This privacy policy (“Privacy Policy”) is published according to the Information Technology Act, 2000, the Information Technology (Amendment) Act, 2008, and the Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011, of the Republic of India.

As a user ("User" or "You") of Turrant, You understand that Platform provides access between multiple Users in the form of consumers, financial institutions, data partners and other partners lenders, borrowers, service providers etc. with a view to facilitate lending and borrowing activities, including providing other financial products i.e. insurance products, credit cards etc. between the Users.

It is hereby clarified that the term "Users" shall mean any person using the Platform i.e. consumers, financial institutions, regulated entities, data partners and other partners. Your use of this Platform implies that You have read, understood and agreed to abide by following, disclaimer, terms & conditions ("Terms & Conditions").

1. Collection of Personal Information

i) By using our Platform, whether from our Platform, we collect and store your information which is provided by you from time to time. Our goal by doing so aims to provide you with secure, efficient, smooth and customized experience and services, which allows us to provide facilities and features that meets your needs, and to customize our Platform to make your experience more secure and simple and to improve the facilities provided by us. In addition, we collect basic personal information from you to achieve the aforementioned purpose.

ii) You′re allowed to browse Turrant without telling us about your identity or revealing any personal information of yours. However, you must provide us with certain basic information required to provide customized services if you′re registering an account. We may collecting information from you for checking your credit rating with third parties so as to assess your creditworthiness and eligibility to avail of the facilities and services that are offered by the Platform. The information we collect from you, inter alia, including:

• Your full name
• Email
• Mailing Address
• Postal Code
• Family Details
• University / College details
• Phone Number
• Permanent Account Number (PAN)
• Academic Records and Certificates
• Details of your occupation or vocation, and
• details related to your income or filings thereof.

iii) Where possible, we specify the mandatory and the optional fields. You always have the right to offer or not to offer your personal information by choosing not to use a particular service or feature on Turrant. If you do not provide certain information as sought by us, it may be not possible for us to extend any facility, feature or service that you may have applied for, and you consent and understand that our inability to be of service to you shall not constitute a deficiency of service, or give rise to any legal liability on our part.

iv) We also collect other identifiable information (your payment card details and transaction histories on the Platform) from you when you set up a free account with us. While you can browse some sections of our Platform without being a registered member as mentioned above, certain activities (such as availing of loans from the third-party lenders on Turrant) requires registration and for you to provide the above details. Turrant shall distinctly display the categories of personal information which requires from you, and you have the option to not provide such personal information. However, this will limit the services, facilities and features available to you on Turrant.

2. Collection of Other Non-Personal Information

i) Certain information about you will be tracked automatically by us based upon your behavior on our Platform, and/or the features, facilities or service that you avail from us. We use this information for internal research on our users' demographics, interests, and behavior for better understanding, protect and serve our users and improve our services.

ii) This information is compiled and analyzed on an aggregated basis. We collect also your Internet Protocol (IP) address and the URL that used for connecting your computer to the internet, etc. This information may include the URL that you just came from (whether this URL is on our Platform or not), which URL you next go to (whether this URL is on our Platform or not), your computer browser information, and your IP address.

iii) Cookies are small data files for a Platform to store on your computer, and we will use it similar to other lending websites / apps and online marketplace websites / apps. Using this information helps us identify you in order to make our Platform more user friendly. Most browsers will permit you to decline cookies, and by declining it might affect some of the services of Our Platform.

iv) We retain this information as necessary to resolve disputes, provide customer support and resolve issues to the extent permitted by law.

v) If you send us personal emails, such as emails or letters, or if other users or third parties send us correspondence about your activities or postings on Turrant, we will collect such information into a file specific to you.

3. Collection of Device Information

i) The information Turrant collects, and how that information is used, based on how you manage your privacy controls on your device.

ii) We store the information that collect with unique identifiers tied to the device you use for the time being when you access Turrant or install the App.

iii) We collect information from the device when you download and install the App and explicitly seek permissions from You to get the required information from the device.

iv) The information we collect from your device includes the unique ID.

v) For providing automatic updates and additional security prevent your account being used in other people′s devices, we collect information about your device. What′s more, the information provides us valuable feedback on your identity as a device holder as well as your device behavior, thereby to allow us to improve our services and provide an enhanced customized user experience to you.

vi) We provide our users loans/ credit after reviewing other data. We need to audit user eligibility and verify these info under secured and confidential condition through accessing SMS, Contacts, Storage and Camera, and to provide credit limit and credit report.

vii) The key information collected from the device is further expressed below. Please notice that some or all of these may be applicable depending on your version of App.

viii) SMS:

• We will collect SMS data from your mobile inbox, and we will require you to authorize SMS permission to read and transmit your SMS data to our server automatically when you're applying, mainly including the names of the transacting parties, a description of the transaction and the amount of the transaction for the purpose of performing credit risk assessment.
• It is mainly used in the following three aspects: one is to automatically read the OTP SMS we send you, which allows you to log in using our app more smoothly; the other is to help us verify your identity and confirm that it is you who applied loans; the third is to use your historical financial transaction SMS records to help us perform a credit risk assessment. We will identify the various loan accounts that you are holding, the cash flow patterns that you have as a user, and if you have any previous non-repayment behaviors. We won't use the information for any purpose other than loan evaluation.

ix) Contacts:

• As a part of our loan journey, we require references from the Loan applicant. In this regard, during filing the form on our App, we collect and upload your contact information which includes name, phone number, account type, contact last modified, favourites and other optional data like relationship and structural address to enable you to autofill the data during the loan application process. This information is required for the purposes of risk analysis, enables us to detect credible references assess your risk profile and to determine your loan eligibility.
• What′s more, we collect and upload contact information from your device in order to do risk analysis through enabling us to detect credible references through the name and phone number of contacts. The more credible the references are, the lower the risk associated with a customer.

ix) Storage:

• We require the storage information permission to allow Turrant to enable you to upload your KYC photos, images, documents or files, such as Aadhaar card front and back images, Pan card images, bank statements, or salary slip files. This will increase security so that your account cannot be used by others. This will also help us assess your risk level and provide you with a product that is more suitable for you.We will upload these to Turrant servers during your loan application journey.

ix) Camera:

• We require the camera permission to take pictures when we need to take your KYC images or proof of employment files. This will ensure that it is you who is applying for the loan, that your identity is not being used by others, and that if you provide proof of employment, you may get a better product that suits you. Also, it can provide you with an easy/smooth experience. We will upload the files/images to Turrant servers during your loan application journey.

ix) Installed applications:

• We collect a list of the installed applications′ metadata information which includes the application name, package name, installed time, updated time, version name and version code of each installed application on your device to check whether your account has been stolen and whether risky and Trojan APPs has been installed in the your device. This is to ensure that your information and funds account are safe. Moreover, we will assess your credit worthiness and enrich your profile with pre-approved customized loan offers.This data will only be collected when you're applying for a loan.

4. Use and Disclosure of your Personal and Other Information

i) We use personal information to provide you with the services you request and we customize user′s experience and improve our services. Your personal information may be used for marketing you some products , we will provide you the options to opt-out of such uses.

ii) We use your personal information to:

• Solve disputes
• Troubleshoot problems
• Help provide a safe service
• Detect and protect us against suspicious or illegal activity, fraud and other criminal activity
• Measure consumer interest and satisfaction in our products and services
• Inform you about online and offline offers, products, services, and updates
• Customize your experience
• Enforce our terms and conditions
• Improvement of our services and as otherwise described to you at the time of collection
• check your creditworthiness.

iii) We will continuously improve our service offerings, and we collect to analyze demographic and profile data about our users' activity on our Platform.

5. Use of your Device Information

i) We will use the information you provided as following:

• To establish identity and verify the same, (ii) monitor, improve and administer our Platform
• Provide our service i.e. perform credit profiling for the purpose of facilitating loans to You
• Design and offer customized services offered by our affiliated or third-party financial partners
• Analyze how Turrant is used, diagnose service or technical problems and maintain security
• Send communication notifications, information regarding the services requested by you or process queries and applications that you have made on Turrant
• Manage our relationship with You and inform You about other products or services we think you might find of some use
• Conduct data analysis in order to improve the Services provided to the User
• Use the User information in order to comply with country laws and regulations
• Conduct KYC for our third-party lending partners based on the information shared by the User
• use the User information in other ways permitted by law to enable You to take financial services from our lending partners.

ii) Your information shall be used by us for such periods for as long as necessary to serve You the Services on our Platform, to comply with our legal obligations, to resolve disputes, and enforce our consents.

6. Disclosure to Third Parties

ii) Your information may shared with third parties including our regulated financial partners for provision of services on Turrant and/or for facilitation of a loan / facility to You. We will share Your information with third-parties only in such manner as described below:

• we share Your information with our third-party partners to conduct data analysis in order to serve you better and provide services on our Platform
• We disclose and share Your information with our financial service providers, banks or NBFCs and Our third-party partners and for facilitation of a loan or facility or line of credit or purchase of a product
• We may disclose Your information, without prior notice. If we are under a duty to do so in order to comply with any legal obligation or an order from the government and/or a statutory authority, or in order to enforce or apply with our terms and conditions or assign such information in the course of corporate divestitures, mergers, or to protect the rights, property, or safety of us, our users, or others. This includes exchanging information with other companies and organizations of fraud prevention and credit risk reduction
• We may disclose your information, without prior notice, if we are under a duty to do so in order to comply with any legal obligation or an order from the government and/or a statutory authority, or in order to enforce or apply our terms and conditions or assign such information in the course of corporate divestitures, mergers, or to protect the rights, property, or safety of us, our users, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction
• We will disclose the data / information provided by a User with other technology partners to track how the User interact with Turrant on our behalf
• We and our affiliates may share your information with another business entity should we (or our assets) merge with, or be acquired by that business entity, or re-organization, amalgamation, restructuring of business for continuity of business. Such a transaction should occur than any business entity (or the new combined entity) receiving any such information from us shall be bound by this Privacy Policy with respect to your information
• We will disclose the information to our third-party technology and credit partners to perform credit checks and credit analysis like Credit Bureaus or third-party data source providers
• We will disclose Your information under a confidentiality consent with the third parties and restrict the use of the said Information by third-parties only for the purposes detailed herein above.

7. Your Privacy Controls

i) You have certain choices regarding the information we collect and how it is used:

• Device-level settings: Your device may have controls over determination of what information we collect
• Delete your entire App account
• You can also request to remove content from our servers based on applicable law or by writing to our Grievance Officer.

8. Security Precautions

i) Turrant has stringent security features that keep your information secure.

ii) Our Platform has strict security measures in place to protect the loss, misuse and alteration of information under control. We endeavor to safeguard and ensure the security of the information provided by you. We exert Secure Sockets Layers (SSL) based encryption, for the transmission of the information, which is currently the required level of encryption in India as per the law.

iii) We work hard to protect information from unauthorized access, alteration, disclosure or destruction of information we hold, including: (i) we use encryption to keep your data private while in transit, (ii) we offer security feature like an OTP verification to help you protect your account, (iii) we review our information collection, storage, and processing practices, including physical security measures, to prevent unauthorized access to our systems, (iv) we restrict access to personal information to our employees, contractors, and agents who need that information in order to process it. Anyone with this access is subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations, (v) compliance & cooperation with regulations and applicable laws, (vi) we regularly review this Privacy Policy and make sure that we process your information in ways that comply with it, (vii) data transfers.

iv) We maintain your information on servers located in India. Data protection laws vary from countries, with some providing more protection than others. We also comply with certain legal frameworks relating to the transfer of data as mentioned and required under the Information Technology Act, 2000.

v) If we receive formal written complaints, we′ll contact the person who made the complaint. We work with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of your data that we cannot resolve with you directly.

9. Choice / Opt-Out

i) All of our users has the right to opt-out of receiving non-essential (promotional, marketing-related) communications from us on behalf of our partners, and from us in general, after setting up an account.

i) If you want to remove your contact information from all Platform lists and newsletters, please visit unsubscribe.

10. Links to Other Sites

i) Our Platform links to other websites may collect personally identifiable information about you. We are not responsible for the privacy practices or the content of those linked websites. With this Privacy Policy, we are only addressing the disclosure and use of data collected by Us. If You visit any website through the links on Turrant, please ensure You've viewed the privacy policies of each of those websites. Their data collection practices and their policies might be different from this Privacy Policy and We do not have control over any of their policies neither do we have any liability in this regard.

11. Advertisements on Turrant

i) We serve ads through third-party advertising agencies to while you visiting our Platform. These companies may use information (not including your name, address, email address, or telephone number) about your visits to our Platform and other websites/ app in order to provide advertisements about goods and services of interest to you.

12. Your Consent

i) By using Turrant and/ or by providing your information, you consent to the collection and use of the information you disclose on Turrant according to this Privacy Policy, which includes but is not limited to your consent for collecting, sharing, using, and disclosing your information as per this Privacy Policy.

13. Governing law and Jurisdiction

i) This Privacy Policy is governed by and construed in accordance with the laws of India. Any dispute arising out of or in connection with the use of Turrant or this Privacy Policy shall be subject to the exclusive jurisdiction of the courts in Bangalore, India.

8. Contact Us