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PRIVACY POLICY

1. WHO IS RR FinCap AND HOW DOES RR FinCap PRIVACY STATEMENT WORK?
RR FinCap Pvt Ltd (“ RR FinCap” “we”, “our”, “us”) is a company incorporated in India bearing CIN No.UP67120DL2009PTC186671, having its registered in 412-422, 4th Floor, Indraprakash Building, 21 Barakhamba Road, New Delhi Central Delhi DL 110005 IN, India and corporate office at Plot D 258 , 3rd Floor , GR tower , Sector 75 Mohali , 160055. RR FinCap is engaged in the business of providing technology products and platforms to various businesses and merchants through its Websites, Apps and Platforms (defined below), in addition to certain data processing services to its customers and other businesses. The purpose of this privacy statement (“ RR FinCap Privacy Statement”) is to give you information on how RR FinCap collects, stores, uses, discloses, transfers and processes your Personal Information including Sensitive Personal Information (defined below) when: (a) you use our websites including www. RR FinCap.in (“Websites”), software applications or mobile applications including the RR FinCap application hosted on RR FinCap.com which is owned by RR FinCap Pvt Ltdand licensed to RR FinCap (“Apps”) or platform(s) of any of our partners (“Platforms”), or (b) you avail any products or services which we may operate or offer to you either directly through our Websites or Apps or Platforms or through a merchant or partner platform; including the steps we take to protect your Personal Information. The term Websites includes all pages that are sub-domains or are associated with or exist within each Website which are hosted by RR FinCap. By accessing the Websites, Apps, Platforms and/or using products or services provided by RR FinCap directly or indirectly, you agree that you have read and understood, and agree to be bound by this RR FinCap Privacy Statement. By using the Websites, Apps, Platforms, and/or having used the products or services offered by RR FinCap directly or indirectly, in the past, present or future, you expressly consent to our use and disclosure of your Personal Information and Sensitive Personal Information submitted to us in accordance with this RR FinCap Privacy Statement. You further acknowledge and accept that your consent herein shall also be applicable to your Personal Information and Sensitive Personal Information submitted to us, directly or indirectly, in the past. It is strongly recommended for you to return to this page periodically to review the most current version of this RR FinCap Privacy Statement which is amended by us from time to time.
2. WHAT IS PERSONAL INFORMATION AND WHAT TYPES OF PERSOANL INFORMATION DO WE COLLECT ABOUT YOU?
“Personal information” means any information that relates to an individual, which directly or indirectly, in combination with other information available or likely to be available with us, is capable of identifying such individual. “Sensitive Personal Information” means any Personal Information of an individual, which consists of information relating to financial information such as bank account, credit card, debit card or other payment instrument details; passwords; biometric information; sexual orientation; physical, physiological and mental health condition; and medical records and history. Information freely available or accessible in public domain is not treated as Sensitive Personal Information. Depending on who you are (e.g., a merchant, customer, cardholder, consumer, supplier or business partner) and how you interact with us (e.g., through Website, Platform, App, telephone, IVR, API, online or offline), we may collect, use, receive, store, analyze, combine, transfer or otherwise process different categories of your Personal Information (including Sensitive Personal Information). Below is a table of the categories of Personal Information and Sensitive Personal Information which we may collect about you:

Categories of Personal Information	Which includes information such as:
Identity and Account Log- In Information”	Full name(s), title, age, user ID, gender, and your date of birth.
“Contact Information”	Telephone/mobile number(s), permanent and current address, state/city of residence, country, pin code, email address, and chosen billing address.
“Financial Information”	Personal bank account numbers and bank account data including e-nach, NEFT, IMPS and UPI ID details, credit or debit card information, including the credit or debit card number, card type, expiry date on the credit or debit card, and name on the card, salary and income details.
“Identification Information”	Know Your Customer (KYC) documents including all proofs of identity and address, photograph, Permanent Account Number (PAN), GST Number, etc.
“Payment Information” (transactional information)	Payment gateway ID, name of issuing bank, merchant’s name, category and other identifiers along with the details of products or services purchased or paid for, mode of payment, the date, currency and amount of the transaction, whether the payment was successful, and other information provided by you directly or indirectly to us or provided to us by banks, merchants or other service providers or business partners.
“Usage and Technical Information”	IP addresses, application, device or browser type, versions and configurations, operating systems, device brand and model, time zone setting, geo-location information, content, unique identifiers associated with your device(s) and pages that you access on the Website(s), Apps or Platforms, and the dates and times that you visit the Website, App or Platform, and paths taken.
“Credit and Lending Information”	Credit or affluence related information or assesment, Credit information (and income information (e.g., employment contract, salary details, employer name, income tax returns, bank account statements, income statements, balance sheet, cashflow statement), credit or affluence score or reliability scores provided by third parties such as financial institutions or account aggregators or similar third parties as permitted under applicable laws of India including our business partners, independent service providers and our group entities.
“Marketing and Communications Information”	Communications with customer service support, behavioural data (for example, data collected using cookies), information about promotions, surveys, promotional campaigns and records of your decision(s) to subscribe or to withdraw from receiving marketing materials, if any.
“Information in your device(s)”	We may also access your contact list, call records, SMS, media files and location data in your devices for various purposes after seeking necessary permissions.

We may also collect, use and/or share non-Personal Information or anonymized data such as statistical or demographic data in accordance with this RR FinCap Privacy Statement. As a matter of principle, we do not collect certain 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, trade union membership, information about your health or any genetic and biometric information). However, we may collect certain Sensitive Personal Information in order to provide our services or products to you, such as some categories of Financial Information including bank account number, name and number on the credit or debit card and your Credit and Lending Information as described above. In such cases, we ensure that such Sensitive Personal Information is used, processed, stored and/or disclosed in accordance with this RR FinCap Privacy Statement and in compliance with applicable laws of India. To the extent the Websites, Apps or Platforms include links to third-party websites, plug-ins and applications (including cookies, tracking technologies and widgets by third party advertisers), it is important that you understand that by clicking on those links or enabling those connections, you may allow third parties to collect or share data about you.
RR FinCap does not have oversight of these third-party websites, plug-ins and applications and we are not responsible for their processing or using of your Personal Information or Sensitive Personal Information. Any information collected by a third party in this manner is subject to that third party’s own data collection, use and disclosure policies and you must make yourselves conversant with those.
3. HOW DO WE COLLECT YOUR PERSONAL INFORMATION?
How we collect Personal Information (including Sensitive Personal Information) will depend on the following broader situations:
3.1. If we receive or collect it directly from you
We collect Personal Information (including Sensitive Personal Information) directly from you in different ways on the Websites, Apps, Platforms or product or service offerings. For example, you give us your Personal Information (including Sensitive Personal Information) when you:

Give us your Contact Information so that we can contact you about our services and products;
Conclude a contract or verify to us who you are (whether by email, phone or electronic verification);
Provide your Personal Information (including Sensitive Personal Information) on the Apps, Websites, Platforms or the checkout pages in order to register for availing our services or for completing a transaction(s);
Apply for our products or services directly with us or through our business partners (such as various third party websites, resellers or credit providers);
Directly register with us for availing any products or services including initiating an account-based relationship with us;
Are prompted to give us your Identity and Account Log- In Information, Contact Information, Financial Information, Identification Information, Credit Related Information and/or Payment Information on our App, Website or web-checkout /payment pages or via other similar channels to register or complete a transaction;
Give us your Credit and Lending Information to avail any loans or services directly from us, or from our business partners and third party service providers;
enter a competition, promotion or survey or you consent to be provided with marketing materials to be sent to you;
Send us a support request for any of our products or services through one or more of our support desks;
Access, use and/or browse our Website(s), Apps or Platforms;
Give us permission to collect the same from your device and other sources available through various means including cookies.

3.2. If we collect it from third parties, or from publicly available sources
We obtain Personal Information (including Sensitive Personal Information) through third parties including our business partners, independent service providers and our group entities, third parties or from publicly available sources, if publicly available, as permitted under applicable laws of India, including:

From various merchants, marketplaces, re-sellers, banks, payment partners, payment aggregators, payments systems, payment service providers and financial institutions. For example, a merchant can share your Personal Information with us for the purpose of doing an eligibility check for our services. We encourage you to read such third parties’ privacy statements to learn more on how they process your personal information.
From group entities or independent third parties for other activities. For example, we may receive information as may be required for our internal analysis, credit checks etc. from RR FinCap Entities for providing services to you. We may also receive your information from various third parties in the process of providing services to such third parties;
From third parties within the group of companies to which RR FinCap belongs, including its affiliates and subsidiaries subject to applicable laws of India;
From social platforms and networks when you give us permission to do so either directly or through a cookie. For example, depending on your social media settings, if you choose or consent to connect your social media account to a RR FinCap product or do not disable cookies while accessing the Website(s), Platform or an App, certain information from your social media account may be shared with us (which may include information that is part of your profile);
From financial institutions, and fraud prevention agencies for the purposes of conducting fraud and risk assessments or analysis. For example, before we provide or enable the provision of any services, goods or finances to you (as applicable), we may undertake checks for the purposes of preventing fraud and money laundering, and to verify your identity. These checks require us to collect information about you from our business partners and independent service providers including technology providers who have entered into contracts with us;
From third party service providers or technology providers, including service providers engaged in the business of collecting data from publicly available sources, who have entered into contracts with us to assist us with our business operations;
From third parties such as merchants or e-commerce platforms who have either entered into a contract with you or have obtained your consent or through any other legal means as may be available in accordance with applicable laws of India, to share your information with other parties;
h. from publicly available sources in accordance with applicable laws of India;

4. WHAT ARE THE LAWFUL GROUNDS THAT WE RELY ON TO PROCESS YOUR SENSITIVE PERSONAL INFORMATION?

5. THE PURPOSES FOR WHICH WE PROCESS YOUR PERSONAL INFORMATION

5.1. To verify, authenticate and authorize your use of our products or services

5.2. To process the transactions

5.3. To provide products and services to you

5.4. To do internal risk assessments and analysis

5.5. To generate variables, affluence and reliability scores

5.6. To protect our business and to ensure compliance with the law

Authenticating and validating your access to your account or to mitigate and protect against identity theft or fraud. To do this, some of your Personal Information (including Sensitive Personal Information) and non-Personal Information may be collected by RR FinCap or these may be directly or indirectly delivered to RR FinCap by merchants, group companies or other business partners of RR FinCap. RR FinCap will use this Personal Information (including Sensitive Personal Information) for the purpose of anti-fraud systems and this may be retained by us for our future use for reference and cross-reference of information;
Consulting and reporting your Personal Information (including Sensitive Personal Information) and behaviour on monetary obligations to legitimately constituted financial, commercial or service risk centres, or to other financial institutions, under applicable laws of India or in furtherance to contracts;
Verifying your identity and comparing your Personal Information (including Sensitive Personal Information) to verify accuracy for reporting obligations under applicable laws or payment scheme rules or KYC norms;
Processing your information for the purpose of ensuring compliance under applicable laws and for resolving or contesting any claims made by or against you against RR RR FinCap, RR FinCap Entities, our group companies, our business partners or any other third party;
Processing or using your Personal Information (including Sensitive Personal Information) if you exert your right of refusal for any of our services or any services provided by RR FinCap Entities, our group companies, our business partners or any other third party;
Processing (including storing or using) your Personal Information (including Sensitive Personal Information) to ensure business continuity of our businesses and appropriate disaster recovery for the Websites, Apps, Platforms, services and products.

5.7. To manage our relationship with you

To inform you about our products or services and any changes to these products or services and any associated legal documents;
To notify you if there is any interruption of services or products;
To ask you to provide information on how we can improve or develop services or products and to otherwise effectively communicate with you;
To provide you with service assistance and problem solutions or to contact or send you notifications related to the services or products we offer to you;
To use your Personal Information (including Sensitive Personal Information) in transactional or fraud monitoring reports (or both) as part of the performance of our contracts with RR FinCap Entities, our group companies, our business partners or any other third party and to comply with any regulatory obligations. You have the option to unsubscribe from such reports in accordance with the terms of our contract.

5.8. To market our products and services including products and services of our business partners

5.9.To conduct research and to develop and improve our products and services

To research and gain insights into market trends and needs and to develop or innovate our technologies, products and services to meet such market trends and needs. We may use machine learning and artificial intelligence techniques to conduct research to gain such insights;
To analyze visitor use of the Websites, Apps, Platform, products or services in accordance with this RR FinCap Privacy Statement;
To improve and personalize our merchant and customer relationships;
To provide merchants with statistical insights and reports based on your information we receive from them.

6. WHEN AND TO WHOM DO WE DISCLOSE YOUR PERSONAL INFORMATION?

6.1. We may share your Personal Information (including Sensitive Personal Information) with RR FinCap Entities, and other entities from the group of companies to which RR FinCap belongs, We may disclose your Personal Information (including Sensitive Personal Information) to these companies, to:

Provide support services and technical services to RR FinCap and group companies of RR FinCap (including RR FinCap Entities) and to receive some of these services from them;
Provide support services and technical services to RR FinCap and group companies of RR FinCap (including RR FinCap Entities) and to receive some of these services from them.
To offer their products and services to you including offering combined products and services.

6.2. We may share your Personal Information (including Sensitive Personal Information) with external third parties such as:

Other third parties and financial institutions for the purpose of enabling such entities to market and offer their products and services to you. We may also share your Personal Information (including Sensitive Personal Information) with such third parties and financial institutions to assist them in understanding your interests, habits, and usage patterns for certain programs, content, services, advertisements, promotions and such third parties and financial institutions may market and offer their products and services to you based on this.
Merchants to in accordance with our service agreements (also referred to as our terms and conditions or contracts) whether directly or through a third party such as a payment aggregator or a referral partner.
Authorized financial institutions and banking partners; with whom we partner to jointly create and offer products and services.
Service providers or vendors under contract who assist us with our business operations.
Companies that we plan to merge with or entities that we may acquire or be acquired by subject to the provisions of applicable laws, in which situation we will require that the new combined entity or the acquired/ acquiring entity follows this RR FinCap Privacy Statement with respect to your Personal Information.
When required by law enforcement, government officials, fraud detection agencies, financial institutions or other third parties and when we are compelled to do so under applicable laws (such as via a subpoena, court order, regulatory query or similar procedure).
International entities we partner with for the offer and/or development of products and services subject to the requirements under this RR FinCap Privacy Statement and applicable laws. RR FinCap ensures that every third party that is involved in the processing of your Personal Information (including Sensitive Personal Information) under a contract with us has the required organizational and technical protections in place as may be required in accordance with applicable laws in India.

7. MARKETING

8. INTERNATIONAL DATA TRANSFERS

9. DATA RETENTION

10. WHAT ARE YOUR INDIVIDUAL RIGHTS?

Review, Correct or Rectify: your Personal Information: You can ask us to have inaccurate Personal Information (including Sensitive Personal Information) we process about you, reviewed, fixed or changed in the time frame as specified in the applicable law.
Right to withdraw your consent:You may withdraw a consent to processing that you have given us and prevent further processing of your Sensitive Personal Information. You may also withhold your consent prior to the collection and processing of your Sensitive Personal Information.
Right to access:You may request record of your Personal Information (including Sensitive

Please note that you do not have an unqualified right under applicable laws for deletion of your Personal Information (including Sensitive Personal Information).

11. SECURITY: HOW WE PROTECT & STORE PERSONAL INFORMATION

12. MINORS

13. CHANGES TO THE RR FinCap PRIVACY STATEMENT AND YOUR DUTY TO INFORM US OF CHANGES

14. HOW TO CONTACT US