Privacy Policy

1.INFORMATION WE COLLECT

• 1.1 When you use our Platform or avail the Services, we seek or collect, amongst others information such as your name, mother’s name, father’s name, password, date of birth, gender, Permanent Account Number (PAN), signature, marital status, nominee details, cancelled cheque, photograph and video recording, email id, phone number, educational or professional qualification, business name, business address, nature of business, Goods and Services Tax Identification Number (“GSTIN”), Tax Deduction and Collection Account Number (TAN), bank account details, vendor details, United Payments Interface (UPI) ID, and/or other payment and investment information and copies of KYC documents that helps us confirm your identity and facilitate provision of the Services through our Platform. No liability pertaining to the authenticity/ genuineness of the information disclosed will lie on the Company. Further, the Company will not be in any way responsible to verify any information obtained from you.

• 1.2 In case you are required to provide your Aadhaar details to us during account creation, you acknowledge and agree that the act of providing your Aadhaar details to us is voluntary. We require Aadhaar details solely for the purpose of carrying out KYC and for filing of ITRs.

• 1.3 We collect mobile numbers, e-mail addresses that you provide us on the Platform and use the same for sending various communications to you.

• 1.4 When you visit our Platform or avail the Services, we collect certain information about your interaction with our Platform including the pages that you view, your internet protocol address, the links you select or actions you take, browser type, the unique identifier of your device and device information such as operating system, operating system version, browser plug-ins, crashes, system activity, hardware settings, location based information, date and time of your request and referral URL, and cookies that may uniquely identify your browser and mobile application and the previously visited webpage.

• 1.5 We may retrieve your information and records available with third party provider including but not limited to credit score and liabilities information or information from the KYC Registration Agency, Goods and Services Tax Network (“GSTN”) and National Informatics Centre such as name, KYC details, KYC status, father’s name, occupation, address details and related documents You hereby authorise the Company to download and retrieve any information from governmental and other statutory bodies including but not limited to GSTN and NIC.

• 1.6 When you avail the Services, we may after obtaining consent, access and read information from your device such as information from your SMS storage for the providing the Services. Further, certain Services require us to obtain access to the ability to make phone calls or send messages using your device. If you choose to avail such Services, by agreeing to this Policy and Terms you are providing your express consent to permit the Company to access the calling and messaging functionalities of your device.

• 1.7 In order to prepare your income tax return, to file your e-return, to assist on your tax matters, and/or to provide an audit defense service, we collect information about your income, deductions, credits, dependents, etc. Collectively, this information is referred as “Tax Return Information”.

2. HOW WE USE THE INFORMATION

2.1. We do not sell or share your personal or financial information to anyone. However, notwithstanding anything contained in this Policy, you expressly acknowledge, consent and agree to the following terms on information use and further authorise us to access and use your information in the manner set out below:

• a. to use your information to manage your account, to contact you and to operate, improve, and deliver our Platform and Services. We use your information to give you a customized, interactive experience as you use our Platform and avail the Services.

• b. to use your information for maintaining a record of such information and your transactions in a secure and confidential manner, and as required under the applicable laws.

• c. to use services of third parties to provide the Platform and Services for you, who are bound to keep such information confidential.

• d. to troubleshoot software bugs and operational issues, to conduct data analysis, testing and research and to monitor and analyse usage and activity trends. Information collected may also be used to share communications to you about our products & services, provide additional features through cookies and to detect and/or prevent any fraudulent/criminal/prohibited activity as per applicable laws.

• e. to use the data in an aggregated/compiled form to produce statistical/demographic analyses for marketing, strategy and other business purposes. However, these will be used in ways that will not be able to identify you or link any specific information to an individual. Such aggregated information and results/analyses shall be our property and you will not be entitled to any compensation for the use thereof.

• f. to share your information with judicial, administrative and regulatory entities to comply with any legal and regulatory requirements.

• g. to summarize information about your usage and combine it with that of others to learn about the use of the Platform and Services and further to help us develop new products and services.

• h. to retain copies of your completed and filed ITRs, including retrieving information from governmental and other statutory bodies including but not limited to GSTN and NIC. This information may also be used to perform analysis or to provide you with a copy of your returns for your convenience.

• i. to use your information to manage your account, to contact you and to operate, improve, and deliver our products and services, including the Platform. You further acknowledge, agree and authorise us to use your information for market research, project planning, product development, troubleshoot problems, analyse user behaviour, marketing purposes, and promotions.

• j. to use your information to compute the charges for the products and services you purchase.

• k. to use the contact information to communicate with you. You further expressly consent and authorise us to send you messages on your mobile number, call you on your mobile number, send you messages and communicate with you in any other manner including for the purpose of providing you Platform and Services and for marketing and promotional purposes.

• l. to (by using your Tax Return Information) prepare and file your IT return, and provide related assistance and services.

• m. to use third-party advertising companies to display advertisements. Such companies may use information about your visits to the Platform and Third-Party Platforms in order to provide advertisements about goods and services of interest to you.

• n. to share your information with identified Strategic Partners, our third party service providers and our affiliates to host, use, copy, transmit, process, store, share, analyse, display, make derivations, and back up all data you submit to us through the Services and as required by us, including but not limited to personal data and any other data relating to financial information of yourself and others, for the purposes of (a) providing the Services requested by you, as set out in this Policy and enable you to use the Platform and avail the Services (including the services provided by our Strategic Partners, third parties and affiliates; (b) allow us to improve, develop and protect the Services; (c) create, market or provide new services through the Company or its Strategic Partners, group companies and affiliates; (d) communicate with you about our Platform and the Services; and (e) send you information we think may be of interest to you. You agree, represent and warrant that you have, and you will maintain, all rights to allow the Company, our Strategic Partners and/ or any third-party service providers, and our affiliates, to host, use, compile, copy, transmit, process, store, share, analyse, display, make derivations, and back up all your data and retain aggregated customer data, including without limitation in combination with data of other users.

• o. to conduct audit of your records without any notice in case of apprehension of fraud;
• p. to retain/ store your data and confidential information, of any nature (either wholly or partially), in the Company’s servers or cloud or otherwise in any other medium as may be transmitted/ processed/ passed through the Platform.

2.2. You acknowledge, agree and authorise us to collect, store, process your information and further transfer and share information (including personal information) with third parties, including Securities Exchange Board of India, National Stock Exchange of India Limited, Bombay Stock Exchange, Central Registry of Securitisation Asset Reconstruction and Security Interest of India (“CERSAI”), payment gateways, banks, KYC Registration Agencies, Asset Management Companies, Registrar and Transfer Agents, Mutual Funds, Income Tax Department etc.

2.3. You acknowledge, agree and authorise our partners and entities for who we act as a technology facilitator (including ClearSharp Technology Private Limited (having its office at X - 58, IInd Floor, Loha Mandi, Naraina New Delhi West Delhi DL 110028 IN) and Right Horizon Investment Advisory Services Private Limited (having its office at 6, Arekere Village Opp. British Biologicals, Bannerghatta Road, Bangalore KA 560076 )) (“Strategic Partners”) to collect, store, process, transfer your information including for the purpose of providing Services to you through the Platform. You allow such Strategic Partners to record, maintain and process your personal and transaction related information for the purpose of using the Services. You further authorise such Strategic Partners to communicate with you in any manner including by way of emails, messages and phone calls.

2.4. If you choose to use Services provided by our Strategic Partners or our third-party service providers through the Platform, your information may be governed by the terms of the privacy policy of such Strategic Partners and the third-party service providers. We will not be responsible or liable for the privacy practices of such Strategic Partners or any third-party service providers.

2.5. We may, share/ transfer/ assign all of your information with any other business entities, including in the event of a merger, sale, re-organization, amalgamation, joint ventures, assignment, restructuring of business or transfer or disposition of all or any portion of our business.

3.ERI SERVICES FOR E-FILING

ERI Services for filing your ITR are provided by our partner ClearSharp Technology Private Limited (“ClearSharp”) through our Platform. ClearSharp is an authorised ERI as per the Electronic Furnishing of Return of Income Scheme, 2007. You authorise ClearSharp to request and collect your personal and other information in order to provide e-filing services to you, add you as a client of the ERI, retrieve your income tax return information using ERI services, E-File access of your ITR, access, store and process your Form-16, perform other additional functions as necessary to discharge its responsibilities as ERI.

4.COOKIE POLICY

Like many websites, we use cookies, flash cookies, web beacons or similar technologies. “Cookies” are small text files that are stored on your computer or other device when you visit certain online pages that record your preferences and actions. We use cookies for a variety of purposes, including remembering you and your preferences, tracking your use of our Platform, and facilitating your use of Platform. Most web browsers automatically accept cookies, but, if you prefer, you can usually modify your browser setting to decline cookies. However, please note that refusing a cookie may limit your access and/or use of Platform and Services.

5.IDENTITY THEFT

We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of your personal information, username, password, transaction information and data stored on our Site. Sensitive and private data exchange between the Site and its users happens over a SSL secured communication channel and is encrypted and protected with digital signatures. Our Site is also in compliance with PCI vulnerability standards in order to create as secure of an environment as possible for Users.

5.2 Such activities are usually carried on by unauthorized individuals and are illegal in nature. They are called phishing or identity theft. In case of any suspicion of such activity or on receiving such an e-mail you are certain it was not sent by us. We advise you to not respond to such mail and to take whatever action you see fit.

6. LINKS TO OTHER SITES

Our Platform provides links to other websites and third-party platforms (“Third-Party Platforms”). Such Third-Party Platforms may collect information about you. We are not responsible for the privacy practices or the content of those linked websites and Third-Party Platforms. We recommend you to review the privacy policies of such Third-Party Platforms. In case you choose to log-in through your Google account, we will access information from your Google accounts once they give us permission to do so whilst using the Google-related functionality (as the case maybe) of the Platform. Once permission is granted, the Platform accesses a user’s account details, mobile number, email address, contact list and location (as applicable). The respective privacy policies of Google will also be applicable.

7.DATA RETENTION BY US

7.1 We will retain your information only for as long as is necessary for the purposes set out in this Policy unless required by applicable Indian laws. We will retain and use your information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

7.2 We encourage you to review the information and inform about any discrepancies and information found to be inaccurate shall be corrected or amended. Please reach out to us at support@credit dhara.in in case you would like to review the information collected by us.

7.3 You shall at all times, take adequate necessary precautions, at your end, to preserve the integrity and security of your data which shall include and not be limited to your personal information. All information disclosed by you shall be deemed to be disclosed willingly and without any coercion.

8. LOG DATA

We want to inform you that whenever you use our Platform or avail the Services, we collect data from your device called Log Data. This Log Data may include information such as your device’s Internet Protocol (“IP”) address, device name, operating system version, configuration of the app when utilising the Service, the time and date of your use of the Service, and other statistics.

9.INFORMATION SECURITY

We are ISO 27001certified and also have a SOC2 Type 2 audit report with respect to our information security practices and infrastructure. Furthermore, our system is configured with data encryption, or scrambling technologies and firewalls constructed to the highest industry standards. We also use Secure Socket Layer (SSL) technology that protects the data you send over the internet.

We recommend that you use the latest available versions of browsers in order to take advantage of updates in security technology. Although we strive to protect your information, no data transmission over the Internet is completely secure. There is some risk associated with any data transmission, including the risk that personal data may be intercepted in transit. Therefore, we cannot guarantee its absolute security. However, we have put in place necessary procedures to deal with any suspected or possible breaches of personal data.

We work to protect your information from loss, misuse or unauthorized alteration by using industry-recognized security safeguards, coupled with carefully developed security procedures and practices. We maintain electronic and procedural safeguards of all information. We use both internal and external resources to review our security procedures.

10. DISCLAIMER

10.1 We make no representation as to providing or storing back-up copies of any information submitted to us. You shall be solely responsible to ensure that you maintain back-up copies of such information and in the event of any malfunctioning or failing of the Platform for any reason whatsoever (including on account of maintenance), you may be required to resubmit such information.

10.2 Although, we take appropriate steps to maintain the security of information we collect from you, we assume no responsibility of whatsoever nature as to make good the losses and damages you may incur, due to privacy and/or security breach of your information. We shall not be liable for any loss or damage sustained by reason of disclosure (inadvertent or otherwise) of any information and/or omission or inaccuracy with respect to any information so disclosed and used whether or not in pursuance of a legal process or otherwise.

10.3 When payment information is being transmitted on or through the Platform, it will be protected by encryption technology of a third-party payment services providers, including payment gateways. You agree, acknowledge and consent to such sharing of your information with third party service providers to process payments and manage your payment-related information. The Company does not guarantee that the transmissions of your payment-related information or other information will always be secure.

10.4 GSTN shall have the sole right and discretion, without any liability of any nature of the Company, by all means (whether manual or automates) to accept/ reject or any User’s data from being transmitted to the GST system from our Platform, including but not limited to, in case of security breach, data traffic beyond prescribed by GSTN, suspected payload (having virus and/ or malware) or transfer of corrupt data or due to any other reasons as mandated by GSTN.

11. CHANGES TO THIS POLICY

Please note that this Policy may change from time to time. The “Last Updated” date at the top of the Policy indicates when the most recent modifications were made to the Policy. We reserve the right to modify or amend the terms of our Policy from time to time. We will endeavor to post any changes to this Policy on our webpage and, if the changes are significant, to provide a more prominent notice. While we will make reasonable efforts to keep you posted on any updates to this Policy, to make sure that you are aware of any changes, we recommend that you review this Policy periodically. In the event we modify this Policy, your continued use of the Platform and Services will signify your acceptance of the modified Policy, and will be adequate proof that you have expressly agreed to the terms of this Policy which shall apply from the date of your first use of the Platform.

12. WITHDRAWAL OF CONSENT BY YOU

You may choose to withdraw your consent provided hereunder at any point in time. Such withdrawal of consent must be sent in writing to support@creditdhara.com In case you later withdraw your consent, we request you not to access the Platform and/or use the Services and also reserve the right to not provide you any Services through the Platform.

13. GOVERNING LAW

This Policy is governed by all laws applicable within the territory of India. By using the Platform and Services, you are agreeing to the terms of the Policy thereby consenting to the exclusive jurisdiction and venue of courts in Bangalore, India, in all disputes arising out of or relating to the use of the Platform or this Policy.