PRIVACY POLICY

The following are our guiding principles regarding privacy:

1. Ask for only the information necessary, gathering only what we believe is essential for doing business, or for the specific transaction at hand.
2. Effective, efficient, and sustainable processes for sharing data with employees, partners and vendors.
3. Approval and authorisation mechanism to access the information collected.
4. Higher control and visibility, and strong technologies in our tools and applications with respect to usage and protection of information.
5. Specific purpose for all information collected.

This privacy policy(“Privacy Policy”) explains our policy regarding the collection, use, disclosure, transfer, or otherwise processing of your personal data by us.The services or products we offer you on or through the Platform (defined below) are referred to as the "Services". The Privacy Policy covers the following aspects:

1. Definitions
2. Collection of personal data
3. Use of collected personal data
4. Disclosure of personal data
5. Security of personal data collected
6. Your rights and choices
7. General information
8. Changes to the privacy policy
9. Grievance redressal

1. “personal data” or “personal information” means any data about an individual who is identifiable by or in relation to such data.
2. “Platform” means our Digital Lending Platform.

1. General
   1. We use different methods to collect and process personal data about you. This includes:
      1. Information you provide us: This is the information (including identity, contact, KYC, financial, and device data) you consent to give us when you use our Services or when you correspond with us (for example, by email or chat, or through the App). It includes information you provide when you register to use the Services, use a Platform feature, share data through the Platform, or when you report a problem with the Platform and our Services. If you contact us, we will keep a record of the information shared during the correspondence
      2. Information we collect about you and your device: Each time you visit the Platform or use the Services, we will automatically collect personal data through cookies.
      3. Information we receive from other sources including third parties and publicly available sources: We will receive personal data about you from various third parties and public sources including our third parties, Google analytics for advertising and user analytics purposes, credit information companies, the Central KYC Registry, GSP APIs, and publicly available sources. We will also collect Credit Data about you with your authorisation from credit information companies
   2. Our Services may, from time to time, contain services provided by or links to and from the websites of our partner networks, service providers, financial institutions, advertisers, and affiliates and other service providers (“Third Party Services”). Please note that the Third Party Services that may be accessible through our Services are governed by their own privacy policies. We do not accept any responsibility or liability for the policies or for any personal data that may be collected through such Third Party Services. Please check their policies before you submit any personal data to such websites or use their services.
   3. We may collect, store, and use the following kinds of information, in accordance with applicable law:
      1. Identity Data: This includes your name, username, or other identifiers such as admin IDs, gender, title, photographs, date of births, educational qualification and background, marital status, feedback, survey responses, DIN, form submissions, your correspondence with us, and details provided during events, trade shows, or marketing activities.
      2. Contact Data: This includes your email address, physical address, phone number, and other contact information.
      3. Credit Data: This includes your credit information, credit history, credit information report and/or credit score.
      4. Business Data: This includes your segment, sub-segment, business profile, type of firm,, annual turnover, promoter details, GST-related data such as GSTIN, PAN details such as business PAN, and other business-related information such as financial reports, ITR (including balance sheet, profit and loss account), trial balance, bank statements, books of account and transaction details, including data accessed or provided by you through the business accounting software you use.
      5. KYC Data: This includes identification documents issued by the government or other authorities, and includes details of or pertaining to your Aadhaar*, PAN, voter ID, and ration card, and other KYC-related information of your organisation or its members;
      6. Transaction Data: This includes details of transactions that may occur in connection with the Services.
      7. Financial Data: This includes your past credit history, income and revenue details, bank account details, bank account statements.
      8. Property Data: This includes details of any immovable or movable property owned, leased, or otherwise used by you or your business. It may include property ownership documents, title deeds, lease agreements, encumbrance details, property tax records, valuation reports, utility bill records, and any other documents or information related to the identification, ownership, possession, or valuation of such property.
      9. Marketing and Communications Data: This includes your preferences in receiving marketing messages from us and our third parties and your communication preferences.
      10. Device Data: This includes your IP addresses, browser types and versions, time zone settings and locations, operating systems, and device information.
      11. Usage Data: This includes information about how you use the Services.

   *In order to comply with the Master Direction – Know Your Customer (KYC) Direction, 2016, we urge you to share a masked Aadhaar copy. In the event you provide us an unmasked Aadhaar copy, you consent and acknowledge the use of Third Party Services by us to ensure valid masking prior to use of our Services. For more information on masked Aadhaar kindly visit myaadhaar.uidai.gov.in.

   While Aadhaar is a preferred KYC document there are alternative options available for KYC and establishing identity.

2. Your information or data will be retained only for as long as necessary to fulfill the purpose for which it was collected or as required under applicable laws, regulatory requirements, or contractual obligations. This includes Your consent to this Privacy Policy, your name, address & contact details. Your Credit Data shall be retained as per the provisions of clause 3.3 of this Privacy Policy. All other information and data provided by you for the purpose of availing for loan facilitation services on the Platform shall be automatically deleted or destroyed within 90 days from the date of submission of the loan application on the Platform, inaccordance with the applicable law.
3. Your Credit Data received by us from TransUnion CIBIL Limited and CRIF High Mark Credit Information Services Private Limited (‘Credit Information Companies’) shall be automatically deleted or destroyed within 180 days from the date of your consent to appoint us as your authorized representative to receive your Credit Information, Credit Information Report and Credit Score from such Credit Information Companies, as part of the Services or until you withdraw your consent as per the Consent Withdrawal Policyor till such time the Credit Data is required to be retained to fulfill the purpose for which it was collected; whichever is earlier.
4. Cookies: Our Services may use cookies and other technologies to function effectively. These technologies may record personal data about your use of our Services or Platform, including: browser and device data, such as IP address, device type, operating system and internet browser type, screen resolution, operating system name and version, device manufacturer and model, and language/version of the Platform you are visiting; and usage data, such as time spent on the Platform, pages visited, links clicked, language preferences, and the pages that led or referred you to our Platform.
5. We may also collect, use, and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal information but is not considered personal data or personal information under applicable laws.

1. In general, we use your personal data for the following purposes in compliance with applicable laws:
   1. To register you as a user of the Services or Platform;
   2. To provide you with our products or Services;
   3. To provide you with financial services, including:
      1. provide information to one or more lender(s) or third parties for making enquiries/checks on you and your partners/directors, conducting other due diligence, processing your loan application and/or monitoring of your loan account;
      2. provide need-based information to third parties to get analysed data to help us decide which applications should be sent to lenders or third parties, or to help lenders or third parties take a decision on your loan application;
      3. contact or locate you in case of any default on a payment due, in compliance with applicable law; or
      4. provide you with your credit score;
   4. To get your data/information analysed by third parties to enable you to avail our Services;
   5. To manage our relationship with you, including notifying you of changes to any products or Services;
   6. To offer user support, including to:
      1. provide any information and Services that you have requested or any applications or Services that you have ordered;
      2. provide, maintain, protect, and improve any applications, products, Services, and information that you have requested from us;
      3. manage and administer your use of applications, products, and Services you have asked us to provide;
      4. provide any information that we are required to furnish under our regulatory or legal obligations;
      5. detect, prevent, investigate, or remediate crime, illegal, or prohibited activities or otherwise protect our legal rights (including liaison with regulators and law enforcement agencies for these purposes); or
      6. to send you offers based on your previous transactions and your interests;
   7. To administer and protect our business and the Platform, including troubleshooting, data analysis, system testing, and performing internal operations;
   8. To deliver content to you;
   9. To send you communications, including through WhatsApp business messages, in relation to your use of the Platform or Services;
   10. To monitor trends so we can improve the Platform and Services;
   11. To improve our business and delivery models;
   12. To perform our obligations that arise out of the arrangement we are about to enter or have entered with you;
   13. To enforce our General Terms and conditions and/or the Credit Information Services Terms and Conditions;
   14. To undertake marketing services via email, phone, or otherwise, including to:
       1. send you promotional messages;
       2. advertise and provide personalised information about our products and Services, on our Platform and through third-parties such as our partners;
       3. invite you to participate optionally in events and surveys conducted either by us or through a third-party market research agency;
       4. follow up with requested products and Services; or
       5. ensure that you are aware of all the features of the products or Services;
   15. To respond to court orders, establish or exercise our legal rights, or defend ourselves against legal claims;
   16. To ensure compliance with applicable laws.

4.2 Please note that we do not have any control over personal data that you may choose to make publicly available. For example, if you post reviews, comments, or messages on public sections of the Platform or on an application store (such as the Google Play Store), you do so at your own risk. We are not liable for third-party misuse of such data

1. In accordance with applicable law, we may share your information with:
   1. our holding subsidiaries, associate, group companies or affiliates or any other entity/ third-party/ body corporate including our partners, for purposes in accordance with this Privacy Policy, as per Section 4 above;
   2. our service providers and agents (including their sub-contractors) or third parties which process information on our behalf (e.g. storage providers, internet service and platform providers, payment processing providers, organisations we engage to help us send communications to you, and analytics service providers) so that they may help us to provide you with the applications, products, Services or information you have requested or which we believe is of interest to you;
   3. our consultants, professional advisors, and auditors;
   4. lenders or third parties processing your loan application, including for the periodic monitoring of your loan account, where applicable;
   5. third parties to facilitate payment transactions;
   6. third parties to extract information related to your business or to analyse information submitted by you;
   7. third parties in the event we go through a business transition, such as a merger, demerger, split, division, acquisition by another organisation, or sale of all or a portion of our assets, and your personal data is among the assets transferred;
   8. third parties such as financial technology companies, to draw meaningful analysis from your data to facilitate your loan, where applicable;
   9. regulators to meet our legal and regulatory obligations and to respond to court orders or other legal process; and
   10. law enforcement agencies so that they may detect or prevent crime or prosecute offenders.

In the event you access or use our services through the platform, we will share your personal data in accordance with applicable laws and to the extent permitted by the credit information companies, where applicable. The lenders or third parties with whom your information has been shared may have their own privacy policies which will be disclosed by them to you during the loan process at an appropriate stage. Processing of your personal data shared with them shall be governed by their own privacy policies over which we shall have no control or restriction.

We may share non-personally identifiable information about the use of our Platform, products and/or Services publicly or with third parties.

1. We take appropriate technical and organisational precautions commensurate with the information assets being protected, as prescribed under applicable laws, to prevent the loss, misuse, or manipulation of the information shared.
2. We store all personal information described under this Privacy Policy on our secure password-protected servers.
3. You acknowledge the fact that data transmitted through the internet may be naturally prone to insecurity and we cannot guarantee security of such data.

1. Right to Confirmation and Access: Right to review your personal data stored by us.
2. Right to Correction and Updation:Right to correct, update, or rectify personal data residing with us that is found to be inaccurate or deficient.
3. Right to Be Forgotten or Deletion: Right to erasure or to restrict or prevent continuing disclosure of personal data. We shall comply with such requests subject to applicable laws and the terms of the loans that may be sanctioned through the Services.
4. Right to withdraw consent: We will provide you with an opportunity to withdraw consent from processing your data. However, that withdrawal of consent will not be retroactive and will be in accordance with the terms of this Privacy Policy, related General Terms and Conditions, related Credit Information Services Terms and Conditions and applicable laws. If you exercise the foregoing rights, it may impact or restrict our ability to provide Services to you. Please note that withdrawing your consent will not affect the lawfulness of any processing we conducted prior to such withdrawal, nor will it affect processing of your personal data conducted in accordance with lawful processing grounds other than consent.

   If you wish to exercise any of the foregoing rights, you can write to us at consentrevocation@tallysolutions.com, providing details in Consent Withdrawal Form and the right(s) you wish to exercise. Please also include a description of the personal data you believe we hold or process about you, so that we may be able to locate such personal data. In the event that we need additional information from you, our Grievance Redressal Officer or any person authorised on behalf of the Grievance Redressal Officer will contact you.

   You are further advised to refer to our Consent Withdrawal Policy for details on the procedure to withdraw your consent granted to us for accessing, using, analysing, aggregating, and retaining your credit information, credit information report and credit score obtained from Credit Information Companies.

1. Consent: If required by applicable law, all collected data is subject to your consent for the collection, use, storage, disclosure and otherwise processing of your personal information in accordance with this Privacy Policy. You can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we have conducted prior to your withdrawal, nor will it affect processing of your Data conducted in reliance on lawful processing grounds other than consent. However, in the event you withdraw consent given to us under this Privacy Policy, such withdrawal may hamper your access to the Platform or restrict provision of our services to you for which we consider that information to be necessary.
2. Children’s Data: We do not knowingly solicit or collect personal information from children under the age of 18 years.

1. Please check our Privacy Policy periodically for changes. We may update this Privacy Policy to reflect changes to our information practices. We may alert you to significant changes by notifying you in accordance with applicable laws.

To exercise any of the rights mentioned in this Privacy Policy or to share any grievance or queries related to our processing of your personal data, please email our Nodal Grievance Redressal Officer.

The name and contact details of the Nodal Grievance Redressal Officer are provided below: