Privacy Policy

Scope

The Data Privacy Policy sets out the requirements for ensuring that Falcon Trading Private Limited (FTPL/we) collect, use, retain and disclose personal information in a fair, transparent and secured way. This Data Privacy Policy is applicable to the personal information (including sensitive personal data or information) of:

• FTPL customers,
• Users of the website, mobile applications (if any), and social media accounts of FTPL,
• Employees or temporary staff,
• Contractors,
• Third party vendors, or
• Unauthorized use of this website may give rise to a claim for damages and/or be a criminal offence.
• Any other persons that are associated with FTPL for any business-related transactions/

This Data Privacy Policy is not applicable to independent data held by third-parties, but will continue to be applicable to:

Personal information collected or processed by third parties on behalf of FTPL.

Personal information of third-parties collected by

By accessing or using this website or services provided by FTPL, you agree to be bound by the terms described herein and all the terms incorporated by reference. If you do not agree to all of these terms, do not use this website or services provided by FTPL.

Objective

This Data Privacy Policy provides guidance on processing of personal information, which includes, but is not limited to, collecting, using, retaining/storing, accessing and/or disclosing such information by FTPL as often as is necessary. FTPL is committed in respecting the individual’s privacy rights and expectations and in protecting the individual’s personal information collected by FTPL from unauthorized access, use, retention/storage and/or disclosure. Meeting this commitment is a primary management objective and collective responsibility of all FTPL employees as well as third parties conducting business with or on behalf of FTPL.

Responsibility for Compliance

The Data Privacy Policy contained in this document has been established to cover information and information systems such as software, hardware, firmware, storage, transmission media and computer networks (collectively referred to as ‘Information Assets’) used by FTPL. FTPL employees, senior professionals, and third-party vendor/contractor etc., shall ensure compliance with the obligations outlined in this policy document. Compliance with this Data Privacy Policy shall be ensured by:

All FTPL employees and temporary staff who have access to personal information as part of their business activities

Senior professionals, who are accountable for ensuring that appropriate privacy controls are in place within their business function

Third party vendors and contractors or any outsourcing partners, who perform services for or on behalf of FTPL and are expected to embrace standards of conduct consistent with the principles of this Data Privacy

Consequence Management & Non-Compliance

Any violation of this Data Privacy Policy is subject to disciplinary action. The specific disciplinary action depends upon the nature of the violation. Violations will be handled as per the existing HR processes and could range from a verbal reprimand to termination of employment/contract and/or legal action.

If a department or function is unable to comply with any requirements detailed within this Data Privacy Policy, an exception shall be obtained. Such exceptions shall be documented, indicating the rationale for the exception and the related risks.

Policy statement

All FTPL employees shall comply with Indian IT Act of 2000 (including IT Amendment Act of 2008 and IT Rules of 2011) for privacy and protection of personal information and sensitive personal data or information of customers, employees, contractors and third party vendors or any other persons or entities that are associated with FTPL for any business related transactions / communications – verbal or implied.

Key Data Privacy Principles

The Data Privacy Policy represents the minimum standards that FTPL has set with respect to data privacy. It aligns with (and in some cases exceeds) the requirements of applicable laws and regulations (i.e. Indian IT Act of 2000, IT Amendment Act of 2008 and IT Rules of 2011).

Personal information refers to any information that relates to a natural person, which, either directly or indirectly, in combination with other information available or likely to be available with FTPL, can identify such person. Personal information includes sensitive personal data or information. The personal information (including sensitive personal data or information) collected by FTPL includes:

• Name
• PAN card number
• Driver’s license number
• Bank Account number
• Passport number
• Email Address
• Aadhaar Card
• Account statement

Any other personal information (including sensitive personal data or information) received by FTPL for processing, stored or processed by FTPL under lawful contract or

FTPL values the personal information entrusted to it and the NBFC is committed to collecting, using, retaining and disclosing personal information in a fair, transparent and secure way by adhering to the following key principles:

Collection Limitation:

Personal information shall be collected by fair, lawful and transparent means. FTPL shall be open with individuals about how the NBFC will use their personal information, with whom it will be shared and where it may be sent.

Consent shall be taken in writing or electronically from the provider of the sensitive personal data or information regarding purpose of usage before collection of such information.

While collecting the personal information directly from the concerned person, FTPL shall take reasonable steps to ensure that the provider of information is aware of the following aspects:

• The fact that personal information is being collected
• The purpose for collecting such information
• The intended recipients of such information
• The name and address of entities who are collecting and retaining such information

The provider of information shall, at any time while availing the services or otherwise, also have an option to withdraw its consent given earlier to FTPL. Such withdrawal of the consent shall be sent in writing to FTPL on Communication address at 2nd and 3rd Floor, The Ridge, Opposite Novotel, Iscon Char Rasta, Ahmedabad, Gujarat – 380060 or through email on grievance@ratnaafin.com In case the provider of information withdraws his / her consent in relation to personal information, FTPL shall evaluate the request and take appropriate If an individual does not provide their personal information or subsequently, withdraws consent in relation to personal information, FTPL shall have the option not to provide services for which the said information was sought. FTPL may retain some data to meet its obligations under applicable law.

Data Minimization:

Only personal information required for authorized business activities shall be collected from the information provider. Personal information shall not be made available to anyone (including internal staff) who is not authorized or does not have a business need to know the information.

Purpose of collection:

As per regulatory requirement, FTPL collect personal information for performing KYC of the customer, bank account statements are collected to establish credit worthiness of the customer, bank account details are collected for collection of dues/loan repayment. Personal Information of employees is collected for the purposes of background verification, salary payment, insurance etc.

Use Limitation:

The personal information shall be used for the purpose for which it has been collected. The privacy risks shall be taken into consideration, before the collection, use, retention, or disclosure of personal information, such as in a new system or as part of a project.

Security:

There shall be adequate protection for the personal information collected, used, retained and disclosed to support FTPL business activities by following the relevant usage, technical and organizational policies, standards and processes:

FTPL has comprehensive documented information security program and information security policies that contain managerial, technical, operational and physical security control measures.

However, FTPL will not be responsible for any loss, unauthorized access or any harm caused to the information provider by any misuse of his or her personal information, unless it is a direct and foreseeable consequence of negligence and non-compliance on the part of FTPL only. The information provider hereby acknowledges that FTPL will not be responsible, in particular, for any third party action or action on the part of the information provider leading to loss, damage or harm to such information provider or any other person.

Access, Correction and Update:

Processes shall be defined to enable the providers of information, as and when requested by them, to review the information they had provided and ensure that any personal information or sensitive personal data or information found to be inaccurate or deficient shall be corrected or amended as feasible. FTPL shall not be responsible for the authenticity of the personal information or sensitive personal data or information supplied by the provider of information. FTPL shall ensure that the data provided by customers is correct through verification of documents submitted by them as per process laid out in the ‘AML / KYC Policy’.

To review, correct or update their personal information, customers can write to us at- grievance@falconfin.ai or reach out to us at our Communication address 210, Parekh Market building, Near Kenedy Brodge , Opera house, Mumbai , Maharshtra, 400004

Retention:

Sensitive personal data or information shall be retained no longer than required, to support a specific business activity or legal or regulatory requirement.

Disclosure:

The personal information (including sensitive personal data or information) collected or stored by FTPL, may be disclosed to comply with applicable law, directions from Government agencies mandated under law for prevention and investigation of offences, or to comply with an order issued by a competent court.

Transfer of Personal Information to Third Parties:

Adequate protection mechanism shall be provided for personal information in case it is transferred outside FTPL network.

FTPL may transfer sensitive personal data or information to any other entity or person located in India or any other country that ensures the same level of data protection that is adhered to by FTPL under the IT Rules of 2011. Transfer of information shall be allowed only if it is necessary for the performance of lawful contract entered into between FTPL or any person on its behalf and the information provider or where the information provider has consented to such transfer.

Personal information, including sensitive personal data or information, may be disclosed or transferred to insurance providers, credit bureau, verification agencies, collection partner, Regulatory & legal authorities (Credit information agencies, law enforcement agencies, judicial agencies), affiliates and business partner

Reasonable due diligence activities shall be conducted to ensure that the third party has appropriate security & privacy controls in place prior to sharing of any personal information (including sensitive personal data or information)

Marketing and Promotional Activities: Marketing and promotional communications shall be sent to providers of information / customers only after obtaining required consent from them in adherence to obligations under applicable law.

Grievance Officer

The grievances or discrepancies reported by provider of information with respect to processing of personal information shall be addressed in a time-bound manner by the designated ‘Grievance Officer ’. Customers can write to us at grievance@ratnaafin.com or reach out to us on our Communication address on grievance@falconfin.ai or reach out to us at our Communication address 210, Parekh Market building, Near Kenedy Brodge , Opera house, Mumbai , Maharshtra, 400004

Grievance Officer Details: Mr. Ravindra Shinde

Communication Address: 210, Parekh Market building, Near Kenedy Brodge , Opera house, Mumbai , Maharshtra, 400004

Email: grievance@falconfin.ai

Third Party Websites and Services

FTPL’s website and services may contain links to third party services, and give the user the ability to access such third-party websites, products, and services. Customer / borrower to proceed to use such third party website or service at r own risk. FTPL will not be held liable for any outcome or harm arising as a result of such use of such third party websites or services. Please read the privacy policies of any third party before proceeding to use their websites, products, or services.

Changes to this Data Privacy Policy

FTPL may periodically revise or update this Data Privacy Policy. Continued use of FTPL’s website and / or services after the effective date of the Data Privacy Policy means that the user accepts the revised Data Privacy Policy. If the user does not agree with any such revised terms, please refrain from using FTPL’s website and / or services.