XSFinance & Investment Private Limited

INTRODUCTION

XSFinance and Investment Private Limited, a non-deposit-taking non-banking financial company registered with the Reserve Bank of India and having its registered office at Unit No. 602, CTS no. 163/165, 6th Floor, 'Western Edge – I', Borivali (East), Mumbai – 400066, (hereinafter referred as "Company", "We", "Us" or "Our"). We respect Your privacy and are committed to protecting it through Our compliance with this privacy policy ("Policy") in compliance with the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, Reserve Bank of India's Guidelines on Digital Lending and other applicable laws.

1. This Policy Describes

1. (a)The types of information that We may collect from You when You access, use or avail any products or services We offer through Our website(s) namely "Solfin", application(s) and other online platform(s) (collectively, Our "Platform"); and
2. (b)Our practices for collecting, using, storing, transferring, processing, maintaining, protecting, and disclosing that information.

For the purposes of this privacy policy the term "User(s)" and wherever the context so requires "You", "Your", "Yourself" shall mean any natural or legal person who accesses or uses the Platform and in the event that a natural person is representing a business entity or a body corporate, reference to such terms shall include a reference to such business entity and/or body corporate as well.

2. Your Acknowledgment and Consent

1. (a)By visiting Our Platform You agree to be bound by the terms and conditions of this Policy. If You do not agree please do not use or access Our Platform.
2. (b)By mere use of the Platform, You expressly and unconditionally agree to the terms and conditions of this Policy and consent to the usage, storage and handling of the information submitted by You in accordance with the terms contained herein.
3. (c)This Policy applies only to the User Information (defined below) that We collect through Our Platform. When You submit User Information on the Platform, it shall be deemed that You have granted Us the right to collect, store, process, handle and use such User Information, in accordance with this Policy (as amended from time to time).

3. Information We Collect

We collect various types of information from and about Users of Our Platform, including:

1. (a)"Personal Information" which includes any information concerning personal or material circumstances of an identified or identifiable individual, e.g., name, address, bank details etc., and can be used to uniquely identify or contact a person and/or the business entity that a person represents; and/or
2. (b)"Sensitive Personal Information" which means any Personal Information of an individual, which consists of information relating to passwords; financial information such as bank account, or other payment instrument details; sexual orientation. Information freely available or accessible in public domain is not treated as Sensitive Personal Information.

Any information that is freely available or accessible in public domain or furnished under the Right to Information Act, 2005 or any other law for the time being in force shall not be regarded as Sensitive Personal Information for the purposes of this Policy. We collect this information:

1. (c)Directly or indirectly from You when You provide such information to Us.
2. (d)Information obtained from independent third-party sources such as merchants, lending service providers, and credit bureaus including TransUnion CIBIL Limited.
3. (e)Video recordings or images used for performing Your KYC verification.
4. (f)Information relating to Your solar or renewable energy financing requirements.

4. Information You Provide to Us

You provide Your explicit consent for collection of information, on Our Platform (which may be collected from the parties as per this Policy), which includes but is not limited to ("User Information"):

1. (a)Your full name, address, email address, telephone number, date of birth and bank details and any proof of Your identity and/or address, postal code, profile picture, password and other information You may provide with Your account;
2. (b)Your device's camera, microphone, location or any other facility as may be required for KYC purposes;
3. (c)Your preferences including settings such as time zone and language;
4. (d)IP addresses, application, device or browser type, versions and configurations, operating systems, device brand and model, time zone setting;
5. (e)Credit related information or assessment, credit information and income information;
6. (f)Financial information such as personal bank account numbers and bank account data;
7. (g)Know Your Customer (KYC) information including all proofs of identity and address, photograph, Permanent Account Number (PAN), etc.;
8. (h)Information collected through cookies.

5. Sources of Information Collection

We may collect User Information in the following ways:

1. (a)As You navigate through Our Platform; and/or
2. (b)Directly or indirectly from You when You provide it to Us; and/or
3. (c)The public domain; and/or
4. (d)through independent third-party sources like Our Financiers, merchants, financial organisations, credit bureaus, our lending service providers, etc;
5. (e)when You give Us permission to do so either directly or through a cookie.

6. Use and Disclosure of Information Collected

Usages

You explicitly provide Your consent for Use of Your User Information collected for the following purposes:

1. (a)To verify and authenticate Your identity;
2. (b)To facilitate Your usage of Platform;
3. (c)To do internal risk assessments and analysis;
4. (d)To protect Our business and ensure compliance with law;
5. (e)To carry out creditworthiness checks;
6. (f)To process and complete Your transactions;
7. (g)To improve the content and features of Our Platform;

Disclosures

You explicitly confirm and provide Your consent for disclosure of Your User Information for various purposes including:

1. (a)For legal purposes, requirements, to comply with applicable laws;
2. (b)To Our affiliates, subsidiaries, group companies, related parties;
3. (c)To Our partners, Financiers, merchants, contractors, service providers;
4. (d)To third parties to enable them to market and offer their products or services to You;

7. Marketing

You may receive marketing communications from Us or third parties if You have provided Us Your User Information. You are entitled to opt out from receiving marketing communication from Us by writing to Us at info@solfin.co.in.

8. Third Party Links

The Platform may contain links to other sites, which may not necessarily be under Our control. We do not endorse or make any representations about third-party Websites or services. Our Privacy Policy does not cover the information You choose to provide to these third parties.

9. Your Rights

In accordance with applicable laws, You can exercise the following rights:

1. (a)Review, Correct or Rectify Your User Information: You can ask Us to have inaccurate User Information reviewed, fixed or changed.
2. (b)Right to withdraw Your consent: You may withdraw consent to processing and prevent further processing of Your User Information.
3. (c)Delete or forget Your User Information: You may request that the User Information collected by Us is deleted.

To exercise any of these rights, please submit a request with the subject "Data Deletion" at info@solfin.co.in.

10. Google Analytics and Tag Manager

We use Google Analytics and Google Tag Manager to analyze how users interact with our Platform. These services collect information including:

1. (a)Your IP address (anonymized);
2. (b)Browser type and version;
3. (c)Pages visited and time spent;
4. (d)User interactions and events.

You can opt-out by installing the Google Analytics opt-out browser add-on at https://tools.google.com/dlpage/gaoptout.

11. Data Protection

We use reasonable physical, electronic, and managerial procedures to safeguard User Information in compliance with the Information Technology Act, 2000. However, no method of transmission over the internet is 100% secure.

12. Cookies and Tracking Technologies

Our website may use cookies and similar tracking technologies to enhance Your browsing experience. You can manage Your cookie preferences through Your browser settings.

13. Your Consent

By submitting Your personal information, You consent to the use of that information as detailed in this policy. You hereby expressly and irrevocably authorize the Company to collect, store, share, obtain and authenticate Your personal information / KYC.

14. Governing Law or Dispute Resolution

This Policy shall be governed by and construed in accordance with Indian laws. The courts at Gurgaon shall have exclusive jurisdiction in relation to any disputes arising out of this Policy.

15. Disclaimer

1. (a)We make no warranties about the accuracy or completeness of Our Platform. To the extent permitted under applicable laws, we will not be liable for any direct, indirect, incidental, special, or consequential damages.
2. (b)Your sole and exclusive remedy for any dispute with Us shall be to discontinue the Use of the Platform and the services.

16. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy, please contact us at:

1. (a)Phone: +91 9599446877
2. (b)Email: legal@solfin.co.in

17. Changes to This Privacy Policy

1. (a)We may update this Privacy Policy from time to time. Any changes will be effective upon posting the revised Privacy Policy on Our Platform. We encourage you to review this Privacy Policy periodically.
2. (b)By using Our website or services after any changes to this Privacy Policy, You acknowledge and agree to the revised terms.