ALFASTAR INDIA FINANCE CONSULTANCY PRIVATE LIMITED (“upaybazaar”/”Company”/”upaybazaar.com”) including online platform(s) www.upaybazaar.com and “Mobile App” (Collectively “Website”) recognizes the importance of maintaining your privacy. upaybazaar.com is committed to maintain the confidentiality, integrity and security of all information of its users. This Privacy Policy describes how upaybazaar.com collects, stores, handles and transfer certain information received from you via the use of the Website on a need basis. This Privacy Policy applies to the visitors to our Website and our existing and future customers. By visiting and/or using our Website, you are accepting and consenting to the practices described in this Privacy Policy.

By using or continuing to use the Website you agree to our use of your information (including sensitive personal information as defined under the Information Technology Act 2000, applicable rules, notification etc.) in accordance with this Privacy Policy, as may be amended from time to time by upaybazaar at its sole discretion.

1. Controllers of Personal Information

Your Personal data/information will be collected and stored at servers located in India by ALFASTAR INDIA FINANCE CONSULTANCY PRIVATE LIMITED along with its parent company (including its, representatives, affiliates, and its business partners) .

2. What Personal Information we gather about you

The information we learn from customers helps us personalize and continually improve your experience at the Website. Here are the types of information we gather.

• We receive and store any information or document you enter or upload on our Website or give us in any other way, in line with the product or service opted by you and as required by us or our business partners, including your personal information like first name, last name, email address, date of birth, residence city etc.. You can choose not to provide certain information but then you might not be able to take advantage of many of our services and features. We neither collect nor store your biometric information.
• We may also have one time access to your camera, microphone, location and mobile device and store such information only for the purpose of onboarding or KYC requirements of us or our Partner with your explicit consent. in accordance with the Digital Lending guidelines issued by RBI and as amended from time to time
• We might receive information about you from other sources and add it to our account information.

3. We Collect Cookies

We receive and store certain types of information whenever you interact with us. For example, like, we use "cookies" and we obtain certain types of information when your web browser accesses the Website or advertisements and other content served by or on behalf of the Website on other websites. A cookie is a piece of data stored on the user's computer tied to information about the user. We may use both session ID cookies and persistent cookies. For session ID cookies, once you close your browser or log out, the cookie terminates and is erased. A persistent cookie is a small text file stored on your computer’s hard drive for an extended period of time. Session ID cookies may be used by upaybazaar.com to track user preferences while the user is visiting the website. They also help to minimize load times and save on server processing.

Most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie and how to disable cookies altogether. Additionally, you can disable or delete similar data used by browser add-ons, such as Flash cookies, by changing the add-on's settings or visiting the website of its manufacturer.

However, because cookies allow you to take advantage of some of the Website’s essential features, we recommend that you leave them turned on. For instance, if you block or otherwise reject our cookies, you may not able to use any Website products and services that require you to Sign in.

4. How do We Use The Information

upaybazaar.com collects your information when you register for an account, when you use its products or services; visit its Website's pages. When you register with upaybazaar.com, you are asked for your first name, last name, state and city of residence, email address, date of birth, and sex. Once you register at the Website and sign in you are not anonymous to us. Also, you are asked for your contact number during registration and may be sent SMS, notifications about our services to your wireless device. Hence, by registering you authorize the upaybazaar.com (including its business partners and affiliates) to send texts and email alerts to you with your login details and any other service requirements, including promotional mails and SMS, even if you have registered yourself under DND or DNC or NCPR services. Your authorization shall be valid as long as your account is not deactivated or unless you withdraw your consent upaybazaar Website may base on your consent also access your mobile device including camera for the purpose of service facilitation and ease of access to our Website for the various services opted by you and in compliance with applicable laws.

Purpose for collecting information:

• Assist us or our business partners in facilitating and delivering services to you, process payments and your applications, communicate with you about products, services and promotional offers.
• Respond to queries, or requests submitted by you, and resolve your grievances/issues/problems with any services supplied to you.
• Administer or otherwise carry out our obligations in relation to any agreement with our business partners.
• Send you information about special promotions or offers. We might also tell you about new features or products/services. These might be our own offers or products/services, or third-party offers or products/services with which upaybazaar.com has a tie-up.
• Use your information for internal analysis and to provide you with location-based services, such as advertising, search results, and other personalized content.
• Use this information to improve our platform, prevent or detect fraud or abuses of our Website and enable third parties to carry out technical, logistical or other functions on our behalf. We may combine information we get from you with information about you we get from third parties.
• Send you notice, communications, and recommend services that might be of interest to you update our records and generally maintain your accounts with us, display content and customer reviews.
• When you provide your contact details, we will use it to send you general notices or important news about your account, request your feedback or opinions and provide updates on special deals and offers that might interest you.
• File storage permissions on android/iOS and Website for uploading customer documents are obtained for the purpose of processing customer applications by our Partners.
• upaybazaar Website may base on your consent also access your mobile device including camera for the purpose of service facilitation, ease of access and logging in to our Website for the various services opted by you.
• As otherwise provided in this Privacy Policy and in compliance with the applicable laws.

Some features of this Website or our Services will require you to furnish your personally identifiable information as provided by you under your account section on our Website.

5. Disclosure to Third Parties

upaybazaar.com will not sell or rent or otherwise disclose your information for commercial purposes to anyone in a way that is contrary to the commitments made and/or other than as set forth in this Privacy Policy. Notwithstanding the foregoing, we may share your information to third parties including our group Company, employees, agents, business partner (Banks/NBFCs),CICs, Payment Aggregator and Service Providers we have a tie up with and any of our affiliates, for the purposes as set out in this Privacy Policy.

These third parties are required to handle your information using the same level of care and confidentiality as is followed by upaybazaar and any accessing or processing of your information by these third parties is in accordance with contractual terms, applicable laws and our instructions and subject to your consent. For the purposes of this paragraph, “Affiliate” shall mean, as to any Person, any other Person that, directly or indirectly, controls, or is controlled by, or is under common control with, such Person. (The term “control” (including, with its correlative meanings, “controlled by” and “under common control with”) shall mean the possession, directly or indirectly, of the power to direct or cause the direction of management or policies of a Person, whether through the ownership of securities or partnership or other ownership interests, by Contract or otherwise. The term "Person" includes any natural person, corporation, partnership, limited liability Company, trust, unincorporated association, or any other entity).

upaybazaar.com may also share, and/or transfer your personally identifiable information to any successor-in-interest as a result of a sale of any part of upaybazaar.com business or upon the merger, reorganization, or consolidation of it with another entity on a basis that it is not the surviving entity

We limit the collection and use of your personal information. We may make anonymous or aggregate personal information and disclose such data only in a non-personally identifiable manner. Such information does not identify you individually. Access to your Account information and any other personal identifiably information is strictly restricted and used only in accordance with specific internal procedures, and for the purposes set out in this Privacy Policy, in order to operate, develop or improve our services. We may use third party service providers to enable you to provide with our services and we require such third parties to maintain the confidentiality of the information we provide to them, under our contracts with them.

We may also share your information, without obtaining your prior written consent, with government agencies mandated under the law to obtain information for the purpose of verification of identity, or for prevention, detection, investigation including cyber incidents, prosecution, and punishment of offences, or where disclosure is necessary for compliance of a legal obligation. You agree and consent for the Website to disclose your information, if so required, under applicable law.

There are number of products/services such as loans, credit cards, mutual funds, offered by third Parties on the Website, such as lenders, banks, credit card issuers. If you choose to apply for these separate products or services, disclose information to these providers, then their use of your information is governed by their privacy policies in addition to the Privacy Policy of the Website. upaybazaar.com is not responsible for their privacy policies. We encourage you to visit and read about the privacy notices and procedures adopted by these third parties/providers, when you apply for their products or services. upaybazaar holds no responsibility for the content of the privacy policies or terms of use etc. of these third party websites

If you are investing in our mutual fund product through our Mobile App, then you agree to the following disclosure:

“upaybazaar's use and transfer to any other app of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements. upaybazaar app helps in tracking the performance of mutual fund investments, that may have been done via multiple channels/platforms over time, which can be otherwise cumbersome for consumers. Here, the basic consumer need is to be able to see and monitor all mutual fund investments together at one place.

To be able to provide this, post customer consent, the upaybazaar Website reads only the Mutual Fund CAS email statement (that includes details of all MF investments) received by the investor/customer every month and provides customers with a complete and comprehensive mutual fund dashboard on a single screen. This not only offers an enhanced consumer experience but helps them check, track and compare all active mutual fund investments together at one place, enabling informed financial decisions.

6. Data Storage

upaybazaar stores your personal information only at servers located in India. upaybazaar may retain your credit report, and credit score from Credit bureaus, including but not limited to a copy of your consumer credit report including credit score, at any time for (i) a limited period of six months or (ii) till such time the credit information is required to be retained to satisfy the purpose for which it was provided or (iii) until you withdraw your consent to store such Consumer Credit Information. For more details, kindly refer Credit Report Terms of Use Basic identification details of our customers are retained perpetually for meeting the servicing requirements of our customers. Any other information is retained for the period for which the same is required to provide the services to you as mandated in our arrangements with our business partners unless consent is withdrawn by you. Retention of information is done as per this policy in compliance with applicable law/regulatory requirements in India.

In following situation, upaybazaar may retain your information for an extended period (i) in case of requirement of any investigations under law or as part of any requirements before courts/tribunals/forums/commissions etc; (ii) to enhance/improve our products/services and (iii) as required under contractual arrangements with business partners.

7. What Is Your Control over Your Personal Information That’s Collected And Used Online

It's important to note that the information we use about you helps us provide you with products, services and experiences that benefit you. You have the ability to control how your non-personal information is collected and used online.

You also have the ability to choose what personal information, including what sensitive personal information (i.e. your financial information) you provide to us, restrict disclosure of your information to third parties, however, please note that this may affect your seamless access to such product/ service as opted by you. However, if you choose not to provide all of the mandatory information and data that is requested of you, we may not be able to provide you with the Services that you have subscribed to.

We believe you should be able to choose what kinds of information you receive via email/SMS. If you do not want to receive marketing materials by email/SMS, just indicate your preference on the contact information for your account or the 'opt-out' or unsubscribe link provided in our marketing emails and you can also write to us at support@upaybazaar.com. Please note that it may take about 10 days to process your request. Please keep in mind that we will continue to notify you by email /SMS/via phone calls regarding your services with us, even after you have opted out.

You can review the information that you have provided to us by logging into your account at the Website and correct or amend any personal information or sensitive personal data or information to ensure that the information or data you provided us is accurate and/or not deficient. upaybazaar.com is not responsible for the authenticity of any personal information or sensitive personal data or information supplied to it by you or any third party.

8. Revocation of Consent

If you feel that we do not require the retention of your personal information or if you ask us to delete or remove your personal data where you think we do not have the right to process it we shall destroy or delete such Customer information. You may, at any time while availing of our Services or otherwise, withdraw the consent given earlier to us to collect and use your sensitive personal data or information by writing to us at support@upaybazaar.com. However, in the case of you withdrawing such consent, upaybazaar.com shall have the option to stop providing you the Services for which the information was sought. You will not be eligible for a refund of any fees paid for any service in such event and you agree that the Website shall not be liable to you for the same in any manner whatsoever.

The data may be required to be retained for the purpose of Product servicing, repayment etc. by us and/or our Partners and also as required under any applicable laws. We assure that such retained information shall be protected following all cyber security norms.

9. Log Files

Like most standard websites, we use log files. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, platform type, date/time stamp, and number of clicks to analyze trends, administer the site, track user's movement in the aggregate, and gather broad demographic information for aggregate use. We may combine this automatically collected log information with other information we collect about you. We do this to improve the services we offer to you, to improve marketing, analytics or site functionality.

10. Data Security

upaybazaar.com is certified organization ensuring applicable compliance standards on information security and understands that the confidentiality, integrity, and availability of your information are vital to our business operations and our own success. We employ appropriate technical and organizational security measures at all times to protect the information we collect from you. We use multiple electronic, procedural, and physical security measures to protect against unauthorized or unlawful use or alteration of information, and against any accidental loss, destruction, or damage to information.. We have put in place appropriate security measures to deal with any suspected data security breach However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security. Further, you are responsible for maintaining the confidentiality and security of your login id and password, and may not provide these credentials to any third party.

During any security breach all the relevant stakeholders (both internal and relevant partners as well as statutory authorities) shall be informed with the relevant information as may be required by the applicable laws.

11. Third-Party Advertisers and Links to Other Websites

Third Party Advertising

We may use third-party advertising companies and/or ad agencies to serve ads when you visit our Website. These companies may use information (excluding your name, address, email address, or telephone number) about your visits to this Website in order to provide advertisements on this Website and other third-party websites about goods and services that may be of interest to you.

We use third-party service providers to serve ads on our behalf across the internet and sometimes on this Website. They may collect anonymous information about your visits to Website, and your interaction with our products and services. They may also use information about your visits to this and other Websites for targeted advertisements for goods and services. This anonymous information is collected through the use of a pixel tag, which is industry standard technology used by most major Websites. No personally identifiable information is collected or used in this process.

Links to Other Websites:

There might be other sites relating to our Banking and Non Banking partners linked to upaybazaar.com and other affiliates. Personal information that you provide to those sites is not our property or responsibility. These affiliated sites may have different privacy practices and we encourage you to read their privacy policies of these websites when you visit them. upaybazaar holds no responsibility for the content of the privacy policies or terms of use etc. of these third-party websites.

12. Changes in this Privacy Policy

upaybazaar.com reserves the right to change this policy from time to time, at its sole discretion. We may update this privacy policy to reflect changes to our information practices. We encourage you to periodically review. Checking the effective date below allows you to determine whether there have been changes since the last time you reviewed the statement.

13. Nodal Grievance Officer

The Company has appointed a Nodal Grievance Officer to redress customer grievances relating to any digital lending-related complaints. The name and contact details of the Nodal Grievance Officer are provided below:

If you have questions, concerns, or suggestions regarding our Privacy Policy, we can be reached using the contact information on our Contact Us page or at support@upaybazaar.com

14. Data Grievance Officer

In case you have any grievances or want to address any discrepancy with respect to the processing of any of the information/data you provided to upaybazaar.com, please contact our Data Grievance Officer. The name and contact details of the Grievance Officer are provided below:

If you have questions, concerns, or suggestions regarding our Privacy Policy, we can be reached using the contact information on our Contact Us page or at support@upaybazaar.com