PRIVACY POLICY

“EMBIFI” is the trademark of EMBIFI GLOBAL SERVICES PRIVATE LIMITED, a company incorporated under the provisions of the Companies Act, 2013, having its registered office at New Delhi, India ( “Company” , “we” , “us” , “our” ). The Company is engaged in the business of, inter alia, providing plug-in technology to enable facilitation of embedded finance/loans for businesses.

This Privacy Policy governs how we and/or our affiliates process, use, collect, use, disclose, transfer, store, retain our Customer's (“you” and “your”) information when you avail and/or use services provided through our embifi.in Website (“Website” , "Platform")

Please note that by visiting or accessing the platform, you are accepting the practices described in this Privacy Policy. It is advised to read and understand our Privacy Policy carefully, and agree to be bound by the terms and conditions of the Privacy Policy including but not limited to consent to the collection, storage and use of information relating to you as provided herein. By using the Embifi services, you expressly consent to our use and disclosure of your personal information in accordance with this Privacy Policy. This Privacy Policy is incorporated into and subject to the Terms of Use.

Our Privacy Policy is subject to change from time to time without notice and it is strongly recommended that you periodically review our Privacy Policy as available on the Platform. In case you need any clarifications regarding this Privacy Policy, please do not hesitate to contact us at support@embifi.in.

COLLECTION, STORAGE AND USE OF INFORMATION RELATED TO YOU

We ask, collect and/or store basic types of information from you in conjunction with your use of the Platform i.e. personal information, which is any information that exclusively identifies you and non-personal information, which is information that does not exclusively identify you but is related to you nonetheless such as, information about your interests, demographics and use of the sites.

We use this information to do internal research like demographics, interests, and behaviour to better understand, protect and serve the users of the Platform. This information is compiled and analysed on an aggregated basis, including but not limited to your computer browser information, your IP address, and other information associated with your interaction with the Platform.

Personal Information

We, on the Platform or otherwise, may gain one time access of the Personal Information provided by you through informed consent, including but not limited to your:

We also receive and collect information from third parties and/or other sources including but not limited to:

When you use our Platform, we collect and store your information (personal information) which is provided by you from time to time by explicitly seeking permissions from YOU to get the required information. Our primary goal in doing so is to provide you a safe, efficient, smooth and customised experience and services. This allows us to provide services and features that meet your needs, and to customise our Platform to make your experience safer and easier and to improve the services provided by us. More importantly, we collect personal information from you that we consider necessary for achieving the aforementioned purpose.

To the extent possible, we provide you the option of not divulging any specific information that you wish for us not to collect, store or use. You may also choose not to use a particular service or feature of the Platform, and opt out of any non-essential communications from the Company. Depending on the activity, some of the information we ask you to provide is identified as mandatory and some is identified as voluntary. If you do not provide the mandatory information for a particular activity that requires it, you will not be permitted to engage in that activity.

We only collect and use such information from you that we consider necessary for achieving a seamless, efficient and safe experience, customised to your needs and use the personal information to provide products to you, enhance the operation of the Platform, improve our marketing and promotional efforts, analyse Platform use, improve our product offerings, to personalise your experience and to provide you a better experience.

Where possible, we indicate the mandatory and the optional fields. You always have the option to not provide your personal information by choosing not to use a particular service or feature on the Platform. We also collect other identifiable information (your payment card details and transaction histories on the Platform) from you when you set up a free account with us as further detailed below. While you can browse some sections of our Platform without being a registered member as mentioned above, certain activities (such as availing of loans from the third party lenders on the Platform) requires registration and for you to provide the above details. The Platform shall clearly display the personal information it is collecting from you, and you have the option to not provide such personal information. However, this will limit the services provided to you on the Platform.

DISCLOSURE TO THIRD PARTIES

Further, we may share your personal information with other corporate entities and affiliates to facilitate transactions. Your personal information may be shared/ sold by us or our affiliates with a third party business entity in case of any proposed merger, acquisition or re-organization, amalgamation, restructuring of business, including but not limited to Credit bureaus financial institutions, body corporates etc. Should such a transaction occur that another business entity (or the new combined entity) will be required to follow this Privacy Policy with respect to your personal information.

Non-personally identifiable information

Non-personally identifiable information is information that does not identify a specific end user. This type of information may include things like the URL of the website you visited before coming to our Website, the URL of the website you visit after leaving our Platform, the type of browser you are using, preferences on the Platform and your Internet Protocol address etc. Such information may be used by us to analyse trends and gather demographic information etc.

Where any service requested by you involves a third party, such information as is reasonably necessary by the Company to carry out your service request may be shared with such third party. We may also engage with other companies/ persons to perform functions such as order fulfilment, delivering packages, analyzing data, providing marketing assistance, providing search results and links (including paid listings and links), processing credit card payments, and providing customer service. They have access to personal information needed to perform their functions.

Where possible, you shall have the option to restrict disclosure to third parties. However, where sharing of information to a particular third party is necessary for providing the services, you shall not be able to avail such services in case you decide to restrict such disclosure.

We also do use your contact information to send you offers based on your interests and prior activity. The Company may also use contact information internally to direct its efforts for product improvement, to contact you as a survey respondent, to notify you if you win any contest; and to send you promotional materials from its contest sponsors or advertisers.

Further, upon registering on the Platform, you may from time to time choose to provide payment related financial information. We are committed to keeping all such sensitive data/information safe at all times and ensure that such data/information is only transacted over secure sites of approved payment gateways which are digitally encrypted, and provide the highest possible degree of care available under the technology presently in use.

The Company will not use your financial information for any purpose other than to complete a transaction with you.

We have reasonable security measures, including as mentioned in Information Technology Act, 2000 in place to protect the loss or misuse of the information under our control. Whenever you change or access your account information, we offer the use of a secure server. However, transacting over the internet has inherent risks which can only be avoided when you follow security practices yourself, such as not revealing account/login related information to any other person and informing our customer care team about any suspicious activity or where your account has/may have been compromised.

If you send us personal correspondence, such as emails or letters, or if other users or third parties send us correspondence about your activities on the Platform, we may collect such information into a file specific to you.

We do not retain any information collected for any longer than is reasonably considered necessary by us, or such period as may be required by applicable laws. The Company may be required to disclose any information that is lawfully sought from it by a judicial or other competent body pursuant to applicable laws.

COLLECTION OF INSTALLED APPLICATIONS

We may collect a list of the installed applications’ metadata information which includes the application name, package name, installed time, updated time, version name and version code of each installed application on your device to assess your credit worthiness and enrich your profile with pre-approved customised loan offers.

STORAGE

We will keep your information as long as you have availed any of the products and/or services through the Platform.

We require the storage information permission that allows the Platform to enable you to upload photos and/or documents to complete the application form during your loan application journey.

LINK TO OTHER SITES

The Platform may contain links to third party websites that may collect personally identifiable information about you. We are not responsible for the privacy practices of such websites which we do not manage and control.

LINK TO THIRD-PARTY SDK

Our Platform may have a link to a registered third party SDK which collects data on our behalf and data is stored to a secured server to perform a credit risk assessment. We ensure that our third party service provider takes extensive security measures in order to protect your personal information against loss, misuse or alteration of the data.

Our third-party service provider employs separation of environments and segregation of duties and have strict role-based access control on a documented, authorized, need-to-use basis. The stored data is protected and stored by Platform-level encryption. They enforce key management services to limit access to data.

Furthermore, our registered third party service provider provides hosting security – they use industry-leading anti-virus, anti-malware, intrusion prevention systems, intrusion detection systems, file integrity monitoring, and platform control solutions.

SECURITY PRECAUTIONS

The Platform intends to protect your personal information and to maintain its accuracy as confirmed by you. We implement reasonable physical, administrative and technical safeguards to help us protect your personal information from unauthorized access, use and disclosure. For example, we encrypt all sensitive personal information when we transmit such information over the internet. We also require that our registered third party service providers protect such information from unauthorized access, use and disclosure.

Our Platform has stringent security measures in place to protect the loss, misuse and alteration of information under control. We endeavour to safeguard and ensure the security of the information provided by you. We use Secure Sockets Layers (SSL) based encryption, for the transmission of the information, which is currently the required level of encryption in India as per the law.

We blend security at multiple steps within our products with the state of the art technology to ensure our systems maintain strong security measures and the overall data and privacy security design allow us to defend our systems ranging from low hanging issue up to sophisticated attacks.

Please note that we will not ask you to share any sensitive data or information such as account/login/passwords/financial information (bank details, OTPs etc) and other sensitive personal information via email/telephone/SMS/link. Please do not share such information with any person.

YOUR CONSENT

By using the Platform and/ or by providing your information, you consent to the collection, storage and use of the information you disclose on the Platform in accordance with this Privacy Policy, including but not limited to your consent for collecting, using, sharing and disclosing your information as per this Privacy Policy.

If we decide to change our Privacy Policy, we will post those changes on this page so that you are always aware of what information we collect, how we use it, and under what circumstances we disclose it.

CHOICES AVAILABLE REGARDING COLLECTION, USE AND DISTRIBUTION OF INFORMATION

To protect against the loss, misuse and alteration of the information under its control, the Company has in place appropriate physical, electronic and managerial procedures. For example, the Company servers are accessible only to authorized personnel and your information is shared with employees and authorized personnel on a need to know basis to complete the transaction and to provide the services requested by you. Although the Company endeavours to safeguard the confidentiality of your personally identifiable information, transmissions made by means of the Internet cannot be made absolutely secure. By using the Platform, you agree that the Company will have no liability for disclosure of your information due to errors in transmission and/or unauthorized acts of third parties.

Please note that we will not ask you to share any sensitive data or information via email or telephone. If you receive any such request by email or telephone, please do not respond/divulge any sensitive data or information and forward the information relating to the same to support@embifi.in for necessary action.

COMMUNICATION WITH COMPANY

If you wish to correct or update any information you have provided, you may do so online, on the Platform itself. Alternatively, you may contact the Company to correct or update such information by sending an e-mail to: support@embifi.in

In the event of loss of access to the Platform, you may contact the Company by sending an e-mail to: support@embifi.in

In the event you wish to report a breach of the Privacy Policy, you may contact the designated Grievance Officer of the Company at:

Name: Gaurav Parashar

Address: 603-604, 6th Floor, Thapar House, Building No. N161 Gulmohar Enclave Community Centre, Near Green park metro station New Delhi 110016

Phone: +91 8448559088

Email: compliance@embifi.in

[10:00 AM to 5:00 PM, Monday to Friday, except Public Holidays]

GOVERNING LAW AND JURISDICTION

This Privacy Policy will be governed by and construed in accordance with the laws of India and subjected to the exclusive jurisdiction of courts of New Delhi.

Annexure 1

CUSTOMER CONSENT AND SELF DECLARATION

1. I/ We hereby declare that all the particulars, information and details provided by me/us are true, correct, complete and up-to-date in all respect and that I/we have not withheld any information whatsoever.

2. I/ We hereby confirm that no insolvency proceedings or suits for recovery of outstanding dues or monies whatsoever for attachment of my/our assets or properties and/or any criminal proceedings have been initiated and/or are pending against me/us and that I/we have never been adjudicated insolvent by any court or any other authority nor has any receiver, administrator, administrative receiver, trustee or similar officer been appointed for my assets.

3. I/We hereby authorise the Lending Partner and/or the Regulated Entity or its associates/subsidiaries/affiliates/agents to obtain, verify, exchange, share or part with all the information or otherwise, regarding my/our office/ residence and/or contact me/us or my/our family/ employer/Banker/Credit Bureau/ RBI or any third parties as deemed necessary and/or do any such acts till such period as they deem necessary and/or disclose to Reserve bank of India, Credit Information Companies, Banks/NBFCs, or any other authority and institution, including but not limited to current balance, payment history, default, if any, etc.

4. I/We hereby authorise Lending Partner’s/Regulated Entity’s employees/agents to access my/our premises during normal office hours for carrying out any verification/investigation and post disbursement scrutiny.

5. I/We hereby authorise the Lending Partner and/or the Regulated Entity to approach my/our existing bankers or any other prospective lenders for any relevant information for consideration of loan and thereafter.

6. I/We hereby provide my/our consent to receive information/services etc for marketing purposes through telephone/mobile/SMS/Email.

7. I/We hereby authorise the Lending Partner and/or the Regulated Entity to market/sell/promote/endorse any other product or service beneficial to me/us.

8. I/We hereby authorise the Lending Partner and/or Regulated Entity to purge the documents submitted by me/us, if the case is not disbursed/approved for whatever reason within 3 months of application.

9. I/We hereby authorise UIDAI to release my/our identity and address through biometric authentication.

10. I/We hereby provide my/our consent to avail information on products and services of other Companies and authorise to cross sell other company’s product and services.

11. I/We hereby authorise the Lending Partner’s/Regulated Entity’s authorised person(s)/Agency to visit my/our residence & business premises for verification, which includes taking photographs.

12. I/We hereby agree to give my/our express consent to the Lending Partner and/or Regulated Entity to disclose all the information and data furnished by me/us and/or to receive information from Central KYC Registry/third parties including but not limited to vendors, outsourcing agencies, business correspondents for analysing, processing, report generation, storing, record keeping or to various credit information companies/ Credit Bureaus, or to information utilities under the Insolvency Bankruptcy Code 2016 through physical or SMS or email or any other mode.

Annexure 2

Consumer Consent for accessing Consumer Credit Information Report (CIR)

I hereby appoint EMBIFI GLOBAL SERVICES PVT LTD (hereinafter referred as “Company”), as my lawful agent and its associated Credit Institutions/Lending Partners to receive and/or pull my credit report/credit history (“Credit Information”) from Credit Information Companies (“CICs”).

I further authorize the Company to share with CICs my personal information/details to procure my Credit Information on a monthly frequency and use the same to provide me with credit report access services (“Purpose”).

I understand and acknowledge that the CIC shall not be liable under law or equity, in any manner whatsoever, for providing my Credit Information to the Company and I will not raise any claim or objections against the CIC.

I confirm that this consent is given by my free will and not due to any solicitation by any person/entity.

This consent/authorization shall be valid for (i) a maximum period of 06 (six) months, from the date of giving the same, (ii) satisfying the Purpose or (iii) until I withdraw my consent at any time, by informing the same to the Company, at their registered office address, website, assigned email id or mobile application, whichever is earlier.

I also consent to the CRIF High Mark Credit Score Terms of Use.

Annexure 3

CRIF High Mark -Credit Score Terms of Use

In connection with submission of the application for my credit information (“Consumer Credit Information”) offered by CRIF High Mark Credit Information Services Pvt. Ltd. (“CIC”) through Embifi Global Services Pvt Limited (referred to as the “Company”) and delivery of the Consumer Credit Information to the Company, I hereby acknowledge and agree to the following:

A. The Company is my lawfully appointed agent and he / it has agreed to be my agent to obtain my Credit Information Report and Credit Score from CRIF High Mark Credit Information Services Pvt. Ltd (CRIF High Mark) for the purpose of credit report access and not for any other purposes. This consent shall be valid for a maximum period of 6 months or till such time the credit information is required to be retained to satisfy the purpose for which it was intended, or I withdraw my consent to store such credit information, whichever is earlier.

A. I hereby expressly grant unconditional consent to, and direct, CIC to deliver and / or transfer my Consumer Credit Information to the Company on my behalf.

B. I shall not hold CIC responsible or liable for any loss, claim, liability, or damage of any kind resulting from, arising out of, or in any way related to: (a) delivery of my Consumer Credit Information to the Company; (b) any use, modification or disclosure by the Company of the contents, in whole or in part, of my Consumer Credit Information, wherever authorized by me; (c) any breach of confidentiality or privacy in relation to delivery of my Consumer Credit Information to the Company;

C. I acknowledge and accept that: (a) CIC has not made any promises or representations to me in order to induce me to provide my Consumer Credit Information or seek any consent or authorization in this regard; and (b) the implementation of the Agreement between CIC and the Company is solely the responsibility of the Company.

D. I agree that I may be required to record my consent / provide instructions electronically or physically as the case may be, and in all such cases I understand that by clicking on the "I Accept" button below or signing this Consent physically, I am providing "written instructions" to the Company authorizing Company to obtain my Consumer Credit Information from my personal credit profile from CRIF High Mark. I further authorize the Company to obtain such information solely to confirm my identity and display my Consumer Credit Information to me. Further in all such cases by checking this box and clicking on the Authorize button or signing this Consent physically, I agree to the terms and conditions, acknowledge receipt of CIC privacy policy and agree to its terms, and confirm my authorization for the Company to obtain my Consumer Credit Information.

E. I understand that in order to deliver the product to me, I hereby authorize the Company, to obtain my Consumer Credit Information from CIC.

F. By submitting this registration form, I understand that I am providing express written instructions for Company to request and receive a copy of my consumer credit report and score from CIC.

G. I understand that the product is provided on an “as-is”, “as available” basis and CIC expressly disclaims all warranties, including the warranties of merchantability, fitness for a particular purpose, and non-infringement.

H. I shall not sue or otherwise make or present any demand or claim, and I irrevocably, unconditionally and entirely release, waive and forever discharge CIC, its officers, directors, employees, agents, licensees, affiliates, successors and assigns, jointly and individually (hereinafter “Releasee”), from any and all manner of liabilities, claims, demands, losses, claims, suits, costs and expenses (including court costs and reasonable attorney fees) (“Losses”), whatsoever, in law or equity, whether known or unknown, which I ever had, now have, or in the future may have against the Releasee with respect to the submission of my Consumer Credit Information and / or my decision to provide CIC with the authority to deliver my Consumer Credit Information to the Company. I agree to defend, indemnify, and hold harmless the Releasee from and against any and all losses resulting from claims made against CIC by third parties arising from and in connection with this letter.

Annexure 4

COMMUNICATION WITH CRIF Highmark

In order to expeditiously and effectively resolve your disputes and/or grievances on the credit information reports generated by the CIC, you may click on the link provided herein (https://cir.crifhighmark.com/personal-credit-report/raisedispute) in an attempt to facilitate your complaints in an automated way