1. Introduction

“Finocred UAE” is a company registered in India with CIN: U66190CT2023PTC015334.
We are committed to respect your online privacy and recognize the need for appropriate protection and management of any personally identifiable information you share with us. This Privacy Policy ("Policy") describes how “Finocred UAE” collects, uses, discloses and transfers personal information of users through its websites and applications, including through www.finocred.in, mobile applications and online services (collectively, the "Platform").
This policy applies to those who visit the Platform, or whose information “Finocred UAE” otherwise receives in connection with its services (such as contact information of individuals associated with “Finocred UAE” including partners) (hereinafter collectively referred to as "Users").
For the purposes of the Privacy Policy, "You" or "Your" shall mean the person who is accessing the Platform.

2. What personal data do we collect and why?

As an online community, we use the information you give us to improve our service and to tailor your experience through the site around your interests and professional background.
We appreciate that, on joining our network, you have trusted us with our data. With this in mind, we pledge to respect your privacy, and be open about what we collect and how we use it. We will go to all reasonable lengths to ensure your data is kept safe.
“Personal data” means any data about an individual who is identifiable by or in relation to such data
The Personal Information that we collect, and how we collect it, depends upon how you interact with us. We collect the following categories of Personal Information in the following ways:

• ♦Name, email address, password, country, city, contact number and company/organization that you are associated with, when the you sign up for either deploying your funds or getting funded for your assets on the Platform;
• ♦Information that one would usually include in a KYC documents when you register on the Platform;
• ♦Information about the services that you use and how you use them, including log information and location information, when you are a user of the services through the Platform;
• ♦We may collect your Personal Information such as name, age, contact details, preferences, etc. through surveys and forms, when you choose to participate in these surveys etc.;
• ♦We may also collect information relating to your caste and information about whether you are eligible for any affirmative action programmes or policies, if you opt to provide such information;
• ♦when you communicate with “Finocred UAE” or use the Platform to communicate with other Users (such as partners), we collect information about your communication and any information you choose to provide;
• ♦when you visit the Platform, we use cookies to automatically collect, store and use technical information about your system and interaction with our Platform;
• ♦when you use a device to access the Platform, “Finocred UAE” may collect technical or other related information from the device as well as the device location;
• ♦If you choose to sign in with your social media account to access the Platform, or otherwise connect your social media account with the services of the Platform, you consent to our collection, storage, and use, in accordance with this Privacy Policy, of the information that you make available to us through the social media interface. Please see your social media provider's privacy policy and help centre for more information about how they share information when you choose to connect your account.

We will work with you to ensure you are able to exercise the rights granted to you under “THE DIGITAL PERSONAL DATA PROTECTION ACT, 2023” and the relevant Indian Statutes.

2.1. Visiting our website

If you visit our website, we will log your IP address and aggregate details about site usage.

2.2. Registration and subscription details

If you register with us and/or subscribe to certain Services, your registration and subscription details will be retained by us for the purposes of administering your account. Details we process for this purpose

Where required for our subscription Services, your payment details will be collected and used by our third party payment provider for administering Contracts on our behalf. We may access such details to address any queries or confirm payments.

We will also collect your date of birth for verification purposes, and to confirm you are over 18 years old. In exceptional circumstances, we may ask you to confirm your date of birth as a security question for identification purposes.

2.3. Your profile(s) and other content

If you upload a profile and other content, this will be visible to other users in accordance with the Services we provide to them. The information included within your profile varies depending on what type of user you are. Some information is required, and some is optional – this will be made clear at the point the information is requested. You can manually edit and/or rectify most of your data.
You will have the choice whether your telephone number is made visible to other registered users. Unless you are classified as a Service Provider, your email and postal addresses are not visible to other users and your telephone number is not visible to unregistered users (unless you voluntarily enter any of these details in a free text field).
We will not publish your real age, but if you are an actor or other performer, you may be required to provide a playing age – see our Age policy for more details.

2.4. Contacting us

If you contact us (via email, telephone, post or otherwise), we may collect and retain your contact details and the contents of your communication. We shall use such details for the purpose of handling your query and keeping records of communications.

2.5. Other use of your personal data

We may also use your personal data for the purposes of:

• ♦Checking your compliance with our terms of service;
• ♦website administration and maintenance, and quality control;
• ♦investigating complaints and conducting risk assessments;
• ♦compliance with legal obligations, or protection and enforcement our legal rights and those of other users; and / or
• ♦managing actual or potential business transactions (eg in the case of an acquisition of our business.
• ♦Providing our services and products to you including to send you notifications of purchase, sale, interest details, notices etc (as the case maybe);
• ♦Protecting our Users and providing you with customer support;
• ♦We use information collected from cookies and other technologies, to improve your user experience and the overall quality of our services. When showing you tailored ads, we will not associate an identifier from cookies or similar technologies with sensitive categories, such as those based on race, religion, sexual orientation or health.
• ♦Improving the Platform and its content to provide better features and services.
• ♦Conducting market research and surveys with the aim of improving our products and services.
• ♦Sending you information about our products and services for marketing purposes and promotions;
• ♦Preventing, detecting, investigating and taking action against crimes (including but not limited to fraud and other financial crimes), any other illegal activities, suspected fraud, or violations of “Finocred UAE” Terms of Use in any jurisdiction
• ♦To the extent required for identity verification, government sanctions screening and due diligence checks.
• ♦Establishing, exercising or defending legal rights in connection with legal proceedings (including any prospective legal proceedings) and seeking professional or legal advice in relation to such legal proceedings.

3. Marketing communications from us and third parties

We may send you marketing materials by email or post, or contact you by telephone for marketing purposes. We will only do this if relevant to the Services provided to you or otherwise with your consent.
If you recommend a person to us for our Services, we may contact such person using contact details provided by you in order to enquire whether they are interested in our Services. It is your responsibility to inform your person that we may contact them in this way and ensure that they are happy for us to do so.

4. How do we collect your personal data?

We collect the majority of personal data directly from you. We may also collect certain information from other users, for example, agents providing details of buyers/sellers/referrals or users recommending a person (see paragraph 3 above). Other information about you, example your previous roles or productions, may be collected from publicly available sources.
Where we collect personal data from you relating to other individuals (such as your staff or, if you are an agent, your buyers/sellers/referrals whom you represent), it is your responsibility to ensure such individuals are aware of that their details are being disclosed to and processed by us (unless this is not required in accordance with the requirements of “THE DIGITAL PERSONAL DATA PROTECTION ACT, 2023” and other relevant legislation).

5. Consent and Compliance with a legal obligation

“FINOCRED FINTECH PRIVATE LIMITED” relies on your consent in order to process your Personal Information in certain situations. If “FINOCRED FINTECH PRIVATE LIMITED” requires your consent to collect and process certain Personal Information, as per the requirements under the applicable data protection laws, your consent is sought at the time of collection of your Personal Information and such processing will only be performed where consent is secured.
Your Personal Information may be processed by “FINOCRED FINTECH PRIVATE LIMITED”, to the extent that such processing is necessary to allow “FINOCRED FINTECH PRIVATE LIMITED” to comply with a legal obligation. An example of this would be if “FINOCRED FINTECH PRIVATE LIMITED” is required to disclose your Personal Information to respond to a court order or if “FINOCRED FINTECH PRIVATE LIMITED” is required to retain specific records for a fixed period to comply with requirements under any applicable law.

6. Use of your personal data by other users

Personal data within your profile, or otherwise submitted by you as content for the Sites, may be accessed by other users in accordance with the Services provided to them. Whilst we seek to ensure all users agree to our terms of service, we are not responsible for the use or misuse of your personal data by other users
However, you may report to us if you experience any misuse of your personal data by any other user or third party in relation to our Sites or Services. We shall, at your expense, reasonably co-operate with you in enforcing our contractual terms against other users who have misused your personal data. We restrict access to your Personal Information to employees who we believe reasonably need to know/or that information to fulfil their jobs to provide, operate, develop, or improve our products or services.
“FINOCRED FINTECH PRIVATE LIMITED” does not disclose, transfer or share your Personal Information with others except with:

• ♦Our affiliates and group companies to the extent required for our internal business and/or administrative purposes and/or general corporate operations and for provision of services;
• ♦Third parties including enforcement, regulatory and judicial authorities, if we determine that disclosure of your Personal Information is required to a) respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims; or b) investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of “FINOCRED FINTECH PRIVATE LIMITED”’s Terms of Use or as otherwise required by law;
• ♦In the event of a merger, acquisition, financing, or sale of assets or any other situation involving the transfer of some or all of “FINOCRED FINTECH PRIVATE LIMITED”’s business assets we may disclose Personal Information to those involved in the negotiation or transfer.
• ♦Third party service providers and marketing partners that “FINOCRED FINTECH PRIVATE LIMITED” engages to a) provide services over the Platform on “FINOCRED FINTECH PRIVATE LIMITED”’s behalf; b) maintain the Platform and mailing lists; or c) communicate with you on “FINOCRED FINTECH PRIVATE LIMITED”’s behalf about offers relating to its products and/or services. “FINOCRED FINTECH PRIVATE LIMITED” will take reasonable steps to ensure that these third-party service providers are obligated to protect your Personal Information and are also subject to appropriate confidentiality / non-disclosure obligations.
• ♦Third party advertisers to display advertisements to you when you visit the Platform. The third-party advertisers include financial service providers (such as banks, insurance agents, stock brokers and mortgage lenders) and non-financial companies (such as stores, airlines, and software companies). These companies may use information about you and your visits to this Platform and other web sites to provide advertisements on this Platform.
• ♦The Company does not provide any Personal Information to the advertiser when you interact with or view a targeted advertisement. However, if you interact with or view an advertisement, the advertiser may make certain assumptions and, in the process, learn certain Personal Information about you. For instance, if you view and click an advertisement that is targeted towards women in the age group 18- 24 from a specific geographic area, the advertiser may assume that you meet the relevant criteria.
• ♦“FINOCRED FINTECH PRIVATE LIMITED” does not intend to transfer Personal Information without your consent to third parties who are not bound to act on “FINOCRED FINTECH PRIVATE LIMITED”'s behalf unless such transfer is legally required. If your Personal Information is transferred outside India, we take the necessary steps to protect your Personal Information in accordance with applicable data protection laws.

7. Disclosure of your personal data to other third parties

We may disclose your personal data for the purposes outlined at paragraph 2 above to third parties where relevant to such purpose, including:

• ♦our service providers and professional advisers;
• ♦governmental bodies and law enforcement authorities;
• ♦any purchaser or (on terms of confidentiality) likely purchaser of our business; and
• ♦other third parties where required or permitted by law.

Please be aware that the Platform sometimes contains links to other sites that are not governed by this Privacy Policy. Users may be directed to third-party sites for more information, such as advertisers, blogs, content sponsorships, vendor services, social networks, etc.

“FINOCRED FINTECH PRIVATE LIMITED” makes no representations or warranties regarding how your information is stored or used on third-party servers. We recommend that you review the applicable privacy statements and policies of each third-party site linked from the Platform to determine their use of your personal information.

8. Storage and security of your personal data

Your personal data is stored in electronic and physical records maintained by us and/or our service providers. Whilst our offices are located in the India, our services providers may have servers located in a country within or outside of India, whose laws may not provide the same protection for personal data as within India.
We keep your information for as long as we need to do in order to fulfil the service we offer, or to comply with requests from law enforcement agencies or regulators.

9. Removal of your details from our Sites

You may request removal of your profile(s) and data from our Sites at any time, though we ask that you put such requests in writing.

10. Access to your details

If you would like to access a copy of any personal data which we hold about you, please contact info@finocred.in. We will respond within one calendar month, and won't charge you to access your information.

11. Queries

We welcome you contact us if you wish to exercise any of your other rights under “THE DIGITAL PERSONAL DATA PROTECTION ACT, 2023”. These include:

• ♦your right to be informed
• ♦your right to access and correct personal data
• ♦your right to erasure
• ♦your right to data portability
• ♦your right to object to data processing
• ♦your rights relating to automated decision making and profiling

All cases will be reviewed individually, in accordance with this policy, alongside “THE DIGITAL PERSONAL DATA PROTECTION ACT, 2023” and other relevant legislation.

12. Children

To use the Platform, you agree that you must be the minimum age (described in this paragraph below) or older.
The minimum age for these purposes shall be eighteen (18), however if local laws require that you must be older for “FINOCRED FINTECH PRIVATE LIMITED” to be able to lawfully provide the services over the Platform to you then that older age shall apply as the applicable minimum age.
If you are under the age of 18 or the age of majority in your jurisdiction, you must use the Platform under the supervision of your parent, legal guardian or responsible adult.
If you have any queries in relation to the processing of your personal data by “Finocred UAE”, please contact us.

13. Web Beacons

www.finocred.in occasionally advertises on third party websites. As part of our effort to track the success of our advertising campaigns, we may at times use a visitor identification technology such as "web beacons," or "action tags," which count visitors who have come to our site after being exposed to a “Finocred” banner ad on a third party site. Our partners may also use web beacons to collect data in the aggregate as provided by your browser while you are on our site or another site where TradeCred.com is third party.
By navigating on our site, you agree that we can place cookie and web beacons on your computer or device. If you prefer not to receive web beacons, then you should stop using our site, or consult your browsing settings.

14. Confidentiality and Security

• ♦The security and confidentiality of your Personal Information is important to us and “FINOCRED FINTECH PRIVATE LIMITED” has invested significant resources to protect the safekeeping and confidentiality of your personal data. When using external service providers acting as processors, we require that they adhere to the same standards as “FINOCRED FINTECH PRIVATE LIMITED” does. Regardless of where your Personal Information is transferred or stored, we take all steps reasonably necessary to ensure that personal data is kept secure.
• ♦We seek to ensure compliance with the requirements of the Information Technology Act, 2000, THE DIGITAL PERSONAL DATA PROTECTION ACT, 2023 and Rules made there under to ensure the protection and preservation of your privacy. We have physical, electronic, and procedural safeguards that comply with the laws prevalent in India to protect your Personal Information. By accepting the terms of this Privacy Policy, you agree that the standards and practices being implemented by us, are reasonable and sufficient for the protection of your Personal Information.

15. Social media

“FINOCRED FINTECH PRIVATE LIMITED” operates channels, pages and accounts on some social media sites to inform, assist and engage with customers. “FINOCRED FINTECH PRIVATE LIMITED” monitors and records comments and posts made on these channels about itself in order to improve its products and services.
Please note that you must not communicate the following information to “FINOCRED FINTECH PRIVATE LIMITED” through such social media sites:
- sensitive personal data including (i) special categories of personal data meaning any information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation and (ii) other sensitive personal data such as criminal convictions and offences and national identification number ; - Excessive, inappropriate, offensive or defamatory content. “FINOCRED FINTECH PRIVATE LIMITED” is not responsible for any information posted on those sites other than the information posted by its employees on its behalf. “FINOCRED FINTECH PRIVATE LIMITED” is only responsible for its own use of the Personal Information received through such sites.

16. Changes to this Privacy Policy

“FINOCRED FINTECH PRIVATE LIMITED” reserves the right to update, change or modify this Privacy Policy at any time. The Privacy Policy shall come to effect from the date of publication of such update, change or modification.

17. Disclaimer

“FINOCRED FINTECH PRIVATE LIMITED” does not store any account related information or any credit / debit card details. “FINOCRED FINTECH PRIVATE LIMITED” shall not be liable for any loss or damage sustained by Users as a result of any disclosure (inadvertent or otherwise) of any information concerning the User's account, credit cards or debit cards in the course of any online transactions or payments made for any products and/or services offered through the Platform.
In case any Personal Information is shared by you with “FINOCRED FINTECH PRIVATE LIMITED”, which is not requested by “FINOCRED FINTECH PRIVATE LIMITED” during registration, (whether mandatorily or optionally), “FINOCRED FINTECH PRIVATE LIMITED” will not be liable for any information security breach or disclosure in relation to such information.
If you have any questions regarding this Privacy Policy or the protection of your Personal Information, please contact “FINOCRED FINTECH PRIVATE LIMITED”’s Data Protection Officer/ Grievance Officer at the following:

18. Cookies, site analysis and monitoring

Cookies are tiny files stored on your computer or other device when you visit certain web pages. Some cookies and other technologies may serve to recall Personal Information previously indicated by a user. Most browsers allow you to control cookies, including whether or not to accept them and how to remove them.
You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser, but please note that if you choose to erase or block your cookies, you will need to re-enter your original user ID and password to gain access to certain parts of the Platform.
Tracking technologies may record information such as Internet domain and host names; Internet protocol (IP) addresses; browser software and operating system types; clickstream patterns; and dates and times that our site is accessed. Our use of cookies and other tracking technologies allows us to improve our Platform and the overall website experience. We may also analyse information that does not contain Personal Information for trends and statistics.
For more information about our use of cookies please refer to our Cookie Policy.
If you disable these cookies, you may be able to still browse the site, however you may not be able to take advantage of all features available on the site. We may use the following cookies:

• ♦Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
• ♦Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
• ♦Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• ♦Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We may use this information to make our website and the advertising displayed on it, or communications that we send to you, more relevant to your interests. We may also share this information with third parties for this purpose.

You can usually (depending on the browser you are using) block cookies by consulting the "Help" tab of your browser via the menu bar. Please note that if you use your browser settings to block all cookies (including strictly necessary cookies), this may prevent our website from functioning properly or at all. You are taken to have agreed to any cookies that you have not blocked.
To change your cookie settings, if you want to be notified each time a cookie is about to be used or if you want to reject cookies that you have previously agreed to, you can amend the settings as described above
You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.
You can usually (depending on the browser you are using) block cookies by consulting the "Help" tab of your browser via the menu bar. Please note that if you use your browser settings to block all cookies (including strictly necessary cookies), this may prevent our website from functioning properly or at all. You are taken to have agreed to any cookies that you have not blocked.
To change your cookie settings, for example if you want to be notified each time a cookie is about to be used or if you want to reject cookies that you have previously agreed to, you can amend the settings as described above.
Except for essential cookies, all cookies will expire (which means they will either be removed or cease operating) after a maximum of two years.
Please also note that we may use pixels in emails that you will receive as a result of signing up with us. Pixels are similar to cookies, and can enable us to, for example, track email opens, if you have images enabled in your email client/mailbox. This is a standard approach for measuring open and click rates, and is used by most email platforms in the market.
All links in emails are proxied through a link redirection service that records data for each link clicked. This leads to the ability to record a set of events which may include:

• ♦Event type (delivery, bounce, open, click, spam complaint, unsubscribe)
• ♦Email address of the recipient (which you will have provided)
• ♦IP address of the recipient (in the case of open and click)
• ♦GEO location based on IP address (city level) (in the case of open and click)
• ♦Device type (e.g. mobile/computer/tablet) and browser (e.g. firefox/chrome/safari).

If you do not want this information to be collectable, you should disable and not open images in your email application.

19. Data Protection Officer/ Grievance Officer

In case you have any complaints and/or grievances in relation to the processing of your Personal Information you can send your complaints via e-mail to our grievance officer:

• ♦Grievance Officer
• ♦Finocred UAE Office 6037, 6th Floor, Currency Tower, VIP Chowk, Raipur - 492001 Chhattisgarh
• ♦Email: info@finocred.in