ELAI Privacy Policy

Last Update: July 1, 2022

PLEASE READ THIS POLICY CAREFULLY BEFORE USING THE APP

This privacy policy ("Privacy Policy") is incorporated into and subject to the Terms of Use. All capitalized terms for which definitions have not been provided in this Privacy Policy shall have the meaning ascribed to them in the Terms of Use.

PLEASE READ THIS PRIVACY POLICY CAREFULLY. THIS POLICY DESCRIBES THE WAY THE COMPANY OR ITS VENDORS ("WE", "US", "OUR") COLLECT, STORE, SECURE, AND USE YOUR PERSONAL INFORMATION. YOU ACCEPT THIS PRIVACY POLICY BY VISITING OUR PLATFORM OR THROUGH AVAILING ANY OF HER SERVICES THROUGH THE PLATFORM. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, YOU MAY NOT AVAIL THE SERVICES

This Privacy Policy is subject to change at any time without notice. You are responsible for regularly reviewing this Privacy Policy so that you will be apprised of any changes. ELAI AGRI TECH PRIVATE LIMITED ("US", "WE", "ELAI”, "Company") are committed to protecting and respecting your privacy.

SCOPE OF POLICY This policy together with our Terms of Use applies to your use of:

1. ELAI mobile application ("Application" or "App") hosted on the Google Play Store ("App Site") once you have downloaded or streamed a copy of the App onto your mobile telephone or handheld device: ("Device").

2. Any of the services accessible through the App ("Services") those are available on the App Site or other sites of ours.

("Services Sites"). This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.

CONSENT

By affirming your assent to this Privacy Policy, you provide your consent to such collection, use, storage, processing and disclosure as set out in this Privacy Policy and the Terms and Conditions. The Information received by ELAI will not be shared with any third party or third-party service providers for the purposes of advertising or marketing. ELAI will only be using the information for providing Services to you. By accessing our services, you agree to this privacy policy. This document supersedes any prior communication on this topic and reflects the entire and exclusive policy for this service.

INFORMATION WE MAY COLLECT FROM YOU

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. We may collect and process the following data about you:

1. Information we collect about you and your device: We collect information from the device when you download and install the App and explicitly seek mandatory permissions from you to get the required information from the device. When you install the App, we store the information and we collect with unique identifiers tied to the device you are using. Each time you use our apps we may automatically collect the following Information:

User Personal Information: ELAI collects and stores your name, mobile number as part of our registration process.

How we use this data: We use this data to uniquely identify, register and enable you to use our app. We collect your mobile number for the purpose of checking active SIM status, uniquely identifying you and preventing frauds and unauthorized access.

SMS Information: ELAI doesn't collect, store or read personal SMS from your Inbox. We collect, store and monitor only Financial and Transactional SMS sent by 6 digit alphanumeric senders. This also includes your historical data. We use secure APIs to intermittently send this information to our servers. You will not be able to use this app if you disable this access.

How we use this data: We use this data to identify bank related transactions, name of transacting parties, description of the Transaction, amount of transaction for performing credit assessment. This data is used to provide the best loan offers, and to keep the loan process convenient risk and seamless. We store this financial information on our secure servers.

Installed Apps Data: ELAI collects, stores and monitors each installed applications metadata information that includes application and package name, installed and updated time, version name and version code for all applications installed on your device.

How we use this information. We use this to assess your creditworthiness and provide you with pre-approved customized loan offers.

Device Data: ELAI collects, stores and monitors specific information about your device including your hardware model, RAM, storage; unique device identifiers like IMEI, serial number, SSAID, SIM information, that includes network operator, roaming state, MNC and MCC codes, WIFI information that includes MAC address and mobile network information.

How we use this data: We use this data to uniquely identify devices and to prevent fraud. This also helps in enriching your credit profile and providing you with the best loan offers according to your profile.

Location Data: ELAI collects, stores and monitors the location data of your device when you enable us to do so.

How we use this data. We use this data to provide you with better loan offers, to verify addresses for KYC, reduce risk associated with your loan application and also to prevent any Fraud.

Storage: ELAI requires storage permission so that your KYC and other relevant documents can be securely downloaded and saved on your phone. You can then easily upload the right KYC related documents for faster loan application details filling and disbursal process. This ensures that you are provided with a seamless experience while using the application.

Usage Data: ELAI collects, monitors and stores details of your use of any of our Apps including but not limited to, traffic data, location data, weblogs and other communication data (Log Information). We collect data about how you interact with our services.

How we use this data. We use this data to improve our app performance, to enable support and create better product offerings for you.

2. Information you give us about you (submitted information): In due course of using our services, you are required to submit data to enable our services. We use this data to create your profile and provide you with the best available services. Mentioned below are the data we collect from you:

Data provided by you by filling in forms in the App.

Data provided by corresponding with us (for example, by e-mail or chat).

Data and information you provide when you register to use the App Site, download or register an App, subscribe to any of our Services (such as applying for a loan), search for an App or Service, enter a competition, promotion or survey, and when you report a problem with an App, our Services, or any of our Sites.

Data including your name, address, gender, date of birth, e-mail address, phone number, username, password and other registration information, PAN Card, Aadhaar Card, financial information such as employer name, monthly salary, bank account no., bank statements, credit information, copies of identification documents, biometric information, digital signature keys, personal description and photographs.

Data generated by your usage of our app.

How we use this data. This data helps us create your profiles, complete mandatory KYC, unlock and approve loans and provide you customized support in case of issues.

3. Information we receive from other sources ("Third Party Information"): We may collect information about you from a limited number of third parties such as credit bureaus and other identity verification and fraud prevention services. You may choose to provide us access to certain third parties like credit information companies, the UIDAI servers for e-KYC and e-Sign services, social media sites, banks and financial institutions with whom you maintain a banking relationship. This information we collect from such third party sources is governed by your privacy policies agreed with those sources and with your express consent.

How we use this data: This data helps us create your profiles, complete mandatory KYC unlock and approve loans and provide you customized support in case of issues.

4. Unique application numbers: When you install or uninstall a Service containing a unique application number or when such a Service searches for automatic updates, that number and information about your installation, for example, the type of operating system, may be sent to us.

How we use this data. This data helps us to uniquely identify you and prevent frauds or unauthorized access.

TRACKING & COOKIES

We may use mobile tracking technologies and to distinguish you from other users of the App, App Site, Appstore or Service Site. The cookies are either used to improve the quality of the portals or for storing your preferences as a user, improving search results and tracking user trends.

USES MADE OF THE COLLECTED INFORMATION

We may associate any category of information with any other category of information and will treat the combined information as personal data in accordance with this policy for as long as it is combined. Information collected by us shall be used to:

1. Perform background verification including satisfying the KYC due diligence as mandated by the Reserve Bank of India and to perform credit checks on the customer;

2. Determine whether or not to provide a loan to the customer, the amount of such loan and the terms and conditions applicable to such loan;

3. Provide effective Services to the customer and assist in the event he/she needs additional support; and

4. Comply with our legal or statutory obligations.

5. Analyze the app performance, create and serve best products

6. Send communications, notifications regarding the products, offerings, loans, collections

We do not disclose information about identifiable individuals to other parties, but we may provide them with anonymous aggregate information about our users (for example, we may inform them that 500 men aged under 30 have applied for a loan on any given day).

DISCLOSURE OF YOUR INFORMATION

We may disclose some or all of the data we collect from you when you download or use the App to credit reference bureaus. We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries.

We may disclose your personal information:

1. With financial service providers, banks or NBFCs and our third party partners for facilitation of a loan or facility or line of credit or purchase of a product

2. With employees, affiliates, vendors, partners and third parties as may be required to offer the Company's Services;

3. If we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request;

4. With other corporate entities and affiliates to help detect identity theft, fraud and other potentially illegal acts, verify your KYC details, retrieve your credit information / bank account details to prevent abuse of our Services, provide customer service and support and resolve disputes;

5. In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;

6. If ELAI or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets; and/or

7. In order to enforce our Terms and Conditions and other agreements or to investigate potential breaches; report defaulters to any credit bureau; or for the purpose of publishing statistics relating to the use of the App, in which case all information will be aggregated and made anonymous.

SECURITY

The Company has stringent security measures in place to protect against the loss, misuse, and alteration of the information under our control. Our servers are accessible only to authorized personnel and your information is shared with employees and authorized personnel on a 'need to know' basis. All backups are encrypted. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

We follow generally accepted standards (secure techniques over HTTP APIs) to protect the information, during transmission and reception.

All communications are encrypted, enabling client and server applications to communicate in a way that is designed to prevent eavesdropping, tampering and forgery. Unfortunately, the transmission of information via the internet is not completely secure. We protect and maintain the security of your ELAI accounts and sessions using firewalls, encryptions, authentications, among others. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to Our Sites; any transmission is at your own risk.

By using this App, you agree that the Company will have no liability for disclosure of your information due to errors in transmission, infrastructure failures by the Company or any intermediary (including telecom and internet service providers), or unauthorized acts of third parties.

DATA RETENTION AND DELETION

We at ELAI promise to protect your personal data from unauthorized access, misuse, and disclosure using the right security measures based on the type of data and how we are processing the same. We retain information about you to provide a seamless experience, to contact you in case of support required and about your account, to detect, mitigate, prevent, and investigate fraudulent or illegal activities. We retain your data for as long as necessary to provide you with our services. We may also retain and use your personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Subject to this section, we may delete your data upon reasonable written request for the same. However, you may not be able to use our services after deletion.

YOUR RIGHTS

We will use your data for the purposes of compiling statistics relating to our user base or loan portfolio and may disclose such information to any third party for such purposes, provided that such information will always be anonymous.

Should we wish to use your information for marketing purposes, we will inform you prior to such use. You shall be entitled to prevent such usage by informing us, within 10 days of being informed of the proposed use, that you do not wish to disclose such information. You can also exercise the right at any time by contacting us at help@elai.app

THIRD PARTY SERVICES

We use third party services providers to help us execute functionalities of our app. These services may include:

1. Validating data provided by you

2. Validating Bank Account providing by you

3. EMandate to setup Auto-debit

4. Analysing user behaviour to enable marketing

Usage of such service providers is subject to their privacy policies. We share limited information with them. We recommend you to have a look at their privacy policies.

THIRD PARTY SDK

By accepting the terms and conditions, you grant complete and unconditional consent to ELAI for using your information and sharing with entities associated with us or with a third party, provided they have undertaken to ensure the same level of data protection.

ELAI app has a link to a registered third party SDK that collects data on our behalf and is stored to a secured server to perform a variety of services such as analyzing your in-app actions, serving retargeting ads, sending personalized push notifications, and performing credit assessment based on your information among others.

We do not sell or misuse your data. We do not share your identifiable data and Government IDs such as PAN Card, Aadhaar Card with these parties. We also don't allow unauthorized access to your non-public personal contacts or financial transaction SMS data with any third party.

UPDATES TO PRIVACY POLICY

We reserve the right to modify this policy at any time, so please review this frequently. Changes and modifications will take effect immediately upon their posting on the portal. Any continued use of the services shall signify your acceptance of such new or updated policy, as the case may be.

Keeping in mind the Information Technology Act 2000 and rules listed, if you have any questions, concerns or grievances regarding this Privacy Policy, please email us at our grievance email-address: grievance@elai.app