PRIVACY POLICY

DATE OF LATEST VERSION: MAY 31st, 2023

The website, www.freo.money, www.moneytap.com, and our mobile application made available thereunder, namely, Freo (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.

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 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; and (v) file and media in order to enable you to upload documents solely for the purpose of onboarding or KYC checks or to raise tickets. Upon completion of the KYC/on-boarding, please ensure that you revoke access to the aforesaid information through your device settings.

How we use this information: We shall collect any Files & Media (Images) for facilitating KYC journey, lending services and such purposes as may be required by the Lending Partners or as per applicable law.

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.

1.11. We may collect information with your consent from your mobile device like device location, 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 Services and to facilitate you to send money to your contacts.

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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 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 third parties with whom User information is shared is available at [•]. 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.

4. SERVICE PROVIDERS

4.1. We may employ third-party service providers and individuals due to the following reasons:

4.1.1. To facilitate our Service; or

4.1.2. To provide the Service on our behalf; or

4.1.3. To perform Service-related services; or

4.1.4. To assist us in analyzing how our Services are used.

4.2. You acknowledge that the third-party service provider/agent/agencies will have access to your personal information on a need to know basis to assist us in rendering Services, and the service providers are restricted from using the same for any other reason. The third-party service providers are obligated not to disclose or use the information for any other purpose.

5. YOUR RIGHTS & PREFERENCES AS A DATA SUBJECT IN INDIA

5.1. This Privacy Policy is intended for Users within the territory of India and govern your rights as per applicable law within the territory of India. However, in the event you fall under a jurisdiction outside the purview of Indian law, MWYN will not be liable for any claim, action and/or right initiated/exercised by you as per the extant laws of that jurisdiction. Therefore, we request you to kindly use the Portal accordingly.

5.2. Furthermore, we will always store any data collected from you in our servers located in India.

6. DATA RETENTION

6.1. We take reasonable steps to ensure that User information is available only for so long as is necessary for the purpose for which it is processed, or longer if required under any applicable law, subject to appropriate safeguards. Please note that we ensure that all other information collected and stored is anonymized and aggregated in an irreversible manner. Furthermore, you explicitly consent and agree that we will be entitled to use such anonymized data or information freely, without any restrictions other than those set out under applicable law. Once any portion of the User information collected by us is no longer necessary for the purpose for which it is processed, or is no longer required under any applicable law, whichever is later, such User information shall be forthwith deleted, without retention of any copies.

7. INFORMATION SECURITY

7.1. The information provided by the User is stored in access controlled facilities with restricted access. User information transmitted over the internet is protected through the use of encryption, using the Secure Socket Layer (SSL) or equivalent protocols.

7.2. If a password is used to help protect User accounts and account information, it is the responsibility of the User to keep the password confidential. You have to ensure that you always log out, before sharing the device with a third party and it is advised that the User utilizes a Service to protect access to the User’s Device.

7.3. We shall use generally accepted industry standards to protect the User information submitted to us, both during transmission and upon receipt. However, please be advised that, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, even though we strive to use commercially acceptable means to protect User information, we cannot guarantee its absolute security and your use of the Portal is at your sole risk and discretion. We also cannot warrant that such User information may not be misused in the event our safeguards and protocols are breached by a malicious third-party. Further, we are not liable to, nor can we fully control the actions of other users with whom you may choose to share your information.

7.4. The collection, usage, and sharing of User information by us shall be in compliance with the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 and other applicable laws.

7.5. If any security breach comes to our knowledge, then we may take all steps required to protect misuse of such information and may attempt to notify you electronically so that you can take appropriate steps. For the purposes of this Clause 7.5, the procedure/responses that would be undertaken by us in case of a security breach is available at https://www.moneytap.com/cyber-security-incident-policy.html.

7.6. Any of your information which you provide when you use our Services to an open, public environment or forum or any third party website including (without limitation) any blog, chat room, community, classifieds or discussion board: (i) will not be considered confidential; and (ii) is not subject to protection under this Privacy Policy. Since such public environments are accessible by third parties, it is possible that third parties may collect or use such information for their own purposes. You should accordingly be careful when deciding to share any of your information in such public environments. Please note that we are not liable to you or any third party for any damages that you or any third party may suffer on account of your disclosure of Information in any public environment.

8. PROCEDURE FOR REMOVING USER NAME FROM THE RECORDS

8.1. If and when a User is desirous of having his/her name and other details: (a) removed from the records of MWYN or not be used by MWYN; (b) not be shared with a third party; immediately upon receiving the User’s written request to that effect we shall, subject to the terms hereof and/or applicable law, remove and/delete all such information.

8.2. If the User no longer wishes to receive notifications about our Services, The User may change his/her notification preferences by contacting us at hello@freo.money. We reserve the right to close the User account if the User opts out of receiving certain crucial notices that are required to perform the Services through the Portal. The User may not opt-out of receiving notifications about due or past due amounts that the User owes MWYN or any other collections efforts.

8.3. Notwithstanding the foregoing, MWYN may retain information of the User if mandated under applicable law, even after receiving the User’s written request to remove/delete all such information.

9. PROCEDURE FOR CORRECTING INACCURACIES IN THE INFORMATION

9.1. The User may correct or update any information online. In the event of loss of access details, the User may retrieve the same or receive new access details by sending an e-mail to: hello@freo.money.

10. PRIVACY POLICY UPDATES

10.1. We reserve the right to change or update this Privacy Policy at any time. Such changes shall be effective immediately upon posting on this Portal. Your access and use of the Portal following any such change constitutes your agreement to follow and be bound by these Privacy Policy, as updated or modified. For this reason, we encourage you to review this Privacy Policy each time you access and use the Portal.

11. NODAL GRIEVANCE REDRESSAL OFFICER

11.1. As required under applicable guidelines issued by Reserve Bank of India (RBI) and Information Technology Act, 2000 and rules made there under and for the purposes of redressing any complaints, you may contact our nodal grievance redressal officer whose name and contact details are provided below:

NAME

Anjali Panwar

ADDRESS

G-405, 4th Floor – Gamma Block, Sigma Soft Tech Park Varthur, Kodi Whitefield Post, Bangalore – 560066.

TEL

tel:+91-80-40974095

EMAIL

mailto:hello@freo.money

12. DISPUTE RESOLUTION

12.1. In the event of any dispute, difference or claim arising out of this Privacy Policy the same shall be settled in accordance with the laws of India through regular judicial process and the courts of Bangalore, India shall have exclusive jurisdiction.

13. COOKIES

13.1. When you visit the Portal, one or more cookies will be sent to the computer/smartphone or other devices being used by you. The cookies are either used to improve the quality of the Portal or for storing your preferences as a user, improving search results and tracking user trends. You have the option of disabling cookies via your browser preferences. However, if you disable cookies on your browser, some parts of the Portal may not function effectively.