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THIS PRIVACY POLICY (PRIVACY POLICY) SETS FORTH THE MODES OF COLLECTION, USAGE, SHARING, TRANSFER AND DISCLOSURE OF YOUR INFORMATION GATHERED ON THE PLATFORM. THIS PRIVACY POLICY APPLIES ONLY TO PERSONAL INFORMATION COLLECTED ON THE PLATFORM. THIS PRIVACY POLICY ALSO APPLIES TO INFORMATION COLLECTED BY THE COMPANY IN OTHER WAYS, INCLUDING INFORMATION COLLECTED OFFLINE. PLEASE READ THIS PRIVACY POLICY CAREFULLY. BY CONTINUING TO USE THE SERVICES, OR ACCESS THE PLATFORM YOU AGREE TO THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, YOU MAY NOT AVAIL THE SERVICES.

By visiting the website, https://paywithring.com/ (“Website”) or the PaywithRing mobile and/or web application (the “App” or “PaywithRing”) (collectively, the “Platform”) and availing the services provided by us (“Service(s)”) you agree to be bound by the terms and conditions (“Terms”) of this Privacy Policy

This Privacy Policy explains how we protect the personal data provided through our Platform and how we use that information in connection with our Service offered through the Platform.

"Personal Information" for purposes of this Policy means information that identifies you, such as your name, address, phone number, mobile number, e-mail address or any other contact details. By providing your number at https://paywithring.com/, you are authorizing PaywithRing & its representatives to give you a call to offer you our Services for the product you have opted for, imparting product knowledge, offering promotional offers running on the website. Irrespective of the fact that you have registered yourself under Do Not Disturb (“DND”) or Do Not Contact (“DNC”) service, you are still authorizing us, our representatives & our partners to communicate with you for the above-mentioned purposes. There is no DNC check required on a number you enter while using PaywithRing Services.

To register with us, you must be 18 (eighteen) years of age or older and Indian resident. Individuals below the age of 18 (eighteen) years and minors are strictly forbidden from using the Service.

How does PaywithRing collect the information?

1. Information provided by you with PaywithRing

   If you intend to open a loan account by using PaywithRing with any of our lending partners, you would be required to provide details like your name, E-mail address, Residential address, Mobile number, PAN number, Aadhaar Card, and other such information which may be needed to assess your creditworthiness. Wherever possible, we indicate the mandatory and the optional fields. You always have the option to not provide any information by choosing not to use a particular Service or feature on the Platform. You shall be provided with an option to give or deny consent for use of specific data, restrict disclosure to third parties, data retention, revoke consent already granted to collect personal data and if required, make the App delete/ forget the data. We also collect user account data which includes email address and user public profile information like name, photo, or information required solely for the purpose of identification, depending on the social media or networking platform used by You like Google or Facebook to log-into an App.

   No biometric data is stored/ collected in the systems associated with the Digital Lending Application (“DLA”) of the Regulated Entities (“RE”)/“REs”)/ their Lending Service Provider(s) (“LSP(s)”), unless allowed under extant statutory guidelines. Our system complies with various technology standards/ requirements on cybersecurity stipulated by the Reserve Bank of India (“RBI”) and other agencies, or as may be specified from time to time, for undertaking digital lending. The Platform does not access mobile phone resources like file and media, contact list, call logs, telephony functions, etc.

   Access to your registration information, account information, and any other Personal Information you provide is strictly restricted and used only under specific internal procedures and safeguards governing access, to operate, develop or improve the Service. We may also use third-party service providers to help us provide the Service to you, such as sending e-mail messages or SMS on our behalf or hosting and operating a particular feature or functionality of the Service. We require such third parties to maintain the confidentiality of the information we provide to them. If you telephone us, we may also record and monitor calls for quality checks and staff training. Such recordings may also be used to help us combat fraud.

   Information that PaywithRing collects from your activities

   In order to provide seamless approval and determine instant creditworthiness of customers, we explicitly request for certain permissions after users complete the signup process:

   FINANCIAL SMS

   We collect all SMSs and upload on our Server to monitor the income, track and analyse financial expenses and determine the creditworthiness for instant credit disbursal. The assessment is automated and the SMSs are encrypted. Even though we have access to all SMS’s, we do not read, share or store any of your personal SMS data. Also, we do not share your SMSs data with any third party app or services.

   DEVICE LOCATION

   The information we collect from your device includes the hardware model, build model, RAM, storage; unique device identifiers like Advertising ID; SIM information that includes network operator, WIFI information and mobile network information to uniquely identify the devices in the onboarding journey, KYC process on the App.

   CAMERA

   We require camera access to take selfie, scan and capture the required KYC documents thereby allowing us to auto-fill relevant fields.

   COOKIES

   If enabled, we may place cookies on your machine that store small amounts of data on your computer about your visit to any of the pages of this website. Cookies can identify the pages that are being viewed, and this can assist us in tracking which of our features appeal the most to you and what content you may have viewed on past visits.

   These technologies are used in analyzing trends, administering the Site, tracking users' movements around the Site, and to gather demographic information about our user base as a whole. Third-party vendors, including www.google.com ("Google"), may use cookies to serve ads based on your visits to this Website. You may visit the website of the third party and choose to opt-out of the use of cookies for interest-based advertising if the third party offers such an option.

   We use cookies on our website to personalize our Service to you. Users can control the use of cookies at the individual browser level. If you reject cookies, you may still use our Site, but your ability to use some features or areas of our Site may be limited. You may refuse to accept cookies by activating the setting on your browser, which allows you to reject the setting of cookies. Unless you have adjusted your browser setting to reject cookies, our system will issue cookies when you log on to the website.

   Information sharing with Third parties

   We may use third-party advertising companies and/or ad agencies to serve ads when you visit our website. These companies may use information (excluding your name, address, e-mail address, or telephone number) about your visits to https://paywithring.com/ to provide advertisements on this Site and other sites about goods and services that may be of interest to you. Explicit consent will be taken from you before sharing Personal Information with any third party, except for cases where such sharing is required as per statutory or regulatory requirement. If you choose to apply for these separate products or services, disclose information to the providers, or grant them permission to collect information about you, then their use of your information is governed by their privacy policies. You should evaluate the practices of these external service providers before deciding to use their services. https://paywithring.com/ is not responsible for their privacy practices. However, in case you wish to restrict sharing of information partially or completely with third party (other than statutory or regulatory authorities) you may reach out to us on privacy@paywithring.com

How does “PaywithRing” protect your personal details?

1. We keep your data secure

   We follow generally accepted standards to protect the Personal Information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. We use a combination of firewalls, encryption techniques, and authentication procedures, among others, to maintain the safety and security of your online session and to protect https://paywithring.com/ accounts and systems from unauthorized access.

   We maintain your information on servers located in India. Our databases are protected from general employee access, both physically and logically. We encrypt your Service password so that your password cannot be recovered, even by us. All backup drives and tapes also are encrypted. No employee may put any sensitive content on any unsecured machine (i.e., nothing can be taken from the database and put on an insecure laptop).

2. Encryption and secure communication

   All communications between your computer, tablet, mobile devices and https://paywithring.com/ that contain any Personal Information are encrypted. This enables client and server applications to communicate in a way that is designed to prevent eavesdropping, tampering, and message forgery.

3. Login id and password confidentiality

   You are responsible for maintaining the security of your Login ID and Password, and may not provide these credentials to any third party. If you believe they have been stolen or been made known to others, you must contact us immediately at care@paywithring.com. We are not responsible if someone else accesses your account through Registration Information they have obtained from you or through a violation by you of this Privacy and Security Policy or the Terms of Use (ToU).

How can “PaywithRing” utilize your information?

The intended purpose of collecting information provided by you is to

1. Establish identity and verify the same with or without help of third party(ies);
2. To complete onboarding and KYC requirements for third party lending partners.
3. Monitor, improve and administer our Platform;
4. Provide our service i.e. perform credit profiling for the purpose of facilitating loans to You.
5. Design and offer customized products and services offered by our third party financial partners;
6. Analyse how the Platform is used, diagnose service or technical problems and maintain security;
7. Send communication notifications, information regarding the products or services requested by You or process queries and applications that You have made on the Platform;
8. Manage Our relationship with You and inform You about other products or services We think You might find of some use;
9. Conduct data analysis in order to improve the Services / Products provided to the User;
10. Use the User information in order to comply with country laws and regulations;
11. Collect KYC for our third party lending partners based on the information shared by the User;
12. Use the User information in other ways permitted by law to enable You to take financial services from our lending partners.

We will use and retain the information for such periods as necessary to provide You the Services on the Platform, to comply with our legal obligations, to resolve disputes, and enforce our agreements.

When you share information with PaywithRing

You can review and edit your Personal Information at any time by logging in to your account on the Website or by contacting the PaywithRing support team on care@paywithring.com. If you choose to close your account, your personally identifiable information will not be used by us for any further purposes, nor sold or shared with third parties, except as necessary to prevent fraud and assist law enforcement, as required by law or under this Privacy Policy.

All other information shall be treated as non-confidential and non-proprietary and PaywithRing shall be under no obligation of any kind concerning such information and shall be free to reproduce, use, disclose, and distribute the information to others without limitation. Additionally, PaywithRing shall be free to use any ideas, concepts, know-how, or techniques contained in such information for any purpose whatsoever, including, but not limited to, developing or marketing services incorporating such information.

There is no legal obligation to destruct the data from the server upon you closing the account or non-usage of our Services from your end. The data will be retained securely on our server and shall help PaywithRing:

• To comply with legal duties and requirements, either statutory or regulatory;
• To avoid liability through "spoliation," the improper destruction or alteration of documents in a litigation situation;
• To support or oppose a position in an investigation or litigation;
• To protect from unnecessary expense and time during discovery;
• To maintain control over discovery and e-discovery;
• To keep documents confidential and avoid leakage to attackers or competitors;
• To enforce our Terms and Conditions

We may share your collected information with only our registered third parties including our regulated financial partners for provision of Services on the Website/ App wherever feasible. We may share your information with third parties only in such manner as described below:

1. We may disclose and share your information with the financial service providers, banks or NBFCs and our third party partners for facilitation of a loan or facility or line of credit or purchase of a product;
2. We may share your information with our third party partners in order to conduct data analysis in order to serve you better and provide Services our Platform.
3. We may disclose your information, without prior notice, if we are under a duty to do so in order to comply with any legal obligation or an order from the government and/or a statutory authority, or in order to enforce or apply Our terms of use or assign such information in the course of corporate divestitures, mergers, or to protect the rights, property, or safety of Us, Our users, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
4. We will disclose the data / information provided by a User with other technology partners to track how the User interact with the Platform on Our behalf.
5. We and our affiliates may share your information with another business entity should we (or our assets) merge with, or be acquired by that business entity, or re-organization, amalgamation, restructuring of business for continuity of business. Should such a transaction occur than any business entity (or the new combined entity) receiving any such information from us shall be bound by this Policy with respect to your information.
6. We will disclose the information to our third party technology and credit partners to perform credit checks and credit analysis like Credit Bureaus or third party data source providers;
7. We will share your information under a confidentiality agreement with the third parties and restrict use of the said Information by third parties only for the purposes detailed herein. We warrant that there will be no unauthorised disclosure of your information shared with third parties.
8. By using the Platform, you hereby grant your consent to the Company to share/disclose your Personal Information (i) To the concerned third parties in connection with the Services; and (ii) With the governmental authorities, quasi-governmental authorities, judicial authorities and quasi-judicial authorities, in accordance with applicable laws of India.
9. We shall disclose your KYC journey or any data with respect to the same to the relevant regulatory authorities as a part of our statutory audit process. Please note that your Aadhaar number shall never be disclosed.

In case we use or disclose your information for any purpose not specified above, we will take your explicit consent.

LINK TO THIRD-PARTY Software Development Kit (SDK)

The App has a link to a registered third party SDK which collects data on our behalf and data is stored to a secured server to perform a variety of services such as analyzing your in-app actions, serving retargeting ads, do location based targeting on social media accounts, deliver personalized push notifications, perform credit assessment based on your information. We share limited information such as Device IDs, Android IDs, Page status, Location, Workflow events with analytics and marketing service providers who may use it to serve targeted, contextual ads to you. We ensure that our third party service provider takes extensive security measures in order to protect your Personal Information against loss, misuse or alteration of the data.

We follow generally accepted standards to protect the Personal Information submitted to us, both during transmission and once we receive it using secure cryptographic techniques over HTTPS APIs. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security. We use a combination of firewalls, encryption techniques and authentication procedures, among others, to maintain the security of your online session and to protect https://paywithring.com/ accounts and systems from unauthorized access.

Furthermore, our registered third party service provider provides hosting security – they use industry-leading anti-virus, anti-malware, intrusion prevention systems, intrusion detection systems, file integrity monitoring, and application control solutions.

We do not sell or misuse your data. We do not share your personal identifiable information and Government IDs such as PAN, Aadhaar Card, VID number with these 3rd parties. We also don't allow unauthorized access to your non-public personal contacts or financial transaction SMS data with any 3rd party.

SECURITY PRECAUTIONS

The Platform intends to protect your information and to maintain its accuracy as confirmed by you. We implement reasonable physical, administrative and technical safeguards to help us protect your information from unauthorized access, use and disclosure. For example, we encrypt all information when we transmit over the internet. We also require that our registered third party service providers protect such information from unauthorized access, use and disclosure.

Our Platform has stringent security measures in place to protect the loss, misuse and alteration of information under control. We endeavour to safeguard and ensure the security of the information provided by you. We use Secure Sockets Layers (SSL) based encryption, for the transmission of the information, which is currently the required level of encryption in India as per applicable law.

We blend security at multiple steps within our products with the state of the art technology to ensure our systems maintain strong security measures and the overall data and privacy security design allow us to defend our systems ranging from low hanging issue up to sophisticated attacks.

We aim to protect from unauthorized access, alteration, disclosure or destruction of information we hold, including:

1. We use encryption to keep your data private while in transit;
2. We offer security feature like an OTP verification to help you protect your account;
3. We review our information collection, storage, and processing practices, including physical security measures, to prevent unauthorized access to our systems;
4. We restrict access to Personal Information to our employees, contractors, and agents who need that information in order to process it. Anyone with this access is subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations;
5. Compliance & Cooperation with Regulations and applicable laws;
6. We regularly review this Privacy Policy and make sure that we process your information in ways that comply with it.
7. Data transfers;
8. We ensure that Aadhaar number is not disclosed in any manner.

We or our affiliates maintain your information on servers located in India. Data protection laws vary among countries, with some providing more protection than others. We also comply with certain legal frameworks relating to the transfer of data as mentioned and required under the Information Technology Act, 2000 and rules made thereunder.

When we receive formal written complaints, we respond by contacting the person who made the complaint. We work with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of your data that we cannot resolve with you directly.

YOUR RIGHTS REGARDING THE DATA

Right to rectification

In the event that any personal data provided by you is inaccurate, incomplete or outdated then you shall have the right to provide us with the accurate, complete and up to date data and have us rectify such data at our end immediately. We urge you to ensure that you always provide us with accurate and correct information/data to ensure your use of our Services is uninterrupted.

Right to withdraw consent

To prevent further sharing of your data, you can also uninstall the App. Your device may have controls that determine what information we collect. For example, you can modify permissions on your Android device for access to Camera or Audio permissions.

Marketing Opt-Out

We may email or send push notifications to you from time to time about our latest offerings and updates. You may opt out of receiving such promotional emails from us by writing to us. You may also opt out of receiving emails and other messages from us by following the unsubscribe instructions in those messages. However, even if you have opted out of receiving information from us, we will still send non-promotional communications, such as repayment reminders and loan approvals message etc.

You can opt out of receiving push notifications through your device settings. Please note that opting out of receiving push notifications may impact your use of the App.

Contact Information of Data Grievances Redressal Officer

We and our Lending Partner have appointed a data grievances redressal officer. Our data grievance officer is: Suraj S, accessible via email at: care@paywithring.com. You can contact the officer confidentially by email to enquire about the treatment of your data by us or our Lending Partner.

CHANGES TO PRIVACY STATEMENT AND YOUR DUTY TO INFORM US OF CHANGES

This Privacy Statement may change or be amended over time. The recent version of this Privacy Statement is published on this App or Platform, as the case may be.

Please revisit this page periodically to stay aware of any changes to this Privacy Statement. We will notify you of any material changes to this Privacy Statement by publishing the same on our App or Platform, as applicable. Your continued use of our Services confirms your acceptance of this Privacy Statement, as amended. If you do not agree to the terms and conditions as contained in our Privacy Statement, as amended, you must stop using our Services and notify us.

It is very important that any Personal Information we hold/pass on to our lending partners about you is up to date and correct. Please inform us of any changes to your Personal Information.

For any privacy related concerns, kindly write to us at privacy@paywithring.com