1. INTRODUCTION

Keish Commerce Private Limited (hereinafter referred to as “Credo Cash/ we/ our”) acknowledges the expectations of its customers (hereinafter referred to as “customer/ you/ your”) regarding privacy, confidentiality and security of personal information that resides with the Credo Cash. Keeping personal information of customers secure and preventing any misuse thereof, is therefore, a top priority of Credo Cash.

We state that Credo Cash is strongly committed to protect the privacy of its customers and has taken all necessary and reasonable measures in line with applicable laws and regulations as well as the best industry practice to protect the confidentiality of your personal information and its transmission through our website.

This Privacy & Security Policy (hereinafter referred to as “Policy”) therefore, explains how we protect your personal information provided to us on our website i.e. www.credocash.com (hereinafter referred to as “Website”) and how we use that information in connection with the service o ered through the Website (hereinafter called as "Service") and must be read in conjunction with our Terms of Use.

This Policy is published and shall be construed to be in accordance with the provisions of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data of Information) Rules, 2011 under the Information Technology Act, 2000 and other applicable laws and regulations that require publishing of the privacy notice for collection, usage, storage, disclosure and transfer of sensitive personal data or information.

2. PERSONAL INFORMATION

Personal Information (“PI”) means any information/ documents/ details that relates to a natural person, which either directly or indirectly in combination with other information available with Credo Cash, can identify such person.

3. APPLICABILITY

(i) This Policy applies to the PI such as details pertaining to your name, parentage, marital status, nationality, state/city of residence, residential address, e-mail address, date of birth, gender, contact number/mobile number, user ids, passwords, recent photograph, signature image, income proof, PAN, credit score, credit information report, e-KYC through UIDAI, Aadhaar based e-Sign and such other Know Your Customer (KYC) documents like address proof, identity proof, officially valid documents/details (OVDs) accepted for concluding a financial transaction, which may be shared/ uploaded by you, as and when you avail any products or use the Website and to which Credo Cash may become privy to.

(ii) By visiting and/or using our website, you agree to this Policy. Further, this policy applies to all current and former visitors to the Website. It is strongly recommended for you to return to this page periodically to review the most current version of the Policy.

(iii) Credo Cash reserves the right at any time, at its sole discretion, to change or otherwise modify the Policy without prior notice, and your continued access or use of this Website signifies your acceptance of the updated or modified Policy.

4. WHAT PERSONAL INFORMATION ABOUT YOU WE GATHER

The information we learn from customers helps us personalize and continually improve your experience at the Website.

Here are the types of information we gather:

• We receive and store any information you enter on our website or give us in any other way. You can choose not to provide certain information but then you might not be able to take advantage of many of our services and features.


• We might receive information about you from other sources and add it to our account information.


• The LSP declares strict adherence to privacy by avoiding access to sensitive mobile resources, ensuring borrowers' consent management, refraining from biometric data storage, and maintaining data exclusively on India-based servers in compliance with statutory regulations.

How do We Use the Information:

Credo Cash collects your information when you register for an account, when you use its products or services, visit its website’s pages. When you register with the Website and sign in you are not anonymous to us. Also, you are asked for your contact number and other details during registration and may be sent SMS, electronic mails (“e-mails”), IVR, notifications, WhatsApp messages about our services to your wireless device.

5. EXPRESS CONSENT

(i) By making use of the Website, and furnishing your personal and contact details, you hereby agree that you are interested in knowing more or availing and/or purchasing various products, services, offers, campaigns or other promotional material that Credo Cash or any other third party may oUer/provide/share/send you from time to time through any means including but not limited to telephone, SMS (short messaging service), IVR, electronic mail (e-mail), WhatsApp or any other messaging service/mobile application or any other physical, electronic or digital means/mode . You hereby agree that Credo Cash may contact you either electronically or through phone, to understand your interest in the selected products and Services and to fulfil your demand or complete your application. Further you also expressly agree and authorize Credo Cash and its partners, service providers, vendors and other third parties to contact you for the purpose of offering or inviting your interest in availing other products or services oUered by third parties, or for sending other marketing campaigns, offers, or any other information either on the Website or through other means including but not limited to telephone, SMS (short messaging service), IVR, electronic mail (e-mail), WhatsApp or any other messaging service/mobile application or any other physical, electronic or digital means/mode. You agree and authorize Credo Cash to share your information with its group companies, vendors, service providers, business partners, agents and other third parties, in so far as required for marketing purposes/oUering/cross-selling various other products and services and/or to provide you with various value-added services, in relation with the Services selected by you or generally otherwise. You agree to receive communications through emails, telephone, IVR, WhatsApp, SMS, or any other form of messaging/communication service from Credo Cash or such third parties. You also agree that Credo Cash reserves the right to make your details available to its partner banks/financial institutions or any such other third party and that you may be contacted by the partners and/or the third party for information through email, telephone, IVR, WhatsApp and/or SMS.

(ii) The usage of the Website may also require you to provide consent for keying in your Personal Information (“PI”) (including but not limited to any personal data or sensitive personal data as defined under applicable law) or to authorize Credo Cash to derive your data/information from any other source or public registry, as may be necessary to complete your profile or your application on the Website, conduct due diligence on you, assessing your eligibility for the products/services, undertaking know-your-customer (“KYC”) checks by Credo Cash or any other third party and/or to process your application through this Website. Your PI may also be used or shared with third parties including but not limited to our vendors, service providers, credit information agencies, analytics and research partners, other banks or financial institutions, insurers or intermediaries or any other third party with the intent of making your experience on the Website better, faster and paperless and frictionless to the extent possible. Credo Cash shall adhere to best industry practices including information security, data protection and privacy law while processing such applications. However, Credo Cash shall not be liable to you against any liability or claims which may arise out of such transactions as any such PI is being collected, used, processed and shared with your explicit consent.

(iii) You hereby authorize and expressly consent us to share your PI with third parties including but not limited to Credit Information Companies (“CIC”) to do an aggregate check of your credit profile for Credo Cash to send you targeted communications and offers.

(iv) If you are no longer interested in sharing your PI, please e-mail your request at: help@credocash.com. Please note that it may take about 72 business hours to process your request. In furtherance to your usage of the Website, you expressly waive the Do Not Call (DNC) / Do Not Disturb (DND) registrations on your phone/mobile numbers for contacting you for such purpose and usage. Hence, there will be no DNC / DND check required for the number you may have left on our website. Such modes of contacting you may include sending SMSs and/ or telephonic calls.

(v) Credo Cash reserves the right (and you expressly authorize Credo Cash) to share or disclose your PI when Credo Cash determines, in its sole discretion, that the disclosure of such information is necessary or appropriate under the law for the time being in force.

6. CREDIT INFORMATION REPORT

(i) Your Credit Information (credit score and credit information report) is procured through a 'hard search' of your credit records with Credit Information Companies “CICs”, and Credo Cash has no control over the content or accuracy of information provided in your credit information by CICs. Credo Cash gets this information from CIC for and on your behalf only when you agree to appoint Credo Cash as your lawfully appointed authorized agent/ representative for collecting your credit information from CICs. By consenting to use and avail your credit information report through Credo Cash, you agree that Credo Cash and CICs shall be entitled to rely on your authorization and consent granted by you to Credo Cash.

(ii) Availing your credit information through Credo Cash is subject to your passing of appropriate identity authentication for security and privacy purposes. Credo Cash shall not notify you the reasons if you are unable to pass such identity authentications and not able to view and/or use your credit information.

(iii) Credo Cash may analyze and profile your credit information in order to assist you in being better informed about, understand and manage your credit score/rating, identify and inform you of credit products that are likely to be suited to your circumstances, to identify whether you may benefit from additional guidance concerning your credit score and steps you can take to improve your score and credit history etc.

7. OPT-OUT

• In case you do not want to be disturbed over telephonic calls, kindly email us with details of the telephone number(s) on which you do not wish to be contacted and submit the same at help@credocash.com from your email address registered at Credo Cash. The details that you provide through the opt-out email will remain confidential and once you have submitted the same to us, your telephone number(s) will be removed from all our telemarketing calling lists within 15 working days. We will make every eUort to ensure that you do not get any further telemarketing calls on such telephone number(s).


• If borrowers want to delete their data partially or completely, they can email help@credocash.com

8. PURPOSE AND USAGE

(i) Credo Cash will not sell or rent your PI to anyone for commercial purposes to anyone in a way that is contrary to the commitments made and/or other than as set forth in this Privacy Policy. Notwithstanding the foregoing, we may share your information to an aUiliate and/or business partner. Credo Cash may also share, sell, and/or transfer your personally identifiable information to any successor-in-interest as a result of a sale of any part of our business or upon the merger, reorganization, or consolidation of it with another entity on a basis that it is not the surviving entity. As used in this Privacy Policy, the term "Person" includes any natural person, corporation, partnership, limited liability company, trust, unincorporated association, or any other entity). We limit the collection and use of your personal information. We may make anonymous or aggregate personal information and disclose such data only in a non-personally identifiable manner. Such information does not identify you individually. Access to your account information and any other personal identifiably information is strictly restricted and used only in accordance with specific internal procedures, and for the purposes set out in this Privacy Policy, in order to operate, develop or improve our services. We may use third party service providers to enable you to provide with our services.

We may also share your information, without obtaining your prior written consent, with government agencies mandated under the law to obtain information for the purpose of verification of identity, or for prevention, detection, investigation including cyber incidents, prosecution, and punishment of oUences, or where disclosure is necessary for compliance of a legal obligation. You agree and consent for the Website to disclose your information, if so required, under applicable law.

There are number of products/services such as loans, credit cards, mutual funds, oUered by third Parties on the Website, such as lenders, banks, credit card issuers. If you choose to apply for these separate products or services, disclose information to these providers, then their use of your information is governed by their privacy policies in addition to the Privacy Policy of the Website. Credo Cash is not responsible for their privacy policies. We encourage you to visit and read about the privacy notices and procedures adopted by these third parties/providers, when you apply for their products or services.

Further Credo Cash may use your information to:

1. Communicate with you about products, services and promotional oUers oUered by Credo Cash or by its business partners, or other third parties


2. Assist third parties like our business partners and/or service providers in facilitating and delivering products and services to you, process payments and your applications


3. Send you any administrative notices, oUer alerts and other communications relevant to your use of the Website.


4. Display tailored product oUers to you and enable you to apply for certain products and services.


5. Send you information about special promotions or oUers oUered by Credo Cash or any of its business partners. We might also tell you about new features or products/services. These might be our own oUers or products/services, or third-party oUers or products/services with whom Credo Cash has a tie - up


6. Carry market research, project planning, troubleshooting issues, detecting and protecting against error, fraud or other criminal activity.


7. Improve our Services and manage our customer relationships better, and to provide you with location-based services, such as advertising, search results, and other personalized content.


8. Enforce Credo Cash General Terms of Use.


9. Comply with all applicable laws and regulations.

You also agree and consent to us collecting, storing, processing, transferring and sharing information (including sensitive personal information) related to you with third parties or service providers for the purposes as set out in this Privacy Policy.

(ii) In the event that you access the Service as brought to you by one of our partners either through the Website or on being redirected from a co-branded URL or any other website , your name, e-mail address, mobile number, date of birth, employment type, residency status, income details/proofs, Form 26 AS, PAN, details of loan / credit card/ mutual fund applied for and loan, credit card and mutual fund status or any other financial product status may be provided to that partner when your application is submitted and whenever the status of application is updated. Credo Cash has a business relationship with these partners, and you may not opt-out of sharing your information with these partners if you have applied via a co-branded URL or any other website or directly through the Website as the case may be.

(iii) For availing the Service such as applying for credit information report, loan, credit card, mutual fund or any other financial product we will require you to provide/upload on the Website the details such as a your name, parentage, marital status, email address, nationality, location, mobile number, PAN, employment & income details/proofs, Form 26 AS, recent photograph, signature image, other Know Your Customer (KYC) documents like address proof, identity proof and personally identifying information about a potential coloan applicant (should you select this option), and to participate on our forum boards, you must provide a username for yourself.

(iv) You may opt out of location-based services at any time by editing the setting of your browser.

(v) In order to provide your bank statement or pay slip electronically along with your loan application, you also must provide your third-party account credentials ("Account Credentials") to allow Credo Cash to retrieve your account data at those other financial institutions ("Account Information") for your use. Your Account Credentials are only used once to retrieve your bank statements/pay slips, Form 26 AS and are not stored in our system. Credo Cash shall not be liable to you against any liability or claims which may arise out of such transactions being carried on your own accord.

(vi) We may also use third party service providers to provide the Service to you, such as sending e-mail messages on our behalf or hosting and operating a feature or functionality of the Service. Our contracts with these third parties outline the appropriate use and handling of your information and prohibit them from using any of your PI for purposes unrelated to the product or service they're providing. We require such third parties to maintain the confidentiality of the information provide to them.

9. DISCLOSURE / SHARING

(i) Credo Cash does not disclose PI of a customer except as directed by law or as consent received from the customer/applicant. No specific information about customer accounts or other personally identifiable data is shared with third parties unless any one of the following conditions is met:

1. To help complete a transaction initiated by you.


2. To perform support services through a third-party service provider, provided it conforms to the Privacy Policy of the Credo Cash.


3. You have specifically authorized it by accepting the General Terms of Use of the Website or otherwise.


4. Where the disclosure is necessary for compliance of a legal obligation or as required by law, such as to comply with a subpoena, or similar legal process.


5. When we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.

(ii) There are number of products/services such as loans, credit cards, mutual funds, oUered by third Parties on the Website, such as lenders, banks, credit card issuers. If you choose to apply for these separate products or services, disclose information to these providers, then their use of your information is governed by their privacy policies. Credo Cash is not responsible for their privacy policies. Credo Cash may share your data with other third parties, such as service providers, advertisers, Credit Information Companies, fraud prevention agencies, marketing channels, aUiliates, without the need for additional consent from you.

(iii) Credo Cash shall not be held liable for disclosure of the PI when used in accordance with this Privacy Policy or in terms of the ‘General Terms of Use’ of Website or an agreement, if any, with the users of Website.

10. INTIMATION BY CUSTOMERS REGARDING CHANGE IN PERSONAL INFORMATION

(i) If your PI provided to us when you had applied for a product on our website changes, you may update it whenever you apply for a new product via our website. To review and update your PI and to ensure that the same is accurate while your application is in process, you may contact us at help@credocash.com. You will not be able to update the information you have provided in an application after a decision has already been made on it; however, you may create and submit a new application with your updated information.

(ii) Note: We will retain your information for as long as your account is active or as needed to provide you services. If you wish to cancel your account or request that we no longer use your information to provide you services, contact us at help@credocash.com. We will respond to your request within a reasonable timeframe. However, we will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and to enforce our agreements.

11. RETENTION OF YOUR DATA

(i) Credo Cash will retain your information for providing you the Services available on the Website or your request for termination of your account with Credo Cash, whichever is later.

(ii) Post termination of your account, Credo Cash may continue to use your anonymized data aggregated or in combination with anonymized data of other users. We use this aggregated anonymized data for data analysis, profiling and research purposes, for example to gain insights about our users and their profiles. We may keep your contact information along with your application details (if any) for fraud prevention purposes and for the exercise/defense of a legal claim or for providing evidence in legal proceeding(s).

12. EMAIL & SMS COMMUNICATIONS FROM US AND OUR PARTNERS

We provide our registered customers with periodic phone calls, IVR, emailers and email/SMS/WhatsApp alerts. We also allow users to subscribe to email newsletters and from time to time may transmit emails promoting Credo Cash or third-party products. Subject to the express consent clause above, Credo Cash’s Website subscribers may optout of receiving our promotional emails and terminate their newsletter subscriptions by following the instructions in the emails. Opting out in this manner will not end transmission of service-related e-mails/SMS/IVR/WhatsApp, such as e-mail/SMS alerts. The above services are also provided by our partners.

13. LOG FILES

This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We may use the collected log information about you to improve services oUered to you, to improve marketing, analytics, or Website functionality.

14. TRACKING TECHNOLOGIES

Credo Cash and its partners use cookies or similar technologies to analyze trends, administer the website, track users’ movements around the website, and to gather demographic information about our user base. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our website or service.

15. BEHAVIOURAL TARGETING / RE-TARGETING

We partner with a third-party service provider to either display advertising on our website or to manage our advertising on other websites. Our third-party partner may use technologies such as cookies to gather information about your activities on this Website and other websites in order to provide you advertising based upon your browsing activities and interests.

16. THIRD PARTIES WILL NOT BE GIVEN YOUR PERSONAL INFORMATION UNLESS YOU GIVE CONSENT TO CREDO CASH

There are several products and services, such as credit information report, loans, credit cards, mutual fund and other financial products being oUered by third parties on our website, such as lenders, banks, credit card issuers and mutual funds (collectively "OUers"). 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 services providers before deciding to use their services. Credo Cash is not responsible for their privacy practices.

17. TESTIMONIALS, BLOGS AND OTHER FORUMS ON CREDO CASH WEBSITE:

(i) With your consent Credo Cash may post your testimonial along with your name. If you want your testimonial removed, please contact Credo Cash at help@credocash.com.

(ii) If you use a blog, comments section or other public forum on Website, any information you submit there can be read, collected or used by other users and could be used to send you messages. Credo Cash shall not be held responsible for the PI you choose to submit in these forums.

18. ADDITIONAL POLICY INFORMATION

(i) Widgets: Our website includes widgets, which are interactive mini programs that run on our website to provide specific services from another company (e.g. displaying the news, opinions, music, etc.). PI, such as your email address, may be collected through the widget. Cookies may also be set by the widget to enable it to function properly. Information collected by this Widget is governed by the privacy policy of the company that created it and not by the Credo Cash.

(ii) Single Sign-On: You can log in to our website using sign-in services such as Facebook Connect or an Open ID provider. These services will authenticate your identity and provide you the option to share certain PI with us such as your sign-in information, name and email address to link between the sites. Social networking media services like Facebook & Twitter give you the option to post information about your activities on this Website to your profile page to share with others within your network.

(iii) Like Button: If you use the "Like" button to share something that item will appear on your Facebook profile page and on your friends’, newsfeed depending on your Facebook privacy settings. You may also receive updates in your Facebook newsfeed from this Website or item in the future. Facebook also collects information such as which pages you have visited on this and other sites that have implemented the "Like" button.

(iv) Links to 3rd Party Sites: Our Website includes links to other websites whose privacy practices may diUer from those of Credo Cash. If you submit your PI to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any website you visit.

19. WE KEEP YOUR DATA SECURE

(i) We follow generally accepted standards to protect the PI submitted to us, both during transmission and once we receive it. Since no method of transmission over the Internet, or method of electronic storage, is 100% secure, therefore, we cannot guarantee its absolute security. If you have any questions about security on our website, you can contact us at help@credocash.com

(ii) We use a combination of firewalls, encryption techniques and authentication procedures, among others, to maintain the security of your online session and to protect Credo Cash online accounts and systems from unauthorized access.

(iii) When you register for the Service, Credo Cash requires a password from you for your privacy and security. Credo Cash transmits information such as your login credentials for Website or Account Credentials securely.

(iv) Our servers are in secure facilities where access requires multiple levels of authentication, including an identity card and biometrics recognition procedures. Security personnel monitor the facilities 7 days a week, 24 hours a day.

(v) 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.

(vi) We enforce physical access controls to our buildings. No employee can put PI on any insecure machine (i.e., nothing can be taken from the database and put on an insecure laptop). We permit only authorized employees who are trained in the proper handling of customer information, to have access to aforesaid PI.

(vii) Credo Cash has been verified for its use of SSL encryption technologies. In addition, However, it is important to understand that these precautions apply only to our website and systems.

20. ALL PRIVATE INFORMATION IS ENCRYPTED AND COMMUNICATED SECURELY

All communications between your computer/mobile and our website that contain any PI are encrypted. This enables client and server applications to communicate in a way that is designed to prevent eavesdropping, tampering and message forgery.

21. YOU ARE RESPONSIBLE FOR MAINTAINING THE CONFIDENTIALITY OF YOUR LOGIN ID AND PASSWORD

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

(ii) If you have any security related concern, please contact us at help@credocash.com. We will work closely with you to ensure a rapid and personal response to your concerns.

22. CONTACT US WITH ANY QUESTIONS OR CONCERNS (GRIEVANCE REDRESSAL)

If you have grievance or complaint, questions, comments, concerns or feedback in relation to the processing of information or regarding this Privacy and Security Policy or any other privacy or security concern, send an e-mail to help@credocash.com