The aim of this privacy policy statement is to inform the Customer including authorised users of the Customer (if such customer is an entity) (collectively hereinafter referred to as “User”) about Autolytics Technology Private Limited’s (“Company”) practices regarding collection, use, disclosure and transfer of Personal Information and other information that is either provided by the User or collected by the Company through User’s use of the Platform (“Privacy Policy”).

Personal Information shall mean information that identifies the User (identifies an individual) and collected by the Company through User’s use of the Platform or provided by User in digital form.

This Privacy Policy will have to read in conjunction with the Terms of Use of the Company as may be in force from time to time and available here. Further, all other provisions of the Terms of Use such as amendment, governing and jurisdiction shall mutatis mutandis be applicable to this Privacy Policy.

Capitalized terms used herein and not defined shall have the meaning given to it in the Terms of Use published on the Platform.

1. Collection, Consent

1.1. For the purposes of providing the Services, through the Platform the Company may collect, process, store and use the following information from the User:

(a)Information provided by the User for creation of account on the Platform, including name, email address, addresses, mobile number and employee identification number (if applicable);

(b)Know your customer information along with necessary documents such as address proof, identity proof (including Aadhaar), for the purposes of performing background verification including satisfying know your customer due diligence and to perform credit checks;

(c)Information regarding the devices through which the User accesses and/or uses the Platform for the purposes of making the Customer’s account information available throughout all the devices used by the User;

(d) Information regarding Users’ visits to the Platform;

(e) Information about Users’ geographical location;

(f) Information submitted by the User on the Platform for obtaining the Services through the Platform including business related information;

(g) Information relating to Products the User may purchase on or through the Website;

(h) Information relating to any transaction that the User may enter into on or through the Website;

(i) User’ computer browser information and IP address to help diagnose problems with Website server and for the purposes of gathering broad demographic information; and

(j) Financial information of the User such as billing address, a credit / debit card number and a credit / debit card expiration date and/ or other payment instrument details including bank account details of the User.

1.2. The User hereby expressly and irrevocably consents to the collection, storage, processing and use of the information stated in paragraph 1.1 above.

1.3. Permissions

1.3.1. The User hereby acknowledges that the Company as part of its service offering through the Platform amongst other things enables the Customer to avail loan, insurance and other investments/products or find suitable Anchor Corporate to transact business with. For this purpose, at the specific request of the Customer, the Platform will collect, retrieve, process, analyse, store and transmit data relating to the Customer including data from income tax returns, goods and services tax filings and bank statements of the Customer. Such data retrieved, collected by the Platform, will be automatically processed, analysed and represented in a manner required by the Service Provider or Anchor Corporate (specifically chosen by the Customer) (“Resultant Data”). The User agrees to the transmission of the Resultant Data to the Service Provider or Anchor Corporate as may be selected by the Customer.

1.3.2. The User hereby expressly and irrevocably consents to the collection, storage, processing, analysis and use of the data relating to the Customer by the Platform, and to creation and transmission of Resultant Data to the Service Provider or Anchor Corporate as set out in paragraph 1.3.1 above.

1.3.3. The Company for the purposes of effectively providing the Services to the Customer, improving the Platform and for statistical and analytical purposes, anonymises the Resultant Data. Anonymisation as set out herein above shall mean an irreversible process of transforming or converting the Resultant data to a form in which the Customer cannot be identified using such anonymised data. The User hereby expressly irrevocably consents to storing and use of anonymised Resultant Data.

1.3.4. Storage, Destruction

The User acknowledges that the information provided by the User will be stored by the Company for the purposes of providing Services under a contract between the User and the Company. Such information will be destroyed in its entirety by the Company within 60 days of termination of the such contract between the User and the Company or pursuant to a request from the User under paragraph 3 below. The User acknowledges that the information once destroyed pursuant to this paragraph becomes irretrievable.

2. Use of Personal Information

2.1 Other than specific use purposes mentioned in paragraph 1 above, Company uses the Personal Information of the User only for the following purposes:

(a)perform necessary background verification of the Customer;

(b)determine the appropriate product/services that may be provided to the Customer; and

(c)effectively providing the Services to the User and to administer the Platform in accordance with the Terms of Use.

2.2 The Company does not disclose the Personal Information in any manner other than as set out in paragraph 4.1. However, the Company collects, aggregates and anonymises the Personal Information to compile statistical and performance information related to the provision and operation of the Platform. For example, the Company may inform that 5 users from Bengaluru has availed a particular product.

3. Purpose, Opt Out and Withdrawal

3.1. If the User chooses to participate in any activity that is offered through the Platform or takes benefit of any feature that is offered through the Platform, the User may be required to furnish some Personal Information to the Company.

3.2. The User may decline to provide Personal Information that is requested from the User, but this may affect our ability to provide to the User the services requested, or to allow User’s participation in any activity that is offered on the Platform.

3.3. The User may, at any time, by writing to the Company, at the email address provided below, withdraw his/her consent for collection, use, disclosure and transfer of Personal Information by the Company in accordance with this Privacy Policy. Upon receipt of such request, the Company will delete the Personal Information of the User from the Platform and provide confirmation of such deletion to the User.

4. Disclosure, Transfer

4.1. Personal Information may be hosted with a third party data centre, and the servers may be located in jurisdictions in India or outside India as may be determined by the Company from time to time. The User acknowledges that the data stored in data centres located outside India may be governed by the laws of the jurisdiction in which the data centre is located. The User expressly and irrevocably consents to the transfer of Personal Information to the data centres or servers operated by the third party service providers located in territories outside India that may not have equivalent laws and regulations regarding protection of personal information.

4.2. The Company may disclose Personal Information and any Customer Content as follows:

(i)To Company’ s affiliates that agree to treat it in accordance with this Privacy Policy.

(ii)To Service Providers, to enable the Customer to obtain Products.

(iii)To Anchor Corporates, to enable the Customer to engage with the Anchor Corporate.

(iv)To other partners who support the business of the Company (such as credit information companies, payment solution providers), provided however, all such third parties agree not to use the Personal Information for purposes other than for which it is disclosed.

(v)To a purchaser or successor entity in connection with the sale, merger, assignment, or other transfer of the Company or any of its affiliates, or a business division of the Company or any of its affiliates, or sale of substantially all of the assets of the Company or any of its affiliates.

(vi)If the disclosure is required by law, rule, regulation, or order of a court of competent jurisdiction or governmental authority, or regulatory authority.

(vii) To enforce this Privacy policy.

5. Security practices

The Company takes reasonable measures to protect Personal Information provided on or through the Platform. The Company ensures that, the Company is compliant with IS/ISO/IEC 27001, international standard on “Information Technology – Security Techniques – Information Security Management System – Requirements” and such other acceptable standards, for the purpose of securing Personal Information.

6. Consent for Aadhaar

6.1. For the purposes of verifying the User’s identity for obtaining services from the Platform, the User may choose to provide his/her Aadhaar Number. Please note that providing Aadhaar Number is voluntary.

6.2. If the User chooses to provide his/her Aadhaar Number to the Company, the User hereby expressly and irrevocably consents for such collection, storage, and use of Aadhaar Number strictly for the purposes of obtaining the services in through the Platform.

6.3. The Aadhaar Number collected by the Company will be processed and used in compliance with Aadhaar (Targeted Delivery of Financial and Other. Subsidies, Benefits and Services) Act, 2016 and regulations made thereunder from time to time.

7. Access to documents uploaded in the Digital Locker portal

7.1. The Company is a registered ‘requester’ with the Digital Locker portal. If the User is a subscriber to the Digital Locker portal, the User may choose to share any electronic record of address proof, identity proof issued to such User with the Company including e-Aadhaar in order to obtain services through the Platform.

7.2. If the User chooses to share the same, User hereby expressly and irrevocably consents for the Company to access the documents available in the User’s Digital Locker account.

8. Cookies

The Company also uses cookies to allow the Usersto enter their password less frequently during a session in the Platform. Cookies can also help us provide information that is targeted to User’s interests. Most cookies are ‘session cookies’, meaning that they are automatically deleted from the User’s devices’ hard drive at the end of a session. The Users are free to decline the cookies if such User’s browser/device permits, although in that case such User may not be able to use certain features on the Platform and may be required to re-enter their password more frequently during a session.

9. How to Contact the Company / Grievance Officer/Nodal Grievance Redressal Officer

If the User has questions about this Privacy Policy or needs to contact the Company in connection with the use or disclosure of the Personal Information, please reach out to the Company by sending an email or a letter to:

Autolytics Technology Private Limited
Attention: Ramkumar
E-mail: privacy.officer@actyv.com

Grievance Officer, as required under the Information Technology Act, 2000 is: Ramkumar

If the User has any questions or complaints relating to Products availed through the Platform from Service Providers, please reach out to the Nodal Grievance Redressal Officer by sending an email to:

Sumit Khaneja
E-mail: nodal.officer@actyv.com

Nodal Grievance Redressal Officer, as under the press release dated August 10, 2022 by Reserve Bank of India regarding the Recommendations of the Working group on Digital Lending – Implementation, is: Sumit Khaneja.

10. Updates

10.1. The Company reserves the right to modify this Privacy Policy without the User’s consent. The Company may inform the User regarding modifications to the Privacy Policy by displaying a banner statement on the Platform or including a statement regarding modifications at the bottom of this Privacy Policy. If the User continue to use the Platform after information regarding the modifications is published, User shall be deemed to have accepted the revised Privacy Policy.

10.2. This Privacy Policy was last updated on August 24, 2022.