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Edgro Privacy Policy

PRIVACY POLICY

 

Edgro Finance Private Limited (“Company”or “Edgro”)) is a Non-Banking Financial Company (“NBFC”)registered with the Reserve Bank of India (‘RBI’) under theSection 45-IA of the Reserve Bank of India Act, 1934, and has its registeredoffice at No.1613 and 1614, 7th Cross, 19th Main,1st Sector HSR Layout, Bangalore- 560102, Karnataka. Edgro, asan NBFC, is engaged in the business of providing loan/ credit facilities to itsCustomers itself or through its Lending Partner(s) and the Company owns,manages and operates its mobile application and its website available athttps://edgrofin.com/

 

This Privacy Policy (“Policy/Privacy Policy”)details the guidelines and procedures adopted by the Company in relation to thecollection, storage, use, processing, and disclosure of data/ information thatits Customers, including You, have chosen to share upon visiting, downloadingand using the Company’s App/ mobile application or its website or DigitalPlatform. Please read this Policy carefully to understand theCompany’s policies and practices regarding Your information and how it will betreated in accordance with this Policy

This Privacy Policy has been drafted inaccordance with the Information Technology Act, 2000, the InformationTechnology (Reasonable security practices and procedures and sensitive personaldata or information) Rules, 2011, Information Technology (IntermediaryGuidelines and Digital Media Ethics Code) Rules, 2021 to the extent applicable,and applicable RBI guidelines and regulations.

 

The services offeredto You through the Company, or its Digital Platform are referred to as “Services”.Please note that capitalised terms shall have the same meaning ascribed to themunder definitions in Paragraph 1 of this Policy. By visiting and accessing theDigital Platform and/ or downloading the App or by using all or any part of theServices, You are expressly agreeing to and consenting to the terms of thisPolicy and, by any use of the Digital Platform, You shall be deemed to havegiven Your consent for the processing of Your Personal Data as set out in thisPolicy agree to the terms of this Policy.

 

THIS POLICY CONSTITUTES A LEGAL AGREEMENTBETWEEN YOU, AS THE CUSTOMER OF THE COMPANY DIGITAL PLATFORM & SERVICES,AND THE COMPANY.

YOU MUST BE A NATURAL PERSON, CITIZEN OFINDIA WHO IS ATLEAST 18 YEARS OF AGE AND ELIGIBLE TO ENTER INTO A BINDINGCONTRACT UNDER THE INDIAN CONTRACT ACT, 1872.

BY ACCEPTING THIS PRIVACY POLICY AND OUR TERMS OF USE, YOUEXPRESSLY CONSENT TO OUR USE, ACCESS AND PROCESSING OF YOUR PERSONALINFORMATION IN THE MANNER PRESCRIBED IN THIS PRIVACY POLICY.

THIS POLICY SUPERSEDES ANY PREVIOUSCOMMUNICATION ON THIS SUBJECT MATTER AND DOES NOT APPLY TO THIRD-PARTY WEBSITESAND APPLICATIONS THAT ARE CONNECTED VIA LINKS TO THE WEBSITE. YOU ACCESSTHIRD-PARTY APPLICATIONS AND WEBSITES AT YOUR OWN RISK AND WE ARE NOT LIABLE ORRESPONSIBLE TO YOU FOR ANY THIRD-PARTY APPLICATIONS AND WEBSITES.

THE COMPANY MAY AMEND/MODIFY THIS PRIVACY POLICY FROM TIME TOTIME. WE URGE YOU TO PERIODICALLY REVIEW THEPOLICY FOR THE LATEST INFORMATION ON OUR PRIVACY PRACTICES. CHANGES ANDMODIFICATIONS TO THIS POLICY WILL TAKE EFFECT IMMEDIATELY UPON POSTING ON THECOMPANY’S DIGITAL PLATFORM. ANY CONTINUED USE OF THE COMPANY SERVICES SHALLSIGNIFY YOUR ACCEPTANCE OF SUCH UPDATED POLICY.

 

  1. DEFINITIONS OF VARIOUS TERMS USED IN THE PRIVACY     POLICY

1.1 ‘We’ or “us” or “Our” shall mean Edgro, its Lending Partners andtheir LSPs and DLAs.

1.2 ‘Customer’ or ‘You’ or ‘Your’ and‘Yourself’ shall mean theprospective and current customers of the Company (including representatives ofthe customers) and visitors to the Company’s Digital Platform whether theWebsite or the App.

1.3 'RBI' shall mean the Reserve Bank of India.

1.4 ‘Digital Lending App’ or ‘DLA’ or ‘App’ shallmean the mobile and web-based applications with user interface that facilitatedigital lending services. DLAs will include apps of the Company as well asthose operated by LSPs engaged by the Company for extending any creditfacilitation services in conformity with extant outsourcing guidelines issuedby the RBI.

1.5 ‘Collected Information’ shall mean a part orwhole of Sensitive Personal Information, Personal Information, and otherinformation pertaining to You received/ collected by us as per this Policy.

1.6 ‘Cookies’ shall mean bits ofdigital/ electronic information that can transfer to Your hard drive, mobiledevice, or other device to keep records of Your use or visit to the DigitalPlatform.

1.7 ‘Device’ or ‘Your Device shallmean Your computer or laptop or mobile phone, computer system, computernetwork, data, computer database or software.

1.8 ‘Device Information’ shall mean uniquedevice identifier such as IMEI number, contact lists (wherever voluntarilyprovided by You), technical data about Your Device including details regardingassociated applications and their usage details.

1.9 ‘Digital Platform’ shall mean theDigital Platforms owned/ used by Edgro Finance Private Limited and/ or BluebearTechnology Private Limited, including the Company’s Website available at https://edgrofin.com/, https://propelld.com/, the Company’s mobile application (“App”) ifany, related online services and digital/ electronic media.

1.10 ‘Lending Partner(s)’ shall mean thoseregulated entities registered with the RBI which have partnered with theCompany to offer loan/ credit facilities to a Customer through the Company byway of a co-lending arrangement or otherwise.

1.11 ‘Lending Service Provider’ (“LSP”) shall meanan agent of the Company which carries out one or more of lender’s functions orpart thereof in customer acquisition or underwriting support or pricingsupport, servicing/ monitoring of loan accounts, recovery of specific loan orloan portfolio on behalf of the Company in conformity with extant outsourcingguidelines issued by the RBI.

1.12 ‘Location Information’ shall meaninformation that may be collected by the Digital Platform that identifies Yourphysical location. This information may be collected from Your Device’slocation-aware features when You request certain services that are dependent onYour physical location.

1.13 ‘Personal Information’ or ‘PersonalData’ shall mean any data/ information that relates to a naturalperson, which, either directly or indirectly, in combination with otherinformation available or likely to be available with the Company, assists inidentifying such person. It also refers to information/ data that identifiesYou (whether directly or indirectly), such as information You may provide informs, surveys, online applications or similar online fields available on theDigital Platform. The ‘Personal Information’ or ‘PersonalData’ for the purpose of this Policy shall include the following:

(a) Your full name/ previous names.

(b) Your postaladdress,

 

(c) Your email address

(d) Your mobile/ telephone number

(e) Your domicile.

(f) Your nationality.

(g) Your date of birth.

(h) Details of Your family.

(i) Details of Your educational qualification, Your college/university etc.

(j) Details of Your profession, employment etc.

1.14 ‘Sensitive Personal Information’ of aperson shall mean ‘Sensitive Personal Data or Information’ asdefined in the ‘Information Technology (Reasonable security practices andprocedures and sensitive personal data or information) Rules, 2011’ (“SPDIRules”) and such ‘Sensitive Personal Information’ for the purpose ofthis Policy shall consist of the following information relating to You:

(a) Password.

(b) Financial information such as Bank account or credit card ordebit card or other payment instrument details or loan & its repaymentdetails.

(c) Physical, physiological and mental health condition

(d) Sexual orientation.

(e) Medical records and history.

(f) Biometric information.

(g) Any such information relating to the above clauses received/collected by the Company for providing the Services; and

(h) Any of the information received/ collected under aboveclauses by the Company for processing, stored or processed under lawfulcontract or otherwise.

However, any information that is freely available or accessiblein public domain or furnished under the Right to Information Act, 2005 or anyother law for the time being in force shall not be regarded as sensitivepersonal data or information for the purposes of these rules.

1.15 ‘Services’ shall mean theservices offered by the Company or by the Company’s Lending Partner(s) to Youon or through the Digital Platform, whether the Website or the App.

1.16 ‘Website’ shall mean the Company’s websiteavailable athttps://edgrofin.com/orhttps://propelld.com/.

  1. INFORMATION COLLECTION

2.1 Collection of Personal Information and Sensitive PersonalInformation- When You use the Digital Platform, whether the Website or theApp, We may collect and store Your Personal Information and Sensitive PersonalInformation, from time to time, with Your explicit consent. Our primary goal indoing so is to provide You with a safe, efficient, smooth, and customizedexperience and services. This allows us to provide services and features thatmeet Your needs and customize the Digital Platform to make Your experiencesafer and easier and improve the services provided by us. 

In general, You can browse the Website or App without telling uswho You are or revealing some of the Personal Information about Yourself.However, to create an account on the Website or the App or start a businessrelationship, You must provide us with the certain basic information requiredto provide customized services. The information We/ DigitalPlatform collect from You, inter alia, may include the following data/information:


(i) Your Personal Information.

(ii) Your Sensitive Personal Information.

(iii) Your Permanent Account Number (“PAN”) details, AadhaarNumber (subject to the statutory requirements relating to Aadhaar Number andits masking), copy or details of Identity Proof & Address Proof andphotograph(s).

(iv) Income, financial data and transaction data pertaining toYou collected, with Your consent, from Your bankers, Your lenders, Youremployer and the entities/organisations.

(v) Credit Information pertaining to You provided by You orreceived from Credit

Wherever possible, We shall indicate the mandatory and theoptional fields. You shall always have the option to not provide Your PersonalInformation/ Sensitive Personal Information by choosing not to use a particularservice or feature on the Digital Platform. 

By using the Services and the Digital Platform, it would bedeemed that You had given specific consent to us to collect, store, analyze,use, and otherwise exploit (including for commercial reasons) Your PersonalInformation and Sensitive Personal Information. While You can browse somesections of the Digital Platform without being a registered member as mentionedabove, certain activities (such as availing of loans from the Company’s LendingPartner(s) on the Digital Platform) require registration and for You to providethe above details. The Digital Platform shall clearly display the PersonalInformation and Sensitive Personal Information it is collecting from You, andYou have the option to not provide such Personal Information/ SensitivePersonal Information. However, this will limit the services provided to You onthe Digital Platform. Further, You specifically consent to share Your SensitivePersonal Information and Personal Information for the usage of Services on theDigital Platform.

2.2 Collection of SMS/ WhatsApp Messages/ Messages with FinancialInformation- We don’t collect or store Your personal SMS/ WhatsApp Messages/Messages. However, We (through the Digital Platform) may collect, store,analyze, and process, Your SMS/ WhatsApp Messages/ Messages containingfinancial information/ data to the Digital Platform’s/ Our servers, which helpsus in identifying the various bank accounts, financial status and repaymentcapacity, for the purpose of performing credit risk assessment, assessing Yourcredit worthiness, and assigning a line of credit faster.

2.3 Collection of Mobile Number and E-mail Address- When Yousign up with us, We collect Your mobile number and email address to uniquelyidentify You. This helps us ensure that no unauthorised device or person isacting on Your behalf.

2.4 Collection of Device Information- Our Appcollects information from Your Device that includes the IMEI number, modelnumber, OS details, mobile network information and Wi-Fi information to provideadditional security so that no unauthorized devices act on Your behalf toprevent fraud.

2.5 Collection of Location- We may collect andmonitor the location information from Your Device to provide more suitableproducts and more efficient services. This may also help us to verify Yourlocation/ address and make a better credit risk decision. We shall be granted aone-time access for the purpose of collection of Device location only in theevent, the same is required for KYC/on-boarding purposes

2.6 Camera- We may require a one-time camera accessso that You could easily scan any document or scan any QR code to initiate duediligence from Know Your Customer (“KYC”) perspective orpayment or video verification or verification of KYC documents and otherdocuments. 

2.7 Collection of Usage Information- Weautomatically track certain information about You based on Your behaviour onthe Digital Platform. We use this information to do internal assessment of Yourdemographics, interests, and behaviour to better understand, protect and serveYour as a user and improve the Services offered by Edgro or its LendingPartner(s). This information is compiled and analysed, including on anaggregated basis. We also collect Your Internet Protocol (IP) address and theURL used by You to connect Your computer to the internet, etc. This informationmay include the URL that You just came from (whether this URL is on thePlatform/ Website/ App or not), which URL You next go to (whether this URL ison the Digital Platform/ Website/ App or not), Your computer browserinformation, and Your IP address.

If You choose to select any product through the DigitalPlatform/ Website/ App, We collect information about Your product choices andpreferences. We retain this information as necessary to resolve disputes,provide customer support and troubleshoot problems as permitted by law. If Yousend us personal correspondence, such as emails or letters, or if other usersor third parties send us correspondence about Your activities or postings onthe Digital Platform/ Website/ App, We collect such information into a filespecific to You.

  1. PURPOSE, USAGE AND DISCLOSURE OF THE COLLECTED     INFORMATION

3.1 The primary purpose of collecting Your information is to provideYou with the Services. We access, store and use the information We collect toprovide the Services, research and develop new ones. We use Your PersonalInformation, Sensitive Personal Information and other Collected Information toprovide the services You request, customize Your user experience and improveOur services. 

To the extent We intend to use Your Personal Information/Sensitive Personal Information to market/ propose any product to You, We willprovide You with the ability to opt-out of such uses. In Our efforts tocontinually improve Our product and service offerings, We collect and analyzedemographic and profile data about Our Customers' activity on the DigitalPlatform/ Website/ App. We will use and retain Your information for suchperiods as necessary to provide You with the Services, comply with Our legal/ regulatoryobligations, resolve any disputes, and enforce Our agreements/ contractualrights.

3.2 Edgro may use and disclose the Collected Information (to itsrepresentatives and its Lending Partner(s)/ Agent(s) etc.) in the various waysto achieve the objectives such as the following: 

(i) To register You as a user of the Digital Platform.

(ii) To establish identity and verify the same.

(iii) To monitor, improve and administer the Digital Platform.

(iv) To provide the Services offered by us or by the Company’sLending Partner(s) including

credit profiling for the purpose of facilitating loans to You.

(v) To design and offer customized products and services offeredby the Company’s third-

party Lending Partner(s).

(vi) To analyse how the Digital Platform/ Website/ App is used,diagnose service or technical

problems and maintain security.

(vii) To send communications notifications, informationregarding the products or Services

requested by You or process queries and applications that Youhave made on the Digital

Platform/ Website/ App.

(viii) To manage Our relationship with You and inform You aboutother products or Services

which as per us may be useful to You.

(ix) To conduct data analysis in order to improve the Services/Products provided to You or a

Customer.

(x) To use the Collected Information in order to comply with theapplicable laws and

regulations.

(xi) To conduct Your due diligence including KYC due diligencefor the Company’s third-party

Lending Partner(s) based on the information shared by You.

(xii) To use the Collected information in other ways permittedby law to enable You to take

financial services from the Company’s Lending Partner(s).

(xiii) To detect and protect us against suspicious or illegalactivity, fraud and other criminal

activity.

(xiv) To resolve disputes or troubleshoot problems.

3.3 In addition to the above, the Collected Information may be used byus for the following purposes:

(i) To provide personalised offers.

(ii) To manage Our relationship with You, including notifyingYou of changes relating to any

of the Services.

(iii) To administer and protect Our business and the DigitalPlatform, including

troubleshooting, data analysis, system testing, and performinginternal operations.

(iv) To deliver content.

(v) To send You communication, including through WhatsAppbusiness messages, in

relation to Your use of the Digital Platform or the Services.

(vi) To monitor trends so we can improve the Digital Platformand the Services.

(vii) To improve Our business and delivery models.

(viii) To perform Our obligations that arise out of thearrangement the Company and its

Lending Partners are about to enter or have entered with You.

(ix) To enforce Our Terms and legal requirements.

(x) To perform collection related activities.

(xi) To undertake marketing services, including sending Youpromotional messages.

(xii) To respond to court orders, establish or exercise Ourlegal rights, or defend Ourselves

against legal claims.

3.4 Edgro will not use the Collected Information for any purpose otherthan in connection with the Digital Platform or beyond the provisions of thisPolicy.

Edgro will not rent, sell or share the Collected Information andwill not disclose any of Personal Information or Collected Information to thirdparties, unless:

(a) it is pursuant to obtaining Your consent.

(b) it is in connection with the Services being rendered throughthe Digital Platform.

(c) it is to help investigate, prevent or take action regardingunlawful and illegal activities.

(d) it is to investigate suspected fraud, potential threat tothe safety or security of any

person, violations of the Digital Platform’s/ Edgro’s Terms& Conditions, or as defence

against legal claims.

(e) if it forms part of the information, Edgro shares withadvertisers on an aggregate basis.

However, Edgro shall not share/ disclose Your Sensitive PersonalInformation to any third party unless it has Your prior permission, or You haveagreed for the same with us.

  1. SHARING OF INFORMATION

As mentioned in this Policy, any or all information pertainingto You, whether provided directly by You or not, may be shared by us with thefollowing in order to render appropriate Services to You: 
(a) The Company’s affiliate or subsidiaries or any company that it intends tomerge with or

acquire.

(b) The Company’s Lending Partner(s) in order to provide theServices to You or develop

new products.

(c) Credit Bureau and other third parties (including collectionagencies) are involved directly

or indirectly in providing services or in running Our businessoperations. This may

include but not be limited to Our Lending Partner(s), storageproviders, data analytics

providers, consultants, lawyers, and auditors.

(d) Where Edgro is required by any applicable law, any court, agovernment agency, or

authority to disclose such information. Such disclosures aremade in good faith and

belief that it is reasonably necessary to do so for enforcingthis Policy or the Terms, or in

order to comply with any applicable laws and regulations.

(e) The acceptance of this Policy by You authorizes the Company,the Company’s Lending

Partner(s), its affiliates/ agents/ representatives andsubsidiaries to contact You via SMS

email, phone, or otherwise regarding the Services or anypromotional offers.

  1. ACCESS AND UPDATE YOUR INFORMATION

By providing any information/ documents on the Digital Platform,You, hereby, confirm, undertake, and warrant that all such information that Youprovide us is accurate, up-to-date, and true. 

  1. DATA SECURITY

Edgro implements appropriate security measures to protect Yourinformation from unauthorised access, and follow standards prescribed by theapplicable law. Edgro uses appropriate security based on the type andsensitivity of data being stored. As with any internet-enabled system, there isalways a risk of unauthorised access, so it’s important to protect Yourpassword and to contact us if You suspect any unauthorised access to Youraccount.

Edgro take appropriate security measures such as using HypertextTransfer Protocol Secure (“HTTPS”) to transfer Your data toprotect against unauthorised access, alteration, disclosure, or destruction ofYour personal data that it collects and stores. These measures vary based onthe type and sensitivity of the data. Unfortunately, however, no system can be100% secured, so Edgro cannot guarantee that communications between You and theCompany/ Digital Platform, the Services, or any information provided to it inconnection with the data collected through the Services will be free fromunauthorised access by third parties. Your password is an important part of Oursecurity system, and it is Your responsibility to protect it. You should notshare Your password with any third party, and if You believe Your password oraccount has been compromised, You should change it immediately. 

The security systems and process governing the Companyand its website are compliant with applicable laws. The relevant data centreand systems maintain backup and We have disaster recovery systems in place withrespect to the information provided by You to Us.

 

In the scenarios where Personal Information collectionis mandatory, for instance any information required to pull bureau report, weencrypt the data with the latest security algorithms before transmitting thedata. All such data is encrypted at rest.

 

We restrict access of Your Personal Information onlyto those employees who are required to know such information in order toprovide Our products and services to You. We train Our employees on all Oursecurity procedures.

 

 

 

 

  1. DATA RETENTION

7.1 You agree and acknowledge that Your information will continue tobe stored and retained by us for as long as necessary to fulfill our statedpurpose(s) or for a reasonable period after termination of Your account on theDigital Platform or access to the Services, whichever is later.

7.2 Criterion For Determining Data Retention Period

It is not possible for us to determine a specific period forwhich Edgro may retain Your data. However, Edgro will use and retain Yourinformation for such periods as necessary to provide You with the Services,comply with Our legal/ regulatory obligations, resolve any disputes, andenforce Our agreements/ contractual rights.  Edgro will retain Your datafor longer than necessary, taking into account the following:

(a) The purpose(s) and use of Your data, both now and in thefuture (such as whether it is necessary to continue to store that informationin furtherance of Our obligations under a contract with You, or to contact Youin the future);

(b) Whether Edgro have any legal obligation to continueprocessing Your data (such as any record-keeping obligations imposed by anyapplicable law);

(c) Whether Edgro have any further legal basis to continueprocessing Your information (including Your consent);

(d) Whether there is any relevant agreed industry practice onhow long such data should be

retained;

(e) The levels of risk and liability involved for us to continueholding the data;

(f) The amount of difficulty Edgro may face to ensure the datacan be kept updated and

accurate; and

(g) Any other circumstances, such as the nature and status ofthe Company’s and the Company’s Lending Partner(s)’s relationship with You.

  1. COOKIES POLICY

8.1 What are Cookies?

Cookies are small text files stored by Your browser as Youbrowse the internet. They can be used to collect, store, and share data aboutYour activities across the Digital Platform/ Edgro, including the Website/ App.Cookies also allow us to remember parameters/ credentials pertaining to Yourvisits to the Digital Platform/ Edgro, like Your account ID, and to make theDigital Platform easier to use.

Edgro uses both types of cookies, i.e. the Session Cookies(which expire after a short time or when You close Your browser) and thePersistent Cookies (which remain stored in Your browser for a set period oftime). Edgro uses the Session Cookies to identify You during a single browsingsession, like when You log into the Website/ App. Edgro uses the PersistentCookies where it needs to identify You over a longer period, like when Yourequest that the Digital Platform should keep You signed in.

8.2 Why does the Digital Platform/ Edgro use Cookies and similartechnologies?

Edgro uses Cookies and similar technologies like web beacons,pixel tags, or local shared objects (also referred to as “Flash Cookies”),to deliver, measure, and improve the Services offered by us or by the Company’sLending Partner(s) in various ways. Edgro uses these Cookies both when Youvisit the Platform and the Services through a browser and through the Website/App. As Edgro adopts additional technologies, Edgro may also gather additionaldata through other methods.

8.3 Uses of the Cookies by Edgro/ the Company

8.3.1 Authentication and Security- TheCookies help authenticate Your access to the Digital Platform/ Edgro andprevent unauthorised parties from accessing Your accounts. The Cookies may beused for the following purposes:

(a) To log You into the Digital Platform.

(b) To protect Your security.

(c) To help detect and fight spam, abuse, and other activitiesthat violate the Digital Platform’s terms and conditions.

8.3.2 Preferences- The Cookies help us remember theprogram/ offer You are interested in, so Edgro can provide communicationrelevant to such program/ offer each time You visit the Digital Platform. TheCookies may be used for the following purposes:

(a) To remember data about Your browser and Your preferences

(b) To remember Your settings and other choices You have made.

8.3.3 Analytics and Research- The Cookies help Ustest different versions of the Platform/ Edgro to see which features orcontent, users prefer, web beacons help us determine which email messages areopened, and Cookies help us see how You interact with the Platform/ Edgro, likethe links You click on. The Cookies may be used for the following purposes:
(a) To help us improve and understand how people use the Platform/ Edgro

(b) For other purposes We may want to use/analyse Your data.

(c) We also work with a number of analytics partners, includingGoogle Analytics, Hotjar and Mixpanel, who use Cookies and similar technologiesto help us analyse how users use the Services, including by noting the sitesfrom which You arrive. Those service providers may either collect that datathemselves or We may disclose it to them.

8.3.4 Personalised Content- The Cookies help usshow a personalised list of recommended programs/ offers on the homepage. Thepersonalised contecnt may be used to customise Edgro with more relevantcontent.

8.3.5 Advertising- While using YourDevice, You may also receive tailored in-app advertisements. Apple iOS, AndroidOS, and Microsoft Windows each provide its own instructions on how to controlin-app tailored advertising. For other devices and operating systems, Youshould review Your privacy settings or contact Your platform operator toprovide You with more relevant advertising. However, please note that whereadvertising technology is integrated into the Services, You may still receiveadvertising on other websites and applications, but it will not be tailored toYour interests.

8.4 What are Your Privacy Options?

You have a number of options to control or limit how Edgro usesCookies:
(a) Most browsers automatically accept Cookies, but Youcan change Your browser settings to decline Cookies by consulting Yourbrowser’s support articles. If You decide to decline Cookies, please note thatYou may not be able to sign in, customise, or use some interactive features inthe Services.

(b) Flash Cookies operate differently than browser Cookies, soYour browser’s cookie management tools may not remove them.

  1. TRANSFER OF INFORMATION

Edgro complies with applicable laws in respect of storage andtransfer of Your information. Please note that Your financial data availablewith/ provided to Edgro is only stored on the servers/ systems located inIndia.

  1. LINKS TO THIRD PARTY WEBSITES

The Services offered by Edgro or its Lending Partner(s) may,from time to time, contain services provided by or links to and from thewebsites of the Company’s Lending Partner(s)’s networks, service providers,financial institutions, advertisers, and affiliates (“Third PartyServices”). Please note that the Third Party Services that may beaccessible through Our Services are governed by their own privacy policies.Edgro does not accept any responsibility or liability for the policies or forany information that may be collected through such Third Party Services. Pleasecheck their policies before You submit any personal data to such websites oruse their services.

  1. BUSINESS TRANSITIONS

You agree and acknowledge that in the event Edgro goes through abusiness transition, such as a merger, acquisition by another organisation, orsale of all or a portion of Our assets, Your personal data might be among theassets transferred.

  1. YOUR RIGHTS

You have certain rights with respect to use of Your data,including Your discretion to opt out of promotional emails, Cookies, andcollection of Your data by certain analytics providers. You can update orterminate Your account registered with us for the Services and can also contactus for individual rights requests about Your personal data such as to restrictOur processing of Your data, to erase all data Edgro has stored about You, andthe right to ask for the data to be provided to You.

12.1 Your Choices About the Provision and Use of Your Data

(a) You can choose not to provide certain data/ information tous, but You may not be able to

use certain features of the Services.

(b) To stop receiving promotional communications from us, Youcan opt out by using the

unsubscribe mechanism in the promotional communication Youreceive or by changing the email preferences in Your account. Note thatregardless of Your email preference settings, We will send You transactionaland relationship messages regarding the Services, including administrativeconfirmations, order confirmations, important updates about the Services, andnotices about the Company’s policies.

(c) The browser or Device, which You use, may allow You tocontrol Cookies and other types of local data storage. Your Device may alsoallow You to control whether location or other data is collected and shared.

12.2 Accessing, Updating and Correcting and Deleting Your PersonalData- You can access and update Your personal data that Edgro collectsand maintains as under:

(a) To update data You provide directly, log into Your accountand update Your account at any time.

(b) To terminate Your account:

  • If You are a user, write to     info@edgrofin.com to delete Your account permanently. We shall act on Your     request within maximum 30 working days.
  • Please note that, even after     Your account is terminated, some or all of Your data may still be visible     to others, including without limitation any data that has been (a) shared     or disseminated by You or others (including in Your shared content); or (b)     posted to a third-party platform. Even after Your account is terminated,     We may retain Your data for as long as We have a legitimate purpose to do     so (and in accordance with applicable law), including to assist with legal     obligations, resolve disputes, and enforce our agreements. We may retain     and disclose such data pursuant to this Privacy Policy after Your account     has been terminated.

(c) To request to access, correct, delete Your personal data, orto restrict processing of Your personal data, please email to gro@edgrofin.comWe shall act on Your request within maximum 30 working days. For Yourprotection, We will require that the request be sent through the email addressassociated/ registered with Your account, and We may need to verify Youridentity before implementing Your request. Please note that post deletion, wemay retain certain data for which We have legal rights/ obligations to do so,including for mandatory record-keeping and to complete transactions.

12.3 Withdrawal of Consent- You may withdraw Yourconsent given for collecting any information and personal data under thisPrivacy Policy and pursuant to use of the Services, at any time by sending anemail to info@edgrofin.com We shall act on Your request within maximum 30working days. 

In case of withdrawal of Your Consent or deletion of YourPersonal Data, Edgro reserves the right to not allow You further usage of thePlatform/ Website/ App or to not to provide/ use any Services thereunder,without any obligations or liability, whatsoever, whether in contract, tort,law, equity or otherwise, in this regard. Further, please note that suchwithdrawal of consent shall be prospective in nature, and shall not affect thelawfulness of any data processed based on Your consent given prior to withdrawal.

  1. CONFIDENTIALITY

Your data may be shared withthird parties for providing and improving Our Services in accordance with thisPolicy. The respective third-party partners are under an obligation under thecontract executed with Us to maintain confidentiality of Your information andnot transfer such information without Our prior consent. Our contracts withthese third parties outline the appropriate use and handling of Yourinformation and prohibit them from using any of Your information for purposesunrelated to the service they are providing. Reasonable measures are taken thatany third party to whom information is transferred maintains the securitystandards per applicable laws. However, We are not responsible for any breachof security or for any actions of any third parties that receive Your PersonalInformation.

  1. OBLIGATIONS     OF THE USER

 

You hereby agree that You shall not host, display, upload, modify,publish, transmit, store, update or share any information that:

 

i.       belongsto another person and to which the Customer does not have any right;

ii.       violatesany law for the time being in force;

iii.       deceivesor misleads the addressee about the origin of the message or knowingly andintentionally communicates any information which is patently false ormisleading in nature but may reasonably be perceived as a fact;

iv.       impersonatesanother person; and

v.       ispatently false and untrue, and is written or published in any form, with theintent to mislead or harass a person, entity or agency for financial gain or tocause any injury to any person.

  1. CHANGE IN PRIVACY POLICY

Edgro may amend the Privacy Policy time to time, at its solediscretion. Any changes shall be deemed effective immediately upon publishingof the updated modified Policy on the Digital Platform/ Website/ App and anycontinuous usage of the Services, following the modification will indicateacceptance of changes in Policy by You.

  1. GRIEVANCE OFFICER

You may contact the Company’s Grievance Officer with any enquiryrelating to this Policy or Your personal data. Details of the Grievance Officerfor this purpose are as under:

  • Mr.  Sudeep Khapre, The Grievance Redressal     Officer, EDGRO Finance Private Limited, 2nd Floor, No.:     1614/1615, Enzyme, 7th Cross, 19th Main     Road, Sector 1, HSR Layout, Bengaluru, Karnataka, 5601012
  • Email:gro@edgrofin.com
  • Tel. 7669571400

17.  UPDATES & CONTACT INFO

From time to time, Edgro may update the Privacy Policy at itssole discretion. If this Policy is updated, Edgro will notify You by postingthe policy on our site with a new effective date. If any material changes aremade, Edgro will take reasonable steps to notify You in advance of the plannedchange.

If You have any questions about Your data, our use of it, orYour rights, You may contact us at the following contact details:

  • Email: info@edgrofin.com
  • Call at:+917669571400

 

18.  SEVERABILITY AND EXCLUSION

 

We have taken every effort to ensure that thisPolicy  and the Company website adhereswith the applicable laws. The invalidity or unenforceability of any part ofthis Policy shall not prejudice or affect the validity or enforceability of theremainder of this Policy. This Policy shall be inapplicable to any unsolicitedinformation You provide us. This includes, but is not limited to, informationposted in any public areas of the website. All unsolicited information shall bedeemed to be non-confidential and the Company is free to use and/ or disclosesuch unsolicited information without any limitations.

 

19.  NO WAIVER

 

The rights and remedies available under this Policymay be exercised as often as necessary and are cumulative and not exclusive ofrights or remedies provided by law. It may be waived only in writing. Delay inexercising or non-exercise of any such right or remedy does not constitute awaiver of that right or remedy, or any other right or remedy.

 

20.  APPLICABILITY OF LOCAL LAWS

 

The Company is based in India. By browsing/using theCompany website, You hereby acknowledge that the Company is not responsible orliable in any manner to comply with any local laws of Your territory exceptIndia.