Privacy Policy for Banxx

This Privacy Policy (“Policy”) of Asset Direct DBA Creditlinks India Private Limited, a private companyincorporated under the Companies Act, 2013 with its registered office at WeWork Vaswani Chambers, 1stfloor, 264-265, Dr Annie Besant Road, Worli Colony, Mumbai City, Mumbai, Maharashtra, India, 400030( “Banxx”, “we”, or “us” or “our”) is aimed at informing the users, members, unregistered visitors, andany person(s) using or accessing the Platform (as defined below) (hereinafter collectively referred to as the“Users” or “You” or “Your” or “Yours”) of the practices in relation to the storage, use, processing, anddisclosure of personal information and personal data that You have chosen to share with us, when You useor access our website hosted at https://www.creditlinks.in/ (the “Platform”).

Banxx is engaged in the business of facilitating provision of various loans and related financial services,and other products or services provided by our Lending Partners (as defined below). Through the Platform,we facilitate provision of short-term credit facilities (“Credit Facility”) to users interested in availing loans(“Borrower(s)”), by connecting them with our non-banking financial company (“NBFC”) partners, whoare authorized by the Reserve Bank of India (“RBI”) to offer and sanction such Credit Facility on thePlatform (“Lending Partners”). Banxx, through this Policy, aims to demonstrate its commitment towardsprotecting Your personal data and respecting Your privacy in compliance with the Information TechnologyAct, 2000 (“IT Act”) and Information Technology (Reasonable Security Practices and Procedures andSensitive Personal Data or Information), Rules, 2011 (“Rules”).

This Policy is applicable to all the Information collected, received, owned, controlled, stored, dealt with,shared with, accessed by, or handled by Banxx with respect to a User. Please read this Policy along withour Terms and Conditions available at: https://www.banxx.com/in/terms-of-use and www.creditlinks.in (“BanxxTerms of Service”).

1. USER ACKNOWLEDGEMENT AND CONSENT

1.1 By accepting this Policy, you understand and agree to the collection, use, sharing and processing ofInformation (as defined below), in the manner described hereinunder. If you provide Banxx withPersonal Information (as defined below) about someone else, you confirm that such person is awareof, and has consented to the sharing and use of such Information by Banxx, in accordance with theterms of this Policy. This Policy applies to all the current and former visitors, users and others whoaccess the Platform. This Policy is an electronic record in the form of an electronic contract formedunder the applicable law. This Policy does not require any physical, electronic or digital signature.This Policy is a legally binding document between you and Banxx.

1.2 Users acknowledge that they have the option to not provide or agree to the collection of personaldata. If a User chooses to not grant us access to such personal data when requested, we will not be ina position to provide the User with the Services. In such an event, we encourage You to stop usingthe Services and accessing the Platform. In addition to this, in the event You do not consent to ouraccess to Your personal data, we may have to terminate, suspend or limit Your access to the Servicesor Platform or part thereof, as may be the case.

1.3. By mere use of the Platform, you expressly consent to Banxx's use and disclosure of your UsageInformation, Personal Information (as defined below) and third-party information in accordance withthis Policy. If you do not agree with the terms of this Policy, please do not use this Platform. ThisPolicy shall be deemed to be incorporated into the Banxx Terms of Service.

1.4. Access to your online Account on the Platform is via Login Credentials, which is password protectedand this helps to secure your Account information. You are solely responsible for maintaining thesecurity and confidentiality of your Account, including the Login Credentials. To ensure safety ofyour Personal Information, you are advised against sharing your Login Credentials with anyone. Ifyou suspect any unauthorized use of your Account, you must immediately notify Banxx by sendingan email to contact@creditlinks.in. You shall be liable to indemnify Banxx for any loss suffered byBanxx due to such unauthorized use of your Account. You hereby explicitly agree that your use andaccess of the Login Credentials shall be governed by the Banxx Terms of Service read with the termsof this Policy and any other agreement that you may enter into with Banxx.

1.5. Banxx does not intend to attract anyone under the legal age of consent to enter into binding legalcontracts under the laws of their respective jurisdictions. Banxx does not intentionally or knowinglycollect Information through the Platform from anyone under that age. Banxx encourages parents andguardians to be involved in the online activities of minors to ensure that no Personal Information iscollected from a minor without their prior consent. If you are using the Platform on behalf of someoneelse, including but not limited to, on behalf of your minor child/children or employer, you representand warrant that you are authorised by such person to accept this Policy on their behalf and to provideconsent on behalf of such person to Banxx's use of such person's Personal Information as describedin this Policy.

2. UPDATE USER INFORMATION

2.1. Users are required to update their Information available with Banxx as and when there are anychanges. Users are also entitled to review the Information provided and ensure that any PersonalInformation or sensitive personal data or Information found to be inaccurate or deficient be correctedor amended as feasible. Such corrections/updations may be done by the User’s account on thePlatform

3. PURPOSE OF COLLECTION OF INFORMATION

3.1. Our primary goal in accessing, collecting and using Your Information, is to provide You with a safe,efficient, smooth and customized experience of our Services. More importantly, we only collect andprocess basic minimal Information of the User that we consider necessary for providing the Servicesand enabling Your use of our Platform.

3.2. In general, you can browse the Platform of Banxx without disclosing Your identity or revealing anyInformation about Yourself. However, to create an account on the Platform You will be required toprovide us with certain basic minimal Information in connection with the Services.

4.WHAT WE COLLECT AND HOW WE USE YOUR INFORMATION

4.1 INFORMATION WE COLLECT FROM YOU

During your use of the Platform, we will collect such “Information” from you including but notlimited to the below mentioned:

  1. Personal Information

    “Personal Information” means any information that may be used to identify an individual,including, but not limited to, the first and last names, physical address, telephone number, date ofbirth, age, gender, e-mail address, or any other contact information, educational qualifications, professional qualifications or skill sets, information collected through social media accounts/loginsof the Users which have been linked to the account on the Platform for the purposes of creating thesame by signing-up on the Platform, information that you provide when you write directly to orcontact Banxx (including by e-mail) or provide us over telephone or any other information that Banxxcollects or is required to be collected from you (during your use of the Platform) as per a specificmandate of or as a requirement under any applicable law (which are now or shall hereafter be in forcefrom time to time) and other relevant financial information. Further, Banxx may also require you toprovide certain user verification information such as your permanent account number ("PAN"),unique identification number, copy of your driving license and passport. Banxx limits the collectionof Personal Information to the extent necessary for its intended purpose or as may be required by itsLending Partners.
  2. Business Information

    “Business Information” means any information that may be used to identify a User’s business,including but not limited to the name and address of the entity, date of incorporation, e-mail addressof the entity, contact information of the registered office, company identification number (CIN),financial information including bank account details, PAN details, names of the directors and suchother information as may be required by our Lending Partners.
  3. Financial Information

    “Financial Information” includes Your income details and bank account details, . Such data shallbe used to verify Your credit worthiness and check Your eligibility for the Credit Facilities offered onthe Platform.
  4. Credit Information

    We will, in order to (i) enable us to assist our business partners in facilitating and delivering Servicesto you on the Platform; (ii) process your applications in terms of such services; (iii) communicatewith you about customized products, services and personalized promotional offers (from time to time)of Banxx and/or its business partners; and (iv) grant access to you on the Platform in terms of thisPolicy and the Banxx Terms of Service.
  5. Transaction Information

    “Transaction Information” includes details of transactions that may occur through the Platform orin connection with the Services. For example, transaction data may include the Services You havesought or availed through the Platform or confirmations of such Services
  6. Device Information

    “Device Information” includes Your IP addresses, browser types and versions, time zone settings,operating systems, and device information. We collect, transmit, and store such data on our securedserver. This data is collected for the purpose of data analytics.
  7. Marketing and communications Information

    “Marketing and Communication Information” includes Your preferences in receiving marketingmessages from us and our third parties and Your communication preferences.
  8. Non-Personal Information

    “Non-personal Information” means information that does not specifically identify a User orbusiness, but includes, inter alia, information collected from you, such as your browser type, the URLof the previous websites you visited, your Internet Service Provider (ISP), operating system, yourInternet Protocol (IP) address. Banxx may gather any Non-Personal Information regarding how manypeople visit this Platform, the pages they visit, their IP address, and the type of browser they usedwhile visiting the Platform. Banxx may also collect Non-Personal Information that you voluntarilyprovide, such as information included in response to a questionnaire or a survey conducted by Banxx.
  9. Usage Information

    “Usage Information” includes, without limitation, all data and information collected automaticallythrough the Platform (or through the third party analytics service providers), by use and access of thePlatform in the nature of system administrative data, statistical and demographical data, andoperational information and data generated by or characterizing use of the Platform including withoutlimitation Non-Personal Information, Cookies (as defined below), Platform traffic, time spent on thePlatform, number of visits to the Platform and other similar information and behaviour indicating themode and manner of use of the Platform.
  10. Cookies

    To enhance your experience with the Platform, many of the web pages use “cookies” and pixel tagsthat enable Banxx features and functionality. Cookies are text files placed in your mobile/ computer'sbrowser to maintain your log-in and session details. Banxx uses three types of cookies, necessarysession cookies (including username, email ID, user access information) which enables Banxx torecognise you and makes it easier for you to return to Platform and interact with the Services withoutsigning in again, and/or preference cookies (including search and browsing history) which are storedfor the maximum duration permitted by law, and/or statistics cookies (including Usage Informationsuch as unique request ID, statistical data) which are stored for 24 (twenty four)hours or the maximumduration permitted by law (collectively referred to as the "Cookies").
  11. Cookies, by themselves, do not tell Banxx your e-mail address or other Personal Information unlessyou choose to provide the same to Banxx by, for example, registering on the Platform and/or byavailing the Services provided by Banxx. Cookies are designed to hold a marginal amount of dataspecific to a particular user and website and can be accessed either by the web server or the userdevice. However, once you choose to furnish the Platform with Personal Information or any otherInformation, this Information may be linked to the data stored in the Cookies. Banxx uses Cookies tounderstand site usage and to improve the content and offerings on the Platform. For example, Banxxmay use Cookies to personalize your experience on the Platform (e.g., to recognize you by namewhen you return to the Platform). Banxx also may use Cookies to offer you products, programs, orServices. Cookies may be placed on the Platform by third-parties as well, the use of which Banxxdoes not control. You are free to accept or refuse the use of Cookies via the cookies banner thatappears when you open the Platform.
  12. Cookies are retained in your browser unless specifically deleted, depending on the type of Cookies.If you decline the Cookies, you may be unable to use certain features on the Platform and you maybe required to re-enter your password frequently. By using or accessing the Platform and/or theServices provided by Banxx, you hereby explicitly authorise Banxx and give your consent to Banxxto store, use and access Cookies for the purposes outlined in this Policy. Most browsers allow you tocontrol Cookies through their settings, which may be adapted to reflect your consent to the use ofCookies, and they may also enable you to review and erase Cookies.
  13. You can manage browser Cookies through your browser settings. The 'Help' feature on most browserswill tell you how to prevent your browser from accepting new Cookies, how to have the browsernotify you when you receive Cookies, how to disable Cookies, and when Cookies will expire. If youdisable all Cookies on your browser, neither we nor third parties will transfer Cookies to yourbrowser. If you do this, however, you may have to manually adjust some preferences every time youvisit the Platform and some features and Services may not work.

4.2. USE OF INFORMATION

  1. By using our Platform and submitting Your Personal Information and other Information to Banxx,You expressly acknowledge and consent to use of such Information in a manner specified under thisPolicy. Such Information can be used for various purposes including:
  2. To register You as a user of the Platform and verifying your identity;
  3. Facilitating your usage of the Platform and our Services. Please note that certain data sets may onlybe used/collected if the User intends to use the Service for a specific product on the Platform asindicated above. In the event that the User wishes to avail any Services such as, insurance productsand mutual funds, certain data sets shall be shared with third parties solely for the purpose ofproviding You such Services;
  4. To manage our relationship with You, including notifying You of changes to any Services;
  5. For extension of Credit Facility and other Services to the User from regulated entities including butnot limited to the Lending Partners;
  6. To ensure compliance with all legal obligations of Lending Partners, vis-à-vis Know-your Customer,Prevention of Money Laundering, CKYRC requirements etc for the purposes of facilitation of theServices;
  7. For fraud prevention and detection;
  8. To send User surveys and marketing communications that Banxx believes may be of User’s interest;
  9. To facilitate repayment of the Credit Facility availed or recovery of outstanding payments on behalfof the Lending Partner;
  10. To diagnose technical problems, provide support and help Users in addressing troubleshoot problems;
  11. To send and receive communications, show advertisements, notifications and make promotionaloffers;
  12. To prepare reports, review and filing as per applicable laws;
  13. To contact Users regarding Lending Partners and the various Services being facilitated throughBanxx, third party services and offers;
  14. To understand User preferences requirements;
  15. To permit User to participate in interactive features offered through the Platform;
  16. To improve the content, our business and delivery models and protect the integrity of the Platform;
  17. To increase/improve the Services offered on the Platform;
  18. To ensure compliance with all applicable laws;
  19. To respond to court orders, establish or exercise our legal rights, or defend ourselves against legalclaims;
  20. To perform our obligations that arise out of the arrangement we are about to enter or have enteredwith You; and
  21. To enforce Banxx Terms of Service.
  22. By consenting to the terms of our Privacy Policy, you acknowledge and agree that Banxx may, afteryour explicit agreement to view eligible offers, automatically submit your provided Information tothe Lending Partners to pre-qualify you as an applicant. This process may result in you receivingsolicitations or offers from Lending Partners for which you are pre-qualified. Please note that our roleis solely as an intermediary and we do not influence or control the offers or solicitations you mayreceive from the Lending Partners.
  23. Once you register on the Platform and sign in, you are not anonymous to Banxx. In the event yourAccount at the time or during registration with Banxx is created using your (a) cell phone numberand password; (b) email address and password; or (c) google or other social media logins (ifapplicable), as the case maybe, you authorize Banxx (including its business partners) to send textsand email alerts to you with your login details and any other service requirements, includingpromotional mails and SMS, even if you have registered yourself under DND or DNC or NCPRservices. Your authorization shall be valid as long as your Account is not deactivated. Further, anyacceptance by you from the mobile number(s) and Email ID(s) provided by you will be binding innature. You confirm that laws concerning the unsolicited communication referred in “National DoNot Call Registry” (the “NDNC Registry”) will not be applicable for such communication receivedfrom Us.
  24. Banxx may use your Non-Personal Information for internal business purposes, such as data analysis,research, developing new products, enhancing and improving existing products and Services, andidentifying usage trends.
  25. Information collected by Banxx from a particular browser or device may be used with anothercomputer or device that is linked to the browser or device on which such Information was collected.

5. HOW YOUR PERSONAL INFORMATION IS SHARED

5.1. Except as required under applicable laws or pursuant to a court/government order or for purposes setforth in this Policy, any Information or data shared by us with third parties shall be undertaken afterobtaining Your explicit consent, solely to render the Services to You.

5.2. We will share Your Information with third parties to facilitate provisioning of Services by us to Youonly in such manner as described below:

  1. We may disclose Your Information to our Lending Partners on the Platform to facilitate provision ofCredit Facility for You;
  2. We may disclose Your Information to our third-party service providers for providing the Services, asdetailed under the Terms & Conditions or for recovery of outstanding Credit Facility sanctioned toYou by the Lending Partners;
  3. We may share Your Information with our third-party partners in order to conduct data analysis inorder to serve You better and provide Services on our Platform;
  4. We may engage third party service providers to perform certain support services, who may haveaccess to Information
  5. We may disclose Your Information, without prior notice, if required under any law or if we are undera duty to do so in order to comply with any legal obligation or an order from the government and/ora statutory authority, or in order to enforce or apply our Terms and Conditions or assign suchinformation in the course of corporate divestitures, mergers, or to protect the rights, property, or safetyof us, our Users, or others.
  6. We may share Your Information with our affiliates and/or group companies for data processing andanalysis;
  7. We and our affiliates may share Your Information with another business entity should we (or ourassets) merge with, or be acquired by that business entity, or re-organization, amalgamation,restructuring of business for continuity of business.

5.3. In the event Banxx exercises its rights reserved under the Banxx Terms of Service to charge any feefor registration/membership or browsing fee at any time, Banxx may direct you to a payment gatewayservice provider of its own choice, which may have access to the Personal Information provided byyou while making such payment.

5.4. Banxx may disclose your Personal Information to companies whose practices are not covered by thisPolicy, (e.g., other marketers, magazine publishers, retailers, participatory databases, and non-profitorganizations) that want to market products or services to you.

5.5. We limit the collection and use of your Information. We may make anonymous or aggregateInformation and disclose such data only in a non-personally identifiable manner. Such Informationdoes not identify you individually. Access to your Account information and any other Information isstrictly restricted and used only in accordance with specific internal procedures, and for the purposesset out in this Privacy Policy, in order to operate, develop or improve our Platform and Services. Wemay use third party service providers to enable us to provide you with our Services and we requiresuch third parties to maintain the confidentiality of the information we provide to them under ourcontracts with them.

5.6. If You fail to provide consent for sharing of such data when requested by us, we may not be able toprovide the Services to You.

5.7. Banxx may engage third party service providers, vendors and/or contractors to perform certainsupport services for Banxx, including, without limitation, software maintenance services, advertisingand marketing services, web hosting services and such other related services which are required byBanxx to provide its services efficiently. These third parties may have limited access to theInformation. If they do, this limited access is provided so that they may perform these tasks for Banxxand they are not authorized by Banxx to otherwise use or disclose Information, except to the extentrequired by law. We may use third-party service providers to serve ads on our behalf across theinternet and sometimes on this Platform. They may collect anonymous Information about your visitsto this Platform, and your interaction with our products and services. They may also use Informationabout your visits to this Platform and other websites for targeted advertisements for goods andservices. Banxx does not make any representations concerning the privacy practices or policies orterms of use of such websites, nor does it control or guarantee the accuracy, integrity, or quality ofthe information, data, text, software, music, sound, photographs, graphics, videos, messages or othermaterials available on such websites. The inclusion or exclusion does not imply any endorsement byBanxx of the website, the website's provider, or the information on such website. The Platform maycontain links and interactive functionality interacting with the websites of third parties. Banxx is notresponsible for and has no liability for the functionality, actions, inactions, privacy settings, privacypolicies, terms, or content of any such website. Personal Information that you provide to thosewebsites are not our property. Before enabling any sharing functions to communicate with any suchwebsite or otherwise visiting any such website, Banxx strongly recommends that you review andunderstand the terms and conditions, privacy policies, settings, and information-sharing functions ofeach such third-party website.

5.8. Third parties with whom we may share Your data for providing services are available [●].

6. DATA PROTECTION AND SECURITY

6.1. Banxx has taken adequate measures to protect the security of Information and to ensure that yourchoices for its intended use are honored. Banxx takes robust precautions to protect your data fromloss, misuse, unauthorized access or disclosure, alteration, or destruction.

6.2. Banxx considers the confidentiality and security of your Information to be of utmost importance andunderstands the integrity and availability of your Information is vital to our own success. It thereforeuses industry standards, and physical, technical, organization and administrative security measuresto keep Information confidential and secure and Banxx will not share your Information with thirdparties, except as otherwise provided in this Policy. Please be advised, however, that while Banxxstrives to protect Information and privacy, no method of transmission over the Internet, or method ofelectronic storage, is 100% secure and Banxx cannot guarantee or warranty its absolute security whenInformation is transmitted over the internet into the Platform.

6.3. For any loss or theft of Information, due to unauthorized access to your device through which youuse the Platform or other reasons solely attributable to you, Banxx shall not be held liable orresponsible under any circumstance whatsoever. Further, Banxx shall not be responsible for anybreach of security or for any actions of any third parties or events that are beyond Banxx's reasonablecontrol including but not limited to acts of government, computer hacking, unauthorized access tocomputer data and storage device, computer crashes, breach of security and encryption, poor qualityof Internet service or telephone service of the user, etc.

7. YOUR LEGAL RIGHTS

7.1. Data Storage and Revocation of Consent:

  1. We will store Your Information and/or data for such period as may be required by Banxx/LendingPartners to (i) enforce or enable Lending Partners to enforce its legal rights and obligations againstYou; (ii) to ensure compliance with its obligations and responsibilities or the Lending Partner’sobligations and responsibilities under applicable laws, as specified by the RBI.
  2. You may, however, withdraw Your consent at any time. Such a request shall be complied with by Ussubject to the applicable laws and the terms of the Credit Facility availed through the Platform. Youfurther understand and agree that neither the repayment of a Credit Facility, nor the deletion of Youraccount with the Platform, automatically rescinds the consents You have provided to us under thePolicy.
  3. You may request Your data deletion by writing to us at contact@creditlinks.in.

7.2. Data Retention

  1. Banxx shall store your Personal Information at least for such period as may be required and permittedby applicable law or as required for defending any future legal claims. These periods vary dependingon the nature of the Information and your interactions with Banxx.
  2. Upon the expiration of the retention period applicable to each category of personal data, we shall, tothe extent technically feasible, delete, destroy, or anonymize the data in our possession or control,ensuring that it no longer qualifies as Personal Information.
  3. You agree that you will not submit any false Information or any illegal or damaging content to thePlatform. Banxx reserves the right to terminate access to or the ability to interact with the Platformin response to any concerns Banxx may have about false, illegal, or damaging content, or for anyother reason, in its sole discretion.

7.3. Data destruction protocol

  1. You may request the deletion of your Information and/or personal data. We shall comply with suchrequests, subject to applicable laws, regulatory requirements, and the need to retain data for defendingagainst potential legal claims. However, if you have an active Credit Facility or ongoing Service,deletion may not be possible.
  2. Information and/or personal data not required under applicable laws, regulatory mandates, or for legaldefense shall be deleted or anonymized upon your request, provided there is no active Credit Facilityor ongoing Service. In certain cases, legal or regulatory obligations may prevent immediate deletion.

8. LOCALISATION OF PERSONAL INFORMATION

Please note that all Your Information, including financial data, is only stored on systems located inIndia. We shall not transfer Your Information to any third country.

9. CHANGES TO PRIVACY POLICY

In the event that Banxx modifies this Policy, the same will be updated on the Platform. In case of anymaterial changes to the Policy, the Users will be notified by means of a notice on Platform prior tothe change becoming effective. The Users are encouraged to periodically review this page for thelatest information on Banxx’s privacy practices.

10. LIMITATION OF LIABILITY

10.1. Banxx shall not be liable to you for any loss of profit, production, anticipated savings, goodwill orbusiness opportunities or any type of direct or indirect, incidental, economic, compensatory, punitive,exemplary or consequential losses arising out of performance or non-performance of its obligationsunder this Policy.

10.2. Notwithstanding anything contained in this Policy or elsewhere, Banxx shall not be held responsiblefor any loss, damage or misuse of your Personal Information, if such loss, damage or misuse isattributable to a Force Majeure Event. The term “Force Majeure Event” shall mean any event thatis beyond the reasonable control of Banxx and shall include, without limitation, sabotage, fire, flood,explosion, acts of God, civil commotion, strikes, lockouts or industrial action of any kind, riots,insurrection, war, acts of government, pandemic, epidemic, computer hacking, civil disturbances,unauthorised access to computer data and storage device, computer crashes, breach of security andencryption, epidemic, pandemic or national/state lockdown due to any reason and any other similarevents not within the control of Banxx and which Banxx is not able to overcome.

11. GRIEVANCE REDRESSAL OFFICER

11.1. Banxx Grievance Officer

In accordance with the provisions of applicable laws, the name and contact details of the GrievanceOfficer are provided below:

Name: Soumya Ranjan Das

Address: Tower B-1131, iThum Industrial Area, Sector 62, Noida, Uttar Pradesh 201309

Cell: +0120-4317269

Email ID: soumya.ranjan.das@creditlinks.in

If You wish to make a complaint regarding any violation of the provisions of this Policy, You maysend a complaint to the Grievance Officer, who shall redress the complaint in accordance with theprovisions of the applicable laws.

The Grievance Officer can be contacted between 10:30 a.m. to 6:00 p.m. from Monday to Fridayexcept on public holidays.

We shall respond to Your request(s) or grievance within twenty four hours from the time of receipt.In the event that we are unable to acknowledge or provide a response within the stipulated timeframefor any reason, we shall duly notify you accordingly.

11.2. Greivance with respect to any Lending Partners

If the grievance is not resolved by the Banxx Grievance Officer within thirty (30) days of lodgingthe grievance, or if the User who has availed any services from the Lending Partner is not satisfiedwith the response received from Banxx, such User may approach the Lending Partner to have suchgrievance resolved. The grievance redressal mechanism of the Lending Partner is accessible at:Lending Partner: https://www.banxx.com/in/our-lenders

12. HOW TO CONTACT US

If You have questions or concerns about this Policy, please contact Banxx at the following emailaddress: contact@creditlinks.in