PRIVACY POLICY

QFI Technologies Private Limited, CIN No. U74999KA2021PTC145339 (“Company”“Company”, "We", "Us", or "Our"), a private limited company with its registered office at #17/1, Bharat Apartments, 44/1 Fair Field Layout, Race Course Road, Bangalore – 560001, Karnataka, India which owns and operates the website www.niro.money and/or the mobile application ‘the Niro App’ (collectively referred to as the “Platform”) is committed to protecting Your privacy and the information that You share while using the Platform. We value the trust You place in Us. That’s why, We maintain the highest security standards for securing the transactions and Your information.

This privacy policy (“Privacy Policy”) specifies the manner in which personal data and other information is collected, received, stored, processed, disclosed, transferred, dealt with or otherwise handled by the Company. This Privacy Policy does not apply to information that You provide to, or that is collected by, any third-party through the Platform, and any Third-Party Sites that You access or use in connection with the Services offered on the Platform.

Please read the Privacy Policy carefully prior to using or registering on the Platform or accessing any material, information or availing any Services through the Platform.

By visiting the Platform or setting up/creating an Account on the Platform for availing the Services and clicking on the “I accept” button provided on the Platform, You (“You”, “Your” as applicable) accept and agree to be bound by the terms and conditions of this privacy policy (“Privacy Policy”). This Privacy Policy is incorporated into and subject to Our terms of use (“Terms”) and shall be read harmoniously and in conjunction with the Terms. All capitalized terms used and not defined in this Privacy Policy shall have the meaning ascribed to them under the Terms.

This Privacy Policy (i) is an electronic record under the Information Technology Act, 2000 read with rules and regulations made thereunder and is generated by a computer system; and (ii) will not require any physical, electronic, or digital signature.

1. Collection of Information

We collect Personal Information (defined below) from You when You register or set up an Account with Us or avail a financial product on the Platform. You may browse certain sections of the Platform without being registered with Us. However, to avail certain Services on the Platform You are required to set up an Account with Us.

This Privacy Policy applies to the following information:

1. Information You give Us: You may provide certain information to Us voluntarily while registering on Our Platform and creating an Account for availing Our Services, such as name, mobile number, Permanent Account Number (PAN), signature, email address, date of birth, gender, photograph (selfie), marital status, communication and residential address details. We may also require You to provide additional information such as proof of address, residence ownership type, location, annual income, employment type, and source of income, number of years in employment, employer name, employer address, designation, official email address, business name, business address, nature of business, and additional income source, and Aadhaar data to facilitate in evaluation of Your credit profile and creditworthiness by the financial institutions offering or proposing to offer financial products to You.In addition to the above Personal Information, We also collect Your signature and also take Your live video or live selfie photo at the time of sign up for verification purposes. We may also collect other related information such as the date and time of contact with You, the number of attempts and Your availability, for the said verification. The information collected in the course of Your verification shall solely be used for completing the Account opening procedures and authenticating Your transactions on the Platform. The act of providing Your Aadhaar data is voluntary in nature and the Company hereby agree and acknowledge that they will collect, use, and store such details in compliance with applicable laws and this Privacy Policy.

   We may also ask You for certain financial information, including Your bank account details and type, Indian financial system code (IFSC) of bank, and/or other necessary payment related details or other payment method data(for which We will obtain Your explicit consent in accordance with applicable laws, from time to time), and debit instructions or other standing instructions including NACH mandate to process the Services, including facilitating disbursement and repayments towards the availed financial products through the Platform. We may ask You to provide certain additional information about Yourself on a case-to-case basis, subject to obtaining Your explicit consent in accordance with applicable laws. The purposes for which such additional information will be used will be communicated to You at the time of seeking the additional information. All information disclosed by You shall be deemed to be disclosed willingly and without any coercion. No liability pertaining to the authenticity / genuineness / misrepresentation / fraud / negligence of the information disclosed shall lie on the Company nor will the Company be in any way responsible to verify any information obtained from You.

   The above information is collectively referred to as (“Personal Information”).

2. KYC related information: We may retrieve from Your records available with third party including from Know Your Customer (KYC) Registration Agency (KRA) such as name, KYC details, KYC status, father’s/spouse’s name, occupation, address details and other related documents, for completion of Your KYC, which is required by the financial institutions for processing of Your application for availing a financial product.

3. Location based information: When and if You download and/or use the Platform through Your mobile, We explicitly seek permissions from You to get the required information from the device. We may receive information about Your location, Your IP address, and/or Your mobile device, including a unique identifier number for Your device and such other information as may be required for onboarding You on the Platform  (through a one-time permission to access and process such information at the time of onboarding and KYC collection). In addition to the above, We identify and use Your IP address to also help diagnose problems with Our server, resolve such problems and administer the Platform. Your IP address is also used to help identify You and to gather broad demographic information.

4. Access to Camera and Microphone: We require a one-time access to Your camera to scan and capture the required KYC documents thereby allowing Us to auto-fill relevant fields. As a part of facilitation of the KYC process, We require a one-time access to Your camera to enable You to initiate Your KYC process. This permission allows Us or Our authorized agents to perform Your video KYC while also taking screenshots of Your original officially verified documents that You present during Your video KYC. Video KYC enables You to complete Your KYC digitally, smoothly, and efficiently. Your video shall be recorded and retained for regulatory purposes along with the screenshots of original official verified documents. We require a one-time microphone permission to enable a two-way communication between Our authorized agent and You for the purpose of performing and completing Your video KYC. Your audio shall be recorded for regulatory purposes.

5. Access to storage: We require storage permission so that Your KYC and other relevant documents can be securely downloaded and saved on Your phone. You can then easily upload the correct KYC related documents for faster financial product application details filling and disbursal process. This ensures that You are provided with a seamless experience while using the Platform. This is a one-time access and the request for the same would be obtained at the time of sign up.

6. Non–Personal and Automatic Information: We may also collect certain non-personal information, such as system generated user ID and access tokens (“Non - Personal Information”), while You browse, access or use the Platform or have the Niro App installed on your mobile device. We receive Non–Personal Information by the use of data collection devices such as “cookies” on certain pages of the Platform, in order to help and analyze Our web - page flow, track user trends, and promote trust and safety. We place both permanent and temporary cookies in Your computer’s hard drive.

7. User communications:  If You choose to post messages on Our message boards, chat rooms or other message areas or leave feedback, We will collect and store such information You provide to Us. We retain this information as necessary to resolve disputes, provide customer support, respond to queries, and inquires, and troubleshoot problems and improve the Services. If You send Us correspondence, such as emails or letters, or if other users or third parties send Us correspondence about Your activities or postings on the Platform, We may collect and retain such information into a file specific to You for responding to Your request and addressing concerns in relation to Your use of the Platform.

All Personal Information gathered by the Company shall be stored on servers, log files and any other storage system owned by the Company or by third parties in India, and such storage will be need-based and to the extent required to render Services.

While We are responsible under applicable laws in India to ensure completeness, accuracy and consistency of Your Personal Information, We cannot comply with this obligation without Your due co-operation. You acknowledge and agree that You are responsible for ensuring that the Personal Information You provide is accurate, complete and current and that You will co- operate with Us to ensure that such Personal Information is complete, accurate and consistent till such time such Personal Information is processed by Us.

Our primary goal in doing so is to provide You a safe, efficient, smooth, and customized experience on the Platform. The information collected allows Us to provide the Services and features on the Platform that most likely meet Your needs, and to customize the Platform to make Your experience safer and easier. More importantly, while doing so, We collect the above - mentioned Personal Information from You that We consider necessary for achieving this purpose.

As a matter of principle, we do not collect any special categories of Personal Information about You such as details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, information about your health or any genetic information.

We also do not voluntarily or actively collect, use or disclose Personal Information of minors according to the minimum age equivalent in the relevant jurisdiction or of persons with disability, without the prior verifiable consent of the parents or guardians of the minor,as required under applicable laws. If we learn that We have collected the Personal Information of a minor, without first receiving a verifiable parental consent, we will take steps to delete the information in a manner consistent with applicable laws of India as soon as possible.

We also use cookies to allow You to enter Your password less frequently during a session on the Platform. Most cookies are “session cookies,” meaning that they are automatically deleted from Your hard drive at the end of a session. You are always free to decline Our cookies if Your browser permits, although in that case, You may not be able to use certain features or Services being provided on the Platform or You may be required to re-enter Your password each time you log – in or access the Platform during a session.

We may obtain some of Your information including Personal Information from third parties, or from publicly available sources. This Policy shall not apply to any information including Your Personal Information made publicly available by You. The third parties from who We obtain Your information include Our business partners, independent service providers, Our group entities, various merchants, marketplaces, re-sellers, banks, payment partners, payment aggregators, payments systems, payment service providers, financial institutions and from credit reference agencies and credit bureaus on Your behalf etc. You hereby provide Your consent for us to do so subject to the applicable law for the time being in force.

In general, You can browse the Platform without telling Us who You are or revealing any Personal Information about Yourself. In such a case, We will only collect and store the Non – Personal Information. Once You give us Your Personal Information, You are not anonymous to Us. Wherever possible, while providing the information to Us, We indicate which fields are mandatory and which fields are optional for You. You always have the option to not provide the Personal Information to Us through the Platform by choosing to not use a particular Service or feature being provided by Us on the Platform, which requires You to provide such information. We may automatically track certain information about You based upon Your behaviour on the Platform. We use this information to do internal research on Your demographics, interests, and behaviour to better understand, protect and serve You. This information is compiled and analyzed by the Company on an aggregated basis and not individually, in a manner that does not specifically identify You. However, please note that we do not track the behavior of persons who are minors (i.e., persons below the age of 18 years).

You also agree that all the information shared by You with the Company is lawful, true and correct and does not violate or infringe any laws. In case of any violations, infringement, furnishing of wrongful or unauthorized information, the Company shall not be liable to You or to any third party for the same.

You acknowledge that if We determine that any information You have provided or uploaded violates the terms of this Privacy Policy, We have the right, in Our absolute discretion, to delete or destroy such information without incurring any liability to You.

2. Use of information:

We use the Personal Information, other information and Non-Personal Information, for the following:

1. to create Your login credentials or establishing Your Account;
2. to provide and improve the Services and features on the Platform that You request;
3. to resolve disputes and troubleshoot problems;
4. to help promote a safe service on the Platform and protect the security and integrity of the Platform, the Services and the users;
5. to inform You about online and offline offers, products, services, and updates;
6. to analyze Your online behavior to customize and enhance Your experience on the Platform;
7. to share marketing material with You;
8. to detect, prevent and protect Us from any errors, fraud and other criminal or prohibited activity on the Platform;
9. to enforce and inform about Our terms and conditions;
10. to process and fulfil Your request for Services or respond to Your comments, and queries on the Platform;
11. to contact You;
12. to allow Our business partners including partnered financial institutions and/or associates to present customized messages and/or promotional or marketing materials to You;;
13. to enable Us to avail services from third party service providers to enhance and customize Your experience on the Platform;
14. to communicate important notices or changes in the Services provided by the Company, use of the Platform and the terms which govern the relationship between You and Us; and
15. for any other purpose after obtaining Your explicit and unambiguous consent at the time of collection.

You also specifically agree and consent to Us collecting, transferring, and sharing information (including Personal Information) related to You with third parties such as with entities registered under applicable laws, with payment gateways/collecting banks/KRAs etc., for the purposes mentioned above and for providing Services to You including processing Your transaction requests for the Services. The list of third parties with whom We share Your information is available at https://www.notion.so/niro-money/QFI-TECHNOLOGIES-PRIVATE-LIMITED-Third-party-partners-f565b239fa6d4864b28bf52ef38813e6. We will take Your specific consent in case We wish to share Your information with any other third party and update the aforementioned list.

We may occasionally ask You to complete optional online surveys. These surveys may ask You for Your contact information and demographic information (like zip code, age, or income level). We use this information to tailor Your experience at the Platform, providing You with content that We think You might be interested in and to display content according to Your preferences. We use Your Personal Information to send You promotional emails, however, We will provide You the ability to opt-out of receiving such emails from Us. If You opt out, the Company may still send You non-promotional emails, such as emails about the Services and Your Account on the Platform. Unless and until, You explicitly give Your consent to Us, to do so, We will not share Your Personal Information with another user of the Platform and vice versa.

Notwithstanding anything contained herein, the Company may, in compliance with applicable laws in India, process Your Personal Information without obtaining Your consent in the event: (a) the purpose is for fulfilling any obligation under any law for the time being in force in India on any person to disclose any information to the State or any of its instrumentalities, subject to such processing being in accordance with the provisions regarding disclosure of such information in any other law for the time being in force; (b) the purpose is for compliance with any judgment or decree or order issued under any law for the time being in force in India, or any judgment or order relating to claims of a contractual or civil nature under any law for the time being in force outside India; (c) the purpose is for responding to a medical emergency involving a threat to the life or immediate threat to the health of the user or any other individual; (d) the purpose is for taking measures to provide medical treatment or health services to any individual during an epidemic, outbreak of disease, or any other threat to public health; or (e) the purpose is for taking measures to ensure safety of, or provide assistance or services to, any individual during any disaster, or any breakdown of public order.

3. Access and Sharing of Information:

Access to Your Personal Information will be provided to certain of Our employees strictly on a need-to-know basis. We may also disclose Your Personal Information to third party vendors, partnered financial institutions, consultants, and other service providers who work for the Company or provide Services through the Platform and are bound by contractual obligations to keep such Personal Information confidential and use it only for the purposes for which We disclose it to them You agree and explicitly consent to disclosure of Your Personal Information to such third-parties. This disclosure may be required for Us, for instance, to provide You access to Our Services including for undertaking credit assessment by the partnered financial institutions, processing loan or line of credit or rent pay later or any other financial product related applications by the partnered financial institutions, and processing payments including validation of Your bank accounts and Account information, to facilitate and assist Our marketing and advertising activities/initiatives, for undertaking auditing or data analysis, or to prevent, detect, mitigate, and investigate fraudulent or illegal activities related to Our Services, related to Our Services, or to conduct in-person verification in relation to the credit facility availed by You. We do not disclose Your Personal Information to third parties for their marketing and advertising purposes without Your explicit consent.

The Company may disclose Your information, to the extent necessary: (i) to comply with applicable laws and to respond to lawful requests and legal process, (ii) to protect the rights and property of the Company, Our users, and others, including to enforce the Terms, subject to applicable laws and (iii) in an emergency to protect the personal safety and assets of the Company, the users, or any person, subject to applicable laws.. In such an event the Company is in no manner responsible for informing You or seeking Your approval or consent.

We may, in compliance with applicable laws, share/transfer/assign all of Your Personal Information and other information with any other business entity(ies), in the event of a merger, sale, re-organization, amalgamation, joint ventures, assignment, restructuring of business or transfer or disposition of all or any portion of Our business.

4. Security Precautions and Measures:

Our Platform has reasonable security measures and safeguards in place to protect Your privacy and Personal Information from loss, misuse, unauthorized access, disclosure, destruction, and alteration of the information in compliance with applicable laws. Further, whenever You change or access Your Account on the Platform or any information relating to it, We offer the use of a secure server. We cannot however ensure or warrant the security of any information You transmit to the Company or guarantee that Your Personal Information and/or other Non-Personal Information provided for availing the Services or Platform may not be accessed, disclosed, altered, or destroyed by a breach of any of Our security measures and safeguards. In the event of any actual or suspected security incident, including data breach, We will take all measures required to be undertaken under applicable laws. It is further clarified that You have and so long as You access and/or use the Platform (directly or indirectly) the obligation to ensure that You shall at all times take adequate physical, managerial, and technical safeguards, at Your end, to preserve the integrity and security of Your data which shall include and not be limited to Your Personal Information.

5. Links to Other Third – party Sites and collection of information:

Our Platform may provide links to other third - party Platforms (“Third – Party Sites”) that may collect Your Personal Information including Your IP address, browser specification, or operating system. The Company is not in any manner responsible for the security of such information or their privacy practices or content of those Third – Party Sites. Additionally, You may also encounter “cookies” or other similar devices on certain pages of the Third – Party Sites and it is hereby clarified by the Company that it does not control the use of cookies by these Third – Party Sites. These third-party service providers and Third-Party Sites may have their own privacy policies governing the storage and retention of Your information that You may be subject to. This Privacy Policy does not govern any information provided to, stored on, or used by these third-party providers and Third-Party Sites. We recommend that when You enter a Third-Party Site, You review the Third-Party Site’s privacy policy as it relates to safeguarding of Your information. You agree and acknowledge that We are not liable for the information published in search results or by any Third-Party Sites.

6. Public Posts:

You may provide Your feedback, reviews, testimonials, etc. on the Platform on Your use of the Services provided by the Company (“Posts”). Any content or Personal Information and Posts that You share or upload on the publicly viewable portion of the Platform  (on discussion boards, in messages and chat areas, etc.) will be publicly available, and can be viewed by other users. Your Posts shall have to comply with the conditions relating to Use of Platform as mentioned in the Terms. The Company retains an unconditional right to remove and delete any Post or such part of the Post that, in the opinion of the Company, does not comply with the conditions in the Terms. The Company reserves the right to use, reproduce and share Your Posts for any purpose. If You delete Your Posts from the Platform, copies of such Posts may remain viewable in archived pages, or such Posts may have been copied or stored by other Users.

7. Your Consent and Changes to Privacy Policy:

Withdrawal of consent: You may choose to withdraw Your consent (including regarding processing of data by Us or by any third party or regarding data retention) provided hereunder at any point in time. Such withdrawal of the consent must be sent in writing to customer@niro.money. In case You do not provide Your consent or later withdraw Your consent, We request You not to access the Platform and use the Services and also reserve the right to not provide You any Services on the Platform. In such a scenario, the Company may delete Your information (personal or otherwise) unless otherwise required under applicable laws. Further, the Company may also de-identify it so that it is anonymous and not attributable to You.

Managing Your information and Correcting inaccuracies in the information: You may correct or update any information, including Your Personal Information online. You also have a right to (a) ask Us for a summary of Personal Information being processed by Us and the processing activities undertaken by Us with respect to such Personal Information; (b) the identities of all other third-party entities with whom the Your Personal Information has been shared by Us, along with a description of the Personal Information so shared, except when such sharing is pursuant to a written request by such entity who obtains the information for the purpose of prevention or detection or investigation of offences or cyber incidents, or for prosecution or punishment of offences. You have the right to ask Us to correct inaccurate or incomplete or misleading Personal Information concerning You or update Your Personal Information (which You cannot update yourself online) by contacting  customer@niro.money. In the event of loss of access details, You may retrieve the same or receive new access details by sending an e-mail to:customer@niro.money.

Right to Erasure:  This is also known as ‘the right to be forgotten’ and, in simple terms, enables You to request the deletion or removal of Your Personal Information where there’s no compelling reason for Us to keep it. Such right of erasure can be exercised by writing to Us at customer@niro.money. On such a request for erasure, we shall delete all Your Personal Information stored by Us, as well as ensure that any third party service provider processing Your Personal Information on behalf of us deletes all Your Personal Information. This is not a general right to erasure; there are exceptions, such as when the law requires Us to retain certain personal information about You or where such retention is required for providing Our services to You, etc.

Right to Nominate:  You shall have the right to nominate, in a manner prescribed by the Central Government, any other individual, who shall, in the event of Your death or incapacity, exercise Your rights in accordance with applicable law in India. Use of a Consent Manager: You are permitted to give, manage, review or withdraw Your consent provided to the Company to process Your Personal Information through a ‘consent manager’. A consent manager is an entity that is registered with the Data Protection Board. The consent manager is accountable to You and can assist You in providing or withdrawing Your consent to Us to process Your Personal Information, on Your behalf. Such consent managers must comply with the obligations imposed on them as may be prescribed by the Central Government.

Changes To Our Privacy Policy:We reserve the unconditional right to change, modify, add, or remove portions of this Privacy Policy at any time, by notifying You of such changes. Any changes or updates will be effective immediately. You should review this Privacy Policy regularly for changes. You can determine if changes have been made by checking the “Last Updated” legend above.

8. Data Retention and Deletion

We shall be entitled to retain Your Personal Information and other information for such duration as may be required for the purposes specified hereunder or for such other periods as may be required under the applicable laws and the said information will be used by Us only in accordance with this Privacy Policy. Notwithstanding anything contained herein, We will not retain your Personal Information and other information for longer than the periods provided below.

When the retention period for Your Personal Information, KYC-related information, information generated through one-time access to camera and microphone as outlined above expires, We will actively destroy/delete such Personal Information and other information from Our systems.

We will comply with the following procedure for destruction and disposal of Your Personal Information and other information:

1. IT department is responsible for deleting or destroying electronic records. This includes ensuring that the Personal Information and other information is permanently removed and from company system and destroyed.

2. No Personal Information and other information that are currently involved in, or have open investigations, audits, or litigation pending shall be destroyed or otherwise discarded.

3. When retention requirements have been met, Personal Information and other information shall be immediately destroyed.

4. The authorized methods of destruction for non-electronic Personal Information and other information are shredding.

We may, however, continue to retain Your Personal Information in anonymized form for analytical and research purposes.

9. Grievance Officer:

If You have any grievance with respect to the Platform or the Services, You may write to the grievance officer, the name and contact details have been provided below:

Name: Sankalp Mathur
Email: grievance@niro.money
Address: 313/1, Workden, Ground Floor, 7th Cross, Patel Rama Reddy Road, Domlur Layout Bengaluru 560071

We will resolve Your concern in an efficient and timely manner, and in a manner compliant with applicable laws in India.

In the event You have exhausted Your opportunity of redressing your grievances with respect to Your Personal Information through the grievance officer, You may raise Your concern to the Data Protection Board of India in the manner prescribed under applicable laws in India.

While you have the right to raise complaints with both the Company and the Board, please note, registering of false or frivolous complaints with the Data Protection Board is a punishable offence.

10. Questions?

Please feel free to contact Us at enquiry@niro.money regarding any questions on the Privacy Policy.