The Company takes the security of your personal data very seriously and is committed to protecting, upholding and respecting the privacy of the users (“You” or “Your”) of [Insert name of application] (the “Portal”).

Your privacy is of paramount importance to the Company, as the Company recognizes the sensitive and personal nature of the information shared by You during Your usage of the Portal. The Company understands that trust is fundamental to the Company’s relationship with You, and the Company is committed to maintaining the confidentiality, integrity, privacy and security of Your personal information.

The Company adheres to strict privacy standards and employs robust measures to safeguard Your data against unauthorized access, misuse, or disclosure. The Company recognizes that You entrust the Company with Your personal information, and the Company takes this responsibility seriously by implementing industry-standard security protocols and regularly updating the Company’s systems to mitigate potential risks. The core principles of these protocols and measures are stipulated below and shall be applicable in equal measure to all users of the Portal, including You.

In addition to this Privacy Policy, the usage of the Portal is simultaneously governed by the Terms of Service at [Insert link] and the Service Agreement executed between You and the Company.

INDEX

Introduction

Collection of Personal Information

Purpose and Usage of Personal Information

Purpose and Usage of Loan Information

Disclosure and Sharing of Information

Third-Party Links

Security Procedures

Retention of Data

Access to and Updating Information

Changes to the Privacy Policy

Contact Us

1

Introduction

1.1

You shall be bound by this Privacy Policy and all its subsequently modified versions.

1.2

Capitalised terms used but not defined in this “Privacy Policy” shall have the meanings ascribed to them in the Company’s Terms of Service (the “Terms of Service”), the latest version of which is available at [Insert link].

1.3

“Personal Information” is any and all information through or using which You can directly or indirectly be identified, including but not limited to Your name, e-mail address, residential address, information made available on social media, telephone number, password, and any other information which You provide while accessing services and products offered by the Company and which allows You to be directly or indirectly be identified and also includes limited personal data connected with use of the Portal e.g. IP address, browser type, operating system, geo-location, referring domains and exit links.

1.4

“Loan Information” is any and all information shared by You with the Company, regarding the hypothecated receivables and securitised/assigned loan assets (the “Loans”) for the purpose of availing the Services provided by the Portal. This includes but is not limited to the names of the loanees/borrowers, their contact information, residential address, financial details such as loan amounts, payment history, credit scores, loan terms and conditions, and any other information provided in relation to the Loans for availing the Services facilitated through the Portal.

1.5

By using or accessing the Portal, You irrevocably and unconditionally agree to the terms and conditions of this Privacy Policy. You also expressly consent to the Portal’s use and disclosure of Your Personal Information in any manner as described in this Privacy Policy. Your subscription to and usage of the Portal constitutes your express and perpetual consent to the Company’s usage of Your Personal Information for the purposes stated herein. At any time, You have the right to not provide the Company with certain information, or withdraw Your consent with respect to the collection, processing or disclosure of the Personal Information provided by You. Please note, however, that in such cases, the Company reserves the right to limit its services offered to You, or refuse the provision of such services in their entirety, including deeming You ineligible for any further usage of this Portal.

2

Collection of Personal Information

2.1

The Company receives Your Personal Information in the following cases: [Note: Please confirm if there would be any other case wherein the personal information of the user will be required.]

2.1.1

Registering an Account: The Company stores the information that You provide to it when You create an account on the Portal, including Your email address, phone number, name, password, address and additional information that You voluntarily provide to the Company during the process of registering Your account on the Portal.

2.1.2

Transactions: The Company collects certain information while providing the Services to You in order to verify Your identity, and the type of information and extent of information collected by it will depend on the nature of Services being availed by You. The Company reserves the right to use any and all such information (including any Personal Information) to verify your identity and to complete any authentication processes that may be required to be undertaken by the Company.

2.1.3

Use of Portal: The Company stores details of any pictures/materials /documents/information shared by You on the Portal. Additionally, the Company collects and stores details pertaining to each instance of Your usage of the Portal (such as pages visited and the installation and uninstallation of the application) and Your interactions through any e-mails or online chat logs, including Communication Channels exchanged between the Company and You. For more information, please see the Company’s policy on cookies below.

2.1

Cookies

2.2.1

The Company uses cookies and other technology like pixel tags for purposes described below. Cookies are small files which are sent from the Portal and then stored on to Your device/s. Pixel tags, also called web beacons, are clear image (i.e. non-visible) files that may be placed on the Portal, which request information from Your device (collectively, “Cookies”).

2.2.2

The Company sometimes collects anonymous information from visits to the Portal and uses this data to analyse trends and statistics and to help provide better customer service. This anonymous information is sometimes known as “clickstream data”.

2.2.3

Cookies may be set in Your devices when You access the Portal or when You visit third-party websites or platforms.

2.2.4

You are free to suitably modify the Portal settings if You do not wish to accept cookies, but please note that changing such settings in the Portal may affect Your experience with the Portal, and also the Company’s ability to effectively provide services to You. [Note to TruHypothesys: Please confirm]

2.3

Types of Cookies [Note to TruHypothesys: Please update as applicable.]

2.3.1

The Company uses Cookies for different purposes, which can be categorised as follows:

Required Cookies: These Cookies enable You to navigate the Portal and use its features, such as accessing secure areas of the Portal while using the Services. Each time You log into the Portal, a Cookie containing an encrypted, unique identifier tied to Your account is placed on Your browser. These Cookies allow the Company to uniquely identify You when You are using the Portal, and to process online transactions and requests.

Functional Cookies: These Cookies are required for the Portal to function. They include, for example, Cookies that enable You to log in. They may also enable the Company to recognise You when You return to the Portal and store information about Your preferences, so they allow the Company to customise the Portal according to Your individual preferences (such as the language chosen by You, changes made to text size and fonts, etc.). The Company uses local shared objects, also known as “Flash Cookies”, to store Your preferences or display content based upon what You view on the Portal to personalise Your visit to the Portal.

Performance Cookies: These Cookies collect information about how You use the Portal, including which pages You visit most often and whether You receive error messages from certain pages. These Cookies do not collect information that individually identifies You. All information these Cookies collect is aggregated and anonymous. It is only used to improve how the Portal functions and performs. From time to time, the Company engages third-parties to track and analyse usage and volume of statistical information from individuals who visit the Portal. The Company may also utilise “Flash Cookies” for these purposes.

Targeting/Advertising Cookies: The Company may engage third-parties to track and analyzs usage and volume statistical information from Your visits to the Portal. The Company may use Cookies delivered by third-parties to track the Company’s performance. For example, these Cookies remember which browsers have visited the Portal. The information provided to third-parties does not include Personal Information, but this information may be re-associated with Personal Information after the Company receives it.

Analytical Cookies: These Cookies analyse how You navigate around the Portal (pages visited, links used etc.) or use e-mails or chat logs that the Company sends to You or that You send to Us. They enable the Company to better understand Your interests and to improve the Portal and the user experience for Your benefit.

Third-party advertising: The Company uses third-party service providers to display advertisements (banners or links) on behalf of it across the internet. These advertising service providers may collect information about visits to the Portal and interactions with the Services, as well as Your visits to other websites. Such information does not include Your names, addresses, or e-mail addresses but may contain Portal related information.

3

Purpose and Usage of Personal Information

3.1

All Personal Information collected by the Company is specific and utilised based on the specific services which You wish to participate in or access, and is utilised for the purpose of providing such services as requested by You. Additionally, the Personal Information collected is utilised for the following purposes:

3.1.1

Transactions: Personal Information is used to administer accounts, process service requests, generate tickets/transaction records, etc.

3.1.2

Internal Record Keeping: Personal Information is used to allow You to use the services on the Portal, to inform You of the usage of the Portal, to communicate changes to the Terms of Services/Privacy Policy, and for any other purposes with the Your consent.

3.1.3

Analytics: The Company uses and collects Personal Information to help learn more about Your preferences (to enable the personalisation of the Portal or to provide You with any offers or promotions, based upon Your interests and preferences), to help address problems with and improve the Portal, to analyse trends and statistics, and to present content with the most clarity and usability.

3.1.4

Advertising: The Company presents information to its online advertisers and brand holders to help them understand its audience and confirm the value of advertising on the Portal. Such information is usually in the form of aggregated statistics on the traffic to various pages or sections within the Portal. When You register on the Portal, the Company may contact You from time to time to update Your information so as to provide You with features and other aspects of the Portal that may benefit You.

3.1.5

Securing the Company’s assets: The Company may also use Personal Information to protect the security or integrity of the Portal and its business.

3.1.6

Legal Proceedings: In the event the Company is required to respond to any legal, regulatory, judicial or administrative proceedings, including any legal notices or court orders, governmental directives, or the Company is otherwise required to adhere to specific applicable laws, Your Personal Information may be disclosed pursuant to such legal regulatory, judicial or administrative proceedings or in accordance with the requirements under applicable law.

4

Purpose and Usage of Loan Information

4.1

All Loan Information collected by the Company is specific and utilised based on the specific Services availed by You. Additionally, the Loan Information collected is utilised for the following purposes:

4.1.1

Transactions: Loan Information is used to administer and facilitate transactions, verify the identity of loanees, process service requests, generate transaction records, and ensure smooth rendering of Services.

4.1.2

Risk Solutions: Loan Information is utilised to perform risk assessments and provide risk solutions for the Loans listed on the Portal. This includes analysing financial details, payment histories, and credit scores to determine risk levels and offer appropriate risk mitigation strategies.

4.1.3

Internal Record Keeping: Loan Information is used to maintain accurate records of all transactions and interactions on the Portal. This helps in tracking loan portfolio performance, managing user accounts, and ensuring compliance with legal and regulatory requirements.

4.1.4

Analytics: The Company uses and collects Loan Information to gain insights into market trends, user preferences, and transaction patterns. This analysis helps improve the Portal’s functionality, enhance Your user experience, and develop new features and services based on Your needs and market demands.

4.1.5

Securing the Company’s assets: The Company may also use the Loan Information to protect the security and integrity of the Portal and the Company’s business. This includes monitoring transactions for fraudulent activities, ensuring data security, and implementing measures to safeguard sensitive information.

4.1.6

Legal Proceedings: In the event the Company is required to respond to any legal, regulatory, judicial or administrative proceedings, including any legal notices or court orders, governmental directives, or the Company is otherwise required to adhere to specific applicable laws, Your Loan Information may be disclosed pursuant to such legal regulatory, judicial or administrative proceedings or in accordance with the requirements under applicable law.

5

Disclosure and Sharing of Information

5.1

The Company treats Your Personal Information and/or Loan Information as strictly confidential.

5.2

The Company may involve other companies in providing services to You with whom the Company may share Your Personal Information, such as third-party service providers for data analytics, payments or other similar purposes. Where the Company engages such service providers that use Personal Information, the Company will ensure that such Personal Information is processed for such specific purposes only.

5.3

Additionally, the Company reserves the right to share, disclose and transfer Your Personal Information and/or Loan Information collected hereunder with its affiliates or the owner of the domain under any specific contractual terms that exist vis a vis such owner. In the event the Company sells or transfers all or a portion of its business assets or capital stock (whether through a private arrangement or in accordance with judicial or administrative directives), consumer information, including Personal Information and/or Loan Information, may be one of the business assets that are consequently shared, disclosed or transferred as part of any such transaction.

5.4

The Company may also share Personal Information and/or Loan Information, where necessary, to comply with any legal obligation or in order to enforce any other agreements under which the Company is contractually bound.

5.5

Prior to the use or disclosure of Personal Information and/or Loan Information for any reasons other than as stated above, the Company will ensure that You are intimated of the same in a timely manner.

5.6

The Company will take reasonable steps to ensure that all usage of and dealings in Your Personal Information shall be:

5.6.1

processed lawfully, fairly and in a transparent manner;

5.6.2

undertaken only with Your consent;

5.6.3

available for review by You, as and when reasonably requested by You;

5.6.4

kept secure against unauthorised or unlawful processing and against accidental loss, destruction or damage, as per legally prescribed standards; and

5.6.5

collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes.

6

Third-Party Links

The Portal may also include links to third-party websites or applications. Such websites or applications are governed by their respective privacy policies and terms of use, which are beyond the Company’s control. Once You leave the Portal, usage of any information provided by You is governed by the privacy policy of the operator of the website or applications which You are visiting or using. The Portal expressly disclaims any responsibility for the privacy practices or the content of such third-party websites and applications.

7

Security Procedures

7.1

The Company strives to ensure the security, integrity and privacy of Your Personal Information and/or Loan Information and to protect the same against unauthorised access, use, disclosure, alteration or destruction. The Company’s databases are stored on servers secured behind a firewall, with access to such servers being password-protected and strictly limited based on a need-to-know basis. The Company will at all times make reasonable endeavours to upgrade its security protocols such that they are in consonance with prevailing and extant legal and regulatory requirements in India.

7.2

Despite the Company’s best efforts to maintain a robust privacy and security system, You agree, acknowledge and understand that no security system is impenetrable and can absolutely guarantee unconditional privacy and security of Your Personal Information and/or Loan Information. Therefore, the Company’s extensive measures to maintain the integrity of its security protocols and systems does not guarantee the security of its database which includes the Personal Information and/or Loan Information that has been provided by You. In light of the above, the Company expressly disclaim all responsibility for any unintended or accidental breach of its security protocols, or any action of any third-parties that are consequently receiving Your Personal Information and/or Loan Information.

8

Retention of Data

8.1

The Company retains and continues to utilise Personal Information and/or Loan Information for as long as necessary, until: (i) the relevant purposes for the use of such Personal Information pursuant to the Service Agreement or any other contractual arrangements are completed; or (ii) as mandated under applicable laws and regulations or (iii) for legitimate business purposes.

9

Access to and Updating Information

9.1

You may contact [insert] in order to view, update and change the Personal Information provided by You within the Portal. You may also ask to erase, restrict or port Your Personal Information and intimate objections, if any, to the use of Your Personal Information by the Company. In such instances, You understand that your usage of the Portal is likely to be restricted in varying measures, and may even need to be discontinued, at the discretion of the Company. Additionally, You may access all information the Portal holds about You, and request a correction where data is incorrect or a deletion of the data, unless the Company has to retain the data for legal reasons and legitimate business purposes.

9.2

You are solely responsible for the accuracy of the Personal Information provided, and for any changes, updates or modifications to such information. The Company does not and will not authenticate the veracity or accuracy of any Personal Information whatsoever, and hence, do not and will not carry any liability to any third party about the authenticity, veracity and accuracy of the information that You choose to provide to the Company or otherwise decide to provide on the Portal during the course of Your usage of the Portal.

10

Changes to the Privacy Policy

This Privacy Policy was posted on [insert date]. The Company will endeavour to undertake periodic evaluations of the legal and regulatory landscape which is applicable to the Portal, this Privacy Policy and the Terms of Service thereof. Consequently, the Company unconditionally reserves the right to periodically, and at any time, review and change the Privacy Policy (or any part thereof) to incorporate such future changes as may be considered appropriate, including as an outcome of any changes to applicable laws or regulations. The updated Privacy Policy will be posted on this page and, where appropriate, notified to You by e-mail. The Company strongly advises You to periodically review this Privacy Policy to update Yourself about any such changes and alterations, irrespective of which You shall be automatically bound by such updated Privacy Policy as soon as such updates are made effective by the Company. Your continued usage of the Portal after such changes constitutes Your unconditional consent to such changes.

11

Contact Us

Any questions, clarifications, concerns or grievances with respect to this Privacy Policy or the Company’s practices concerning Personal Information may be addressed to the grievance officer at:
[insert phone number]
[insert address]