Arambh Fintech Private Limited (“Arambh”, “we”, “our” or “us”) recognizes the importance of protecting personal details and Information, and thus provides this Privacy Policy with respect to the access and use of various products and Services of Arambh by way of any type of devices and media, including web-based, mobile-based applications, devices, URLs/links, notifications, chatbot  and other forms of digital, (“Platform”) as owned and operated by us and/or our affiliates and Services provided thereon by us and/or our affiliates (“Services”). The term Platform will also include all pages that are sub-domains or are associated with or within each Platform and all devices, applications, features, technologies, functionalities and other Services that Arambh operates or offers through such Platform.

For the purpose of this Privacy Policy, the user of Services may be customers, channel partners, vendors or any other persons using Services or accessing the Platform (“user”, “you” or “your”). This Privacy Policy will help you understand our policies and procedures regarding the collection, handling and use of your Information.

We are committed to respecting your online privacy and recognize your need for appropriate protection and management of any Information you share with us on the Platform.

This Privacy Policy (“Policy”) is being framed in accordance under the applicable law.

By using our Services through the Platform, you signify your assent to this Policy and consent to the processing of your personal Information and/or sensitive Information or any other transaction that is generated with your use of the Platform (“Information”). If at any time, an individual provides Information about someone other than himself or herself, the individual warrants that they have that person’s consent to provide such Information for the purpose specified. The Services are not available to persons below the age of 18 years.

If you do not agree with this Policy, ensure that you do not, in any manner, use our Services or download, install and/or use the mobile application.

By accessing or using the Platform and/or availing the Services provided through the Platform or otherwise giving us your Information, you undertake that you have the capacity to enter into a legally binding contract vide this Policy, which constitutes a legally binding document between you and Arambh under the applicable law. Arambh collects and processes your usage data, Information and third-party data carefully, only for the purposes described in this Policy and only to the extent necessary as defined herein and within the scope of all applicable legal regulations. This Policy seeks to ensure that any Information or third-party Information handled by Arambh is managed in a way that is ethical, compliant and adheres to the best industry practices.

This Policy describes the types of Information Arambh collects, why and how Arambh uses the Information, with whom Arambh shares it, and the choices you can make about Arambh use of the Information. We also describe the measures taken by us to protect the security of the Information and how you can contact Arambh about its privacy practices.

This Policy describes Arambh current data protection policies and practices which may be amended or updated from time to time. Any changes to this Policy will become effective upon posting of the revised Policy on the Platform. It is recommended that you regularly check this Policy to apprise yourself of any updates. Your continued use of Platform or provision of data or Information thereafter will imply your unconditional acceptance of such updates to this Policy.

We intend to provide Services and features that meet your needs. To do so, when you use our Platform, we may obtain the following Information about you and your device from which you avail Services–

1. 1. Device Information: Information such as device ID, pages accessed, IP address, mobile network, operating system or a unique identifier.
2. 2. Information: Such as name, date of birth, residential status, postal address, e-mail address, mobile number, etc. This helps us fulfil our legal obligations which require us to confirm your identity.
3. 3. Location Information:  If you have authorized tracking it will help us provide to you any and/or all location-based Services and protect you against any and/or all fraud.
4. 4. The use and transfer to any other app of Information received from Google APIs will adhere to Google API Services user data policy, including the limited use requirements.
5. 5. Cookies: Cookies aid us in recognizing you as a customer and remember your preferences so we can personalize our Services. Cookies are required to prevent fraud and ensure the security of websites we control. You are free to decline our Cookies if your browser permits this. However, that may not guarantee you a seamless user experience.
6. 6. Services Usage and Transactional Information: For enabling you to make payments and to provide you Services for your account using our Services, we may store your financial Information such as your bank account or details mentioned on your credit cards or debit cards, or other payment instrument details etc. that are required for a successful transaction.
7. 7. Chat conversations: Information you send us through chat which includes images and voice recordings our conversations with you, so that we can help you in every way possible.
8. 8. Any other Information that is required to be collected as per specific mandate from any bank or as a legal requirement in India.

Arambh primarily collects your Information to provide you with a secure, smooth, and efficient experience on our website. Not only does this help us personalize and improve your experience, but the additional Information also helps in preventing any misuse.

Wherever possible, Arambh will indicate the data fields as either required or are optional. However, if you are unable to provide the required Information we need, we may not be able to provide you with the product or Services you have requested. Provided that once we get your consent, we may also use your Information for other lawful purposes which we will inform you about when it is required. By way of example, some of the uses of your Information would include the following:-

1. 1. Providing additional Services including customer support.
2. 2. Generating and maintaining your profile on the app, to contact you through a voice call or SMS or email and to provide you offers and customizing offers for you.
3. 3. Processing transactions and verifying your identity (including during account creation and password reset processes.
4. 4. Processing transactions and verifying your identity (including during account creation and password reset processes.
5. 5. Remedying fraud or other potentially prohibited or illegal activities and detecting/preventing violations of policies or applicable user agreements.
6. 6. Financial reporting, regulatory reporting, management reporting, risk management (including monitoring credit exposures), audit and record keeping purposes.
7. 7. Data collected by cookies helps us track, analyse and understand user trends so as to enable us to understand lacunas (such as slow response time on our website page or application) and improve your interactive experience of using our Services, our design, features and functionalities.
8. 8. We access data or Information stored by third parties in case required for providing you uninterrupted and satisfactory Services or in case consented by you.
9. 9. We only share data with our affiliated business partners and third-party vendors for the purposes mentioned in this section.
10. 10. to improve our Services, we need to constantly update and alter our business and marketing strategies for which we require the navigational and log Information to determine and analyse the merchants, markets, technology, operating systems, browsers, devices, locations from which our Services are used most or used least. For example, such Information and its analysis will help us focus more on your needs by providing you a wider range of Services, or developing updates for particular operating systems and mobile application versions, etc. Further, the Information collected helps us offer you other products, programs, or Services that we believe may be of interest to you. In addition, such Information collected will help us alert you in case of software compatibility issues.

Your Information is only accessible to those with a legitimate need-to-know basis. We do not disclose or share your Information with any third-party without your consent and ordinarily for some or all matters set out below:-

1. 1. Members of Arambh (including our affiliates/subsidiaries and business partners) for Services such as providing content, products, customer support etc.
2. 2. Where necessary to exercise, establish or defend legal rights, including to enforce our agreements and policies.

Law enforcement, government officials, or other third parties pursuant to a summon, court order, or other legal process or requirement applicable to the Arambh or one of its affiliates/subsidiaries; when we need to do so to comply with law.

We take care to allow your Information to be accessed only by those who really need it in order to perform their tasks and duties and to third parties who have a legitimate purpose for accessing it and with your consent.

If we go through a corporate sale, merger, reorganization, dissolution or similar event, Information we gather from you may get transferred in connection with such an event. Any acquirer or successor of the Arambh may continue to use the Information described in this Policy.

We share, disclose or distribute any of your Information to any third party unless required under an arrangement between Arambh and the third party for Services delivery, product enhancement, analysis, risk and security purposes, communication purpose, etc.

To complete a transaction, we may share financial Information (such as credit card details or other payment mode details) provided by you with authorised third parties, for instance, our business partners, financial teams/institutions involved in fulfilment of the said transactions, if any.

We are dedicated to guarding the security of your Information. We use several industry-standard security technologies and procedures devised to help protect your data from unauthorized access, use, or disclosure. The detailed specifics for the same have been provided below.

We work to protect the security of your Information during transmission by using appropriate software, which encrypts Information you input. This encrypted Information is stored on secure servers and data center. Further, we ensure that the number of employees involved in the management of the data center who have physical access to these computers is limited. Also, we use advanced security technology to prevent our computers from being accessed by unauthorized persons.

We use all reasonable and appropriate technical and organizational security measures to protect the security of your Information both online and offline including the implementation of access controls, implementation of firewalls, network intrusion detection and use of anti-virus software.

Please note that no system is completely secure. So, while we strive to protect your data, we cannot guarantee that unauthorized access, hacking, data loss or a data breach will never occur.

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 protective steps.

In addition to being able to update and correct your Information, you may also have other data protection rights. This revolves around what you can allow or restrict us to do with your Information.

1. 1. If we have collected and processed your Information with your consent, then you have the right to withdraw your consent at any time stating your reasons or concerns.
2. 2. You also have the right to ask for a copy of your Information in a portable (machine-readable) format. You can also say no to us using your Information for direct marketing and in certain other circumstances which include events where ‘legitimate interest’ is involved.
3. 3. Withdrawing your consent will not affect the lawfulness of any processing we carried out before your withdrawal, nor will it affect processing of your Information carried out in reliance on other lawful grounds other than consent.
4. 4. We will keep your Information for as long as it is needed to carry out the purposes we’ve described above, or as otherwise required by law. Generally, this means we will keep your Information as long as your account is active or as needed to provide our Services. If you cancel/ deactivate/ unsubscribe your account with us, we are not under any obligation to retain your Information. However, we may retain your Information for twenty-four (24) months (post cancellation/ deactivation), as our business practice.
5. 5. You can make any of these requests by contacting us at [[email protected]]. We will respond to all requests in accordance with the applicable laws.

1. 1. Aarambh shall not be liable to you for any loss of profit, production, anticipated savings, goodwill or business opportunities or any type of direct or indirect, incidental, economic, compensatory, punitive, exemplary or consequential losses arising out of performance or non-performance of its obligations under this Policy.
2. 2. Notwithstanding anything contained in this Policy or elsewhere, Aarambh shall not be held responsible for any loss, damage or misuse of your Information, if such loss, damage or misuse is attributable to a Force Majeure Event. The term “Force Majeure Event” shall mean any event that is beyond the reasonable control of Aarambh and shall include, without limitation, industrial action of any kind, riots, insurrection, war, acts of government, pandemic, epidemic, computer hacking, civil disturbances, unauthorised access to computer data and storage device, computer crashes, breach of security and encryption, or national/state lockdown due to any reason and any other similar events not within the control of the Aarambh.

1. 1. If you have any questions, queries, concerns or feedback about this Policy or our privacy related practices, please feel free to contact us on our Platform’s ‘Contact Us’ page.
2. 2. In case you have any grievances relating to the collecting, receiving, possessing, storing, dealing or handling of Information provided by you, you may contact our Grievance Officer at the following address.