4Fin Finance Private Limited, a company incorporated under the Companies Act, 2013 having registered office at Park Plaza, 3rd Floor, near Central Mall, Shivajinagar, Pune, Maharashtra 411005, (“4Fin” or “Company”or “we” or “our” or “us”), is a Non-Banking Financial Company (NBFC) registered with Reserve Bank of India and is in the business of providing lending solutions to – assisting micro SMEs in procuring/fulfilling their financial requirements (“Service”) from “4Fin”, Banks and Other NBFCs (hereinafter collectively referred to as (“Lenders”) registered with the Reserve Bank of India (“RBI”) through our website www.4fin.in (referred to as “Website”)or the mobile application – 4Fin app available from the google play store or the apple app store (“Mobile App”). Any services of the Website and/or the Mobile App used by the visitors who visit the Website and/or the Mobile App (hereinafter referred to as “you”, “your” or “user”) or your use of the Website and/or the Mobile App is conditioned upon your acceptance of the terms and conditions contained in Terms and Conditions (“Terms and Conditions”) as available on the Website and/or the Mobile App and this privacy policy (“Privacy Policy”).

I. INTRODUCTION

4Fin is fully committed to respecting your privacy and want you to understand how we collect, use, and share data about you. This Privacy Policy covers our data collection practices and describes your rights to access, correct, or restrict our use of your personal data. We are committed to protecting it through our compliance with this Privacy Policy. This Privacy Policy describes: (a) what is the Information that we collect; (b) how do we collect your Information, and (c) how we use your collected Information; and (d) other relevant information such as security of your Information etc. Thus, it is important that you review this privacy policy.

a)
For the purposes of this Privacy Policy, except where the context otherwise requires, (i) capitalised terms defined anywhere in this Agreement by inclusion in quotations and/or parenthesis have the meanings so ascribed, and (ii) the following terms shall have the following meanings:
“Act” shall mean the Information Technology Act, 2000 and Rules thereunder as amended from time to time.

“Information” shall mean and include Personal Information and Sensitive Personal Data and Information as may be collected by.

“Personal Information (PI)” shall have the same meaning as under Rule 2 (i) of the Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011 as amended from time to time.

“Rules” shall mean the Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011 as amended from time to time.

“Sensitive Personal Data and Information (SPDI)” shall have the same meaning as under Rule 3 of the Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011 as amended from time to time.

b)
This Privacy Policy does not cover information you may choose to provide to (a) third party websites we advertise, (b) third party service provider’s website/platform/mobile app we may refer you to or (c) to social media sites where we have a profile. These will be governed by the privacy policies on those sites.

c)
By providing us with your Personal Information you expressly consent to us processing your Personal Information in accordance with the terms of this
Privacy Policy.

II. CHANGES TO THE PRIVACY POLICY

The policy is prepared in line with the RBI Digital Lending Framework dated August 10, 2022; considers UIDAI guidelines and regulations; aligned with Personal Data Protection bill 2021 (draft). The policy may be updated from time to time in line with the company’s requirements. 4Fin reserves the right to change or update this policy at any time on our site. Such changes shall be effective immediately upon posting to this site.

III. WHAT DATA DO WE COLLECT

We collect the following data from the users in the manner stated in this Privacy Policy:
a)
Upon registration on our Website and/or our Mobile App, personally identifiable information such as

• i. your name,
• ii. physical address,
• iii. email address,
• iv. telephone number,
• v. date of birth,
• vi. Photograph
• vii. Gender
• viii. Mobile phone information
• ix. Financial Information (as per sub-clause (c) of this clause III)
• x. and other similar information is collected.

b)
KYC details and documents including but not limited to PAN Number, as the case may be, shall be provided by the user at the time of the registration. We do not ask for AADHAAR numbers in our application process.

c)
Financial Details. Financial details and documents are collected during the time of registration with customers confirmation, these financial details and documents include but are not limited to: Bank documents; salary slips; business details; GST details; GST Returns, Financial documents; PAN card;

IV. HOW DO WE COLLECT YOUR DATA:

We collect the data in the following manner:
a)
Collection by 4Fin: All the PI or SPDI that we collect is directly provided by you.
In the following situations, we will collect and process the information about you:

• • – where you register for, log in or visit our Website and/or Mobile App, or opt to use any such Services of 4Fin, which is available only to registered users;
  • – where your directly provide any of the Information to 4Fin’ representatives, service providers, or any other person associated with 4Fin;
  • – where you voluntarily complete any user survey or provide feedback to us via email or any other channel;
  • – where you provide Personal Information to 4Fin in physical form whether sent through post or courier or handed over to a 4Fin representative in person;

b)
Through Google Analytics:

• • – We use a third-party JavaScript plug-in or mobile app library provided by Google called “Google Analytics” to provide us with useful traffic statistics and to better understand how you use our Website. We do not have direct access to the information obtained from Google Analytics, but Google provides us with a summary through their dashboard.
  • – Google does not provide us with direct access to your Personal Information and therefore we cannot see this information./li>
  • – We may share the information obtained from Google Analytics with business partners who are interested in advertising on our website. The information shared with these business partners will not contain any Personal Information.
  • – You can opt-out of having your information collected by Google Analytics by downloading the Google Analytics opt-out browser add-on provided by Google. This will prevent your information being used by Google Analytics. Doing this will not affect your ability to use our Website in any way. We also honour the Do Not Track header and will not track visitors who have Do Not Track switched on.

V. HOW WE USE THE INFORMATION WE COLLECT

We use the information we collect about you for the following purposes or in the following manner:

a)
We may disclose collected data to certain individual(s) for certain purpose(s) or in certain cases, these may include but not limited to:

• i. Lenders: We may share your Personal Information with the RBI registered Lenders, who are working with us in connection with the operation of the Services or the Platform, so long as such Lenders are subject to confidentiality restrictions consistent with this Privacy Policy.

b)
For other business purpose: By registering on the Website/Mobile App, you give us your express consent to receive promotional emails about our services and emails announcing changes to, and new features on, the Website and/or the Mobile App. If at any time, you decide that you do not wish to receive any such emails, you can opt out of receiving such emails.
c)
4Fin will share some or all of your Information with another business entity should we (or our assets) plan to merge with, or be acquired by that business entity. Should such a transaction occur then the other business entity (or the new combined entity) will be required to follow this Privacy Policy with respect to your Information.
d)
Legal Obligation: We may need to disclose your Information to law enforcement agencies, government agencies or other third parties where we are compelled so to do by court order or similar legal procedure; where we are required to disclose your Information to comply with law; where we are cooperating with an ongoing law enforcement investigation or where we have a good faith belief that our disclosure of your Information is necessary to prevent physical harm or financial loss, to report suspected illegal activity or to investigate a possible violation of our Terms.
e)
We do not sell or rent any of your Information to third parties in the normal
course of doing business and will only share your Information with third parties in accordance with this privacy policy.

VI. LINKS

The Website and/or the Mobile App contains links to other websites/apps/platforms and we are not responsible for the privacy practices of such websites/apps/platforms. 4Fin encourages its users to read the privacy policies of all websites/apps/platforms. This privacy statement applies solely to information collected by 4Fin.

VII.SECURITY OF YOUR PERSONAL INFORMATION

We hold your Personal Information on secure servers. By providing us with Personal Information, you consent to the transfer of your Personal Information to, and its storage on, our secure servers. We protect it on the Platform against loss, misuse or alteration by taking extensive security measures. In order to protect your Personal Information, we have implemented adequate technology and will update these measures as new technology becomes available, as appropriate. All Personal Information is securely stored on a secure cloud setup and all communication happens via bank-grade secure SSL communication channels. Though we provide appropriate firewalls and protections, we cannot warrant the security of any Personal Information transmitted as our systems are not hack proof. We take every precaution to safeguard all your Personal Information from unauthorized access, use or disclosure. However, the Internet is not a secure medium and we cannot guarantee the privacy of your Personal Information. Data pilferage due to unauthorized hacking, virus attacks, technical issues are possible and we take no liabilities or responsibilities for it.

• You must enter your username and password/OTP each time you want to access your account or make transactions on the Website and/or the Mobile App.
• Choose your password carefully using unique numbers, letters and special characters. Never share your username and password/OTP with anyone.
• If you are concerned that your username or password/OTP has been compromised, please contact our customer support team immediately and ensure you change your password by logging onto the user settings section of the Website and/or the Mobile App.
• You are responsible for all actions that take place under your User account. If you choose to share your User account details and password/OTP or any Personal Information with third parties, you are solely responsible for the same. If you lose control of your User account, you may lose substantial control over your Personal Information and may be subject to legally binding actions.

VIII. SHARING OF INFORMATION

Where PI/SPDI is required to be shared, arising out of any contractual obligation, 4Fin shall part with such PI/SPDI only in accordance with your consent for the same. To the extent necessary to provide you the requested services or to the extent required under applicable law, we may provide your PI/SPDI to the following third parties without notice to you:

• Entities like auditors, authorized vendors etc on a ‘need to know’ basis under a Non-Disclosure Agreement;
• – Governmental authorities, in such manner as permitted or required by applicable law;

IX. RETENTION AND REVOCATION OF INFORMATION

Your PI/SPDI will be retained with 4Fin as long as you avail our Services. We may retain your information for such a period as may be necessary under applicable law. In the event, you wish to no longer avail our Services or intend to request that 4Fin no longer retain your PI/SPDI or where you intend to modify the current PI/ SPDI, you may contact 4Fin as provided herein below. Please note, however, that there might be delay in deleting Personal Information from our servers and backed-up versions might exist even after deletion.

X. ACCESSING, CORRECTING, OR DOWNLOADING YOUR PERSONAL INFORMATION

You have the right to seek access to your Personal Information owned by 4Fin. Unless an exception applies, we must provide you with access to the Personal Information we keep about you within a fair timeframe and at no cost, unless an exception applies.

XI. GRIEVANCE OFFICER

In accordance with the Information Technology Act, 2000 and the rules made thereunder, any questions, disputes, opt-out requests, grievances with respect to
the processing of PI or SPDI can be referred to the Data Privacy and Grievance officer designated by 4Fin as below:

Name: Chetan Sakate
Contact Number: +91-895607-7440
Email ID: chetan.sakate@4fin.in

XII. Our Partners

U GRO Capital limited