary to fulfill the purpose for which it was processed or to comply with statutory legal mandates:

11. Technical, Operational & Organizational Security Safeguards

Pursuant to Section 43A of the IT Act, 2000 and Rule 8 of the SPDI Rules 2011, Setthi implements comprehensive industry-standard technical and organizational security controls:

1. Cryptographic Protection:
   • Data in Transit: All network communication between the App, backend APIs, and sub-processors uses Transport Layer Security (TLS 1.3) with cipher suite negotiation enforcing Perfect Forward Secrecy (PFS).
   • Data at Rest: Cloud databases, automated backups, and disk volumes employ AES-256 bit encryption.
2. Database Row Level Security (RLS):
   • Supabase database architectures enforce cryptographic tenant isolation, preventing any user from reading, modifying, or deleting financial rows belonging to another user.
3. Access Control & Vulnerability Management:
   • Production environments enforce strict least-privilege access, multi-factor authentication (MFA), and immutable audit logs.
   • Continuous automated dependency vulnerability scanning and regular security reviews.
4. Data Breach Notification Protocol:
   • In the event of a confirmed personal data breach affecting Users, Setthi shall notify the Data Protection Board of India (DPBI) and affected Data Principals in such form and manner as prescribed under Section 8(6) of the DPDP Act 2023, and report cybersecurity incidents to CERT-In within statutory timelines mandated under Section 70B of the Information Technology Act, 2000.

12. Protection of Children's Personal Data (Strict 18+ Mandate)

1. Strict 18+ Requirement: Setthi is strictly intended, licensed, and designed for individuals who have reached the age of majority under Indian law (eighteen (18) years of age).
2. Compliance with Section 9 of the DPDP Act 2023:
   • Setthi does not knowingly track, collect, or process personal data belonging to children (individuals under 18 years of age).
   • Setthi does not engage in behavioral monitoring, tracking, or targeted advertising directed at children.
3. Immediate Account Termination: If Setthi discovers that personal data of an individual under 18 years has been inadvertently submitted, we will immediately terminate the account, block access, and permanently erase all associated data records from active databases.

13. Statutory Data Principal Rights under DPDP Act 2023

Under Chapter III (Sections 11 to 14) of the DPDP Act 2023 and Rule 5 of the SPDI Rules, you hold the following statutory rights:

1. Right to Access Information (Section 11): You have the right to request a summary of your personal and financial data stored by us, alongside a list of third-party processors who have handled your information.
2. Right to Correction and Erasure (Section 12): You have the right to correct inaccurate financial entries directly in the App, or invoke your right to erasure by requesting complete account deletion via in-app settings or email.
3. Right to Withdraw Consent (Section 6(4)): You may withdraw consent for data processing at any time through in-app settings. Withdrawing consent for core processing activities (e.g., storing expenses) will necessitate account closure.
4. Right of Grievance Redressal (Section 13): You have the right to readily available grievance redressal mechanisms regarding the performance of our obligations, with statutory escalation to the Data Protection Board of India.
5. Right to Nominate (Section 14): You have the right to nominate any other individual who shall, in the event of your death or incapacity, exercise your rights as a Data Principal.

14. Designated Grievance Officer & Statutory Redressal Mechanism

In accordance with Rule 9 of the Information Technology (SPDI) Rules, 2011, Rule 3(2) of the Information Technology (Intermediary Guidelines) Rules, 2021, and Section 13 of the DPDP Act 2023, the details of our designated Grievance Officer are set forth below:

• Name of Grievance Officer: Santosh Patil
• Designation: Founder & Grievance Officer
• Operating Entity: Setthi Technologies
• Corporate Address: Bangalore, Karnataka, India
• Compliance Electronic Mail: setthi2003@gmail.com
• Support & Web Portal: mailto:setthi2003@gmail.com
• Response Timelines:
  • Acknowledgment of Complaint: Within twenty-four (24) hours of receipt.
  • Statutory Resolution Period: Within thirty (30) business days (and in no event exceeding thirty (30) days) from formal receipt.

Document 2 — Terms of Service

Effective Date: September 24, 2026
Version: 1.0
Operating Entity: Setthi Technologies / Santosh Patil
Jurisdiction: Bangalore, Karnataka, Republic of India

1. Agreement to Terms & Eligibility

These Terms of Service ("Terms") constitute a legally binding agreement between you ("User") and Setthi Technologies / Santosh Patil ("we," "us," or "our").

By downloading, installing, registering for, or using the Setthi mobile application, you represent and warrant that:

1. You are a natural person of at least eighteen (18) years of age;
2. You possess the legal capacity to enter into a binding contract under the Indian Contract Act, 1872;
3. You have not been previously suspended or removed from using the Application; and
4. Your use of the Application strictly complies with all applicable local, state, national, and international laws.

If you do not agree to these Terms, you must immediately cease using the App and uninstall it from your devices.

2. Description of the Application & Architecture

Setthi provides an automated, artificial intelligence-assisted personal budgeting, expense tracking, and financial analytics platform. Features include:

• Manual, OCR receipt-based, and consent-based Account Aggregator expense and income logging;
• Categorical budget ceiling allocation, spending tracking, and automated threshold alerts;
• Generative AI natural language conversational assistance for budgeting scenarios and financial habit analysis;
• Historical spending trend analytics, balance sheets, and visual summaries.

3. Mandatory Regulatory & Financial Disclaimer (SEBI Non-Advisory Exemption)

[!IMPORTANT]

CRITICAL REGULATORY DISCLAIMER — NOT FINANCIAL, INVESTMENT, TAX, OR LEGAL ADVICE

1. No SEBI Registration: Setthi, its developers, founders (Santosh Patil), directors, employees, and parent entities are NOT registered as Investment Advisers (RIA), Research Analysts (RA), Portfolio Managers, Stock Brokers, or Merchant Bankers under the Securities and Exchange Board of India (SEBI) Act, 1992, the SEBI (Investment Advisers) Regulations, 2013, or regulations framed thereunder. We are not Chartered Accountants, certified financial planners, or licensed tax consultants.
2. Informational & Budgeting Purpose Only: The App, its algorithms, computational engines, and AI assistant outputs are provided STRICTLY FOR PERSONAL BUDGETING, MATHEMATICAL AGGREGATION, AND EDUCATIONAL INFORMATIONAL PURPOSES.
3. No Fiduciary Relationship: Use of the Application does not create any advisory, fiduciary, brokerage, or professional client relationship between you and Setthi Technologies.
4. No Financial Recommendations: Nothing generated by the App constitutes personalized investment advice, a solicitation, an endorsement, or a recommendation to buy, sell, hold, or subscribe to any stock, bond, mutual fund, derivative, cryptocurrency, insurance policy, or financial instrument.
5. User Sole Discretion & Independent Professional Consultation: All financial actions, budget allocations, debt payoffs, and expenditures are executed at your own sole discretion and risk. You are strongly advised to independently verify all calculations and consult a certified Chartered Accountant (CA) or SEBI-registered Investment Adviser before making significant financial commitments or tax filings.

4. Artificial Intelligence Accuracy & Hallucination Clause

1. Probabilistic Nature of AI Models: You explicitly understand and acknowledge that Setthi utilizes probabilistic Large Language Models (LLMs) and automated machine learning heuristics.
2. Possibility of Inaccuracies: AI-generated outputs, categorization rules, currency calculations, and financial summaries may occasionally contain mathematical inaccuracies, calculation misalignments, erroneous merchant categorization, outdated regulatory references, or algorithmic "hallucinations."
3. Verification Obligation: You bear the exclusive responsibility to independently audit, review, and verify all expense totals, tax estimates, conversion rates, and budget calculations before relying on them.
4. Complete Exclusion of Liability for AI Errors: Under no circumstances shall Setthi Technologies or Santosh Patil be held liable for any financial shortfalls, unexpected bank overdrafts, late fees, tax penalties, or damages resulting from reliance on AI suggestions.

5. User Account Security & Two-Factor Confidentiality

1. Account Confidentiality: You are solely responsible for maintaining the absolute secrecy of your login credentials, password, and two-factor authentication devices. You accept full legal liability for all activities occurring under your account.
2. Immediate Notification: You must report any suspected unauthorized access or compromise of your account immediately to setthi2003@gmail.com.
3. Account Recovery: Setthi relies on email OTP verification and cryptographic tokens. We cannot recover accounts if the primary email address is compromised by third parties outside our control.

6. Acceptable Use Policy & Prohibited Conduct

You agree that you will NOT, directly or indirectly:

1. Use the App for money laundering, fraudulent tracking, illegal tax evasion schemes, or financing unlawful activities under the Prevention of Money Laundering Act, 2002 (PMLA) or the Indian Penal Code / Bharatiya Nyaya Sanhita;
2. Submit fraudulent, deceptive, fictitious, forged, or maliciously manipulated financial entries, bank narrations, or receipts;
3. Attempt to reverse engineer, decompile, disassemble, scrape, crawl, or extract source code, proprietary algorithms, prompt libraries, or API routes of the App;
4. Introduce viruses, Trojan horses, worms, or malicious scripts designed to damage or intercept server architecture;
5. Execute prompt injection, jailbreaking, or adversarial poisoning attacks intended to compel the AI engine to generate defamatory, obscene, or illegal content;
6. Rent, lease, sublicense, resell, or distribute the App to third parties for commercial accounting or commercial financial advisory services without our prior written authorization;
7. Bypass, circumvent, or probe application security mechanisms, rate limits, or Row Level Security policies.

7. Intellectual Property Rights & Data Ownership

1. Setthi Intellectual Property: All intellectual property rights in Setthi—including its name, logos, UI designs, code base, visual assets, financial calculation engines, system prompts, database schemas, and AI workflows—are exclusively owned by or licensed to Setthi Technologies.
2. User Data Ownership: You retain full legal ownership over your raw input data (your transaction entries, logs, and custom queries). You grant us a limited, worldwide, non-exclusive, royalty-free license to store, process, display, and format your data solely to the extent necessary to deliver the App's services to you.

8. In-App Subscriptions, Invoicing & Billing Terms

1. Paid Subscriptions: Certain enhanced features (e.g., unlimited AI queries, advanced OCR receipt scanning, multi-currency ledgers) may require a paid recurring subscription.
2. Third-Party Billing Ecosystems: Subscriptions purchased through the Apple App Store or Google Play Store are processed, billed, and managed exclusively by Apple or Google under their respective terms and conditions.
3. Refund Terms: All in-app subscription fees are non-refundable to the fullest extent permitted by applicable law, subject only to mandatory consumer protection laws and individual store platform refund policies.

9. Account Suspension & Immediate Termination

1. Termination by User: You may terminate your account at any time through the in-app settings by submitting a permanent account deletion request.
2. Termination by Setthi: We reserve the right to immediately suspend or permanently terminate your account without notice if:
   • You breach any provision of these Terms or the Acceptable Use Policy;
   • Required by law enforcement or regulatory authorities;
   • You engage in conduct that damages our infrastructure, reputation, or other users.

10. Disclaimer of Warranties ("AS IS" & "AS AVAILABLE")

THE APPLICATION IS PROVIDED ON AN "AS IS" AND "AS AVAILABLE" BASIS WITH ALL FAULTS AND DEFECTS, WITHOUT WARRANTY OF ANY KIND. TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE INDIAN LAW, SETTHI TECHNOLOGIES AND SANTOSH PATIL EXPRESSLY DISCLAIM ALL WARRANTIES, WHETHER EXPRESS, IMPLIED, STATUTORY, OR OTHERWISE, INCLUDING ALL IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE, ACCURACY, AND NON-INFRINGEMENT. WE DO NOT WARRANT THAT THE APP WILL BE UNINTERRUPTED, ERROR-FREE, FREE FROM HARMFUL COMPONENTS, OR THAT ANY DEFECTS WILL BE CORRECTED.

11. Limitation of Liability & Absolute Monetary Liability Cap

TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW:

1. Consequential Damages Exclusion: IN NO EVENT SHALL SETTHI TECHNOLOGIES, SANTOSH PATIL, ITS DIRECTORS, EMPLOYEES, AFFILIATES, OR LICENSORS BE LIABLE TO YOU OR ANY THIRD PARTY FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, EXEMPLARY, OR PUNITIVE DAMAGES—INCLUDING LOSS OF PROFITS, REVENUE, SAVINGS, BUSINESS OPPORTUNITY, DATA CORRUPTION, OR FINANCIAL LOSSES ARISING FROM RELIANCE ON APP OUTPUTS—REGARDLESS OF THE THEORY OF LIABILITY (CONTRACT, TORT, NEGLIGENCE, STRICT LIABILITY, OR OTHERWISE).
2. Absolute Monetary Cap: OUR TOTAL AGGREGATE LIABILITY ARISING OUT OF OR IN CONNECTION WITH THESE TERMS OR YOUR USE OF THE APPLICATION SHALL BE STRICTLY LIMITED TO AND NOT EXCEED INR 500 (FIVE HUNDRED INDIAN RUPEES) OR THE TOTAL AMOUNT ACTUALLY PAID BY YOU TO SETTHI IN THE PRECEDING TWELVE (12) MONTHS, WHICHEVER IS LESS.

12. Mutual Indemnification

You agree to indemnify, defend, and hold harmless Setthi Technologies, Santosh Patil, and their respective officers, directors, contractors, and agents from and against any and all claims, liabilities, damages, losses, and reasonable legal expenses arising out of or in any way connected with: (i) your access to or use of the App; (ii) your violation of these Terms; (iii) your violation of any statutory regulations; or (iv) any tax returns, investments, or financial decisions made based on AI-assisted calculations.

13. Governing Law, Amicable Dispute Resolution & Forum Jurisdiction

1. Governing Law: These Terms, the Privacy Policy, the Consent Notice, and any disputes arising hereunder shall be governed by, construed, and enforced in accordance with the substantive laws of the Republic of India, without reference to conflict-of-law principles.
2. Mandatory 30-Day Amicable Resolution Period: Prior to initiating any formal arbitral or judicial proceedings, the aggrieved party must send a written notice detailing the dispute to setthi2003@gmail.com. Both parties shall attempt in good faith to resolve the dispute amicably within thirty (30) business days from receipt of such notice.
3. Exclusive Forum Jurisdiction: Any dispute that cannot be resolved amicably within the thirty (30) business day period shall be subject to the exclusive jurisdiction of the competent civil courts situated in Bangalore, Karnataka, Republic of India.

Document 3 — DPDP Statutory Consent Notice

Statutory Pre-Registration Notice published pursuant to Section 5 and Section 6 of the Digital Personal Data Protection Act, 2023.

[!IMPORTANT]

Mandatory Statutory DPDP Consent Notice

Notice to Data Principal: Under Section 5(1) of the Digital Personal Data Protection Act, 2023 (DPDP Act), every request for your consent must be accompanied or preceded by a notice informing you of the personal data to be processed and the specific purpose of processing.

Implementation Mandate: This Notice must be presented to the user prior to final account registration. Consent must be signified by an explicit affirmative action via an unchecked-by-default declaration checkbox. Pre-ticked checkboxes or implied consent mechanisms are strictly unlawful under Section 6 of the DPDP Act 2023.

Data Collection Breakdown & Specified Purposes

Authorized Sub-Processors & Data Security

Your data is securely stored and processed via industry-standard encryption protocols (TLS 1.3 in transit, AES-256 at rest) by our certified infrastructure partners:

• Database & Authentication: Supabase, Inc. (PostgreSQL Row Level Security, AWS Mumbai Region ap-south-1)
• AI Model Inference: OpenAI LLC / Anthropic PBC / Google Vertex AI (Operating under enterprise Zero Data Retention agreements; data is never used to train public foundation models)
• Push Notifications: Google LLC / Firebase Cloud Messaging (FCM)
• Subscription Billing: Cashfree / Razorpay / Apple In-App Purchase / Google Play Billing (PCI-DSS compliant)

Statutory Data Principal Rights & Withdrawal

Under the DPDP Act 2023, you retain the statutory right to:

1. Access a summary of your personal data being processed;
2. Request correction, completion, or updating of your data;
3. Request permanent erasure of your personal data;
4. Register grievances with our designated Grievance Officer at setthi2003@gmail.com and escalate unresolved matters to the Data Protection Board of India;
5. Withdraw Consent: You may withdraw this consent at any time via in-app settings or by emailing setthi2003@gmail.com. Please note that withdrawal of consent for core processing (account identity and expense ledgers) will result in the immediate closure and deletion of your account.

Mandatory Unchecked Declaration Checkbox (Implementation String)

[ ] I confirm that I am at least 18 years of age. I have read, understood, and accept the DPDP Statutory Consent Notice, Privacy Policy, and Terms of Service. I hereby grant my free, specific, informed, unconditional, and unambiguous consent to the collection, cryptographic storage, and processing of my personal and financial data as specified above.

Appendix A — Entity & Technical Configuration Schedule

This schedule outlines the core configuration parameters and variables governing the Setthi application deployment:

Appendix B — Statutory Concordance Index

This index provides a statutory mapping of Setthi's compliance policies against applicable Indian legislation:

Setthi — End User License Agreement (EULA)

Effective Date: September 24, 2026
Version: 1.0
Application: Setthi Mobile Application ("App")
Licensor / Developer: Setthi Technologies / Santosh Patil ("Licensor," "we," "us," or "our")
Contact: setthi2003@gmail.com

[!IMPORTANT]
PLEASE READ THIS END USER LICENSE AGREEMENT CAREFULLY BEFORE DOWNLOADING, INSTALLING, OR USING THE APP.
By downloading, installing, accessing, or using the Setthi mobile software application from the Apple App Store, Google Play Store, or any authorized distribution channel, you agree to be bound by the terms and conditions of this End User License Agreement ("EULA"). If you do not agree to the terms of this EULA, do not download, install, or use the Application.

1. Acknowledgement of Parties (Apple App Store & Google Play Minimum Terms)

This EULA is entered into strictly between you ("End-User" or "Licensee") and Setthi Technologies / Santosh Patil ("Licensor"), and not with Apple Inc. ("Apple") or Google LLC ("Google"). Licensor, and not Apple or Google, is solely responsible for the Application and the content thereof.

You acknowledge and agree that:

1. No Maintenance or Support Obligations: Neither Apple nor Google has any obligation whatsoever to furnish any maintenance or support services with respect to the Application.
2. Warranty Disclaimer & Refunds: In the event of any failure of the Application to conform to any applicable warranty, you may notify Apple, and Apple will refund the purchase price (if any) paid for the Application to you. To the maximum extent permitted by applicable law, Apple will have no other warranty obligation whatsoever with respect to the Application, and any other claims, losses, liabilities, damages, costs, or expenses attributable to any failure to conform to any warranty will be the sole responsibility of Licensor.
3. Product Claims: Licensor, not Apple or Google, is solely responsible for addressing any claims of the End-User or any third party relating to the Application or your possession and/or use thereof, including but not limited to:
   • Product liability claims;
   • Any claim that the Application fails to conform to any applicable legal or regulatory requirement; and
   • Claims arising under consumer protection, privacy, data protection, or similar legislation (including the Digital Personal Data Protection Act, 2023).
4. Third-Party Intellectual Property Claims: In the event of any third-party claim that the Application or your possession and use of the Application infringes that third party's intellectual property rights, Licensor, and not Apple, will be solely responsible for the investigation, defense, settlement, and discharge of any such intellectual property infringement claim.

2. Scope of License Grant & Usage Rules

2.1 Limited License Grant

Subject to the terms and conditions of this EULA and your payment of any applicable fees, Licensor grants you a personal, revocable, non-exclusive, non-transferable, non-sublicensable, limited license to download, install, and execute the Application onto mobile devices that you own or control, solely for your personal, non-commercial financial budgeting and tracking purposes.

2.2 Apple Media Services Usage Rules

You may only access and use the Application on Apple-branded products running iOS or iPadOS that you own or control, and strictly as permitted by the "Usage Rules" set forth in the Apple Media Services Terms and Conditions, except that the Application may be accessed and used by other accounts associated with you via Family Sharing or volume purchasing programs where permitted.

2.3 Strict License Restrictions

You expressly covenant and agree that you shall NOT:

1. Decompile, reverse engineer, disassemble, decrypt, or attempt to derive the source code, underlying ideas, algorithms, or system prompts of the Application;
2. Modify, adapt, translate, enhance, or create derivative works based upon the Application;
3. Rent, lease, lend, sell, sublicense, distribute, publish, or commercially exploit the Application to third parties;
4. Use the Application for commercial accounting, corporate financial auditing, or professional wealth management advisory services without an explicit enterprise agreement;
5. Circumvent, disable, or tamper with any digital rights management, security controls, or Row Level Security policies implemented within the Application;
6. Remove, alter, or obscure any proprietary copyright, trademark, or legal notices placed by Licensor on or within the Application.

3. Acceptable Use Policy & AI Conduct Guidelines

Setthi integrates artificial intelligence, automated receipt scanning (OCR), and natural language reasoning engines. You agree to use these computational interfaces strictly in a lawful, ethical, and responsible manner.

3.1 Prohibited Conduct & Activities

You are strictly prohibited from using the Application, its text prompt inputs, receipt uploads, or AI assistant to:

1. Unlawful Financial Schemes: Plan, structure, facilitate, or execute transactions intended for money laundering, illicit tax fraud, illegal evasion of customs or excise duties, or financing unlawful activities under the Prevention of Money Laundering Act, 2002 (PMLA) or the Indian Penal Code / Bharatiya Nyaya Sanhita;
2. Fraudulent Entries: Ingest deceptive, forged, fictitious, or maliciously fabricated financial ledgers, receipts, or bank statements;
3. Adversarial AI Attacks: Execute prompt injection attacks, jailbreaking exploits, or adversarial poisoning intended to bypass safety guardrails or induce the AI engine to generate harmful, illegal, defamatory, or obscene content;
4. Harassment & Abuse: Transmit abusive, profane, defamatory, harassing, or sexually explicit prompts through the conversational AI interface;
5. Malicious Payloads: Introduce viruses, worms, Trojan horses, or malicious scripts designed to compromise backend databases, rate limits, or server infrastructure.

3.2 Enforcement & Immediate Account Termination

Licensor maintains a strict zero-tolerance policy toward system abuse, illegal financial conduct, and adversarial exploitation. Licensor reserves the right, in its sole discretion and without prior notice or refund liability, to immediately revoke your license, suspend or permanently terminate your account, and cooperate with law enforcement authorities in the event of any prohibited conduct.

4. Mandatory Regulatory & Financial Disclaimer (SEBI Non-Advisory Exemption)

4.1 Not a Registered Financial or Investment Adviser

SETTHI IS AN AUTOMATED PERSONAL BUDGET MANAGEMENT, MATHEMATICAL AGGREGATION, AND EDUCATIONAL ASSISTANT POWERED BY ARTIFICIAL INTELLIGENCE. NEITHER SETTHI TECHNOLOGIES NOR SANTOSH PATIL IS REGISTERED AS AN INVESTMENT ADVISER (RIA), RESEARCH ANALYST (RA), PORTFOLIO MANAGER, OR STOCKBROKER UNDER THE SECURITIES AND EXCHANGE BOARD OF INDIA (SEBI) ACT, 1992, OR THE REGULATIONS FRAMED THEREUNDER. WE ARE NOT LICENSED CHARTERED ACCOUNTANTS, CERTIFIED FINANCIAL PLANNERS, OR TAX CONSULTANTS.

4.2 Non-Advisory Nature of Outputs

Nothing contained in the Application, generated by its algorithms, or output by the conversational AI assistant constitutes:

• Personalized investment, trading, portfolio management, or financial planning advice;
• A recommendation or solicitation to purchase, sell, hold, or subscribe to any stock, bond, mutual fund, derivative, insurance policy, cryptocurrency, or financial instrument;
• Certified tax advice, tax calculation guarantees, or statutory legal counsel;
• A promise, warranty, or guarantee of investment return, debt reduction, or financial outcome.

4.3 User Sole Discretion & Due Diligence

All budgeting allocations, expense categorizations, debt repayments, and financial decisions are made at your own sole discretion and risk. You are strongly advised to consult a qualified Chartered Accountant (CA) or SEBI-registered Investment Adviser before executing significant financial investments, business transactions, or statutory tax filings.

5. Artificial Intelligence Accuracy & Hallucination Clause

1. Probabilistic Nature of LLMs: You explicitly understand that the Application utilizes probabilistic Large Language Models (LLMs) and automated machine learning heuristics.
2. Possibility of Inaccuracies: AI outputs, automatic category assignments, currency conversions, and aggregated cash flow projections may occasionally contain mathematical discrepancies, calculation errors, outdated regulatory figures, or algorithmic "hallucinations."
3. Independent Verification: You bear the exclusive responsibility to audit, verify, and confirm all numerical figures, expense summaries, and budget limits before relying on them for actual payments or financial reporting.
4. Exclusion of AI Liability: Under no circumstances shall Licensor be held liable for any unexpected bank overdraft fees, missed bill payments, late penalties, tax audits, or financial damages resulting from reliance on AI suggestions or automated categorizations.

6. Warranty Disclaimer ("AS IS" & "AS AVAILABLE")

TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, THE APPLICATION IS PROVIDED TO YOU "AS IS" AND "AS AVAILABLE", WITH ALL DEFECTS, ERRORS, AND FAULTS, AND WITHOUT WARRANTY OF ANY KIND.

LICENSOR EXPRESSLY DISCLAIMS ALL WARRANTIES, WHETHER EXPRESS, IMPLIED, STATUTORY, OR OTHERWISE, INCLUDING ALL IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE, QUIET ENJOYMENT, DATA ACCURACY, AND NON-INFRINGEMENT. LICENSOR MAKES NO WARRANTY THAT THE APPLICATION WILL MEET YOUR FINANCIAL REQUIREMENTS, ACHIEVE ANY INTENDED RESULTS, BE COMPATIBLE WITH ALL DEVICE HARDWARE OR OPERATING SYSTEMS, OPERATE WITHOUT INTERRUPTION, BE FREE FROM DEFECTS, OR THAT ANY ERRORS WILL BE CORRECTED.

7. Limitation of Liability & Exclusion of Damages

TO THE MAXIMUM EXTENT PERMITTED UNDER APPLICABLE LAW:

1. Exclusion of Consequential Damages: IN NO EVENT SHALL LICENSOR, SANTOSH PATIL, ITS DIRECTORS, EMPLOYEES, CONTRACTORS, OR AFFILIATES BE LIABLE TO YOU OR ANY THIRD PARTY FOR ANY INDIRECT, SPECIAL, INCIDENTAL, CONSEQUENTIAL, EXEMPLARY, OR PUNITIVE DAMAGES—INCLUDING DAMAGES FOR LOSS OF PROFITS, SAVINGS, BUSINESS INTERRUPTION, CAPITAL DEFICITS, REGULATORY PENALTIES, BANK CHARGES, LOSS OF DATA, OR SYSTEM DOWNTIME—ARISING OUT OF OR RELATING TO THIS EULA OR THE USE OF (OR INABILITY TO USE) THE APPLICATION, REGARDLESS OF THE THEORY OF LIABILITY (CONTRACT, TORT, STRICT LIABILITY, OR OTHERWISE), EVEN IF ADVISED OF THE POSSIBILITY OF SUCH DAMAGES.
2. Absolute Aggregate Monetary Liability Cap: IN NO EVENT SHALL LICENSOR'S TOTAL AGGREGATE LIABILITY ARISING OUT OF OR IN CONNECTION WITH THIS EULA OR THE APPLICATION EXCEED INR 500 (FIVE HUNDRED INDIAN RUPEES) OR THE TOTAL AMOUNT ACTUALLY PAID BY YOU FOR THE APPLICATION IN THE PRECEDING TWELVE (12) MONTHS, WHICHEVER IS LESS.

8. United States Export Regulations & Sanctions Compliance

You represent, warrant, and covenant that:

1. You are not located in a country or territory that is subject to a U.S. Government or United Nations embargo, or that has been designated by the U.S. Government as a "terrorist supporting" country; and
2. You are not listed on any U.S. Government or international list of prohibited, sanctioned, or restricted parties, including the U.S. Department of the Treasury's Specially Designated Nationals (SDN) List or the U.S. Department of Commerce Denied Persons List.

9. Third-Party Beneficiary (Apple Legal Compliance)

You acknowledge and agree that Apple, and Apple's subsidiaries, are third-party beneficiaries of this EULA. Upon your acceptance of the terms and conditions of this EULA, Apple will have the right (and will be deemed to have accepted the right) to enforce this EULA against you as a third-party beneficiary thereof.

10. Governing Law, Dispute Resolution & Exclusive Jurisdiction

1. Governing Law: This EULA and all claims, disputes, or causes of action arising out of or related hereto shall be governed by, construed, and enforced in accordance with the substantive laws of the Republic of India, without reference to conflict-of-law doctrines.
2. Mandatory 30-Day Pre-Litigation Amicable Settlement: Prior to initiating any formal legal or arbitral proceedings, the complaining party shall deliver a detailed written statement of dispute to setthi2003@gmail.com. Both parties agree to engage in good-faith negotiations to resolve the dispute amicably within thirty (30) business days of receipt of such notice.
3. Exclusive Forum Jurisdiction: Any dispute, controversy, or claim that is not resolved through amicable discussions shall be subject to the exclusive jurisdiction of the competent civil courts situated in Bangalore, Karnataka, Republic of India.

11. Amendments, Modifications & Termination

1. Modifications: Licensor reserves the right, at its sole discretion, to modify, update, or replace this EULA at any time. Continued use of the Application following the publication of revised terms constitutes your binding agreement to the updated EULA.
2. Termination: This EULA remains in effect until terminated. Your rights under this EULA will terminate automatically without notice from Licensor if you fail to comply with any provision of this agreement. Upon termination, you must cease all utilization of the Application and permanently delete all copies of the Application installed on your devices.

12. Contact, Support & Legal Notice Information

For any questions, product claims, maintenance inquiries, or legal communications concerning this EULA, please contact:

Setthi Technologies
Attn: Santosh Patil (Founder & Lead Developer)
Corporate Seat: Bangalore, Karnataka, Republic of India
Compliance Email: setthi2003@gmail.com
Support & Dispute Portal: mailto:setthi2003@gmail.com

This End User License Agreement was last updated and ratified on September 24, 2026.