This Privacy Policy (“Policy”) explains our policy regarding the collection, use, processing and disclosure of your information by FinLock Technologies Private Limited and/or its subsidiary(ies) and/or affiliate(s) (hereinafter collectively referred to as “Company”) that operates the website (“Site”), mobile application (“FinLock App” or “App”) and other services including but not limited to online fraud detection, post-fraud reporting, transaction monitoring and related content (hereinafter collectively referred to as the "FinLock Platform") via any mobile or internet connected device or otherwise.

This Policy forms part and parcel of the Terms & Conditions for the FinLock Platform.

As we update, improve and expand the services offered by the FinLock Platform, this policy may change, so please refer to it periodically. By accessing the website, FinLock App or otherwise using any service offered by the FinLock platform, you consent to collection, storage, and use of the personal information you provide (including any changes thereto as provided by you) for any of the services that we offer.

The company respects the privacy of the users of the FinLock platform, understands the sensitivity of the information and is committed to protect it in all respects. The information about the user as collected by the company is: (a) information provided by users and (b) information automatically tracked while a user uses the FinLock Platform (c) information generated while availing our services including but not limited to transactional information (collectively referred to as "User Information" or "Information").

Information Provided by Users

To avail certain services on the FinLock Platform, users are required to provide some personally identifiable information for the registration process which may include:- a) your name, b) email address, c) phone number etc. and any other such information as required. The Information as supplied by the users enables us to improve the FinLock Platform, develop new services and provide you with the most user-friendly experience.

We may also use your phone number, email address or other personally identifiable information to send commercial or marketing messages without your consent [with an option to subscribe/unsubscribe (where feasible)]. We may, however, use your email address and phone number without further consent for non-marketing or administrative purposes (such as notifying you of major changes, for customer service purposes, providing information about updates to FinLock platform, billing, etc.).

Any personally identifiable information provided by you will not be considered as sensitive if it is freely available and/or accessible in the public domain. Further, any reviews, comments, messages, blogs posted/uploaded/conveyed/communicated by users on the public sections of the site or an Application Store (like the App Store or Play Store) becomes published content and is not considered personally identifiable information subject to this Privacy Policy.

In case you choose to decline to submit personally identifiable information on the FinLock App/Site, we may not be able to provide certain services on the App/Site to you. We will make reasonable efforts to notify you of the same at the appropriate time. In any case, we will not be liable and or responsible for the denial of certain services to you for lack of you providing the necessary personal information.

When you register with the FinLock Platform, we may contact you from time to time about updating your personal information to provide such features that we believe may benefit/interest you.

Information Automatically Tracked While Using FinLock Platform

a) Log File Information

Our Servers automatically collect limited information about users’ device’s connection to the Internet, including IP address or device ID. We receive log information from the App and/or your browser including IP address, computer’s name, device’s name, device’s serial number, ADID of Android device, device operating system, browser type, and version, CPU speed, and connection speed among many others.

b) Cookies

To improve the responsiveness of the FinLock Platform for our users, we may use “cookies”, or similar electronic tools to collect information to assign each visitor a unique, random number as a User Identification (User ID) to understand the user’s individual interests using the identified computer or device. Our partners may also assign their own cookies to your browser, a process that we do not control.

c) Demographic and Related Information

We use Firebase Analytics to track user behavior on our App/Site and provide them with more targeted communications and promotions. It also helps us to understand our users’ Demographics and Interests, and analyze App performance metrics. The reports collected are anonymous and cannot be associated with any individual personally identifiable information that has been shared with us.

d) SMS Inbox Information

After obtaining the user’s specific consent to access the SMS inbox, the FinLock App identifies spam messages that originate from unknown senders (not in your device contacts) to alert the user of fraudulent activity. No personal SMSes are read or backed up.

The Spam SMSes are also used to train our Fraud Detection algorithm and continuously enhance protection of users from new types of threats.

The FinLock App also collects partial payment data and other information arising out of transactions made from cards, banks or while using other services through SMSes to allow easy reporting of any suspicious activity. The collection of such information is only limited to the extent that such data is available in the relevant messages.

e) Phishing Links Information

With specific consent from the user to turn on the Accessibility settings of their device, we collect information on website links accessed by users on their mobile browsers to alert them of phishing sites. No other information on the actual website pages or user activity on those pages is tracked.

Links to Third Party Sites

The FinLock Platform may include links to other websites or applications. Such websites or applications are governed by their respective privacy policies, which are beyond our control. Once you leave our servers (you can tell where you are by checking the URL in the location bar on your browser), use of any information you provide is governed by the privacy policy of the operator of the site you are visiting. That policy may differ from ours. If you can’t find the privacy policy of any of these sites via a link from the site’s homepage, you should contact the site directly for more information.

Sharing and disclosure of data with third parties

We neither rent nor sell your personal information to anyone. However, we may share personal information with third parties without obtaining the prior consent of the user in the following limited circumstances:

• When it is requested or required by law or by any court or governmental agency or authority to disclose, for the purpose of verification of identity, or for the prevention, detection, investigation including cyber incidents, or for prosecution and punishment of offences. These disclosures are made in good faith and belief that such disclosure is reasonably necessary for enforcing these Terms or for complying with the applicable laws and regulations.

• When it is required by the insurance company to issue a policy for coverage against cyber frauds and also at the time of filing a claim for reimbursement of any financial losses.

• No personally identifiable data of an individual user such as name, phone number, email address etc. would be shared with any other user and/or third party – unless explicitly approved by the concerned individual user in order to avail of certain services. However, if this conflicts with conditions mentioned in the points above, this condition would become null and void.

The Company may also present information related to fraudulent alerts, user spending patterns and user data tracked by the company only in the form of aggregated statistics on data such as risk score trends, fraud alerts by category, date, time etc. within our App to our partners.

Accessing and updating personal information

You may review, update, and correct your personal information through the Profile section on the FinLock App. In the event when your information is not accessible online and you wish to change your personal information or other information that you may have provided, please write to us at support@finlock.in.

You may also request to delete your account by writing to us at support@finlock.in. Because of the way we maintain certain services, after deleting your account, residual copies may take a period of time before they are deleted from our active servers.

Information Storage and Backup

We take a backup of user data in FinLock App on our Cloud database to restore their data in case their phone becomes unusable, if the phone is lost, or the user moves to a new phone device.

Information Security

We take appropriate security measures to protect against unauthorised access to or unauthorised alteration, disclosure or destruction of data. These include internal reviews of our data collection, storage and processing practices and security measures, including appropriate encryption and physical security measures to guard against unauthorised access to systems where we store personal data. All information gathered on the FinLock App is securely stored within the controlled database. Access to the servers is password-protected and is strictly limited.

Changes to Privacy Policy

We may update and/ or modify this Policy from time to time to incorporate necessary changes in technology, applicable law, or any other variant. In any case, we reserve the right to change (at any point of time) the terms of this Policy or the Terms of Use. Any changes We make will be effective immediately, upon posting the new policy on our FinLock Platform. While we will make reasonable efforts to keep you posted on any updates to this privacy policy, to make sure that you are aware of any changes, we advise you to review this policy periodically for the latest version, continued use of the sites or services, after such notice, will be deemed acceptance of such changes. .

Questions / Grievance Redressal

In the event you have any grievance relating to the processing of information provided by you, you may contact our Grievance Department, at support@finlock.in. .