This document is an electronic record in terms of the Information Technology Act, 2000. This is a computer-generated document and hence does not require any physical or digital signatures.

YOU MUST CAREFULLY READ THIS PRIVACY POLICY BEFORE USING ANY OF OUR SERVICES

1. INTRODUCTION

SarvaGram Fincare Private Limited, and its subsidiaries, affiliates, and group companies (hereinafter collectively referred to as ‘SarvaGram’/‘us’/‘we’/‘our’) are fully committed to respecting your privacy and we recognize the need for appropriate protection of any personal information and data you share with us.

This Privacy Policy (‘Policy’) highlights our privacy practices and procedures and describes how SarvaGram collects, uses, discloses, transfers and deals with personal information and sensitive personal information of the visitors, users (registered as well as unregistered) and subscribers (hereinafter collectively referred to as ‘Users’) of our website www.sarvagram.com and/or application and all other websites, if any, and Services (as defined in Terms of Use) including any associated web-pages, accessed through computer, mobile or any other electronic device, and also information that you provide us while participating in our online surveys, registrations and/or subscriptions or at the time of customer onboarding while availing the products and services provided by SarvaGram (hereinafter collectively referred to as ‘Website’ or ‘Platform’).

For the purposes of this Policy,

• ‘you’ or ‘your’ shall mean the individual or person who is accessing the Platform;
• “Personal Information” shall mean any information/data which, directly or indirectly, relates to an individual or person who may be identified or contacted from such information/data or from a combination of a set of such information/data and other information which is in possession of SarvaGram collected on the Platform including, for example, your name, address, telephone number, e-mail address, as well as any other non-public information about you that is associated with or linked to any of the foregoing data. Personal Information includes Sensitive Personal Data or Information;
• “Sensitive Personal Data or Information” of a person shall mean such personal information which consists of information relating to (a) Password; (b) Financial information such as bank account or credit card or debit card or other payment instrument details; (c) Physical, physiological and mental health condition; (d) Sexual orientation; (e) Medical records and history; and/or (f) Biometric information. Provided that, 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 Data or Information for these purposes.

All Users are requested to read and understand this Policy as it has been formulated to safeguard your online privacy. This Policy is incorporated into and subject to the Terms of Use available at terms of use. Capitalized terms not defined in this Policy have the meanings given in our Terms of Use available at terms of use.

By accessing the Services provided by the Website and submitting Personal Information through our Website and by accepting this Policy and the Terms of Use of use of the Website, you agree to the terms of this Policy and you expressly consent to the collection, use and disclosure of your Personal Information in accordance with this Policy.

This Policy is not intended to override the terms of any contract you have with us, nor any rights you may have under other applicable data privacy laws.

If you read and fully understand this Policy, and remain opposed to our practices, you must immediately leave and discontinue the use of the Website or use of any of our Services.

2. Personal Information we collect and process

When you use the Platform and/or register for any of our Services, and/or when you contact us directly by any communication channel, you may provide us Personal Information. We collect and store such Personal Information provided by you from time to time to extend the Services available on the Platform. Our primary goal in doing so is to provide you a safe, efficient, smooth, and customized experience.

In general, you can browse the Platform without telling us who you are or revealing any Personal Information about yourself. However, once you give us your Personal Information by accessing certain Services on our Platform, you are no longer anonymous to us. Where possible, we indicate which fields are required and which fields are optional for you to choose whether you wish to provide us the information for accessing the Services on the Platform.

We collect and store the following categories of Personal Information in the following ways:

• We collect Personal Information from you when you set up a free account with us and/or sign up for alerts on the Platform and/or seek any information in relation to our Services.
• In relation to our Services, we may also collect Personal Information including Sensitive Personal Data or Information which includes bank account numbers, credit card details and related details to facilitate such Services available on the Platform.
• We may automatically track certain Personal Information about you based upon your behaviour on our Platform. We use this Personal Information to do internal research and analysis to better understand, protect and serve our Users for providing improved experience and value-added services.
• When you use a device to access the Platform, we may also collect technical or other related information from the device as well as the device location.
• We may collect your Personal Information such as name, age, contact details, preferences, and demographic information (like zip code, age, or income level), etc. through optional online surveys, campaigns, and forms, etc. when you choose to participate in these surveys.
• We may receive Personal Information about you from third-party sources, such as security providers, fraud detection and prevention providers, social media platforms, advertising and marketing partners, etc.
• We may also monitor your communications with us to ensure compliance with applicable laws as well as our internal policies.
• If you choose to post messages on our message boards, chat rooms or other message areas or leave feedback, we will collect that all such information you provide to us.
• If you send us personal correspondence, we may collect such information into a file specific to you.
• The Website may contain links to other web sites. SarvaGram is not responsible for the privacy practices of such web sites which it does not own, manage, or control.

3. USE OF PERSONAL INFORMATION

Please be assured that we will use your Personal Information in a fair and reasonable manner only and in accordance with this Policy and applicable Laws.

We use your Personal Information for providing you the Services you request on our Platform. Our use of your Personal Information depends on the purpose for which you interact with us and the Service you request. We use and process your Personal Information in the course of providing Services to you including, without limitation, for the following purposes:

• To measure consumer interest in our Products and Services;
• To conduct market research and surveys with the aim of improving our Products and Services;
• To customize your experience and to provide access to desirable content based on your preferences;
• To understand which parts of the Website are visited and how frequently;
• To create your login user ID and to identify you once you register on the Platform;
• To generate business enquiries and leads;
• To help us to update, expand and analyze our records to identify new customers;
• To send out communications, notifications, newsletters, and customized mailers, etc. to the Users;
• To send you information about new products, services, and special offers. We might tell you about new promotions, features, or updates. These might be third party offers or products we think you might find interesting;
• To reach out to you and respond to your questions, requests, complaints, applications, and entries;
• To contact you about your account or feedback;
• To process job applications received or other career opportunities related requests received through the Platform and to send out job/opportunities’ alerts;
• To advertise, market, promote and for publication purposes;
• To inform you about online and offline offers, Products, Services, and updates;
• To provide better usability, troubleshoot problems and site maintenance;
• To protect our Users and provide you with customer support;
• To help promote a safe service;
• To collect money/Fees;
• To create aggregated statistical data and other aggregated and/or inferred Personal Information, which we or our business partners may use to provide and improve our respective Services;
• To improve your user experience and the overall quality of our Services (in relation to information collected from cookies);
• Communications between Users and our representatives, for quality control and/or training purposes;
• To prevent, detect, investigate, and protect us against any other illegal activities, suspected fraud and other criminal activity, violations of our Terms of Use, etc.
• To establish, exercise, defend legal rights in connection with any legal disputes (including prospective legal disputes) and for seeking professional legal advice for the purposes of resolving such legal disputes;
• To comply with any applicable Laws and regulations; and/or
• To help diagnose problems with our server, and to administer our Platform. Your IP address is also used to help identify you and to gather broad demographic information.

4. SHARING OF PERSONAL INFORMATION

We may share your Personal Information with service providers and others (or otherwise allow them access to it) in the following manners and instances:

• Third Party Service Providers: SarvaGram has partnered with a number of selected service providers, whose services and solutions complement, facilitate, and enhance our own. These include hosting and server co-location services, data and cyber security services, billing and payment processing services, domain name registrars, logistic service providers, fraud detection and prevention services, web analytics, monitoring services, session recording and remote access services, performance measurement, data optimization and marketing services, content providers, and our legal and financial advisors (collectively, “Third Party Service Provider(s)”). SarvaGram may share your Personal Information with Third Party Service Providers for business purposes.
• Law Enforcement, Legal Requests and Duties: SarvaGram may disclose or otherwise allow access to your Personal Information pursuant to a legal request, such as a summons, legal proceedings, search warrant or court order, or in compliance with applicable Laws, if we have a good faith belief that the Law requires us to do so, with or without notice to you. SarvaGram may also share or disclose, without obtaining your prior written consent, your Personal Information 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.
• Protecting Rights and Safety: SarvaGram may share your Personal Information if we believe in good faith that this will help protect the rights, property, or personal safety of SarvaGram, any of our Users, or any member of the general public, with or without notice to you.
• SarvaGram Subsidiaries and Affiliated Companies: We may share your Personal Information internally within our group companies, for the purposes described in this Policy. We may also share your Personal Information with our employees who we believe reasonably need to know the same to fulfill their jobs to provide, operate, develop, and/or improve our products or services.
• In connection with a change in corporate control: In addition, should SarvaGram or any of its affiliates undergo any change in control, including by means of merger, acquisition, or purchase of substantially all of its assets, your Personal Information may be shared with the parties involved in such event.
• Upon your further direction: SarvaGram may also share your Personal Information with third parties for other purposes upon your further direction or with your explicit approval.

You authorize SarvaGram to exchange, share, part with all information related to the details and transaction history of the Users to its affiliates / banks / financial institutions / credit bureaus / agencies/participation in any telecommunication or electronic clearing network as may be required by Law, customary practice, credit reporting, statistical analysis and credit scoring, verification or risk management or any of the aforesaid purposes and shall not hold SarvaGram liable for use or disclosure of this Personal Information.

5. Data Transfers

Your Personal Information collected by us may be transferred to, and stored at, any of our subsidiaries/affiliates/group companies, partners, or service providers, authorized third-party agents, or contractors data centers in or outside India, subject to applicable Law. By submitting your Personal Information, you give your consent to such transfers and storage of Personal Information. When we transfer or disclose your Personal Information to other countries, we will protect your Personal Information by appropriate contractual safeguards to ensure that your Personal Information is processed with the highest or same standards of transparency and fairness, as described in this Policy in accordance with applicable Laws.

• Data Localization Obligations: If you reside in a jurisdiction that imposes “data localization” or “data residency” obligations (i.e., requiring that Personal Information of its residents be kept within the territorial boundaries of such jurisdiction), and this fact comes to our attention, we may maintain your Personal Information within such territorial boundaries, if we are legally obligated to do so.

You acknowledge that while doing so, we may continue to collect, store, and use your Personal Information elsewhere, including in India, as explained above.

6. Consent

By visiting and using the Platform, and/or by submitting your Personal Information, you explicitly consent to the collection, use, sharing, and disclosure of your Personal Information as outlined in this Policy. If you do not agree with these terms, please refrain from using or accessing our Platform.

You have the right to withdraw your consent to the processing of your Personal Information at any time by informing us in writing (which includes electronic form). Upon withdrawal of your consent, your contract with SarvaGram will terminate as per the terms agreed between us. Please note, however, that if you withdraw your consent to process your Personal Information, we may have to discontinue providing you with our Services through the Platform.

7. Access, Updating, Correction, and Amendment of Personal Information

Users may review, access, update, correct, or amend their Personal Information, including their profile and preferences, in accordance with applicable Laws. This can be done in the sections where such information was initially provided or by logging into your account on the Platform. Changes may take some time due to verification processes and caching policies. If you encounter difficulties in updating or accessing your Personal Information, please contact us.

8. Retention of Personal Information

SarvaGram will not retain your Personal Information longer than necessary for the purposes for which it was collected and processed, or in accordance with legal, regulatory, contractual, or statutory obligations. Upon expiry of the retention period, your Personal Information will be deleted or archived in compliance with applicable Laws.

We may retain your Personal Information even after account deactivation or cessation of particular Services as reasonably necessary to comply with legal obligations, resolve disputes, prevent fraud and abuse, enforce agreements, or protect legitimate interests.

Note that permanently deleting your account removes most of your Personal Information from SarvaGram’s databases. However, some Personal Information may be retained for compliance with legal requirements, audit, and internal compliance purposes. After this process, you will no longer be able to use any Services or access your account.

9. Security Precautions

SarvaGram employs reasonable and appropriate security practices and procedures to safeguard your Personal Information and prevent unauthorized use, misuse, loss, or alteration of the information under our control. This includes managerial, administrative, operational, physical, and technical security measures to maintain data accuracy and ensure proper use.

Despite these efforts, no data transmission over the Internet can be guaranteed as fully secure. We continually seek new ways and third-party services to enhance our security and protect user privacy.

We advise you to set strong passwords, avoid sharing sensitive Personal Data, and use secure methods of communication. Do not disclose passwords or important credentials to anyone, and ensure you sign out of your account when using a shared or public computer.

10. Changes in Policy and Interpretation

SarvaGram reserves the right to update, change, or modify this Policy at any time. Such changes will take effect from the date of publication. To stay informed about any updates, please periodically review this Policy.

This Policy is written in English and may be translated into other languages for convenience. If there are discrepancies between the English version and any translated version, the English version will prevail.

11. Use of Cookies

We use cookies and similar technologies (“Cookies”) to provide and improve our Services, analyze performance and marketing activities, and personalize your experience.

For more information on how we use Cookies and how you can control them, please refer to our Cookie Policy.

Most browsers allow you to control Cookies, including setting preferences to accept or block them. You can set your browser to notify you when you receive a Cookie or block Cookies entirely.

12. Disclaimer

We do not store any account-related or credit/debit card information and are not liable for any loss or damage resulting from the disclosure of such information during online transactions or payments.

If you share Personal Information not requested by SarvaGram during registration, we are not liable for any security breaches or disclosures related to such information. For any questions regarding this Policy or the protection of your Personal Information, please contact our Grievance Officer.

13. Grievance Officer

For any grievances or questions regarding this Policy, please contact:

Name: Ankit Agarwal
Email address: grievance@sarvagram.com

For other inquiries, you may also reach out to us at our email.