AVANTI FINANCE PRIVATE LIMITED

Privacy and Security Policy

This document is an electronic record in terms of Information Technology Act, 2000 and rules there under as applicable. This electronic record is generated by a computer/electronic system and does not require any physical or digital signatures.

1. Introduction

• Avanti Finance Private Limited (“Company” / “Us” / “We” / “Our”) has entered into business relationships with various partners (“Partners”) under the respective partner engagement agreement or master services agreement (each of which is referred as “Agreement”) whereby We appoint respective Persons (as defined below) as Partners (terms of the relevant Agreement) and engage them for the provision of certain services more particularly described in the Schedule of Services of the respective Agreement. In order to increase the efficiency of provision of services, the Partner may be provided access and usage of the Avanti App (as defined below) on the terms as given under the respective Agreement.
• Moreover, access to the Avanti App is provided to any other Person who is not appointed as a Partner as mentioned in the paragraph above. Both classes of Persons (appointed as Partners and as other Persons) may have access and usage of Avanti App and are recognized as Users (as defined below) in the manner as defined below.
• We consider User relationship and data security to be an important component of Our service offerings through Avanti App. We are committed to maintaining the confidentiality, integrity and security of any Personal Information (as defined below) of Our Users. We are proud of Our privacy practices and the strength of the security controls in relation to Avanti App and want the User to know how We protect information of the User and use it to provide Our products and services to the User.
• This Data Privacy and Security Policy (“Policy”) gives a broad outline as to how We protect information provided by Users during the course of access and usage of Avanti App. We constantly re-evaluate this Policy and adapt it to meet data security standards and to deal with new challenges.
• Where applicable, this Policy shall be read in conjunction with the respective Agreement for the respective User under which such User may have been given access to the Avanti App

2. Definitions

In this Policy: (i) capitalized terms defined by inclusion in quotations and / or parenthesis have the meanings so ascribed; and (ii) the following terms shall have the following meanings assigned to them herein below:

“Applicable Law” includes all applicable Indian statutes, enactments, acts of the state legislature or parliament, laws, ordinances, rules, bye-laws, regulations, notifications, guidelines, directions, directives and orders of any governmental authority, statutory authority, board,  as may be applicable including but not limited to Reserve Bank of India and in each case, any implementing regulation or interpretation issued thereunder including any successor applicable law;

“Avanti App” shall mean and include https://avantifinance.in, mobile application of the Company, including with the name Avanti Early Access, any successor website/ applications, any website of related entity or any other channel facilitated and permitted by the Company including but not limited to Avanti Early Access Application, any other digital medium including phone, displays, emails, social media interfaces, messaging interfaces, wallet, payment intermediaries using Company’s interface;

“Non-Personal Information” shall have the meaning as provided under Paragraph 3(f) of this Policy;

“Person” shall mean any individual (including personal representatives, executors or heirs of a deceased individual) or legal entity, including but not limited to, any partnership, joint venture, corporation, trust, unincorporated organisation, limited liability company, limited liability partnership or governmental authority;

“Personal Information” shall mean certain personally identifiable information of the User as specified under Paragraph 3(a) of this Policy;

“User” / “You” / “Your” shall mean any natural or legal person who has access to and is using the Avanti App; and

“User Information” shall have the meaning as provided under Paragraph 3(h) of this Policy.

3. Collection, Storage and Use of Information

Personal Information:

1. We may collect Your Personal Information when You voluntarily and successfully submit information against relevant fields on the Avanti App. Personal Information is the data that, alone or in combination with any other information, can be used to uniquely identify You (“Personal Information”). Personal Information may include, without limitation, the following:

1. Name
2. User ID(s)
3. Phone numbers
4. Email address (es)
5. Mailing address (es)
6. Banking and other financial data
7. Government identification numbers, eg., driver’s license number
8. Date of birth
9. Gender
10. Location data of the handheld device used by User to open and use the Avanti App (such location data is not collected when Avanti App is closed)
11. Health and disability data
12. Family information
13. Financial and asset information

2. In particular, if You register/log-in on Avanti App through any social media platform (for example, Google), then We may collect the following information:

1. The email/phone number used on the social media platform to register/ log-in;
2. The display name connected to the relevant social media account used; and
3. The profile image (if any) connected to the relevant social media account used.

1. Please note that the information We obtain from such social media accounts also depends on the privacy policies of the social media platforms and Your respective settings therein. Please check the respective policies to understand the privacy practices of those social media platforms.

2.In case of Partners, We may request such additional Personal Information as may be specified in or as part of the respective Agreement.

3. Purpose of Collection of Non-Personal Information: Your Personal Information is collected when You voluntarily submit such information. It is used, handled and stored by Us for the purposes of Your identification/ verification and/or creation of Your account on Avanti App. Accordingly, such information shall be retained by Us till the time You have access and use Avanti App or You communicate to Us Your decision to withdraw Your permission to store and retain such information.

Non-Personal Information:

1. When You visit the Avanti App, We may collect certain non-personal information for the purpose of enhancing Your use of the Avanti App (“Non-Personal Information”). This Non-Personal Information is in the nature of technical and navigational information generated each time You visit the Avanti App, which are saved in Our server logs. The Non-Personal Information may include, without limitation, the following details in respect of:

1. the server (Internet Protocol) from where the Avanti App is being accessed;
2. the browser and operating system used to browse the Avanti App;
3. links clicked, scrolled and pages visited;
4. details of Your last visit to the Avanti App, including time, date and the duration of Your session on the Avanti App, etc.; and/or
5. cookies as per Paragraph 4 of this Policy.

1. Purpose of Collection of Non-Personal Information: Non-Personal Information is in the form of encrypted statistics, which helps Us in improving the efficiency of the Avanti App by giving Us information relating to Your use of the Avanti App.2.

2. Personal Information and Non-Personal Information are together referred to as “User Information” in this Policy.

3. By using the Avanti App, You authorize Us to collect, store, process, handle and use such User Information, in accordance with this Policy and any other terms and conditions of use of the Avanti App (as amended from time to time).

4. We reserve the right to retain such User Information that forms part of anonymized and aggregated data derived from User Information which may be used for improvement of the Avanti App, to produce analytical reports, marketing, advertising or such other activities as We may deem fit.

4. Cookies

1. Like most other sites, We use data collection devices known as “cookies” to collect and store information of Users visiting the Avanti App. A cookie is an alpha-numeric identifier, which is small amount of data that is sent to a User’s browser from a web server and is eventually stored on a User’s computer hard drive. Cookies are a reliable mechanism to remember the activities of the User on the Avanti App and help in improving Your experience on the Avanti App.

2. We may set and access cookies on Your computer to track and store preferential information about You. We may gather information about You through cookie technology. This anonymous information is maintained distinctly and is not linked to the Personal Information You submit to Us. The option of accepting cookies is up to You, however certain features of the Avanti App including Content and the forms may not be accessible without accepting cookies. If You choose to eliminate cookies, the full functionality of the Avanti App may be impaired for You.

3. Most cookies are session cookies that are automatically deleted from Your device’s hard drive when You close the Avanti App. Additionally, You may encounter cookies or other similar devices on certain pages of the Avanti App that are placed by third parties. We do not control the use of cookies by third parties and shall not be liable for any reason whatsoever for these third-party cookies.

4. We may use third party service providers to help Us analyse certain online activities. For example, these service providers may help us measure the performance of Our online campaigns or analyse visitor activity on the Avanti App. We may permit these service providers to use cookies and other technologies to perform these services for the Company. We do not share any Personal Information with these third party service providers, and these service providers do not collect such information on Our behalf.

5. User Rights

1. Review:

To ensure the accuracy and adequacy of the Personal Information provided by You, You shall at all times have the option of reviewing the same by requesting Us in the manner as provided under Paragraph 10 of this Policy.

1. Withdrawal of Consent:

You shall at all times have the option of withdrawing Your consent for the collection, storage and retention of Your Personal Information. In case of Partners, their right to withdraw consent shall also be subject to the respective Agreement.

1. Please note that Your withdrawal of consent may result in restriction/revocation of access and/or usage of the Avanti App. Please further refer toParagraph 11of this Policy for the manner of communication with Us.

3. Account Deletion:

You may choose to delete Your account at any time You like by requesting Us in the manner as provided under Paragraph 11. Please note that it may take up to 30 (thirty) days to delete all of Your information, like the data stored in our backup systems. However, We may also preserve such information/data as required for legal reasons or to prevent harm.

6. Disclosure of User Information

1. We do not share Your User Information with any third parties for commercial use or revenue generation. However, We may share User Information with third party service appointed by Us who may be located in India or outside India:

1. for sending SMS/ Email communications to You in relation to Avanti App and Our products and services; and
2. to improve and personalize Our products and services. This may involve, for example, activities such as troubleshooting and protection against errors; data analysis and testing; and developing new features

2. We ensure that such third-party service providers maintain strict confidentiality (ensuring the same level of confidentiality as maintained by Us) in respect of User Information. Our third-party service providers are required to comply fully with this Policy.

3. Further, We reserve the right to utilize, share and/or disclose User Information if:

1. required to do so to comply with orders of governmental authorities that have jurisdiction over it or as otherwise required by Applicable Law after providing You a written intimation prior to such disclosure; and/or
2. We determine, in Our sole discretion that disclosure of User Information is necessary to identify, contact, or bring legal action against You.

7. Indemnification

You agree to indemnify, defend and hold harmless Us and Our parent, subsidiaries, affiliates, partners, officers, directors, agents, contractors, licensors, service providers, subcontractors, suppliers, interns and employees, harmless from any claim or demand, including reasonable attorneys’ fees, made by any third-party due to or arising out of Your breach of this Policy or the documents they incorporate by reference (including the respective Agreement, where applicable for use of the Avanti App), or Your violation of any law or the rights of a third party.

8. Security Precautions

To prevent any form of unlawful interception or misuse of User Information, We use reasonable physical, electronic and managerial procedures to safeguard and secure User Information collected. We use reasonable secure and technologically appropriate measures, in compliance with the Information Technology Act, 2000 and the rules related thereto to protect You against loss or misuse of Your User Information including internal reviews of data collection, storage and processing practices and other reasonable security measures which are equivalent to security measures that We use to protect Our own confidential information. However, as You are aware, no internet website or online platform is completely free of security risks and We do not make any representation in respect of the same.

9. Change in Privacy Policy

We reserve the right to update, modify and amend any of the terms of this Policy, at any time without prior intimation to You. These changes will become effective immediately on posting. We shall not be liable for any failure or negligence on Your part to review the updated Policy before accessing the Avanti App. Your continued access to the Avanti App, following changes to this Policy, will constitute Your acceptance of those changes.

10. Contacting Us

If You have any queries regarding: (i) this Policy; (ii) information and/or services available on the Avanti App, or (iii) Your dealings with Us or believe that We have not adhered to it, You may contact Us at Urvashi Bahirsheth, Company Secretary at urvashi@avantifinance.in.

11. Email Opt-Out

You can opt out of receiving Our marketing and update emails. To stop receiving Our promotional emails, please email at info@avantifinance.in. It may take about 10 (ten) days to process Your request. Please note that Your opting out of getting marketing emails/messages would still enable You to receive transactional messages through email and SMS in relation to Your usage/access of the Avanti App.