Privacy Policy

PART A: ACCOUNT CREATION AND REGISTRATION

1. COLLECTION OF INFORMATION

   • 1.1. All Information collected on the Platform for creation of Your account and registration as a user on the Platform and general use of the Platform (Profile Data) is done through the means of:
     • 1.1.1. Your mobile and email address provided at the time of account creation on the Platform;
     • 1.1.2. Consents (other than the consents as specified in Part-B to Part-D hereof, if any) that You provide when You register on or browse through the Website or the Application;
     • 1.1.3. Data provided during communications with us (for example, by e-mail or chat) with respect to Your account;
     • 1.1.4. Data generated by Your general usage of our Platform, and when You report a problem with our Platform.
   • 1.2. Collection of other Non-Personal Information
     • 1.2.1. Cookies: Cookies are small data files that the Website stores on Your computer. Use of this Information helps Us identify You in order to make our Website more user friendly. We do not store personal/identity Information in the cookies. You have the right to reject our access to Cookies since most browsers will permit You to decline cookies but if You choose to do this it might affect service on some parts of Our Website.
     • 1.2.2. If You choose to avail any Services through the Platform, we collect Information about the manner in which You are using the Platform. We retain this Information as necessary to resolve disputes, provide customer support and troubleshoot problems as permitted by law. If You send us personal correspondence, such as emails or letters, or if other users or third parties send us correspondence about Your activities or postings on the Website, we collect such Information into a file specific to You.
   • 1.3. Consents sought as part of rendering the Services (through the Website or Application)
     • 1.3.1. Upon creation of Your account and registration on the Platform, we collect the following Information which is mandatorily required for the Applications functionality and performance. This access is enabled at the time You install the Application on Your mobile phone via Google PlayStore and Apple Store or visit the Website.

       S. No.	Data	Purpose	Mandatory/Optional
       1.	Personal Information Name Mobile number Email address	This Information is used for identifying You, preventing unauthorised access, providing the Services, register and enable You to use the Website, and App functionality*	Mobile number and Email id Mandatory Name Mandatory if any Service is availed
       2.	Device Information or other IDs such as log Information (via the domain server through which the User accesses the app search queries, IP address, crashes, date etc), browser details, device Information when You download and install the Application, usage Information, feedback and similar Information. Information the Website collects, and its usage, depends on how You manage Your privacy controls on Your device.	Your Log Information is collected (via the domain server through which the User accesses the Platform Search queries, IP address, crashes, date etc) for the purpose of improvising the Platform functionality, for Identity Verification, Fraud Prevention and app functionality*.	Mandatory
       3.	Application Information Crash logs Diagnostics Other app performance data	The Information related to the performance of the Platform and other diagnostic data is collected for identifying and resolving any technical glitches that may be identified from such Information, data analytics and also for app functionality*	Mandatory

       *The term app functionality means the Information collected for provision of any of the services on, and improving the overall performance of, the KreditBee DLA.

     • 1.3.2. Please refer other Parts of this Privacy Policy for details on other accesses enabled via Google PlayStore, Apple Store and the Website for the respective Services availed by You.
   • 1.4. Consents sought for Profile Creation and Registration (through our Application)

     S. No.	Nature of Consent sought	Purpose	Mandatory/Optional
     1.	Your consent that You have read the terms of our Terms of Use/Terms & Conditions and this Privacy Policy	Profile Creation and Registration Consent type: Recurring	Mandatory
     2.	Consent to access Your Google email Information	Identity verification, Sending communications Consent type: One-time	Optional
     3.	Social Account Information - We may provide You with the option to register using social accounts (Google or Facebook) to access the app and shall collect only such registered email id and user public profile Information like name, email, ASID depending on the platform used by You to log-into the Website during registration/ sign in process for the Services.	We may collect and store email id and name associated with that account for the purpose of verification and to pre-populate relevant fields in the course of Platform interface Consent type: One-time	Optional
     4.	Consent for sending promotional communication via SMS, Email and WhatsApp	Advertisement and Marketing Consent type: Recurring	Mandatory at the time of registration (can be opted out later)

     • 1.4.1. Please refer other Parts of this Privacy Policy for details on other consents taken by the Application for the respective Services availed by You.

2. PURPOSE OF COLLECTION

   • 2.1. We understand the importance of Your Information and as a responsible company, we strive to ensure that it is used for the following intended purposes only. We shall use the Information collected from You for facilitating the Services for the following purposes as detailed below.
   • 2.2. The intended purpose of collecting such Information provided by You is summarized below:

     Used For	Purpose
     Account/profile creation and registration	Your Profile Data is collected to establish/verify Your identity, and to create and verify Your account.
     For Enabling Customer Support	We use Your mobile number and email id (forming part of the Profile Data) to provide customer support, including to facilitate any request, customize Your experience and enforce our terms and conditions, and to resolve Your concerns in relation to Your account.
     Data Analytics	We may use the Profile Data collected to develop automated actions to be triggered in certain events. We may also use the Information collected to offer / recommend new products and services for Your use. We may further measure consumer interest and satisfaction in our products and services and manage Our relationship with You.
     For Enabling Communications Between You and Us	We may add features that enable communications between You, and Us, and may access communications, notifications, Information regarding the products or services requested by You or process queries and applications that You have made on the Application, or for any transaction, promotion activity, marketing and/or commercial communications in relation thereto; We may also be required to disclose the Information under special circumstances such as compliance with the applicable local law, court summons, court orders, requests/order from legal authorities or law enforcement agencies requiring such disclosure.
     For Legal Compliance and Requirements	We will use the Profile Data collected to and detect and protect us against suspicious or illegal activity, fraud, money laundering and other criminal activity, or to investigate, prevent, and take action against illegal activities, conduct forensic audits or investigate / address claims or disputes relating to Your account, or as otherwise allowed by applicable law, or as requested by regulators, government entities, and official inquiries.
     Advertising, Branding and Marketing	We may use the Profile Data collected to market the different products and Services on the Application. This includes sharing Your feedback, ratings and screen names for purely promotion and marketing purposes. We may contact You for marketing and promotional purposes through e-mails, telephones, messages, SMS, WhatsApp or any other available modes and inform You about online and offline offers, products, services, and updates.

3. STORAGE OF PERSONAL INFORMATION:

   • 3.1. We ensure that all information collected by us from You under this Part A including Your mobile number and email address is stored in servers located within India.For account creation and registration purposes, we ensure that no other personal Information belonging to You is collected by us. In case, if any of our representatives ask for the same from You, we request You to kindly refrain from doing the same and address this concern to our Grievance Officer (the details of the same have been provided below).

4. DISCLOSURE TO THIRD PARTIES

   • 4.1. We will share Your Profile Data only on a need-basis with the governmental/regulatory authorities, courts, regulators, law enforcement agencies, quasi-governmental authorities, judicial authorities and quasi-judicial authorities (Governmental Agencies) if any Information is requested from us and we think that disclosure is required or appropriate in order to comply with laws, regulations or legal process. We may share Your Profile Data, as required, upon receipt of notice/communication/ order, as a part of Our legal obligations as per applicable laws as may be sought by the Governmental Agencies. By accepting this Privacy Policy, You hereby provide Your consent to disclose Your personal Information for such regulatory disclosure.
   • 4.2. Further, Your Profile Data will also be shared with Lending Partners and Additional Service Partners (Platform Partners), strictly based on the nature of Services availed by You, and in terms of the policy set out in the respective Part of this Policy, as applicable.
   • 4.3. We will share Your Information under a confidentiality agreement with these Platform Partners and restrict use of the said Information by these Platform Partners specifically for the purposes detailed hereinabove.
   • 4.4. Any disclosure to the Platform Partners is subject to the following:
     • 4.4.1 If we are under a duty to disclose or share Your personal Information in order to comply with any legal or regulatory obligation or request, we shall not seek Your explicit consent nor notify the same to You;
     • 4.4.2 We shall share Your Information with third-party only on a need basis and only for the purpose stated hereunder, as per the applicable laws;
     • 4.4.3 We shall additionally seek explicit consent at appropriate stages of Information collection, if so required under applicable laws; and
     • 4.4.4 Usage of Your Information by such Platform Partnersis subject to their privacy policies. We share Information with them to the extent required. We recommend You to go through the privacy policies of such Platform Partners.

5. DATA RETENTION AND DELETION

   • 5.1. We retain Your Profile Data to provide a seamless experience, to contact You in case of support required and about Your account, to detect, mitigate, prevent, and investigate fraudulent or illegal activities during the course of the Services.
   • 5.2. We retain Your Profile Data from the date of creation of Your account on the Platform (a) for period of 6 (six) years from the last date of submission of Information or inactivity (whichever is later) if You have registered on the Application but not availed any Services; and (b) for a period of 10 (ten) years from the last date of Services availed, or inactivity (whichever is later) if You have availed any of the Services on the Application.
   • 5.3. The Profile Data retained by Us will be subject to Your right to withdraw/deny your consents as per the terms of this Policy and the retention requirements as per applicable laws. Please note, certain Profile Data (such as mobile and email address required for account creation) is mandatory for maintaining an account with us and availing any of the Services on the Application, and hence Your request to delete such Information will be addressed only after closure of all Services availed by You and deletion of Your account on the Platform.

6. OTHER TERMS

   Terms as set-out in Part-E of Privacy Policy shall apply mutatis mutandis to this Part A, to the extent applicable to Profile Data in relation to Your account.

PART B: DIGITAL LENDING SERVICES

1. COLLECTION OF INFORMATION FOR PROVISION OF DIGITAL LENDING SERVICES (DL DATA)

   We only facilitate collection of the DL Data below via the Platform, We do not store any such DL Data collected via the Platform (other than Profile Data as detailed in Part A of this Policy).

   • 1.1. All DL Data collected on the Platform for provision of Digital Lending Services is done through the means of:

     i. Profile Data provided by You as per Part-A of this Policy;

     ii. Data provided during communications with us (for example, by e-mail or chat) in relation to any Digital Lending Services;

     iii. Data, consents and Information that You provide when You subscribe to any Digital Lending Services (such as applying for a loan), search for a loan product, and when You report a problem with any of our Digital Lending Services;

     iv. Data received by us from third parties based on consents given by You under this Part B of Privacy Policy; and

     v. Data generated by Your usage of our Platform while availing Digital Lending Services. The entire collection of DL Data is further detailed below.

   • 1.2. Information collected by the Application from You
     • 1.2.1. The collection of DL Data on the Platform in accordance with this Part-B of Privacy Policy is done for facilitating Digital Lending Services being provided by it in the capacity of a lending services provider (LSP) or digital lending application (DLA) (both terms as defined under the DLD) of the regulated entities who are registered with the RBI and whose details are available on the Website, the Application and application stores (such as Google PlayStore and Apple App Store) (Lending Partners). Please refer Annexure-I for the list of active Lending Partners on the Platform, along with their respective privacy policies and terms and conditions.
     • 1.2.2. The entire collection, processing and storage (to the extent permitted under applicable laws) of DL Data is done on a standalone basis, in accordance with this Part-B of the Privacy Policy and not accessible for any of the other Services set out in other Parts of this Privacy Policy
     • 1.2.3. KreditBees role with respect to Digital Lending Services is limited to facilitating the access of DL Data pertaining to or provided by You on the Platform to our Lending Partners in a secure manner and to ensure that all the recipients of Your personal Information comply with data protection, confidentiality, fidelity and secrecy obligations and duly execute covenants in this regard.
     • 1.2.4. We have indicated in this Part-B the mandatory and the optional fields of Information required from You. You always have the option to not provide any Information by choosing not to use a particular service or feature on the Platform. While You can browse some sections of our Platform without being a registered member as mentioned above, certain activities (such as availing of loans from the Lending Partners on the Platform) require registration and for You to provide the mandatory details.
     • 1.2.5. The personal Information collected by our Lending Partners via the Application, its purpose (summarised below and as further detailed in Para 2 of this Part-B of Privacy Policy) and whether the DL Data to be provided by the User is mandatory or optional is listed below:

     S No.	Data Category	Purpose	Mandatory/Optional
     General
     1.	Personal and Demographic Information including but not limited to Mobile, Email, Name, Gender, DOB, Address, postal code, PAN.	Account Creation, Identity Verification, Customer KYC, Fraud Prevention, Underwriting Enabling Communication and Customer Support, Legal Compliance, Advertisement and Marketing This Information is used for identifying You, preventing unauthorised access and providing the Digital Lending Services to uniquely identify, register and enable You to use the Website. This Information is also used for the purpose of underwriting You in order to determine Your eligibility as part of offer of loan products to You.	Mandatory
     2.	Asset Information	Underwriting and assessing financial repayment capability	Optional
     3.	PAN and Credit Information from Bureaus	Underwriting, Legal Compliance	Mandatory
     4.	Device hardware details Device hardware Information or other IDs such as log Information (via the domain server through which the User accesses the app search queries, IP address, crashes, date etc), device Information when You download and install the Application. Information the Website collects, and its usage, depends on how You manage Your privacy controls on Your device.	Your Log Information is collected (via the domain server through which the User accesses the Platform Search queries, IP address, crashes, date etc) for the purpose of improvising the Platform functionality, for Identity Verification and Fraud Prevention. The Information related to the performance of the Platform and other diagnostic data is collected for identifying and resolving any technical glitches that may be identified from such Information and also for improving the overall functionality of the Website.	Mandatory if applied through the Applications on iOS or Android
     5.	KYC Information	Identity Verification and Fraud Prevention, Legal Compliance	Mandatory
     6.	Geolocation and IP Information	Identity Verification/Customer KYC and Fraud Prevention	Mandatory
     7.	Reference Information including name, number and address of References that You provide to the Lending Partners voluntarily	Identity Verification, Fraud Prevention, and Loan Collection	Mandatory on the Application on Android and the Website. Optional for the Application on iOS.
     8.	SMS and Installed apps Information We collect, store and monitor SMS Information from your device. A list of specific installed applications metadata Information is collected, which includes the application name, package name, installed time, updated time, version name and version code of each installed application on Your device. This Information may be collected even when the application is closed or not in use.	This Information is used to provide You with updates or confirmation of any actions taken during the term of Digital Lending Services, provide customised offers, Identity Verification, Fraud Prevention, Underwriting	Mandatory on the Application on Android. Optional for the Website and Application on iOS.
     9.	Transaction Information	For Enabling the App and its Services, Legal Compliance	Mandatory
     10.	Usage Information	For enabling and enhancing the Digital Lending Services	Mandatory
     11.	Feedback and similar Information	For Enabling the App and its Services	Mandatory
     12.	Risk evaluation score received from payment gateway providers	Underwriting	Mandatory
     Personal Loan
     13.	Employment Information	Underwriting and assessing financial repayment capability	Mandatory for Salaried individuals
     14.	Financial Information	Underwriting and assessing financial repayment capability	Mandatory for Salaried individuals
     Business Loan
     15.	Business Information	Underwriting and assessing financial repayment capability	Mandatory
     16.	Financial Information	Underwriting and assessing financial repayment capability	Mandatory
     Loan Against Property
     17.	Business Information	Underwriting and assessing financial repayment capability	Mandatory if business is disclosed
     18.	Employment Information	Underwriting and assessing financial repayment capability	Mandatory if employment is disclosed
     19.	Financial Information	Underwriting and assessing financial repayment capability	Mandatory
     20.	Property Information	Underwriting and assessing financial repayment capability	Mandatory
     Two Wheeler Loan
     21.	Employment Information	Underwriting and assessing financial repayment capability	Mandatory if employment is disclosed
     22.	Financial Information	Underwriting and assessing financial repayment capability	Mandatory

   • 1.3. Consents sought as part of rendering the Services (through Website or Application)

     Please refer the table below for the Information type that maybe asked by Us (on behalf of Lending Partners) from You on the Platform for providing the Digital Lending Services, as disclosed on the App stores (i.e. Google PlayStore and Apple App Store).

     S No.	Data	Purpose	Mandatory/Optional
     1.	Personal Information Name Email address User id Phone number Address Other info (such as gender and date of birth)	App functionality*, Advertisement and Marketing Profile Data as covered in Part A, and other Personal and Demographic Information as covered under Paragraph 1.2.5	Mobile, Email ID Mandatory (collected as part of Profile Data) Name, User id, Address, and other info (such as gender and date of birth) Mandatory if Part B Services are availed
     2.	Approximate Location	App functionality*, Advertisement and Marketing, Identity Verification/Customer KYC and Fraud Prevention	Mandatory only for Part B Services
     3.	Device hardware details Device hardware Information or other IDs such as log Information (via the domain server through which the User accesses the app search queries, IP address, crashes, date etc), device Information when you download and install the Application. Information the Website collects, and its usage, depends on how you manage your privacy controls on your device.	Your Log Information is collected (via the domain server through which the User accesses the Platform Search queries, IP address, crashes, date etc) for the purpose of improvising the Platform functionality, for Identity Verification and Fraud Prevention, App functionality*, Advertisement and Marketing, Data analytics. The Information related to the performance of the Platform and other diagnostic data is collected for identifying and resolving any technical glitches that may be identified from such data and also for improving the overall functionality of the Website.	Mandatory
     4.	Application Information Crash logs Diagnostics Other app performance data	The Information related to the performance of the Platform and other diagnostic data is collected for identifying and resolving any technical glitches that may be identified from such Information, data analytics and also for app functionality*	Mandatory
     5.	Audio we are not facilitating access to Your device files, other than the audio that You voluntarily record as part of the Digital Lending Services.	Microphone permissions are requested to enable a two-way communication between authorised agents and You for the purpose of performing, completing Your Video KYC, customer grievance and App functionality*	Mandatory for Part B Services
     6.	Photos and videos we are not facilitating access to Your device files, other than photos and videos that you voluntarily take through camera or upload as part of the Digital Lending services.	Camera access is requested to scan and capture the required KYC documents in accordance with applicable laws, and App functionality*	Mandatory for Part B Services
     7.	Financial Information User payment info Purchase history Other financial info (such as e-NACH mandate)	App functionality*, Underwriting, assessing financial repayment capability, for Enabling the Platform and its Services, Legal Compliance	Mandatory for Part B Services
     8.	Other Files and Docs (such as bank statements and GST returns, as may be required for provision of the Digital Lending Services or upload supporting documents when raising a query) - we are not facilitating access to Your device files, other than files that You voluntarily upload as part of the services.	App functionality*, Fraud prevention, security, and compliance, Identity Verification and Fraud Prevention, Legal Compliance, Underwriting and assessing financial repayment capability	Optional for Part B Services
     9.	SMS and Installed apps Information We collect, store and monitor SMS Information from your device. A list of specific installed applications metadata Information is collected, which includes the application name, package name, installed time, updated time, version name and version code of each installed application on Your device. This Information may be collected even when the application is closed or not in use.	This Information is used to provide You with updates or confirmation of any actions taken during the term of Digital Lending Services, provide customised offers, Identity Verification, Fraud Prevention, Underwriting, App functionality*, security, and legal compliance	Mandatory for Part B Services

     *The term app functionality means the Information collected on the Application and Website or provision of any of the Services on, and improving the overall performance of, the Application and Website.

   • 1.4. Consents sought by our Lending Partners as part of rendering Digital Lending Services

     S. No.	Nature of Information/Consent sought	Purpose	Mandatory/Optional
     During registration
     1.	Your consent that (a) You have read the terms of the Terms of Use/Terms & Conditions and privacy policy(ies) of the respective Lending Partners, (b) You consent to us sharing your Information with the Lending Partners as per this Policy, and (c) using the Platform and allowing Lending Partners to collect (via the Platform), process and further share the DL Data as per their policy(ies) for availing the Digital Lending Services.	For availing the Digital Lending Services Consent type: Recurring	Mandatory
     2.	Consent for Digital Lending Partners to send promotional communication via SMS, Email and WhatsApp	For availing Digital Lending Services Consent type: Recurring	Mandatory at the time of availing a Digital Lending Service (can be opted out later)
     Loan Servicing and Disbursement
     3.	Consent for verifying Your PAN on the various PAN databases	Customer KYC Consent type: Recurring	Mandatory
     4.	Consent for increasing Your credit limit (if required) for availing any loan product on the Application.	Customer KYC Consent type: One-time	Optional
     5.	Consent for offline submission of Your Aadhaar	Customer KYC (for submission of paperless Aadhaar and provide Your masked Aadhaar and related Information) Consent type: One-time	Mandatory (if option availed)
     6.	Consent to obtain Your CKYC record from CERSAI for CKYC verification	Customer KYC Consent type: Recurring	Mandatory
     7.	Consent that Your monthly household income is above INR 25,000	Underwriting Consent type: One time	Mandatory
     8.	Consent for acceptance of Terms of Use of KreditBee for completing video KYC	Underwriting Consent type: One time	Mandatory
     9.	Consent for submission of e KYC	Customer KYC Consent type: One time	Mandatory (if option availed)
     10.	Consent for obtaining Your Udyam registration status	Underwriting Consent type: One time	Mandatory (if applicable)
     11.	Consent for availing insurance services	Loan Servicing Consent type: One time	Mandatory (if insurance option availed)
     12.	Consent to fetch Your credit report from credit information bureaus	Underwriting, Loan Servicing Consent type: Recurring	Mandatory
     13.	Consent for obtaining Your SMS Information and installed apps on Your device	Underwriting, Fraud Prevention, Loan Servicing Consent type: Recurring	Mandatory for all Loan Products on Android Application. Optional for iOS Application and Website
     14.	Consent for collecting Your financial Information from account aggregators	Underwriting Consent type: Recurring	Optional
     15.	Consent to access Your Location and IP Information	Customer KYC, Fraud Prevention Consent type: One-time	Mandatory
     16.	Consent to access Your Microphone	Customer KYC, Fraud Prevention Consent type: One-time	Mandatory
     17.	Consent to access Your camera (to share photos of necessary documents)	Customer KYC, Fraud Prevention Consent type: One-time	Mandatory
     18.	Consent to get Your risk evaluation score from payment gateways	Underwriting Consent type: Recurring	Mandatory

2. PURPOSE OF COLLECTION

   • 2.1. We understand the importance of Your Information and as a responsible Application, we strive to ensure that it is used for the following intended purposes only. We shall use the Information collected from You for facilitating the Digital Lending Services for the following purposes as detailed below.
   • 2.2. At various stages during Your loan journey (i.e. from the moment You register on the Platform for availing a Digital Lending Service till the repayment of any loan product availed by You via our Platform), we facilitate collection of different sets of DL Data via the Application. The intended purpose of collecting such Information provided by You is summarised below:

   Used for	Purpose
   Account creation and registration	Your personal Information is collected to establish/verify Your identity, register You as a User of the Platform, and to create and verify Your account.
   Enabling the Application and the Services	We use this Information to enable the Digital Lending Services on the Application and Website, as well as the features on the Application that help You check Your loan and transaction history, and other such Website features as may be added from time to time. This also provides us critical usage Information and feedback Information on the activity on the Platform.
   Supporting Customer KYC, Underwriting, and LoanProcessing	We facilitate collection of the DL Data by the Lending Partners as per this Part-B of Privacy Policy to enable provision of Digital Lending Services on the Platform. All Information collected for supporting customer KYC, underwriting and loan processing activities is used to analyse Your creditworthiness, loan eligibility, KYC documents and current employment verification as per instructions from our Lending Partners and to provide You with the Digital Lending Services i.e. facilitating loans and providing the terms of Your loan by our Lending Partners to You. For this purpose, by installing the Platform and availing the Digital Lending Services, You hereby consent to voluntarily submit KYC documents and other documents/Information to our Lending Partners as further detailed in this Privacy Policy, You further hereby grant the Lending Partners explicit consent to fetch Your KYC (Know Your Customer) details from the Central KYC Records Registry using the details provided by You. You are aware that Your KYC details would be downloaded from the Central KYC Registry, solely for performing customer due diligence on You in order to process Your loan application. You also declare that Your Information on the Central KYC Registry is updated and has not been subjected to any change, as on the date of making the loan application. You further grant Lending Partners explicit consent to validate, process, upload and/ or share Your KYC details and other legally mandated Information with the Central KYC Records Registry. The Lending Partner also use the Information to track disbursement and repayment of Your loan and display the status of the loan on the Application. We have the right to receive the Information from the Lending Partners and facilitate the display on the Application. We may provide Your personal Information to such third parties as listed/linked in this Privacy Policy strictly for facilitating the Digital Lending Services, who may then use such Information in accordance with their privacy policy, which shall include to process such personal Information in order to send You communications to solicit their products or services.
   For Enabling Customer Support	We and our Lending Partners use the Information to provide customer support, including to facilitate any transaction request, customize Your experience and enforce our terms and conditions, and to resolve Your concerns from the use of the services on the Platform (in consultation with our Lending Partners, if required). Further, the contact details (i.e. the phone number) of any references provided by You at the time of loan application may be used for the purpose of establishing contact in case we are unable to contact You, including at the time of collection of instalments based on the instructions of our Lending Partners;
   Data Analytics	We may use the Information collected for analysis, product development to improve the UI/UX experience, and also to analyse how the Platform is used, diagnose service or technical problems and maintain security, troubleshoot problems, monitor, improve and administer our Platform - all of which will ultimately improve how You experience the Platform. This also helps us develop automated actions to be triggered in certain events, such as to identify if photographs uploaded are not clear, occurrence of fraud, incorrect IFSC etc. We may also use the Information collected to offer/recommend new products and services for Your use. We may further measure consumer interest and satisfaction in our products and services and manage Our relationship with You.
   For Enabling Communications Between You and Us	We may add features that enable communications between You, and Us, including through the Platform or other channels, and may access communications, notifications, Information regarding the products or services requested by You or process queries (in consultation with the Lending Partners, if required) and applications that You have made on the Platform, or for any transaction, promotion activity, marketing and/or commercial communications in relation thereto; We may also be required to disclose the Information under special circumstances such as compliance with the applicable local law, court summons, court orders, requests/order from legal authorities or law enforcement agencies requiring such disclosure
   For Legal Compliance and Requirements	We and our Lending Partners may use the Information collected to and detect and protect us against suspicious or illegal activity, fraud, money laundering and other criminal activity, or to investigate, prevent, and take action against illegal activities, conduct forensic audits or investigate / address claims or disputes relating to use of Services (in consultation with the Lending Partners, if required), or as otherwise allowed by applicable law, or as requested by regulators, government entities, and official inquiries.
   Advertising, Branding and Marketing	We and the Lending Partners may use the Information collected to market the Platform/other lending services. This includes sharing Your feedback, ratings and screen names for purely promotion and marketing purposes. We and our Lending Partners may contact You for marketing and promotional purposes through e-mails, telephones, messages, SMS, WhatsApp or any other available modes and inform You about online and offline offers, products, services, and updates.

3. STORAGE OF PERSONAL INFORMATION

   • 3.1. For facilitating the Digital Lending Services on the Application, we only have access to the Profile Data collected and stored as set out in Part A of this Policy.
   • 3.2. For the DL Data that is collected by the Lending Partners on the Application for providing Digital Lending Services, we only facilitate collection of such Information upon the instructions of the Lending Partners and do not store the same.

4. DISCLOSURE TO THIRD PARTIES

   • 4.1. We will share Your Information on a need-basis with the third parties including our regulated financial partners, vendors etc for facilitation of Digital Lending Services on the Platform.
   • 4.2. We will share Your Information with the following categories of third parties and for the purposes as described below:

     S. No.	Party Type	Purpose of Disclosure
     1.	Lending Partners	Analysing transaction behaviour Customer KYC, Identity verification and authentication Loan servicing, monitoring or recovery of loan or managing any activity post availing of lending services. Data analytics Enabling customer Communication Legal compliance Fraud Monitoring Branding and marketing, including ad tracking, campaigns, etc.
     2.	Governmental or regulatory authority	If any Governmental Agency request or require any Information and we think disclosure is required or appropriate in order to comply with laws, regulations, or a legal process, we or our Lending Partners may share such required Information with the governmental authority or law enforcement officers. We shall reach out to the Lending Partners requesting for such Information which is not available with us.

   • 4.3. We will share Your Information under a confidentiality agreement with these third parties and restrict use of the said Information by such third parties specifically for the purposes detailed hereinabove.
   • 4.4. We may share Your personal Information upon receipt of notice/communication/order, as a part of Our legal obligations as per applicable laws as may be sought by the Governmental Agencies. By accepting this Privacy Policy, You hereby provide Your consent to disclose Your personal Information for such regulatory disclosure.
   • 4.5. Any disclosure to the aforesaid third parties is subject to the following:
     a. If we are under a duty to disclose or share Your personal Information in order to comply with any legal or regulatory obligation or request, we shall not seek Your explicit consent nor notify the same to You;
     b. We shall share Your Information with third-party only on a need basis and only for the purpose stated hereunder, as per the applicable laws.
     c. Usage of Your Information by such third parties is subject to their privacy policies. We share Information with them to the extent required. We recommend You to go through the privacy policies of such third parties.

5. DATA RETENTION AND DELETION

   • 5.1. Please refer to Part-A of this Policy for further Information on our retention and deletion policy with respect to Profile Data.
   • 5.2. With respect to DL Data which is collected by the Lending Partners under this Part B, please refer to the privacy policy(ies) and data retention policy(ies) of the respective Lending Partners (available on their websites). In the event of receipt of Your request to modify Your Information /delete any Information which is collected by the Lending Partners, we will communicate the request to such Lending Partners for taking necessary actions as per their respective privacy and data retention policies. You are advised to review the privacy policy and data retention policy of the Lending Partners prior to availing any Digital Lending Services from them.

6. OTHER TERMS

   Terms as set-out in Part-E of Privacy Policy shall apply mutatis mutandis to this Part B, to the extent applicable to DL Data for facilitating Digital Lending Services.

PART C: KREDITBEE UPI SERVICES

1. COLLECTION OF INFORMATION FOR PROVISION OF UPI SERVICE ON THE APPLICATION (UPI SERVICE DATA)

   • 1.1. All UPI Service Data collected on the Platform for provision of UPI services on the Platform (KreditBee UPI Services) is done through the means of:

     i. Profile Data provided by You as per Part-A of this Policy;

     ii. Data provided during communications with us (for example, by e-mail or chat) in relation to the KreditBee UPI;

     iii. Data, consents and Information that You provide when You avail KreditBee UPI Services, and when You report a problem with the KreditBee UPI Services;

     iv. Data received by us from third parties based on consents given by You under this Part C of Privacy Policy; and

     v. Data generated by Your usage of our Platform while availing KreditBee UPI Services. The entire collection of UPI Service Data is further detailed below.

   • 1.2. Information collected by the Application from You
     • 1.2.1. The collection of UPI Service Data in accordance with this Part-C of Privacy Policy is done for facilitating the KreditBee UPI Services on the Platform in partnership with the multiple payment service provider banks (PSP) and the National Payments Corporation of India ("NPCI") for the movement of funds between the sender's and receiver's bank accounts.
     • 1.2.2. The entire collection, processing and storage of UPI Service Data is on a standalone basis, in accordance with this Part-C of the Privacy Policy and not accessible for any of the other Services set out in other Parts of this Privacy Policy.
     • 1.2.3. KreditBees role with respect to KreditBee UPI Services is limited to facilitating the access of UPI Service Data pertaining to or provided by You on the Platform to PSPs and NPCI in a secure manner and to ensure that all the recipients of Your personal Information comply with data protection, confidentiality, fidelity and secrecy obligations and duly execute covenants in this regard.
     • 1.2.4. In addition to Your mobile and email id (forming part of Profile Data) collected for creating Your account, we also collect, store, process and share the following personal Information for facilitating the KreditBee UPI Services:

       S No.	Data Category	Purpose	Mandatory/Optional
       Information
       1.	Bank account Information	Provision of KreditBee UPI Services	Mandatory
       2.	Masked debit card Information	Provision of KreditBee UPI Services	Mandatory
       3.	Masked Aadhaar Information	Provision of KreditBee UPI Services	Mandatory
       4.	Contact Information	Provision of KreditBee UPI Services, Identity Verification and Fraud Prevention	Mandatory
       5.	Device hardware details Device hardware Information or other IDs such as log Information (via the domain server through which the User accesses the app search queries, IP address, crashes, date etc), device Information	Identity Verification and Fraud Prevention	Mandatory
       6.	Transaction Information	For Enabling the App and KreditBee UPI Services, Legal Compliance	Mandatory
       7.	Feedback and similar Information	For Enabling the App and its Services	Mandatory
       Consents
       8.	Your consent to using the Platform and availing the KreditBee UPI Services as per this Privacy Policy, the Security Guidelines (as displayed on the Platform during registration for KreditBee UPI Services) and the UPI Terms and Conditions available on the Website.	For enabling the Application and availing KreditBee UPI Services Consent type: Recurring	Mandatory
       9.	Consent to read and send SMS Information	Identity Verification and Fraud Prevention Consent type: Recurring	Mandatory
       10.	Consent to read phone state	Provision of KreditBee UPI Services Consent type: Recurring	Mandatory
       11.	Consent to monitor UPI usage	Provision of KreditBee UPI Services Consent type: Recurring	Mandatory
       12.	Consent to access Your camera (to share photos of necessary documents)	Provision of KreditBee UPI Services Consent type: Recurring	Mandatory
       13.	Consent for UPI usage	Provision of KreditBee UPI Services Consent type: Recurring	Mandatory
       14.	Consent for linking Your mobile number to receive money	Provision of KreditBee UPI Services Consent type: Recurring	Mandatory
       15.	UPI Lite enablement consent	Provision of KreditBee UPI Services Consent type: Recurring	Mandatory
       16.	UPI International activation consent	Provision of KreditBee UPI Services Consent type: Recurring	Mandatory
       17.	UPI international transaction charges consent	Provision of KreditBee UPI Services Consent type: Recurring	Mandatory
       18.	Consent for sharing Your Aadhaar details	Provision of KreditBee UPI Services Consent type: Recurring	Mandatory
       19.	Consent for adding payment instrument for KreditBee UPI Services	Provision of KreditBee UPI Services Consent type: Recurring	Mandatory

     • 1.2.5. We have indicated in this Part-C the mandatory and the optional fields of Information required from You. You always have the option to not provide any Information by choosing not to use a particular service or feature on the Platform. While You can browse some sections of our Platform without being a registered member, availing the KreditBee UPI Services require registration and for You to provide the mandatory details.
     • 1.2.6. The registration process for availing KreditBee UPI Services is determined by NPCI as per the UPI guidelines as amended from time to time, and requires access to Your mobile network and sending a unique SMS using Your phone to verify, validate, register and link Your bank account on the Platform and create a unique Virtual Account Number (VPA). KreditBee, in the capacity of a third party application provider (TPAP), is responsible for implementing the process as notified by NPCI from time to time, and facilitate UPI based payment transactions on the Platform.
     • 1.2.7. When you register to use KreditBee UPI Services, You provide Your bank's name and confirm the bank account. If you do not have a UPI PIN already for your bank account, you can set one using your partial debit card number, expiry date, PIN (if required by your bank), and bank issued one-time password (OTP) to set up a UPI PIN.
     • 1.2.8. While we obtain Your masked bank account Information, we do not collect Your bank account number linked to Your VPA for facilitating the KreditBee UPI Services or store sensitive personal data such as debit card number, expiry date, PIN, OTP, or UPI PIN). We do not have access to the UPI PIN set by You, as it is encrypted.
     • 1.2.9. When You send, receive, or request payments, You provide or confirm Information about Your transaction, including the receivers name, phone number, KreditBee UPI ID (virtual payment address), payment amount, and currency. To authorize every payment You make, You need to use Your UPI PIN. Further, we automatically also collect UPI Service Data when You send, receive, or request a payment, i.e. the date, time of the transaction, reference transaction number. When the sender makes a payment to a contact, we collect account and transaction Information, including the sender's and receiver's names and KreditBee UPI IDs. This payment transaction Information is handled securely.
   • 1.3.Collection of Information from NPCI and PSP banks
     • 1.3.1. We receive financial Information about You and Your transactions from PSP bank, including Information to confirm Your registration, the payment sender's or receiver's name, account Information and status, balance sufficiency, transaction and account identifiers, risk or fraud alerts, etc. All such UPI Service Data is stored in encrypted format.
     • 1.3.2. Please note that the PSP bank's or NPCI's terms/guidelines for provision of KreditBee UPI Services will govern Your use of their services.
   • 1.4.Consents sought as part of rendering the KreditBee UPI Services (through the Application)

     Please refer the table below for the Information type that maybe asked by Us from You on the Platform for providing the KreditBee UPI Services, as disclosed on the App stores (i.e. Google PlayStore and Apple App Store).

     S. No.	Data	Purpose	Mandatory / Optional
     1	Personal Information Name Email address Phone number	App functionality Account Creation Identity Verification Customer KYC Fraud Prevention Underwriting Enabling Communication and Customer Support Legal Compliance Advertisement and Marketing	Mobile, Email ID – Mandatory (collected as part of Profile Data) Name – Mandatory as returned from UPI registration
     2	Device hardware details Device hardware information or other IDs such as log information (via the domain server through which the user accesses the app) Search queries IP address Crashes Date etc. Device information	Identity Verification and Fraud Prevention	Mandatory
     3	Application Information Crash logs Diagnostics Other app performance data	The information related to the performance of the platform and other diagnostic data is collected For identifying and resolving technical glitches that may be identified from such Information, data analytics and also for app functionality	Mandatory
     4	Photos – We are not facilitating access to your device files Other than photos that you voluntarily take through camera Or upload as part of the KreditBee UPI Services	Camera / photos access is requested To scan and capture or upload required QR codes For facilitating quick payments App functionality	Optional for Part C Services
     5	Contacts – No contact information is shared off the device Other than the phone number of the voluntarily selected contact To which a payment has to be made	App functionality Provision of KreditBee UPI Services	Optional for Part C Services
     6	Other Files and Docs (such as photos as may be required for provision of the KreditBee UPI Services) We are not facilitating access to your device files Other than files that you voluntarily upload as part of the services	App functionality	Optional for Part C Services
     7	SMS and Phone state Permission to send and receive SMS Permission to collect SIM data (phone number, network provider) No SMS information is shared off the device Apart from the UPI registration SMS response received as part of the Registration process.	This Information is used during registration for KreditBee UPI Services for phone/number verification and device binding, Fraud Prevention, App functionality*, security	Mandatory for Part C Services

     *The term app functionality means the Information collected on the Application for provision of the KreditBee UPI Services on, and improving the overall performance of, the Application.

2. PURPOSE OF COLLECTION

   • 2.1. We understand the importance of Your UPI Service Data and as a responsible company, we strive to ensure that it is used for the following intended purposes only. We shall use the Information collected from You for facilitating the KreditBee UPI Services for the following purposes as detailed in the table below.

     Purpose	Manner of Use
     Enabling the Application and the Services	We use the UPI Service Data to enable the KreditBee UPI Services, and operate, provide, improve our KreditBee UPI Services; to protect You and others using KreditBee UPI Services from fraud, abuse, or other misconduct; and to review Your account activity to determine whether You continue to meet our Terms of Service (available at https://www.kreditbee.in/terms-and-conditions).
     For Enabling Customer Support	We use Your personal Information (including mobile and email id shared as part of Profile Data) to provide customer support, including to facilitate any request, customize Your experience and enforce our terms and conditions, and to resolve Your concerns in relation to Your account. We may add features that enable communications between You, and Us, including through the Platform or other channels
     Data Analytics	We may use the Information collected for analysis, and product development to improve the UI/UX experience - all of which will ultimately improve how You experience the Platform. This also helps us develop automated actions to be triggered in certain events, such as occurrence of fraud, etc. We may also use the Information collected to offer / recommend new products and services for Your use.
     For Enabling Communications Between You and Us	We may add features that enable communications between You, and Us, and may access communications, notifications, Information regarding the products or services requested by You or process queries and applications that You have made on the Platform, or for any transaction, promotion activity, marketing and/or commercial communications in relation thereto; We may also be required to disclose the Information under special circumstances such as compliance with the applicable local law, court summons, court orders, requests/order from legal authorities or law enforcement agencies requiring such disclosure.
     For Legal Compliance and Requirements	We may use the Information collected to investigate or address claims or disputes relating to use of KreditBee UPI Services, fraud prevention, investigate, prevent, and take action against illegal activities and conduct forensic audits or as otherwise allowed by applicable law, or as requested by any regulators, Government Agencies, and official inquiries.
     Advertising, Branding and Marketing	We use Your Information to customize, market and improve KreditBee UPI Services, including cross-selling, advertisement/marketing/promotions, providing value-added services and other NPCI approved purposes, and in accordance with applicable law. We may contact You through e-mails, telephones, messages, SMS, WhatsApp or any other available modes in relation to the above or any other aspect pertaining to KreditBee UPI Services availed by You.

3. STORAGE OF PERSONAL INFORMATION

   • 3.1. For facilitating the KreditBee UPI Services on the Platform, we store the personal information as set out in para 1.2.4 of this Part C, along with Profile Data stored in terms of Part A of this Policy. We ensure that the UPI Service Data that we collect and retain is stored in servers located in India and the same is compliance with all the statutory/regulatory obligations.

4. DISCLOSURE TO THIRD PARTIES

   • 4.1. We will share the Information with the following categories of third parties and for the purposes as described below:

     S. No.	Party Type	Purpose of Disclosure
     1.	Payment Senders and Recipients	You and people with whom You send or receive payments may store or reshare Your UPI ID, name, or transaction Information with others on or off Payments.
     2.	Governmental or regulatory authority	If any Governmental Agency or law enforcement officers request or require any Information and we think disclosure is required or appropriate in order to comply with laws, regulations, or a legal process, we, PSP or our service partners may share such required Information with the Governmental Agency or law enforcement officers.
     3.	Service partners	In conformance with our relationship with PSP banks, We work with service providers to provide KreditBee UPI Services to You. We may share Information collected under this Part C of Privacy Policy with identified service providers to send payment instructions to PSP banks; maintain Your transaction history; provide customer support; improve, understand, customize, support, and market KreditBee UPI Services; and keep KreditBee UPI Services safe and secure, including to detect, prevent, or otherwise address fraud, safety, security, abuse, or other misconduct. When we share Information with service providers, we require them to use Your Information on our behalf in accordance with our instructions, terms, and applicable law.
     4.	PSP Banks and NPCI	We share Information with PSP banks and NPCI to help us operate KreditBee UPI Services. The PSP banks and NPCI receive account Information, including Information to authenticate Your account; transaction Information, including payment amount and UPI IDs; country; transaction and account identifiers; Information to detect, prevent, or otherwise address fraud, safety, security, abuse, or other misconduct; and customer support Information. Please note that when You use PSP banks and NPCI services, their own terms and privacy policies will govern Your use of those services.

5. DATA RETENTION AND DELETION

   • 5.1. We retain Your UPI Service Data to provide a seamless experience, to contact you in case of support required and about Your account, to detect, mitigate, prevent, and investigate fraudulent or illegal activities during the course of the KreditBee UPI Services.
   • 5.2. We retain the UPI Service Data from the date of provision of such Information (a) for period of 6 (six) years from the last date of submission of Information or inactivity (whichever is later) if the User has registered on the Application but not availed any KreditBee UPI Services; and (b) for a period of 10 (ten) years from the last date of KreditBee UPI Services availed, or inactivity of the User (whichever is later) if the User has availed any of the Services on the Application.
   • 5.3. The Profile Data retained by us will be subject to Your right to withdraw/deny your consents as per the terms of this Policy and the retention requirements as per applicable laws. Please note, certain Profile Data (such as mobile and email address required for account creation) is mandatory for maintaining an account with us and availing any of the Services on the Application, and hence Your request to delete such Information will be addressed only after closure of all Services availed by you and deletion of Your account on the Platform.

6. OTHER TERMS

   Terms as set-out in Part-E of Privacy Policy shall apply mutatis mutandis to this Part C, to the extent applicable to UPI Service Data for facilitating KreditBee UPI Services.

PART D: ADDITIONAL SERVICES

This Part-D stipulates our privacy policy in relation to the following services (Additional Services) that are made available to You on the Platform:

(A) Digital Gold products (including sale, purchase and leasing of digital gold products), and (B) Any and all other non-lending related services that may be provided on the Platform from time to time.

1. COLLECTION OF INFORMATION FOR PROVISION OF ADDITIONAL SERVICES ("NL DATA)

   • 1.1 All NL Data collected on the Platform for provision of Additional Services is done through the means of:

     i. Profile Data provided by You as per Part A of this Policy;

     ii. Data provided during communications with us (for example, by e-mail or chat) in relation to any Additional Services;

     iii. Data, consents and Information that You provide when You search for or subscribe to any Additional Service, and when You report a problem with any of the Additional Services;

     iv. Data received by us from third parties based on consents given by You under this Part D of Privacy Policy; and

     v. Data generated by Your usage of our Platform while availing Additional Services. The entire collection of NL Data is further detailed below.

   • 1.2 Information collected by the Application from You
     • 1.2.1 The collection of NL Data on the Application in accordance with this Part-D of Privacy Policy is done for facilitating the Additional Services on the Platform in partnership with the relevant third party service providers (Additional Service Partners).
     • 1.2.2 The entire collection, processing and storage of NL Data is on a standalone basis, in accordance with this Part-D of the Privacy Policy and not accessible for any of the other Services set out in other Parts of this Privacy Policy.
     • 1.2.3 KreditBees role with respect to Additional Services is limited to facilitating the access of NL Data pertaining to or provided by You on the Platform to our Additional Service Partners in a secure manner and to ensure that all the recipients of Your personal Information comply with data protection, confidentiality, fidelity and secrecy obligations and duly execute covenants in this regard.
     • 1.2.4 Collection of personal Information by the Application: In addition to Your mobile and email id (forming part of Profile Data) collected for creating Your account, we also collect, store, process and share the following personal Information for facilitating the Additional Services as per the nature of service sought and provide You with customized support in case of issues. Please note that we do not store any personal Information provided by Users for availing the Additional Services except the Information below:

       S No.	Data Category	Purpose of collection and sharing	Mandatory/Optional
       1.	Full name	Enabling Communication and Customer Support, Legal Compliance, Identity Verification	Mandatory if Part-D service availed
       2.	Address and pincode	Enabling requested Additional Services	Mandatory if Part-D service availed
       3.	Date of birth	Enabling requested Additional Services	Mandatory if Part-D service availed
       4.	Gender	Enabling requested Additional Services	Mandatory if Part-D service availed
       5.	Nominee details (i.e. name, gender, date of birth and relation with User)	Nominee selection for requested insurance related Additional Services	Optional

     • 1.2.5 We have indicated in this Part-D the mandatory and the optional fields of Information required from You. You always have the option to not provide any Information by choosing not to use a particular service or feature on the Platform. While You can browse some sections of our Platform without being a registered member as mentioned above, availing the Additional Services require registration and for You to provide the mandatory details.
     • 1.2.6 The personal Information collected and consents sought by our Additional Service Partners via the Application, its purpose (summarised below and as further detailed in Para 2 of this Part-D of Privacy Policy) and whether the NL Data to be provided by the User is mandatory or optional is listed below:

       S. No.	Information collected from You	Purpose and use	Mandatory/Optional
       Information
       1.	Personal and Demographic Information (as listed in para 1.2.4 above)	Legal Compliance, Identity Verification, and Enabling Communication and Customer Support	Mandatory
       2.	Nominee details (as listed in para 1.2.4 above)	Provision of insurance related Additional Services	Optional
       3.	Device hardware details Device hardware Information or other IDs such as log Information (via the domain server through which the User accesses the app search queries, IP address, crashes, date etc), device Information when You download and install the Application. Information the Website collects, and its usage, depends on how You manage Your privacy controls on Your device.	Your Log Information is collected (via the domain server through which the User accesses the Platform Search queries, IP address, crashes, date etc) for the purpose of improvising the Platform functionality, for Identity Verification and Fraud Prevention. The Information related to the performance of the Platform and other diagnostic data is collected for identifying and resolving any technical glitches that may be identified from such Information and also for improving the overall functionality of the Website.	Mandatory if applied through the Applications on iOS or Android or Website
       4.	Transaction Information	For Enabling the App and Additional Services, Legal Compliance	Mandatory
       5.	Usage Information	For enabling and enhancing the Additional Services	Mandatory
       6.	Feedback and similar Information	For Enabling the App and Additional Services	Mandatory
       Consents
       7.	Your consent that You have read the terms of the Terms of Use/Terms & Conditions and this Privacy Policy of the respective Additional Service Partners, and that You consent to using the Platform and collection (via the Platform), processing and further sharing of Your NL Data by the Additional Service Partners to avail the Additional Services as per their policies.	For enabling the Application and availing the Additional Services Consent type: Recurring	Mandatory
       8.	Consent for the Additional Service Partners to send promotional communication via SMS, Email and WhatsApp	For availing the Additional Services Consent type: Recurring	Optional

   • 1.3 Collection of Information from third parties
     • 1.3.1 KreditBee engages lead generation and customer sourcing partners for sourcing, procuring, acquiring Users on the Application for availing any of the Additional Services on the Platform, by way of offline lead generation or system integration through API integration with lead sourcing partners. The nature of personal Information provided by the partners to KreditBee is limited to the Information mentioned in para 1.2.4 above.

2. PURPOSE OF COLLECTION

   • 2.1 We understand the importance of Your Information and as a responsible company, we strive to ensure that it is used for the following intended purposes only. We shall use the Information collected from You for facilitating the Additional Services for the following purposes as detailed below.
   • 2.2 At various stages (i.e. from the moment You register on the Application for availing an Additional Service till the closure of all loan products availed by You), the Additional Service Partners collect different sets of Information via the Application as mentioned above. The intended purpose of collecting Information provided by You is to:

     Purpose	Manner of Use
     Enabling the Application and the Services	We use the NL Data to enable the Additional Services on the Application and Website, as well as the features on the Application that help You check Your transaction history, and other such Website features as may be added from time to time. This also provides us critical usage Information and feedback Information on the activity on the Application.
     For Enabling Customer Support	We use Your personal Information (including mobile and email id shared as part of Profile Data) to provide customer support, including to facilitate any request, customize Your experience and enforce our terms and conditions, and to resolve Your concerns in relation to Your account. We may add features that enable communications between You, and Us, including through the Platform or other channels
     Data Analytics	We may use the Information collected for analysis, and product development to improve the UI/UX experience - all of which will ultimately improve how You experience the Platform. This also helps us develop automated actions to be triggered in certain events, such as occurrence of fraud, incorrect IFSC etc. We may also use the Information collected to offer / recommend new products and services for Your use.
     For Enabling Communications Between You and Us	We may add features that enable communications between You, and Us, and may access communications, notifications, Information regarding the products or services requested by You or process queries and applications that You have made on the Application, or for any transaction, promotion activity, marketing and/or commercial communications in relation thereto; We may also be required to disclose the Information under special circumstances such as compliance with the applicable local law, court summons, court orders, requests/order from legal authorities or law enforcement agencies requiring such disclosure.
     For Legal Compliance and Requirements	We may use the Information collected to investigate or address claims or disputes relating to use of Additional Services, fraud prevention, investigate, prevent, and take action against illegal activities and conduct forensic audits or as otherwise allowed by applicable law, or as requested by any regulators, government entities, and official inquiries.
     Advertising, Branding and Marketing	We may use the Information collected to market the Platform. This includes sharing Your feedback, ratings and screen names for purely promotion and marketing purposes. We may contact You through e mails, telephones, messages, SMS, WhatsApp or any other available modes for marketing purposes or any other aspect pertaining to Additional Services availed by You.

3. STORAGE OF PERSONAL INFORMATION

   • 3.1 For facilitating the Additional Services on the Platform, we store only the personal Information as set out in para 1.2.4 of this Part D, along with Profile Data stored in terms of Part A of this Policy. We ensure that the above Information that we collect and retain is stored in servers located in India and the same is compliance with all the statutory/regulatory obligations.
   • 3.2 The Additional Service Partners on the Application also receive the same Information as stated above for providing the requisite Additional Services. Please refer to the privacy policy of the Additional Service Partner for the manner of storage by such Additional Service Partners as available on their respective websites.

4. DISCLOSURE TO THIRD PARTIES

   • 4.1 We will share Your Information on a need-basis with our third parties including our regulated financial partners, vendors etc. for facilitation of Additional Services on the Platform.
   • 4.2 We will share the Information with the following categories of third parties and for the purposes as described below:

     S. No.	Party Type	Purpose of Disclosure
     1.	Additional Service Partners	For provision of the relevant Additional Service being provided by the Company.
     2.	Governmental or regulatory authority	If any governmental authority or law enforcement officers request or require any Information and we think disclosure is required or appropriate in order to comply with laws, regulations, or a legal process, we, or our Additional Service Partners may share such required Information with the governmental authority or law enforcement officers.

   • 4.3 We will share Your Information under a confidentiality agreement with these third parties and restrict use of the said Information by third parties specifically for the purposes detailed hereinabove.
   • 4.4 We may share Your personal Information upon receipt of notice/communication/ order, as a part of Our legal obligations as per applicable laws as may be sought by the governmental authorities, quasi-governmental authorities, judicial authorities and quasi-judicial authorities. By accepting this Privacy Policy, You hereby provide Your consent to disclose Your personal Information for such regulatory disclosure.
   • 4.5 Any disclosure to aforesaid third parties is subject to the following:

     a. If we are under a duty to disclose or share Your personal Information in order to comply with any legal or regulatory obligation or request, we shall not seek Your explicit consent nor notify the same to You;

     b. We shall take Your express consent in the event we share Your personal Information with third parties;

     c. We shall share Your Information with third-party only on a need basis and only for the purpose stated hereunder, as per the applicable laws.

     d. We shall additionally seek explicit consent at appropriate stages of Information collection, if so required under applicable laws.

     e. Usage of Your Information by such third parties is subject to their privacy policies. We share Information with them to the extent required. We recommend You to go through the privacy policies of such third parties.

5. DATA RETENTION AND DELETION

   • 5.1 We retain the NL Data from the date of provision of such Information (a) for period of 6 (six) years from the last date of submission of Information or inactivity (whichever is later) if the User has registered on the Application but not availed any Additional Services; and (b) for a period of 10 (ten) years from the last date of Additional Services availed, or inactivity of the User (whichever is later) if the User has availed any of the Additional Services on the Application.
   • 5.2 The above personal Information collected by us will be deleted upon receipt of reasonable written request from You in the form specified under this Privacy Policy, subject to retention requirements under applicable law. Please note that we will address a request to modify/delete Your personal Information or revoke any consents only upon closure of all ongoing Additional Services/transaction accounts.
   • 5.3 With respect to NL Data under this Part D which is collected by the Additional Service Partners, please refer to the privacy policy(ies) and data retention policy(ies) of the respective Additional Service Partners. You are required to raise any request to modify Your Information /delete any Information which is collected by the Additional Service Partners directly with such Additional Service Partners for taking necessary actions as per their respective privacy and data retention policies. You are advised to review the privacy policy and data retention policy of the Additional Service Partners prior to availing any Additional Services from them.

6. OTHER TERMS

   Terms as set-out in Part-E of Privacy Policy shall apply mutatis mutandis to this Part D, to the extent applicable to NL Data for facilitating Additional Services.

PART E: MISCELLANEOUS TERMS

The terms set-out below shall apply for any and all Services provided on the Platform.

1. CHANGES IN THIS PRIVACY POLICY

   We reserve the right to change, modify, add, or remove portions of this Privacy Policy at any time for any reason. In case, any changes are made in the Privacy Policy, we shall update the same on the Platform. Once posted, those changes are effective immediately, unless stated otherwise. We encourage You to periodically review this Privacy Policy for the latest Information on our privacy practices. Continued access or use of the Services constitute Your acceptance of the changes to the Privacy Policy.

2. SECURITY PRECAUTIONS

   • 2.1. 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 the Information in digital form. We also require that our registered third-party service providers as listed in this Privacy Policy protect such Information from unauthorized access, use and disclosure.
   • 2.2. 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.
   • 2.3. We comply with all mandatory technology standards, requirements on cybersecurity guidelines stipulated by any regulators /agencies, or as may be specified from time to time, for facilitating any of the Services on the Platform.
   • 2.4. 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.
   • 2.5. In addition, the Website and App have been certified for the following security certifications:

     a. ISO 9001: being the international standard that details requirements for a quality management system (QMS). Organizations use the standard to demonstrate the ability to consistently provide products and services that meet customer and regulatory requirements with the requisite security protections.

     b. ISO 27001 (formally known as ISO/IEC 27001:2005): is a specification for an information security management system (ISMS) and is the suggested level of certification required under the Information Technology Act, 2000. An ISMS is a framework of policies and procedures that includes all legal, physical and technical controls involved in an organizations information risk management processes.

   • 2.6. We aim to protect from unauthorized access, alteration, disclosure or destruction of Information we hold, including:

     a. Encryption to keep Your Information private while in transit;

     b. Security feature like an OTP verification to help You protect Your account;

     c. Review of our Information collection, storage, and processing practices, including physical security measures, to prevent unauthorized access to our systems;

     d. Restricting access to personal Information to our employees, representatives, contractors, and agents who need that Information in order to process it. Anyone with this access is subject to strict contractual confidentiality obligations and suitable disciplinary action taken, in case they fail to meet these obligations;

     e. Compliance & Cooperation with regulations and applicable laws;

     f. Periodic review of this Privacy Policy and make sure that we process Your Information in ways that comply with it;

     g. Compliance with legal frameworks relating to the transfer of Information as mentioned and required under the IT Act, DPDPA, and corresponding rules and the amendments made thereunder; and

     h. Upon receipt of formal/ written complaints, responding by contacting the person who made the complaint. We work with the appropriate regulatory authorities, including local Information protection authorities, to resolve any complaints regarding the transfer of Your Information that we cannot resolve with You directly.

   • 2.7. 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 Information as mentioned and required under the Information Technology Act, 2000, rules and the amendments made thereunder.
   • 2.8. 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 Information that we cannot resolve with You directly.
   • 2.9. The Website and Application have a link to registered third party SDKs, Application Programming Interface (API) integrations, redirections which collects Information on our behalf and Information is stored to a secured server. 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 Information as required under the applicable laws, and employ separation of environments and segregation of duties and have strict role-based access control on a documented, need-to-use basis.
   • 2.10. Our third-party service providers employ separation of environments and segregation of duties and have strict role-based access control on a documented, authorized, need-to-use basis. The stored Information is protected and with application-level encryption. They enforce key management services to limit access to Information.
   • 2.11. 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.
   • 2.12. The Platform links to other websites that may collect Information about You. We are not responsible for the privacy practices or the content of those linked websites. With this Policy we are only addressing the disclosure and use of Information collected by Us. Their Information collection practices, and their policies might be different from this Policy and We do not have control over any of their policies neither do we have any liability in this regard.

3. CONSENT

   • 3.1. You hereby expressly consent to provide the Information that may be required (and for the purposes as specified in this Privacy Policy) in relation to creation of Your account, registration as a user on the Platform and general use of the Platform as per this Privacy Policy.

4. YOUR RIGHTS

   • 4.1. Modifying or rectifying Your Information: In the event that any Profile Data provided by You is inaccurate, incomplete or outdated, You shall have the right to provide Us with the accurate, complete and up to date Information and have Us rectify such Information at Our end immediately. We urge You to ensure that You always provide Us with accurate and correct Information to ensure Your use of Our Services is uninterrupted. In case of modification of Information, Users will be required to furnish supporting documents relating to change in Personal Information for the purpose of verification by the Company.
   • 4.2. Your Privacy Controls: You have certain choices regarding the Information we collect and how it is used:

     a. Your device may have controls that determine what Information we collect. For example, You can modify permissions on Your Android/iOS device or Browser to remove any permissions that may have been given. However, Platform does not provide a guarantee of Services if any such controls are exercised / access is denied.

     b. Delete the App from Your device.

     c. You can also request to remove content from our servers in accordance with Clause below.

   • 4.3. Withdrawal/Denial of consent:
     • 4.3.1 You acknowledge that the Platform has duly collected the Profile Data with Your consent and You have the option to not to provide such Information, or deny consent for use of a specific Information, restrict disclosure by Us to any third parties, deny retention by Us of any of Your Profile Data, or revoke the consent already given for any of the above, and if required, make the Platform/Website delete/forget any such Information. However, any withdrawal of such Your Profile Data will not be permitted in case any Service availed by You is active and such Information is necessary to be retained by Us or service partners until the continuation of such Service.
     • 4.3.2 Where a consent has been withdrawn, the Platform does not guarantee or cannot be liable for providing any of the Services, especially where such Information sought is mandatory for availing such Service. For exercising Your right to withdraw/deny consent as per this clause, please contact us at dataprivacy@kreditbee.in .
     • 4.3.3 Please note, any request for withdrawal/denial of consent or deletion of Your Information will be accepted only after all ongoing/active Services have been completed/closed. Further, upon receipt of any request to update the consents provided by You, or a request to delete/forget any of Your Profile Data as per this clause, We will purge/delete Your Information within 30 (thirty) days of receipt of (a) a written request; or (b) at the end of the tenure of all ongoing Services, whichever is later. In the absence of any such request, we will retain Your Profile Data as per paragraph 5.2 of this Part-A and stipulated under any Applicable Laws. Also, the Information may still be used for execution of any outstanding or termination activity of any Services.
     • 4.3.4 You shall have the following rights pertaining to Your Profile Data collected by us:

       a. Deny Consent: You shall have the right to deny consent for use of specific Information, restrict disclosure to third parties, data retention, revoke consent already granted to collect personal Information and if required, make the App delete/ forget the Information. However, any such denial will not prejudice Our right to retain any Information in relation to any ongoing Services availed by You in terms of this Privacy Policy. Further, in case of a denial of a consent, the Platform does not provide a guarantee or will not be liable towards the continued facilitation of the Services if any such controls are exercised.

       b. Withdraw Consent: You may withdraw Your consent to contact You, for the continued collection, use or disclosure of Your Profile Data, or request for deletion of Your Login account by raising a request on the Platform or by mailing Us at dataprivacy@kreditbee.in. We shall have the right to continue processing Your Profile Data for any Services availed by You. Do note that multiple legal bases may exist in parallel, and We may still have to retain certain Information at any time to comply with applicable law or as otherwise stated under this Privacy Policy.

   • 4.4. Report an issue: You have a right to report a security breach/incident to the grievance redressal officer (GRO) (details mentioned hereinbelow). You are entitled shall be entitled to prevent unauthorised such usage of Your Information by our personnel/ staff / representative agents by informing us immediately / within 10 days of being informed of the proposed use, that You do not wish to disclose such Information. You can also exercise the right at any time by contacting us at dataprivacy@kreditbee.in
   • 4.5. Notwithstanding anything to the contrary stated above, the following are specific scenarios listed below which may have consequences to Your withdrawal of consent:

     a. Marketing and Communication: The consent for this Information is mandatory at the time of account creation and user registration, but can be withdrawn subsequently if You write an email to the email address published on the Platform or avail the Communication Opt-out option on the Platform.

     b. Information deletion may not be implemented for ongoing Services including but not limited to Services cover under the relevant parts.

5. GRIEVANCE REDRESSAL

   • 5.1. For any information regarding the Privacy Policy or grievance relating to collecting receiving, possessing, storing, dealing or handling of personal Information on the Platform, please contact dataprivacy@kreditbee.in or legal@kreditbee.in.

     • You may also contact our Grievance Officer on the following address or write an email:

        

       Grievance Officer

        

       Name: Ms. Asharani
       Address: KrazyBee Services Limited,
       4th Floor, Anjaneya Techno Park, No. 147, HAL Old Airport Road, ISRO Colony,
       Kodihalli, Bengaluru-560008, Karnataka, India
       Email: help@kreditbee.in
       Time: Mon - Sat (10:00 - 19:00)

        

       If You do not receive a response from the Grievance Officer within 14 (fourteen) days of making a representation, or if You are not satisfied with the response received from the Grievance Officer, You may reach the Nodal Officer on the contact details below:

        

       Name: Mr. Abhishek Kumar
       Address: KrazyBee Services Limited,
       4th Floor, Anjaneya Techno Park, No. 147, HAL Old Airport Road, ISRO Colony,
       Kodihalli, Bengaluru-560008, Karnataka, India
       Email: grievance@kreditbee.in
       

   • 5.2. Customers who have availed Digital Lending Services are requested to address all their grievances at the first instance to the following Grievance Redressal Officer:

      

     • Name: Mr. Sauraw Kumar
       Address: KrazyBee Services Limited,
       3rd Floor, No. 128/9, Maruthi Sapphire, HAL Airport Road,
       Murgesh Palya, Bangalore, Karnataka-560017
       Alternate Address: 10th Floor, Plot No E/3, Khata No 612, Infinia Tower,
       Chandrasekhapur, Bhubaneswar, Odisha-751024
       Contact: 080-44292555 / 080-68534555
       Email: grievance@kbnbfc.in

        

       If You do not receive a response from the Grievance Officer within 14 (fourteen) days of making a representation, or if You are not satisfied with the response received from the Grievance Officer, You may reach the Nodal Officer on the contact details below:

        

       Name: Mrs. Chaithra Krishnappa
       Address: KrazyBee Services Limited,
       3rd Floor, No. 128/9, Maruthi Sapphire, HAL Airport Road
       Murgesh Palya, Bangalore, Karnataka-560017
       Contact: 080-44292244 / 080-68534544
       Email: pno@kbnbfc.in
       Principal Nodal Officer may be reached anytime between 10:00 to 19:00 from Monday to Saturday except public holidays or write to the Principal Nodal Officer at the e-mail address above.