PLEASE READ THIS POLICY CAREFULLY BEFORE USING THE APP

POCKETWISE PRIVACY POLICY PLEASE READ THIS POLICY CAREFULLY BEFORE USING THE APP

This privacy policy (“Policy”) explains how PocketWise Technologies Limited (formerly known as PocketWise Technologies Private Limited) having its registered office at Shop No 62, Level 2, Forum Value Mall, Whitefield Main Road, Whitefield, Bengaluru, Karnataka 560066 (“our”, “us”, “we”, “Company”, “PocketWise”), and our Partners (identified below) collect, store, use, transfer and otherwise process your personal data, for providing you the Services (defined in the Terms of Use, available here) through the PocketWise Technologies mobile application (“App”).

To provide you (and any co-applicants) with loan services through the PocketWise app, we (the Company) need to collect certain data and information from you with your prior and explicit consent.

By setting up an account on this App, you agree to the processing, storage, usage and sharing of the data provided by you pursuant to this Policy. We may revise this Policy as well as update the Services and the App from time to time, so please keep visiting this page regularly to take notice of any changes we make. If you do not agree with any part of this Policy, please stop using our Services immediately. Please also read our Terms of Use (“Terms”), which describe the terms under which we provide our and our Partner’s Services and the terms under which you can use our and our Partner’s Services.

We are a part of the PocketWise Group of companies. You can learn more further below in this Policy about the ways in which we share information across this group of companies. This Policy applies to all our Services unless specified otherwise. Do note that if you avail any services from PocketWise Finserv Limited, through the (i) Cash Loan App, please refer to their Cash Loan App terms of use and privacy policy and (ii) Home Loan App, please refer to their Home Loan App terms of use and privacy policy. We also process data as a lending service provider of PocketWise Finserv Limited. Do note that the collection, use, storage, processing of your data by PocketWise Finserv Limited (and sharing with, and processing by, PocketWise Finserv Limited’s service providers) is governed solely by their privacy policy, terms of use, and other agreements executed between you and PocketWise Finserv Limited or their co-lending partners.

This Policy incorporates and includes our Terms and the Agreement(s) executed by you (and co applicants, members, nominees, if any) for availing our Services and our Partners’ Services. Words and phrases not defined in this Policy shall mean the same as provided in the Terms. All references to you (as a user/visitor) shall include references to all co-applicants, covered members or nominees, joint investors, if any.

SECTION 1: COMPANY AND COMPANY SERVICES

By registering and setting up an account on the App (“PocketWise Account"), you agree to the processing, storage, usage and sharing of the data provided by you pursuant to this Policy.

1.WHAT DATA IS COLLECTED?

Summary: We collect certain information provided by you, some of which is sensitive personal information. We have detailed what data and the manner in which this data is collected. By using the App, you consent to provide us, with prior and explicit consent, data in the ways listed below.

S. No. Means of Gathering Data Data Collected

1. Data collected during sign-up to use our Services PocketWise Account Data: We collect the data you provide us when you create or update your PocketWise Account. This may include your name, phone number, email ID, date of birth, pin code, PAN. We may require you to share further information on a later date to confirm the veracity of your information or pursuant to any additional features added to the App. You accept that we collect and verify, inter alia, your name, date of birth, and PAN for the purposes of onboarding, undertaking fraud checks and that we will share these details with our Affiliates and Partners for providing you with services.

How we use this data: See, For Enabling the App and its Services; For Enabling Customer Support; For Research and Development; For Enabling Communications Between You and Us; For enabling Marketing and Outreach; For Automated Decisions; For Legal Compliance and Requirements. Feedback Data and Other Data: We may collect your feedback data or other data. This includes the following: If you call our call centers, we may record information provided by you to service you or record the calls for quality and training purposes. Data you input when you participate in our referral programs or use any discount codes offered by us. This information collected includes the name and email address of the person you have referred, and we will send the referred person a one-time email inviting them to visit the App. If you provide any feedback or comments to us on the App or as part of our research programs for improving the App or through any survey conducted by PocketWise or any other mode of offline interactions.

How we use this data: See, For Enabling the App and its Services; For Legal Compliance and Requirements.

2. Data we collect from your usage of our Services Geolocation data: We collect the location data from you in two ways: (i) when you add the pin code as part of your PocketWise Account data; and (ii) from your mobile device when enabled by you to do so. We use this data to assess servicing of products to you.

User Personal Information: Our App collects user account data which includes email address, name to log in to the app. This information is required as part of the registration process to access our service and it is also used to auto-populate relevant fields in the course of the interface of our app. Our App also collects mobile numbers for verification to check the active SIM status on the device, uniquely identify you, and prevent fraud and unauthorized access.

How we use this data: See, For Enabling the App and its Services; For Enabling Customer Support; For Enabling Marketing and Outreach; For Automated Decisions; For Legal Compliance and Requirements.

Phone Book Contacts: When you grant us access to the address book on your mobile device, then we access the names and contact information from your address book to facilitate invitations and to assess your phone usage and habits. As part of the App journey, we access your phonebook contacts which include their contact names, phone numbers, account types, favorites (starred), and contact labels to enrich your profile. We use this data to determine your social network from your phonebook contacts and identify fraudulent contacts in your network and for promotional and marketing purposes. This helps us in detecting frauds and reducing risk.

How we use this data: See, For Enabling the App and its Services; For Marketing and Outreach; For Automated Decisions; For Legal Compliance and Requirements.

SMS Data: When you grant us access to the SMSs on your mobile device, then we collect SMS data and store only financial SMS data. We use this data to analyze your financial profile and provide you the best offers.

How we use this data: See, For Enabling the App and Services; For Automated Decisions; For Legal Compliance and Requirements.

App Data: We collect the data about your installed applications, including the applications that you have installed on and from the date you create your PocketWise Account and the manner in which you use them. This also includes having access and permission to send you messages and notifications via your social media and instant messaging applications. We use this data for fraud detection and prevention and to make tailored product offerings to you.

Usage data: We collect data about how you interact with our Services. This includes data such as access dates and times, App features or pages viewed, App crashes and other system activity, type of browser, and third-party sites or services used before or in the course of interacting with our Services.

Storage: This permission is required so that users' documents can be securely downloaded and saved on users' phones and upload the right documents. This helps provide a very smooth and seamless experience while using the app.

How we use this data: See, For Enabling the App and its Services; For Legal Compliance and Requirements.

3. Information we receive from other sources We may also be working closely with third parties (including, for example, business partners, partner banks and financial institutions, technical sub-contractors, analytics providers) and may lawfully receive information about you from such sources. Such data may be shared internally and combined with data collected on the App. We may also use the content you have shared publicly, including on third-party platforms or applications, to promote our Services (including by quoting your content, reviews and/or recommendations, or displaying screenshots of your content, reviews and/or recommendations).

4. Data received from Google We may use data received from your Gmail account connected/integrated with the App. Such data may be shared internally and combined with data collected on the App. Our usage of information received from Google APIs complies with the Google API Services User Data Policy, encompassing the requirements for Limited Use.

2. How and Why Is the Collected Data Used?

Summary: The Company collects and uses data collected from you to ensure that the Services are as up to date as possible and provided in the most optimal manner to you.

The data collected in accordance with Section 1 of this Policy will be used as follows:

1. For Enabling the App and its Services

We use the data collected to personalize, maintain, and improve our Services. This includes:

Creating and updating the PocketWise Account.
Detecting and flagging fraud.
Assessing serviceability of Services to you.
Performing internal operations necessary to provide our Services, including
troubleshooting software bugs and operational problems, conducting data analysis, testing, and research, and monitoring and analyzing usage and activity trends.
Improving our products and services.
Personalizing your experience on the App, which may include displaying appropriate content based on our judgment and discretion.
Adding features that allow you to call us (through the App or otherwise), and similarly, contacting you (through the App or any other channels you provide, such as WhatsApp).

2. For Enabling Customer Support

We use the information to provide customer support, resolve concerns from the use of the Services, and train our customer service executives.

3. For Research and Development

We may use the collected data for research, analysis, and product development to improve the UI/UX experience, which will ultimately enhance how you experience the App. This also helps us develop automated actions to be triggered in certain events, such as identifying unclear photographs, fraud, or incorrect data.

4. For Enabling Communications Between You and Us

We may add features that allow you to call us (through the App or otherwise), and similarly, contact you (through the App or any other channels you provide, such as WhatsApp). We might use the information you provide to:

Confirm a purchase on the App.
Respond to pre-sale and post-sale service requests.
Support your needs efficiently and without delay.
Send updates about services or products of relevance to you or for promotional purposes.
Respond to your requests or questions, including confirming your registration for events or contests.
Send transactional communications about your account or a policy purchase via emails or SMS.

5. For Marketing and Outreach

We may use the data we collect to market the App and our Services. This includes sharing your feedback, ratings, and screen names for promotional and marketing purposes. Even if your name appears in the Do Not Call or Do Not Disturb Register, we may contact you through e-mails, telephones, messages, SMS, WhatsApp, or any other available modes for marketing schemes, financial or investment products, or any services availed by you. You acknowledge that such communication will not cause inconvenience and that we will not be liable for any claims against or by third parties. Marketing may be done via hoardings, banners, pamphlets, calls, SMSes, emails, and other means.

6. For Automated Decisions

The App may provide automated features for customer responses, etc. As our App grows, we will keep adding more automated features to the App.

7. For Legal Compliance and Requirements

We may use the data we collect to investigate or address claims or disputes relating to the use of our Services, or as otherwise allowed by applicable law, or as requested by regulators, government entities, and official inquiries.

8. For Product Innovation

We may use the data we collect to offer new products and services for your use. We analyze site trends and customer interests to improve the App and our products. We may also combine information from you with information from third parties.

3. How Do We Share The Collected Information?

Summary: While none of your data is sold, it is shared with third parties on a contractual basis for processing information and ensuring you receive the Services.

We are protective about your data. We may enter into data-sharing agreements or disclose the collected data to provide Services and new product offerings as detailed bel

1. Sharing with Third Parties

We work with third-party service providers to execute various functionalities of the App and may share your information with them to help us provide the App. This may include:

Analyzing customer behavior, conducting research, and automating marketing and outreach efforts..
Detecting and flagging fraud..
Cloud services..
Validating and authenticating employment status and information..
Third-Party Services: The App may connect with other websites or services beyond our control (e.g., external wallet facilities). Usage of such third-party services is subject to their privacy policies. We recommend reviewing their privacy policies before use..
Third-Party SDK: Our application links to a third-party SDK that collects data on our behalf and stores it on a secure server. We ensure our third-party service provider takes security measures to protect your personal information..

2. Sharing with Law Enforcement When Needed

If requested by governmental authorities or law enforcement officers, we may disclose information to comply with laws, regulations, or legal processes.

3. Sharing with Affiliates

Please see Section 5.

4. How Do We Handle Information Security Breaches?

We have an Information Security Incident Management Policy to tackle information security breaches. This process enables the incident response team to detect, analyze, contain, eradicate, and recover from such incidents.

PLEASE READ THIS POLICY CAREFULLY BEFORE USING THE APP

2. How and Why Is the Collected Data Used?

3. How Do We Share The Collected Information?

4. How Do We Handle Information Security Breaches?

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