This privacy policy (referred to as the "Policy") is aligned with the Information Technology Act, 2000, the Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011, as well as relevant guidelines and regulations issued by the Reserve Bank of India (RBI). The Policy outlines the collection, usage, storage, and disclosure of information obtained from individuals (referred to as "You," "Your," or "User") when visiting and utilizing the Platform (defined further). It also covers the rights and choices available to You concerning the collected information. RBS Nidhi Limited and its affiliates, successors, and assigns (referred to as "Phone Touch Finance," "We," "Us," or "Our") are committed to protecting the collected information in accordance with this Policy.

Phone Touch Finance is the owner and operator of a website accessible at www.phonetouchfinance.in, as well as a mobile application known as 'Phone Touch Finance' (collectively referred to as the "Platform").

This Policy serves as a legally binding agreement between You, the User of the Platform, and Phone Touch Finance, the owner of the Platform. It is important to clarify that the term "User" refers to any individual who visits, uses, or conducts transactions through the Platform. You are eligible to access and utilize the Services provided on the Platform only if you are a natural person, a citizen of India, and at least twenty-one (21) years of age.

This Policy takes precedence over any previous communication regarding this topic and specifically does not apply to third-party websites or applications that are linked to the Platform, as well as stores from where You download the Phone Touch Finance mobile application. We strongly advise You to carefully review the terms and conditions of these third-party websites, stores, and applications, and utilize or access them at Your own discretion. Phone Touch Finance holds no liability or responsibility for the actions or omissions of such third-party websites, applications, or stores, as Phone Touch Finance has no control over them.

By visiting or accessing the Platform and willingly providing Us with information, including personal information and sensitive personal information, You are giving Your consent for Us to use the information in accordance with this Policy.

IF YOU DO NOT AGREE WITH THE TERMS AND CONDITIONS OF THIS POLICY, PLEASE DO NOT USE OR ACCESS THIS PLATFORM.

This Policy will be legally binding and enforceable against You in the same manner as any other written agreement.

We retain the right to amend and update this Policy at any time. It is advised that You regularly review this Policy to stay informed about the latest privacy practices implemented by Us. Any modifications or changes to this Policy will be effective immediately upon being posted on the Platform. Your continued use of the Services indicates Your acceptance of the updated Policy.

This Privacy Policy has been prepared in compliance with:

1. Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011;

2. Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021

3. Guidelines on Digital Lending issued by the Reserve Bank of India (RBI), 2022

4. Other applicable acts, regulations and rules which requires the publishing of a privacy policy for handling of or dealing in personal information including sensitive personal data or information and all applicable laws, regulations, guidelines provided by applicable regulatory authorities including but not limited to the RBI.

1. Services

Phone Touch Finance is involved in various business activities, including but not limited to providing a range of services ("Services"), such as:

1. Credit Score Service
• As Your agent, Phone Touch Finance obtains Your explicit consent and authorization to fetch Your credit report ("Report") from credit bureaus. We then share the Report with You, along with an analysis, to provide insights into Your financial health. This Report helps us evaluate Your credit health, enabling us to offer advice on ways to improve it. Our goal is to educate You about Your credit health and provide guidance to enhance it.
• Information that We Collect: To establish Your identity for the purpose mentioned, We collect the following information from You: Name, Address, Email ID, Mobile number, Age, Date of birth, Gender, PAN (Permanent Account Number). These details are collected in order to verify and authenticate Your identity accurately.
• The credit report obtained on Your behalf is provided to You and is not shared with any third party. It remains confidential and is solely for Your personal use and reference.

By providing the information as mentioned in this clause, You explicitly consent to Us using the information for the purposes outlined in this clause, in accordance with the provisions of this Policy.

2. Provision of Loan
• Phone Touch Finance has collaborated with several banks and NBFCs, collectively referred to as "Lending Partners," who provide loans. As an intermediary, Phone Touch Finance's role is to connect You with these Lending Partners, facilitating the process of accessing and obtaining products such as loans and other financial offerings that they provide. Through the platform, You can explore the various loan options available from the Lending Partners and take advantage of the financial products they offer.
• Information that We Collect: With Your explicit consent, Phone Touch Finance collects the following information from You as instructed by the Lending Partners for the purpose of processing Your loan application:
1. Identity and profile-related data: TThe collected information comprises personal particulars such as full name, parents' names, birth date, gender, photographs, educational background, loan purpose, house ownership status, employment status, company name, contact details (including addresses, email IDs, and phone numbers), and marital status.
2. KYC data: This encompasses official identification documents issued by the government or other authorized authorities, such as Aadhaar, PAN card, voter ID, and similar documents. It involves collecting and storing details related to these identification documents for verification and authentication purposes.
3. Financial data: This entails collecting information related to your past credit history, income details, details of loans applied for or issued through the Platform, payment records, repayment history, bank account details, and bank account statements. These details are collected to assess your creditworthiness, evaluate loan eligibility, and facilitate loan processing and repayment tracking.
4. Device data: This encompasses the collection of your IP addresses, browser types and versions, time zone settings, operating systems, and device information. This data is collected, transmitted, and stored on our secure phone touch finance's server to ensure the protection and privacy of the information.
5. Any other information as required by Lending Partners.

Additionally, for KYC (Know Your Customer) purposes, We may require a one-time access to Your camera for taking selfies/photos, as well as collecting KYC documents. Furthermore, We may collect any other information that is necessary and requested by the Lending Partners for processing Your loan application.

In certain cases, when we provide ancillary services to the Lending Partners as outsourced by them, we may receive information pertaining to your loan-related transactions. This information may include details related to the collection of loan dues. However, please note that we may also outsource these services to third parties who will handle the collection process. Rest assured that we will ensure the proper handling and confidentiality of the information received in accordance with our privacy practices and applicable regulations.

We do not access or retrieve any personal data from your mobile phone resources, including your contact list, call logs, telephony functions, files, and media, except as specifically mentioned above for the purpose of document upload. We also do not collect any biometric data. However, we may request access to your camera, microphone, location (fine and coarse GPS data), or any other device feature solely for the purpose of onboarding or conducting KYC (Know Your Customer) checks. Prior to accessing these features, we will obtain your explicit consent.

• Sharing of information: We share the aforementioned information with the Lending Partners and relevant third parties for the purpose of collecting the necessary documents to complete the KYC (Know Your Customer) process required for the credit product you wish to avail. This ensures that the necessary KYC requirements are fulfilled as per the regulations and guidelines set forth by the Lending Partners and relevant authorities.

  We will collect the information mentioned in this clause for application processing purposes. Before collecting such information, we will seek Your explicit consent and provide detailed information about the purpose of collection and the entities with whom the information might be shared. A consent form will be provided to You at each stage of information collection to ensure transparency and obtain Your explicit consent.

  For detailed information about Our Lending Partners, You can refer to the website links of Our Lending Partners that We publish on Our Platform. These links will provide comprehensive information about Our Lending Partners, including their offerings, terms and conditions, and any other relevant details.

3. Marketing and Promotional Campaigns
• By using the Platform and providing information about the Services, You indicate Your interest in acquiring knowledge of and availing various products, services, offers, or campaigns displayed on the Platform, including pre-approved loan offers from Our Lending Partners. When You provide information, You expressly consent to Us (including Our IVR, third-party marketing channels, and network of Lending Partners) contacting and communicating with You through SMS, calls, emails, WhatsApp, and/or other communication modes. This includes conducting follow-up calls related to the Services, such as providing information about credit products and Services, informing You about promotional offers on the Platform, and presenting offers from Our Lending Partners regarding their products and services.
• Information that We Collect: The information collected as detailed under Clause 1(b) (referring to personal information) and employment-related information as mentioned under Clause 2(b) will be collected and utilized specifically to provide the services listed in this Clause. This ensures that the collected information is used solely for the purpose of delivering the specified services.
• Sharing of information: To facilitate marketing and promotional campaigns as detailed under Clause 3, We share Your information with third parties and our network of Lending Partners. This enables them to contact You regarding these campaigns and provide relevant information about their products and services. The sharing of Your information is done to ensure effective communication and engagement with You in relation to the marketing and promotional activities outlined in Clause 3.
4. Dedicated Customer support
• For any customer support related to the Services provided by Us, You have the option to contact Us via phone or in writing. Our customer support team is available to assist You and address any queries, concerns, or issues You may have regarding the Services.
• Information that We Collect: When you write to us or call us for support in order to improve our services, we collect the following information:
• Your name
• Contact details (such as phone number, email address, or postal address)
• Details of your query, concern, or request
• Any other information relevant to the matter you are contacting Us about
• We may retain recordings of telephonic conversations between You and Our call center executives, who may be third parties, when you seek query or assistance. These recordings are maintained for quality assurance purposes, to monitor and improve customer service, and to ensure accurate and thorough handling of your queries or requests.

This information is collected in order to effectively address your inquiries, provide assistance, and ensure a satisfactory customer support experience.

• Sharing of information: To provide effective customer support services, We may share Your information with third parties and Lending Partners. This sharing of information is done to ensure that Your queries, concerns, or requests are addressed in a timely and efficient manner. By sharing Your information with these parties, We aim to provide the necessary assistance and support needed to resolve any issues or provide the desired services.

By contacting us through writing or phone calls, You provide Your explicit consent for Us to utilize the information listed in this Clause for the purposes mentioned within the same Clause. This consent allows Us to effectively address Your queries, concerns, or requests and provide the necessary support and assistance as required.

5. Cookies

Cookies are small data files that are stored on Your computer by a website. Similar to other lending marketplace websites/apps, We use cookies on Our Platform. The use of cookies allows Us to identify You, analyze User behavior, track the products that You browse on Our Platform, and enhance the user-friendliness of Our Platform. This information helps Us provide You with relevant information regarding credit products that may be of interest to You. Additionally, We may use this information to display advertising from third-party companies. You will always have the option to decline cookies, but please note that choosing to do so may impact the Services provided to You.

6. Your rights

With regard to the information collected by Us to provide Services, You have the following rights available to You:

1. Right to deny

You have the option to deny providing any information that is required by Us. However, please note that this may limit our ability to provide you with certain Services or fulfill your requests.

You also have the right to restrain Us from sharing your information with Lending Partners or third parties, if applicable. However, please be aware that this may impact our ability to connect you with relevant products and services or provide you with certain features.

Furthermore, you have the right to deny the storage of your information or not provide Us with the right to contact you. However, please note that this may restrict our ability to provide you with personalized assistance and support.

It is important to consider these factors and the potential impact on the services and support we can provide before exercising these options.

2. Right to Withdraw Consent

You have the right to withdraw your consent for the use of your information at any time. If you choose to withdraw your consent, we will no longer process your information for the purposes for which you originally provided consent, unless there are other legal grounds for us to do so.

Additionally, you have the right to request the deletion or erasure of your personal information, also known as the right to be forgotten. If you exercise this right, we will take reasonable steps to remove your information from our records, unless there are legal obligations or legitimate reasons that require us to retain it.

To withdraw your consent or exercise your right to be forgotten, please contact us using the contact details provided in this Policy. We will process your request in accordance with applicable laws and regulations.

3. Right to rectify

You have the right to request the rectification or correction of any inaccurate or incomplete personal information we hold about you. If you believe that the information we have is incorrect or needs updating, you can contact us and provide the necessary corrections or updates. We will review your request and make the appropriate amendments to ensure the accuracy and completeness of your personal information.

7. Storage and security of information

We are committed to ensuring the storage and security of the information we collect from you. We implement reasonable technical and organizational measures to protect your personal information from unauthorized access, disclosure, alteration, or destruction. We follow industry-standard security practices and regularly review and update our security measures to ensure the ongoing protection of your information.

Your information is stored on secure servers and is only accessible to authorized personnel who have a legitimate need to access it. We also have strict internal policies and procedures in place to safeguard your information.

However, it is important to note that no method of transmission or storage over the internet is completely secure. While we strive to protect your personal information, we cannot guarantee its absolute security. Therefore, we encourage you to take appropriate precautions to protect your information, such as using strong and unique passwords and keeping them confidential.

If you have any concerns about the security of your information, please contact us using the contact details provided in this Policy.

We utilize various storage and security technologies to safeguard the information we collect. Some examples of storage and security technologies we may employ include:

• Encryption: We use encryption techniques to protect sensitive data during transmission and storage. This helps to ensure that the information remains confidential and secure.
• Firewalls: We employ firewalls to create a barrier between our internal systems and external networks, helping to prevent unauthorized access and potential security breaches.
• Secure Socket Layer (SSL) or Transport Layer Security (TLS): We may use SSL or TLS protocols to establish secure connections between your device and our servers. This helps to encrypt data transmitted between you and our platform, enhancing its security.
• Intrusion Detection and Prevention Systems (IDPS): We may utilize IDPS technologies to monitor network traffic and identify any suspicious activities or potential security threats. This enables us to take proactive measures to protect against unauthorized access.
• Access Controls: We implement access controls and user authentication mechanisms to ensure that only authorized individuals have access to sensitive information. This includes using unique login credentials, role-based access controls, and multi-factor authentication.

These are just a few examples of the storage and security technologies we may employ to safeguard your information. We continually assess and update our security measures to stay aligned with industry best practices and protect your data to the best of our abilities.

8. Confidentiality Agreement

We may share Your data with third parties for various purposes related to providing and improving Our Services, enforcing our Terms & Conditions, or in the context of corporate divestitures or mergers. Additionally, we may use or assign Your information to protect the rights, property, or safety of Us, Our Users, or others. However, in cases where sharing information is required by regulatory or statutory authorities, we may be obligated to comply.

When sharing Your data with third parties, We ensure that they are bound by a confidentiality agreement that restricts them from further disclosing the information, unless it is necessary for the provision of the agreed-upon Services outlined in the confidentiality agreement.

We strive to ensure that the third parties with whom we share Your information maintain a level of protection that is at least equivalent to the standards set forth in applicable laws. However, We cannot be held responsible for any breach of security or actions taken by third parties that receive Your personal information.

It is important to review Our Privacy Policy and understand the extent of Our responsibility and the measures We take to protect Your information.

9. Phishing

Phishing refers to fraudulent activities where individuals or entities attempt to deceive and trick others into providing sensitive information such as passwords, credit card details, or personal information. This is typically done through deceptive emails, websites, or messages that impersonate legitimate organizations or individuals.

10. Severability and Exclusion

We have made diligent efforts to ensure that this Policy complies with applicable laws, rules, and regulations. If any part of this Policy is deemed invalid or unenforceable, it will not affect the validity or enforceability of the remaining portions of the Policy.

It's important to note that this Policy only applies to the information collected by Phone Touch Finance through the Platform. It does not extend to any unsolicited information that You provide to us through the Platform or any other means. This includes information posted in public areas of the Platform. Any unsolicited information will be considered non-confidential, and Phone Touch Finance will have the freedom to use and disclose such information without any limitations.

11. No Waiver

The failure or delay by either party to enforce any provision of this agreement shall not be construed as a waiver of that provision or the right to enforce it at a later time. Any waiver of a provision of this agreement must be in writing and signed by the party granting the waiver. Waiver of a breach of any provision shall not constitute a waiver of any subsequent breach of the same or any other provision.

12. Governing Law and Dispute Resolution

This Policy is subject to the governing laws and jurisdiction as specified in the 'Terms and Conditions'. The interpretation and enforcement of this Policy will be carried out in accordance with those laws and the designated courts mentioned in the 'Terms and Conditions'.

13. Applicability of local laws

By browsing or using the Platform, You acknowledge that Phone Touch Finance is incorporated and registered under the Companies Act, 2013, with its registered office located in Kolkata, India. You further acknowledge that Phone Touch Finance is not responsible or liable to comply with any local laws of Your territory outside of India.

14. Grievance Redressal

If You have any grievance regarding Your personal information, please direct your concerns to the Grievance Redressal Officer (GRO). The contact details of the GRO are provided below:

Name of the Grievance Redressal Officer: Mr. Uttam Makur

Email Address: grievance@phonetouchfinance.in

Phone Number:

Office Address: Astra Towers, ANO-805, Action Area IIC, Newtown, New Town, West Bengal 700135

You can reach out to the GRO for assistance and resolution of your grievances related to your personal information.