PRIVACY POLICY

The Syndicate Tech LLP (the “Syndicate”), is engaged in the business of designing, developing and operating various finance, technology and education products, and is compliant under the Information Technology Act 2008 (“Act”) and the rules thereof, more specifically the Information Technology Intermediaries Guidelines Rules, 2011 (“Rules”), signifying that this privacy statement and our practices have been reviewed for compliance with the Act and Rules and applicable laws. This privacy policy (“Policy”) covers the information collected through this website, [insert]. If you, being either a beneficiary or an investor of the assurance, (also known as “user(s)”) have questions or concerns regarding this Policy, you should first send a mail to [insert]. This Policy applies to the data collected by the Syndicate. Your privacy and the protection of Your personal and sensitive information are important to us. We collect and/or store certain types of information from and about you, therefore it is necessary to explain our Policy and the terms and conditions surrounding the capture and use of that information.

This Policy discloses which information we collect and how we use it, as well as the choices you can make about the way your information is collected and used. We also explain how any sensitive and/or personal information that we may request will be used; these explanations can usually be found on the same pages where the information is requested. We also detail below our security policy, which describes how your personal and sensitive information is protected both electronically and physically.

In general, and as described in detail below, we collect several types of information from you, such as: Personal information required to verify your identity; Demographic information such as postcode, preferences and interests; Information regarding credit ratings, which may also be received from referral sources; Optional personal information you may wish to share in the furtherance of your goals in using our website; Information about your visits to and use of this website to help us maintain the appropriate features, functionality and user experience.

The Syndicate works with a number of trusted partners that perform vital functions as part of our operations, including our sister entities and group companies. Our partners are legally required to keep your information private and secure.

You accept this Policy when you access or view our website, sign up for or use our products, services or any other features, technologies or functionalities offered by us on our website or through any other means (collectively the “Services”).

Information We Collect From You and About You

We collect personal and financial information from you while you use the website, and most of this collection occurs during registration. Some information is required and some is optional, some will remain private and some will be displayed to other users. We always let you know which is which. Additional information may be gathered during your subsequent use of the website, whenever you choose to provide it. Certain personal information must be supplied during the member registration processes or accessing certain areas of our website, as indicated below, in order to, (a) enable registered users to login to the site; (b) determine eligibility for Services; (c) verify identities; (d) guard against potential fraud. This basic personal information

includes:

Your name;

Your e-mail address;

Your date of birth;

Your home address and telephone number;

Your Aadhaar card details;

Your Permanent Account Number and Bank Account Information;

Your Net Banking / Credit or Debit Card Information.

We will also use your required and optional information to facilitate activities and transactions that need to occur during your utilisation of Services, such as:

Generating user profiles on the website;

Contacting you if there is a problem in accessing our Services, or to discuss a problem with your account;

Maintaining regular communications with you concerning your use of the Services, such as requesting information or assistance, submitting an assurance request, etc.;

Enabling our services partners to implement their services;

Maintaining regular communications with you as may be necessary;

To contact you for market research purposes, in an effort to improve Services and customize our website in accordance with your interests;

To provide information to our partners for marketing and promotional purposes.

Communications from Us

When you register with Us, You may receive e-mails, SMS’s and OTP authorization that confirm specific actions you requested. You will receive notifications confirming your registration, the successful verification of e-mail addresses and bank accounts, and confirmation of successful submissions of user requests. You will also receive progress updates on the status of your requests and submitted portfolios. These are transactional notifications that you cannot opt out of receiving, as they are in place to protect the security of your account and your personal information. We will also send you responses to any e-mails you send us. From time to time, we will also send user surveys and requests for user feedback regarding user experience and site operations. The completion of these surveys or requests for feedback is strictly voluntary. If you do not wish to receive these surveys or user feedback e-mails, you may opt out by writing to [insert], or by following the unsubscribe instructions located at the bottom of each e-mail communication.

We will send you e-mail notifications from time to time, and these are required elements of your transactions on our website, such as confirmations of particular actions you have taken. These required notices are sent typically to notify you of a change in status, such as when you are confirmed as a user of Services, or for legal or security purposes. For example, certain notifications are sent for your own protection to ensure that no one can make a change to your account without your knowledge, such as confirming the addition of a new e-mail address, etc. These notifications are sent to you so that you can be assured that no one is making changes to your account without your knowledge. In other cases, these notifications involve changes to various legal agreements or site policies. Generally, you may not opt out of these service related e-mails.

How Long Will My Information Be Stored?

We will retain your information for as long as your account is active, or as needed to provide you Services. If you wish to cancel your account or request that we no longer use your information to provide you services contact us at [insert]. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

How and When Your Information is Shared With Other Parties

We do not sell, share, rent, or trade your personal information with third parties other than as disclosed herein. Information is shared with other parties in the following ways:

Required information (such as name, address and e-mail address) and optional information about users is displayed on profiles that you can update at any time. Certain information is optional (such as additional phone number) and you can choose not to supply it and/or can remove the optional information at any time; Information (such as gross income, length of employment);

Financial and credit information about users is displayed to qualified investors on assurance listing pages; Information is shared directly between users and other or potential users (who are only able to view assurance postings but do not have access to the full loan listings);

Information shared directly by users might contain personal information (such as name and e-mail address); Information may be shared with collection agencies and/or service providers, but only if they are contractually obligated to keep such information confidential.

We may share your information with law enforcement or other government agencies as required by law or for the purposes of limiting fraud. We reserve the right to disclose your personal information when we believe that disclosure is reasonably necessary to protect our rights and/or to comply with a judicial proceeding, court order, or legal process served on our website.

We work with a number of trusted partners that perform vital functions as part of our operations, including but not limited to e-sign providers, credit bureaus, collection agencies, data and background verification agencies and electronic payment service providers with whom personal information is shared only to the extent necessary for us to process the transactions you initiate or perform other specific services with our partners legally mandated to keep your information private and secure.

These third parties are prohibited from using your personal information for promotional purposes but are authorized to use your personal information only as necessary to provide these services to us. We may also disclose your personal information if We are involved in a merger, acquisition, or sale of all or portion of its assets, you will be notified via e-mail and/or a prominent notice on our website of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

Sharing Your Information with Trusted Third Parties

With your express consent we will share your information with our trusted third parties from whom you wish to avail of any products or services offered through our website or our sister and group companies (“Trusted Third Party”). In the circumstance you would wish to procure or avail of any such services or products offered by a Trusted Third Party, you will expressly consent to the Syndicate sharing your data (including but not limited to your KYC information and documents) with such Trusted Third Party/ies as may be required.

You further understand that the sharing of such information will take place at such time you intend to avail of a service or product offered by a Trusted Third Party and that the Syndicate will not be liable for any and all breaches, leaks, loss or damage caused by the use of, or failure to protect your information by such Trusted Third Party. Any and all such liability will rest solely with the Trusted Third Party.

Where You Can Find and/or Correct Your Information

You can access all of your personal information that we collect online and maintain by visiting your profile at [insert]. This section of the site is password-protected to better safeguard your information. As a registered user, you can correct, update, amend your password, e-mail address, physical address, phone number at any time on the website. Further, in the event that you need to modify your bank account information disclosed to us or change any other information in your profile, you may do so by contacting us at [insert]. You may also ask to have your personal information deleted/removed from a public forum on our site and make changes to sensitive account information in order to protect your privacy and security by contacting us at [insert]. We will respond to your access request within 30 days.

Links to Other Sites

We may offer links to partners’ websites. We make the decision to provide links to these sites based on the quality of information provided at the time the links are enabled, and we make every effort to monitor the continuing quality of content provided on these sites. However, these external sites are not subject to this Privacy Policy. Further, the Syndicate has no control over the content of these sites. The data collected and shared by such third-party websites is governed by their concerned privacy policy, which we do not exercise any control over. Accordingly, please consult the privacy policies on these sites before you provide them with any of your personal information.

Security Policy

We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once it is received. If you have any questions about the security of your personal information, you can contact us at [insert].

The Syndicate takes strong steps to safeguard your personal information through vigorous physical, electronic and operational policies and practices. All data is considered highly confidential. Data can only be read or written through defined service access points, the use of which is password-protected. The physical security of the data is achieved through a combination of network firewalls (there is no direct communication allowed between the database server and the Internet) and servers with hardened operating systems, all housed in a secure facility. Access to the system, both physical and electronic, is controlled and sanctioned by a high-ranking manager.

Session Time-outs

We also employ session time-outs to protect your account. You will be logged out of the site automatically after a specified period of inactivity. This time-out feature reduces the risk of others being able to access your account if you leave your computer unattended.

Passwords

We require the use of numbers in your password. We have also instituted secure steps by which you can regain access to your account should you forget your password, including the use of a security question. Your password is not known to any employee or third party with whom we may partner, and we will never ask for your password as a means of identifying yourself. You should never share your password with anyone, and if you ever receive an e-mail purporting to come from the Syndicate that asks for your password, you should immediately report this development at [insert].

What You Can Do

In addition to our own substantial efforts, you can take several precautions to protect the security of your computer and personal information. For instance, you can start by using a well-chosen password. You should avoid using any information that others can easily learn about you, such as a family member’s name or birthday, and you can also use special characters in place of letters. We also recommend that you change your password frequently. You can also install and regularly update antivirus and firewall software to protect your computer from external attacks by malicious users. When you are finished with a session on our site, be sure that you log out and close the browser window.

To protect your account, we send automatic notifications confirming certain actions taken on your account, such as changes to a password or external linked account. We do this for your own protection so that you can be sure no one else is making changes to your account without your knowledge. However, the security offered through these notifications can be undermined if other people have access to your e-mail account. Therefore, you might consider restricting access to the e-mail account you registered with on this site and/or changing your password on that e-mail account frequently.

If you use a computer that is accessed by other people, such as in a public library or Internet cafe, we recommend that you take special precautions to protect the security of your account and personal data. When you are finished using our site, you should log out completely, then close the browser window and clear the browser’s cache files. You should also be aware of fraudulent attempts to gain access to your account information known as “phishing.” Phishing is a tactic used by scammers in which unsuspecting people are brought to a website by a genuine-looking e-mail purporting to be from a legitimate company. The phony or “spoof” e-mail takes the person to a website that looks legitimate but in fact is not. Either in the e-mail itself or on this fake site, scammers will ask for login information to gain access to people’s accounts and withdraw their money. The Syndicate will never ask you for your login information in the context of any e-mail. In general, you can protect yourself against phishing by never providing personal or login information via e-mail—instead, go the website directly.

We May Make Changes to This Policy

We may update this privacy Policy to reflect changes to our information practices. If we make material changes we will notify you by mail (sent to the e-mail address specified in your account) or by means of notice on this website prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices. You may contact us at: