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Your privacy is important to us!

Saarathi FinBiz Private Limited '('Saarathi)respects your privacy regarding any information the company may collect while operating our website or application. This Privacy Policy applies to Saarathi FinBiz Private Limited '('Saarathi) (hereinafter, "us", "we", "company" or "www.saarathi.ai"). We respect your privacy and are committed to protecting the information you may provide us through our Platform.

The company has adopted this privacy policy ("Privacy Policy") to explain what information may be collected on our website or application, how we use this information, and under what circumstances we may disclose the information to third parties. This Privacy Policy applies only to information we collect through our Platform and does not apply to information collected from other sources. This Privacy Policy, together with the terms & Conditions posted on our website or application, set forth the general rules and policies governing your use of our website or application. Depending on your activities when visiting our website or application, you may be required to agree to additional terms of service.

 This Privacy Policy has been prepared incompliance with:

• Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information)Rules, 2011;
• Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021;
• Guidelines on Digital Lending issued by the Reserve Bank of India (RBI), 2022;
• Other applicable acts, regulations, and rules requiring the publication of a privacy policy for handling or dealing with personal information, including sensitive personal data or information, as well as all applicable laws, regulations, and guidelines issued by applicable regulatory authorities, including but not limited to the RBI.

 This Privacy Policy delineates how the borrower's information is collected, used, retained, and managed. By using the Saarathi platform or voluntarily sharing information on Saarathi, the borrower consents to be bound by its terms and further consents to the collection, use, retention, and management of the borrower's information under its terms and conditions.

We, therefore, advise the borrower to read this policy before using our Platform. If these terms, in parts or whole, are not acceptable to the borrower, then the borrower is advised not to use Saarathi or our services that require the collection, use, or retention of the borrower's information.

This Privacy Policy is incorporated into and at all times is subject to and is to be read in conjunction with the Terms& Conditions of the Platform.

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‍1.     DEFINITION
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1.1. "Cookies" mean small text file created by Saarathi that is stored on the borrower's device, either temporarily (session cookies) or permanently (persistent cookies), that remembers the information about the borrower to recognise the borrower's device and set the borrower's preferences as per the borrower's usage of Saarathi.

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1.2. "Channel Partner" (CP) or "Direct Selling Agent" (DSA) shall mean the person who acts as an agent who uses the Platform to provide services to the Borrower/Customer.

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1.3. "Customer”/”Applicant”/”Borrower” shall mean the person whose personal information is being shared with us by the Channel Partners for whom the loan is applied for.

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1.4. "Information" means the borrower's data that we collect during the borrower's usage of Saarathi, including personal, non-personal, and financial information.

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1.5. "Personal Information" means personally identifiable information that can be used to contact or identify the Borrower or the Customer. Personal information includes, without limitation, the name, email address, residential and permanent address, date of birth, phone number, Aadhar card, PAN card, and other financial information, including, without limitation, income, expenses, credit history, credit score, payment details, bank accounts information and other information as required from time to time.

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1.6. "Non-personal Information" means information such as cookies, log data, third-party analytics for data collection, and analysis that the borrower's browser sends whenever the borrower uses Saarathi, and includes, without limitation, information such as the borrower's computer's Internet Protocol address, pages of Saarathi that the borrower visit, time and date of the borrower's visit, time spent on those pages, unique device identifiers, the mobile device the borrower use (including the hardware models), the borrower's mobile device unique ID, the IP address of the borrower's mobile device, the borrower's mobile operating system, type of mobile Internet browser the borrower use, unique device identifiers, location, device data, and other diagnostic data.

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2.     DATA COLLECTION

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As part of our commitment to transparency and compliance with the Reserve Bank of India (RBI) Digital Lending Guidelines, we ensure that borrowers' data is handled responsibly and securely. This section outlines the type of data we collect, its purpose, and our retention policies. We collect personal information only when borrowers voluntarily provide it while using the Saarathi Platform or through our channel partners. In digital loan journeys, the data collected may vary depending on the type of loan.

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2.1. Specific Data Permissions:

‍1. Camera Access: One-time access may be required for:

• Taking selfies for KYC compliance.
• Uploading necessary documents.

2. Location Data:

• Collected once to verify current addresses, check serviceability, and prevent fraud.
• Methods of collection:
  • PIN code entered in the application.
  • Device location when enabled by the borrower.
• Note: Disabling location access may restrict some application features.

3. Transaction Information:

• Transaction data generated through the Saarathi Card is stored and shared with Financing Partners.

4. Storage:

• Permission is required to securely download, save, and upload documents for smoother loan processing.

5. Feedback and Other Data:

• Data collected during feedback submission, referral program participation, or communication with Saarathi.

6. Third-Party Information:

• With explicit consent, information may be obtained from credit bureaus, account aggregators, and other partners.

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2.2. Types of Data Collected

The following information may be collected for identification, verification, and loan processing:

• Personal Identification Data
• Business Information
• Financial Information
• Address Details
• Additional information as required for loan eligibility assessments

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‍2.3. Location Data:

Data is used exclusively for:

• Identification and Verification: Authenticating borrowers' identity for compliance.
• Eligibility Checks: Assessing loan eligibility and creditworthiness.
• Serviceability: Evaluating financial requirements and serviceability.
• Loan Processing: Application processing and payout invoicing.

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‍2.4.Borrowers Rights

Complying with Indian Regulations, borrowers have the right to access, correct, or delete personal information. Requests to delete data can be made through the Platform or by email to care@saarathi.ai.

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2.5. Digital Business Loans

For digitally integrated business loans, the following data may be collected:

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2.6. Disclaimer

1. Personal information is collected only with prior consent and may be verified using publicly available data to prevent identity theft or fraud.
2. We do not knowingly collect data from minors (under 18 years of age). If a guardian becomes aware of such collection, they may contact us to have the data removed promptly.

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3.  USE OF DATA COLLECTED

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3.1. By Saarathi:

1. We will use the borrower's information to allow the borrower to participate in Saarathi's interactive features when the borrower chooses to do so, provide service support, and gather information or analysis to improve our Platform and Services provided thereof.
2. We will use the borrower's information to analyse the application usage to improve and develop the Saarathi Platform and Services provided thereof by gathering and analysing surveys taken, feedback, reviews, and ratings provided or posted by the borrower.
3. To provide service support and promptly and satisfactorily respond to and resolve the borrower's queries, complaints, and grievances, if any.
4. Facilitate credit assessment and personalised offers.
5. Undertake market research, project planning, and problem troubleshooting to protect against error, fraud or other criminal activity.
6. Disclose to employees, agents and representatives on a need-to-know basis as part of the services.
7. Disclose this to relevant and authorised financial service providers and financing partners who have partnered with Saarathi to provide loan facilities to customers.
8. Assist in resolving disputes in relation to loan facilities made available by Financing Partners.
9. Disclose to the credit information bureau and such other authorities as may be required by applicable laws and
10. Such other purposes as provided in this policy

Saarathi may also be required to share Personal Information with its third-party contractors, such as financial service providers, banks, or NBFCs/Financing Partners. Saarathi may make information available to third parties that are financial and non-financial companies, such as service providers, government agencies, courts, legal investigators, and other non-affiliated third parties, as requested by the borrower or the borrower's authorised representative or otherwise when required or permitted by law.

In addition to registration, personal information may be requested to report a problem/complaint with Saarathi. We may send the borrower emails about Our Application, new products, payment reminders, and other updates. We may use the phone number provided and verified by the borrower to reach out to the borrower via phone, WhatsApp, and SMS. Saarathi will ensure that the Personal Information provided by the borrower is treated securely under the provisions of this Policy and the Rules. The borrower is advised to refrain from posting personal information anywhere on the application other than those specifically required by Saarathi. If any person claiming to be an authorised representative of Saarathi contacts the borrower, we request that the borrower not provide any information to such person and instead immediately contact Saarathi as per the contact details provided in this policy. Saarathi shall not be liable for any loss of Personal Information provided to such persons.

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3.2. By Third-Party Service Provider: We engage third-party service providers (Financial Institutions) to render certain services; thereby, the borrower's information will be used by such third-party service providers solely and strictly to provide the services to the borrower. Sharing of Information is limited to the extent necessary for rendering such services and is shared under the strict obligation of confidentiality subject to the permitted disclosure provided under this Privacy Policy. Third-party service providers will use the borrower's information for the following purposes, but not limited to, as stipulated under this policy.

1. Web Analytics: We use third-party service providers to monitor and use our Platform to track and report traffic on the Platform; thereby, the web analytics service providers may use the collected data to contextualise and personalise advertisements of their own advertising network. Kindly refer to their respective privacy practices to understand the borrower's data usage by these service providers. The borrower can access the Privacy Policy and terms of use of these service providers on their respective websites.
2. Credit Information Company: The borrower's financial information may be subject to disclosure to third-party service providers for the preparation of the borrower's credit report when such services are availed by the borrower through Saarathi. Such information is disclosed to such third parties under confidentiality obligations.

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3.3. Other third-party service providers and facilitators: The borrower's information will be used by other third parties, such as banks, NBFCs, etc., when the borrower uses Saarathi for availing a financial product, making payments, money transfers, or any other financial transaction of any nature as available on Saarathi.

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4.   RETENTION OF DATA COLLECTED

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Saarathi will comply with Indian Data Privacy regulations and RBI' 's digital lending guidelines for all digital loans. Saarathi will follow the  information collected from the borrower for digital loans as follows.

• Disbursed Loans: Retained for three months post payout invoice generation or as required by lenders.
• Rejected or Incomplete Applications: Retained for one month.
• Basic Details: Name, address, and contact details may be retained for compliance.

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5. DISCLOSURE OF DATA COLLECTED

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We may share the borrower's data with lenders, third-party vendors, credit bureaus, analytics providers, and other service partners for borrower assessment, loan evaluation, verification, and service delivery. Data may also be shared to comply with legal or regulatory requirements.

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5.1. We will not voluntarily disclose the borrower's stored information without the borrower's prior consent. We may disclose the borrower's information to our domestic or international affiliates, subsidiaries, joint venture partners, licensees, and representatives solely for the purposes stipulated in this policy.

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5.2. Permitted Disclosure: Notwithstanding anything provided in the foregoing clause, we will disclose the borrower's information in parts or whole under the following conditions:

1. Business Transaction: The Company is involved in any form of restructuring by way of merger, acquisition, asset sale, etc.; we will transfer the borrower's information to such person or entity that is responsible for the operation of Saarathi and the service rendered thereof. The borrower shall be notified of the same, which thereon will become subject to a revised or different Privacy Policy as the case may be at the discretion of such third-party entity.
2. Third-Party Service Provider (Financial Institutions): To provide services on Saarathi, we may share the borrower's information—either partially or fully—with third-party service providers, including banks, NBFCs, insurers, brokers, mutual funds, and AMCs. This sharing is necessary for service delivery. Saarathi ensures that any disclosure is made under confidentiality obligations, preventing third-party providers from sharing the borrower's information with unauthorised parties. Additionally, the borrower's data may be shared with lenders, vendors, credit bureaus, and analytics providers for borrower assessment, loan evaluation, verification, and service delivery, as well as to comply with legal or regulatory requirements.
3. Disclosure for Law Enforcement: The Company will disclose the borrower's information to law enforcement agencies, Government authorities, or any other third party if required by a court order or under any law enforced from time to time, in good faith, or to enforce the terms of use or privacy policy of Saarathi.
4. Legal Requirements: We will disclose the borrower's information in good faith and belief if such action is necessary to comply with a legal obligation to protect and defend the rights and property and restrict the company's legal liability, to prevent or investigate possible wrongdoing in connection with the Platform, or to protect the personal safety of Saarathi users.
5. We shall not be held liable for disclosure of the Customer Information or Statistical Information in accordance with this Privacy Commitment or in terms of any other agreements with the borrower.
6. We may disclose Customer Information to any of our associates and affiliates without any limitation, and the borrower hereby gives the borrower's consent for the same.
7. We may disclose the Customer Information to third parties, without limitation, for the following reasons, and the borrower hereby gives the borrower's irrevocable consent for the same:
   • To enforce the Terms and Conditions of the products or services. or
   • To protect or defend our rights, interests and property or that of our associates and affiliates, or that of our or our Affiliate's employees, consultants, etc., or
   • For fraud prevention purposes. or
   • As permitted or required by law.
8. We may disclose the Customer Information to third parties for the following, among other purposes, and will make reasonable efforts to bind them to the obligation to keep the same secure and confidential and an obligation to use the information for the purpose for which the same is disclosed, and the borrower hereby gives the borrower's irrevocable consent for the same:
   1. For participation in any telecommunication or electronic clearing network. or
   2. For credit rating by a credit rating agency. or
   3. For advertising. or
   4. Facilitating joint product promotion campaigns. or
   5. For credit reporting purposes, verification and risk management to/ with clearing house centres or credit information bureaus and the like. or
   6. For availing of the support services from third parties, e.g. collecting subscription fees and notifying or contacting the borrower regarding any problem with, or the expiration of, any services availed by the borrower.
9. For sharing with third parties information obtained once (such information will only be taken one time, the information obtained once will only be shared) with the borrower's consent from the borrower's mobile device like device location, device information (including storage, model, installed apps, Wi-Fi, mobile network), transactional and promotional SMS, communication information including contacts and call logs, for statistical modelling, credit scoring and any other purpose that will help us in providing the borrower with optimal and high-quality services.

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6. THIRD-PARTY LINKS AND CONTENTS THEREOF

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Our Platform may link to third-party websites and services outside our control. Such third-party websites may collect and store information and data about the user. The company takes no responsibility for the privacy practices followed by these websites or the content available thereon. The company takes no liability for any loss or damage arising directly or indirectly from using such websites by browsing or transacting through them.

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7.SECURITY OF DATA

7.1. We have implemented and employed existing and necessary internet security methods and technologies to secure the information and data, to prevent loss and misuse of the information, and to data disclosed through unauthorised access from third-party, alteration, disclosure, or destruction of the borrower's information, username, password, transaction information and other stored Information on Saarathi.

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7.2. The Platform is scanned regularly for vulnerabilities to ensure the borrower's safe usage of Saarathi.

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7.3. We assure the compliance and adoption of all such measures as required under the applicable laws from time to time.

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7.4. The protection and confidentiality of the borrower's username, password, and other login credentials is solely the borrower's responsibility, and we recommend the borrower not to disclose it to anyone, including any third party, including anyone claiming to be the representative of the company or its affiliates. We never call or ask for such information from users. We shall not bear any responsibility or liability for such unauthorised disclosure or usage of the borrower's information or action taken from the borrower's account and its consequences thereof.

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7.5. Notwithstanding anything provided under this policy, the company shall be under no obligation for the permitted disclosure of information per the terms of this policy.

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7.6. Although we use our best endeavours to protect and secure the information and data shared or transmitted over the internet, it cannot be entirely guaranteed; hence, we cannot provide an absolute hundred per cent guaranteed security of the information provided by the user. Therefore, we disclaim all warranties and liabilities in respect of:

1. Any loss or injury caused to the borrower due to voluntary disclosure of the borrower's Personal Information to any unauthorised party.
2. Privacy practices and security of the borrower's information collected by third-party websites and services provided thereof that are outside our control.

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8. AMENDMENTS

We update our Privacy Policy to comply with applicable laws as amended from time to time. The borrower is requested to periodically review the policy to apprise the borrower's-self of the requisite changes. All such changes shall be effective immediately upon posting the updated policy on the Platform.

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9. GRIEVANCE REDRESSAL

If the borrower has any questions related to this Privacy Policy or any other grievance related to the borrower's information's privacy, the borrower can write to us at grievance.redressal@saarathi.ai or call us at +91 82878 70870. We will endeavor to redress the borrower's issues to the best of our abilities.

*Note: Appendix A has details of partner lenders for reference.

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If you have any questions related to this Privacy Policy or any other grievance related to your information’s privacy, you can contact

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Manish Sharma

Grievance Redressal Officer

‍grievance.redressal@saarathi.ai

+9182-87-870-870

Address:

12th Floor, Tower – B,
M3M Urbana Business Park,
Behind M3M Urbana, Sector 67, Gurugram,
Haryana 122102

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