PRIVACY POLICY

The website, www.freo.money, www.moneytap.com, and our mobile application made available thereunder, namely, Freo & MoneyTap (jointly and individually, where applicable, the “Portal”) are operated by MWYN TECH PRIVATE LIMITED (“MWYN”), a company incorporated under the provisions of the Companies Act, 2013, and having its registered office at G-405, 4th Floor – Gamma Block, Sigma Soft Tech Park, Varthur Kodi, Whitefield Post, Bangalore 560 066. For the purposes of this privacy policy (“Privacy Policy”), “we”, “our” and “us” shall mean MWYN and “you” and “your” shall mean you as a user of the Portal (“User”), whether registered or not. This Privacy Policy shall be read along with the relevant terms of use (each, a “Terms of Use”). The capitalized terms that are used in this Privacy Policy but not defined herein shall have the same meaning as defined in the applicable Terms of Use. This Privacy Policy is incorporated into, and is subject to, the Terms of Use pertaining to the services provided by us through the Portal (“Services”). This Privacy Policy sets out what information we collect and how and why we use it, when you access the Portal, create an account with us (“Account”) and avail of our Services. You are advised to read the Privacy Policy carefully before using this Portal. To access or use the Portal, you are required to accept the terms of this Privacy Policy. By accepting this Privacy Policy, you signify that you have read, understood and agree to be bound by this Privacy Policy. We reserve the right to update or modify this Privacy Policy at any time without prior notice and such changes shall be effective immediately in accordance with Clause 10.

BY ACCEPTING THE PRIVACY POLICY, YOU EXPRESSLY CONSENT TO MWYN’S COLLECTION, RETENTION, ANALYSIS, USE AND DISCLOSURE OF YOUR PERSONAL INFORMATION IN ACCORDANCE WITH THIS PRIVACY POLICY.

1. INFORMATION COLLECTED

1.1.1. We will collect personal information of the User, as detailed further in this clause 1 and as expressly set forth in this Privacy Policy. While some User information has to be mandatorily provided, others are optional and certain portions of the information will remain private; We shall always let the User know which is which. Additional information may be gathered during subsequent use of the Portal and availing of Services, by the User, whenever the User chooses to provide it.

1.2. Certain mandatory information will be collected at the time of registration on the Portal which is required to enable the User to login to the Portal and for us to: (i) verify the User’s identity; (ii) determine the User’s eligibility for taking loans using, inter alia, our proprietary technology and such additional rules that may be determined by: (a) us; (b) our banking partners; or (c) both (a) and (b); and (iii) safeguard against illegal activities like fraud, cheating, misappropriation, etc.

1.3. For providing the Services, we require certain mandatory User information as described below:

1.3.1. For the purposes of registering, we require basic personal information such as name, date of birth, mobile number, e-mail address, permanent address, current address, employment details, PAN, salary, etc. and certain information about your personal identity such as gender, age, etc;

1.3.2. Once you are duly registered, we, on behalf of our lending partners, may also require certain additional information such as your designation, mode of salary, parent names, loan requirement reasons, educational qualification, bank details etc. for the purposes of processing your application; and

1.3.3. Further, we also collect and store your usernames, passwords, email addresses and other security related information that you use for our sites in relation to our Services.

1.4. In order to use the facilities and Services available on the Portal, the User may be required, from time to time, at the request of MWYN to provide certain additional personal information after registration on the Portal, which information shall be collected only upon receiving the User’s express consent.

1.5. In the event we are required to do a Know Your Customer (“KYC”) verification process for the purposes of enabling you to avail of the Services, we will do so as per the guidelines and directions issued by the Reserve Bank of India, as amended from time to time.

1.6. We may also automatically receive and collect certain anonymous information in standard usage logs through the web server, including mobile-identification information obtained from the equivalent of “cookies” sent to the Portal, including mobile network information, standard web log information, traffic to and from our Portal, tracking inside the Portal and any other available information, from:

1.6.1. an IP address, assigned to the device used by the User;

1.6.2. the domain server through which the User accesses the Portal and the functions and features therein; and

1.6.3. the type of device used by the User (“Device”).

1.7. The User may choose to provide us with access to certain personal information stored by third parties like social networking sites (e.g., Facebook and Twitter). We will have access to such information to the extent allowed by the User’s privacy settings on that site and the User’s specific authorization. In the event the User associates a User account managed by us with an account maintained with any third party to enable us to access certain information maintained in such third party managed accounts, the User agrees that we may collect, store and use such information in accordance with this Privacy Policy. Provided that we will not store personal information except some basic minimal data (viz., name, address, email, gender, contact details of the customer, etc.) when we are acting in the capacity of a digital lending application/lending service provider.

1.8. After obtaining the User’s specific consent to allow the Portal to access the User’s SMS inbox, we may collect, store, monitor and transmits to it our server, relevant information from text messages (SMS) received by the Users from providers of services and/or products (including but not limited to retail outlets, financial institutions, mobile carriers and utility companies), that will enable us to provide better access to financial services and products to the Users. We will access business messages, which shall be used solely for the purposes of providing the Services.

How we use this information: We shall collect any SMS information for facilitating you any lending services and such purposes as may be required by the Lending Partners or as per applicable law.

1.9. In order to enhance our ability to provide valuable Services and experiences to the User, we may take only a one time access to: (i) automatically receive, collect and analyze your location information which may be accessed through a variety of methods including, inter alia, GPS, IP address, and cell tower location; and (ii) collect information pertaining to your Device and your usage thereof, including, inter alia, the names of the other applications on your mobile Device and how you use them, information about your Device, and information about your use of features or functions on your Device; (iii) camera access to scan and capture selfie and the required documents; (iv) microphone permissions to enable a two-way communication between our authorised agent and you for the purpose of performing and completing your video KYC;

1.10. You explicitly consent that 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 creditworthiness and enrich your profile with pre-approved customized loan offers. This also includes having access and permission to send you messages and notifications via your social media and instant messaging applications. Provided that we shall not access mobile phone resources like file and media, contact list, call logs, telephony functions, etc.

1.11. We may collect information with your consent from your mobile device like device information (including, model, installed apps, Wi-Fi, mobile network) transactional and promotional SMS, communication information to provide customized offerings and services.

1.12. We may need access to your contacts Information to enable you to transact using Our UPI Services and to facilitate you to send money to bank account/UPI ID of your contacts. However we don't store your contacts Information. Provided that we will not access your contacts information when we are acting in the capacity of a digital lending application/lending service provider.

2. METHOD AND MANNER OF USE OF INFORMATION

2.1. When the User registers with the Portal, we will use the information supplied by the User to access credit information from credit bureaus, with User consent, and identity verification services to facilitate banks and other financial institutions to evaluate the User’s loan request in the context of the User’s complete financial situation.

2.2. We will also use the User information to enable activities and transactions that need to occur during the process of lending, such as:

2.2.1. generating and maintaining User profiles on the Portal;

2.2.2. provide personalized features;

2.2.3. aiding financial services organizations to provide better Services;

2.2.4. facilitating collection activities as needed;

2.2.5. maintaining regular communications with the User concerning transactions that the User initiates, such as requesting information or assistance, submitting a loan request, making payments, transferring funds, etc.

2.2.6. modifying the Portal from time to time to cater to the User’s interests;

2.2.7. delivering any administrative notices, alerts, advice, notification and communication relevant to your use of any facilities on the Portal through WhatsApp, SMS, Facebook and other mediums;

2.2.8. marketing research, project planning, troubleshooting problems, detecting protecting against error, fraud or other criminal activity;

2.2.9. for undertaking KYC authentication;

2.2.10. resolving disputes in relation to the credit facilities, if any;

2.2.11. providing the Portal and the functions and features therein, efficiently; and

2.2.12. preserve social history as governed by existing law or policy.

2.3. You acknowledge that if we determine that any information you have provided or uploaded violates the terms of this Privacy Policy, we have the right, in our absolute discretion, to delete or destroy such information without incurring any liability to you.

2.4. You acknowledge that you are licensing us to use, modify, display, distribute and create new material from the information you provide through the Portal to render certain Services on the Portal. By providing such information, you automatically agree, or promise that the owner of such information has expressly agreed to allow or license, as the case may be, us to use the information in the manner set out in this Privacy Policy, without the payment of any fees. We may, to the extent permitted by law, also use, license, reproduce, distribute disclose, and aggregate, non-personally identifiable information that is derived through your use of the Portal and you hereby provide consent for the same.

2.5. For the avoidance of any doubt, it is hereby clarified that any User information collected from you and eventually stored by us will be used only for the purposes of providing our Services.

3. SHARING OF INFORMATION

3.1. We will not use User information for any purpose other than in connection with the Portal. You understand that in order to provide the Services, we will share the User information with third parties, including entities / organizations / lenders that provide the loans / credits availed through the Portal or otherwise in connection with the Services (and other functionalities of the Portal) and you explicitly agree to such User information being shared. Please note that the list of such third parties with whom User information is shared is available at https://freo.money/our-partners/ In the event you are directed to a third-party website and if you choose to access them (or avail of such third party’s offerings), we will not be responsible for such third-party websites or applications. Please note that in case you share any data or information with such third parties, you will be bound their respective privacy policies and/or terms of use/service. Furthermore, MWYN will not rent, sell or share User information and will not disclose any of the User’s personally identifiable information to third parties or affiliates, unless:

3.1.1. it is pursuant to obtaining the User’s permission;

3.1.2. it is in connection with disclosure to financial institutions and banks, in which case, the User hereby gives his express permission;

3.1.3. it is in connection with the Services being rendered through the Portal;

3.1.4. it is to help investigate, prevent or take action regarding unlawful and illegal activities; suspected fraud, potential threat to the safety or security of any person, violations of our Terms of Use, or as defence against legal claims;

3.1.5. it is a case of special circumstances such as compliance with court orders, requests/order, notices from legal authorities or law enforcement agencies compel us to make such disclosure;

3.1.6. it forms part of the information we share with advertisers on an aggregate basis;

3.1.7. it improves personalization, analysis and for offering new products/services;

3.1.8. it is for promotional purposes for other services being rendered by us; and

3.1.9. it is required under an arrangement between us and the third party for product enhancement, analysis, risk and security purposes, communication purpose, etc.

3.2. If all or some of the business, stock or assets of MWYN are acquired or merged with another business entity, we will share all or some of your information with the acquiring / merged entity to continue to provide the Services to you.

3.3. If you decline to submit information to us, then we will unfortunately not be in a position to provide the Services to you.