Softmint Digital Services private Limited

Data privacy and Security policy

This document is an electronic record in terms of Information Technology Act, 2000 and rules thereunder as applicable.
This electronic record is generated by a computer/electronic system and does notrequire any physical or digital signatures

Introduction

Softmint Digital Services Private Limited (“Company” / “Us” / “We” / “Our”) considers Userrelationship and data security to be an important component of their service offerings(“Services”) through Our Website and Platform (as defined below). We are committed tomaintaining the confidentiality, integrity and security of any personal information of our Users.We are proud of our privacy practices and the strength of our Platform and Website securityand want you to know how We protect your information and use it to provide you with Services.This Data Privacy and Security Policy (“Policy”) enables us guard against identity theft andprovide security for User profiles and transactional history. We constantly re-evaluate thisPolicy and adapt it to meet data security standards and to deal with new challenges.

Definations

In this Policy: (i) capitalised terms defined by inclusion in quotations and / or parenthesis havethe meanings so ascribed; and (ii) the following terms shall have the following meaningsassigned to them herein below :

“Applicable Law” includes all applicable Indian statutes, enactments, acts of the statelegislature or parliament, laws, ordinances, rules, bye-laws, regulations, notifications,guidelines, directions, directives and orders of any governmental authority, statutory authority,board, recognised stock exchange, as may be applicable including but not limited to Guidelineson Managing Risks and Code of Conduct in Outsourcing of Financial Services by Banks, BusinessCorrespondent Guidelines issued by RBI from time to time, Payment & Settlement Systems Act,2007, Payment & Settlement Systems Regulations, 2008, Policy Guidelines on Issuance andoperation of Pre-paid Payment Instruments in India, and any other guideline in relation to pre-paid cards issued from time to time by Reserve Bank of India and in each case, any implementingregulation or interpretation issued thereunder including any successor Applicable Law;“Company” / “Us” / “We” / “Our” shall mean Softmint Digital Services Private Limited, a privatelimited company registered under Companies Act, 2013 and having its registered office at OfficeWARD NO-5 PANCHTILAKPUR, KOLGAMA SULTANGANJ, Bhagalpur BIHAR 813213 INDIA (whichexpression shall, unless it be repugnant to the context or meaning thereof, be deemed to meanand include its successors and permitted assigns);“Softmint ccount” shall mean the access account created by a User to avail Services onWebsite and/or Platform;“Person” shall mean any individual (including personal representatives, executors or heirs of adeceased individual) or legal entity, including but not limited to, any partnership, joint venture,corporation, trust, unincorporated organisation, limited liability company, limited liabilitypartnership or governmental authority;

“Personal Information” shall mean any personally identifiable information provided to Us by aUser for creation of a Softmint Account or availing Services through Website and/or Platform;“Services” shall mean the services provided by Company through its Platform including but notlimited to financial inclusion services in partnership with banks as business correspondent,distribution of financial products and services including loans, insurance products, investmentservices, issuance and sales of wallets and prepaid cards and non-financial nature products andservices through the Platform in collaboration with various partners;“User” / “You” / “Your”͖ shall mean any natural or legal person who has access to and is usingPlatform; and“Website” / “Platform” shall mean shall mean and include www.softmintindia.com, mobileapplication of Company, any successor website/ applications, any website of Related Entity orany other channel facilitated and permitted by Company including but not limited to App, anyother digital medium including phone, displays, emails, social media interfaces, messaginginterfaces, wallet, payment intermediaries using Company’s interface

3. Collection, Storage and Use of Information

3.1. We collect Your Personal Information when You successfully submit information while creatingzour Softmint ccount on Platform (“User Information”).User Information is the data thatcan be used to uniquely identify or contact a person and/or the business entity that a personrepresents and shall include, but not be limited to, Your Personal Information and such otherinformation for the purposes of identification and verification.

3.2. Without prejudice to the generality of paragraph 3.1 above, We may request such additionalUser Information as may be required for accessing and availing any Services through Platformas may be specified in the terms and conditions of use of such Service.

3.3. By creating a Softmint Account and by accessing Services, You authorize Us to collect, store,process, handle and use such User Information, in accordance with this Policy and any otherterms and conditions of use of Platform and/or Services (as amended from time to time)

3.4. Personal Information provided by You is used by Us to improve Platform and/or Service. We donot share Your Personal Information with any third parties for commercial use or revenuegeneration.

3.5. may share Personal Information such as Your name, mobile number and email address withthird party service providers appointed by Us to for sending SMS / Email communications toYou in relation to Platform and/or Services. We ensure that such third party service providersmaintain strict confidentiality of Your Personal Information.

4.Representations and Warranties

4.1. By creating a Softmint Account and accessing Services on Platform, You represent that Youare at least the age of majority in Your state or province of residence.

4.2. You shall not, in the use of the Service, violate any Applicable Laws in Your jurisdiction

4.3. You also understand and acknowledge that the use of the Platform requires internet and/ormobile connectivity. You shall bear the costs incurred to access and use the Platform and Weshall not, under any circumstances whatsoever, be responsible or liable for such costs.

4.4. You shall be solely responsible for all activities undertaken through Your Softmint Account,whether or not You have authorized such activities or actions and shall, at all times, keep Usindemnified in this regard.

4.5. A breach or violation of any of this Policy will result in an immediate termination of Services andmay result in reporting to the law enforcement agencies.

4.6. In addition to other prohibitions as set forth in the Terms of Use, You understand and agreethat You are prohibited from using the Platform or its Content:

(i)for any unlawful purpose;

(ii)to solicit others to perform or participate in any unlawful acts

(iii)to violate any international, federal, provincial or state regulations, rules, laws, orapplicable ordinances;

(iv)to infringe upon or violate our intellectual property rights or the intellectual propertyrights of others;

(v)to harass, abuse, insult, harm, defame, slander, disparage, intimidate, or discriminatebased on gender, sexual orientation, religion, ethnicity, race, age, national origin, ordisability

(vi)to submit false or misleading information

(vii)to upload or transmit viruses or any other type of malicious code that will or may beused in any way that will affect the functionality or operation of the Service or of anyrelated Platform, other Platforms, or the internet

(viii) to collect or track the personal information of others;

(ix)to spam, phish, pharm, pretext, spider, crawl, or scrape;

(x) for any obscene or immoral purpose;or

(xi) to interfere with or circumvent the security features of the Service or any relatedPlatform, other Platforms, or the internet. We reserve the right to terminate your use ofthe Service or any related Platform for violating any of the prohibited uses

5. Accuracy and Completeness of Information

5.1. You represent and warrant that You shall be responsible for accuracy and correctness of all UserInformation provided by You for creation of a Softmint Account and for accessing any Servicesavailable on Platform.

5.2. For the purposes of internal verification and/or for compliance with Applicable Law includingbut not limited to e-KYC requirements, You may be required to submit such personalidentification documents as may be required by Us from time to time. You shall remain solelyresponsible for accuracy and validity of all such personal identification documents.

6. Third-Party Services

6.1. We may allow You to access certain Services provided by third-party service providers, whichwe neither monitor nor exercise any control over.

6.2.You acknowledge and agree that We provide access to such third-party Services on an “as isbasis” and “as available” without any warranties, representations or conditions of any kind andwithout any endorsement. We shall have no liability whatsoever arising from or relating to youruse of such third-party Services.

6.3. Any use by You of third-party Services offered through Platform is entirely at Your own risk anddiscretion and You should ensure that You are familiar with and approve of the terms on whichthird-party Services are provided by the relevant service provider(s).

6.4. We may also, in the future, offer new services and/or features through Platform (either by Usor by third-party service providers). Such new features and/or services shall also be subject tothis Policy.

7. Intellectual Property

7.1. All copyright, database right and all other proprietary rights, title and interest in all informationpresented on Platform (“Intellectual Property”) is owned by and/or licensed to Us or owned byand/or licensed to the provider of Services or is owned by and is or may be protected or coveredby copyright, trade mark, intellectual property law and/or other proprietary rights, unlessexpressly stated otherwise

7.2. use of Platform and/or Services does not confer on You or any other party, any licence orother rights under Intellectual Property or other proprietary rights of Company and/or providerof Services and/or of any third party, whether implied or otherwise.

8. Disclosure of User Information

8.1. Notwithstanding paragraph 3 above, We reserve the right to utilize, share and/or disclose UserInformation if:

(i) required to do so to comply with orders of governmental authorities that havejurisdiction over it or as otherwise required by Applicable Law after providing You awritten intimation prior to such disclosure; and/or

(ii)We determine, in Our sole discretion that disclosure of User Information is necessary toidentify, contact, or bring legal action against you

9. Removal of Stored Information

9.1. We ensure that any User Information stored with Us is and remains to be in Yourownership. Upon deletion of Softmint Account, We will, to the reasonable extentpossible, remove User Information stored with Us within 3 (three) months from the dateof such deletion

9.2. Notwithstanding the above, We reserve the right to retain such User Information thatforms part of anonymized and aggregated data derived from User Information which maybe used for improvement of our Platform and/or Services, to produce analytical reports,marketing, advertising or such other activities as We may deem fit

10. Indemnification

You agree to indemnify, defend and hold harmless Us and Our parent, subsidiaries, affiliates,partners, officers, directors, agents, contractors, licensors, service providers, subcontractors,suppliers, interns and employees, harmless from any claim or demand, including reasonableattorneys’ fees, made by any third-party due to or arising out of Your breach of this Policy orthe documents they incorporate by reference (including terms and conditions of use of Platformand/or Services), or Your violation of any law or the rights of a third-party

11.Security Precautions

To prevent any form of unlawful interception or misuse of User Information, We use reasonablephysical, electronic and managerial procedures to safeguard and secure User Informationcollected. We use reasonable secure and technologically appropriate measures, in compliance with the Information Technology Act, 2000 and the rules related thereto to protect You againstloss or misuse of Your User Information including internal reviews of data collection, storageand processing practices and other reasonable security measures which are equivalent tosecurity measures that We use to protect Our own confidential information. However, as Youare aware, no internet website or online platform is completely free of security risks and We donot make any representation in respect of the same.

12.Change in Privacy Policy

We reserve the right to update, modify and amend any of the terms of this Policy, at any timewithout prior intimation to You. We will post these changes on Platform for Your information.These changes will become effective immediately on posting. We shall not be liable for anyfailure or negligence on Your part to review the updated Policy before accessing Platformand/or availing Services. Your continued use of the Platform, following changes to this Policy,will constitute Your acceptance of those changes.

13. What we collect?

We may collect and/or gain access to and/or record certain information including personal information from or of User in a variety of ways, including,but not limited to,when User access and uses the Services and in connection with other activities,services,features or resources we make available on the Services. These information may relate to and include but not limited to your name,date of birth,gender,father name,mother name, marital status,email address,address (including PIN code,city,state, residence type),phone number (including alternative mobile number, reference mobile number,reference person name),your unique device ID (persistent / non-persistent),photograph/ selfie,your KYC details/ documents,business details/ documents (including business address), PAN Number,GST details (including extracting of GST from PAN or from GST Number),hardware type,international mobile equipment identity ("IMEI"), the version of your operating system ("OS"),your device name,your email address (if you have connected to Facebook or Google+),and your location (based on your Internet Protocol ("IP") address) (including demographics (LAT LONG) on various stages, and contact information, applications installed by User through our mobile application,applications uninstalled by User,all other applications installed by User on his/her device,foreground running apps/process (RUN event; We update server about the app downloaded/installed by our mobile application),SMS data and read SMS, network information,User behaviour analysis,demographic information (such as preferences and interests etc),Credit/Debit Card information of User for Internet banking (We do not store credit/debit card information on our servers),credit or affluence related information or assessment and/ or documents,user selected offer,bank statement (upload or net banking), personal bank account numbers and bank account data/ details including e-nach,NEFT,IMPS,UPI ID details,salary and income details. Users can always refuse to supply Personal Information,however,it may prevent them from engaging in certain Services related activities.

14. What we do with the Personal Information we gather?

We may use your Personal Information to :

Administer the Services.

Personalize the Services for User

End to User direct links to the Services.

Process transactions.

Process installation.

Send User our newsletter.

Develop,deliver,and improve our products,services,content,and advertising.

Send important notices,such as communications about purchases/downloads and changes to our Policy

Auditing,data analysis,and research to improve the Services.

Troubleshooting and helping us to understand usage trends

Send alerts to User.

Marketing and promotion of the Services.

15. Collection and use of non-personal information

We may collect non-personal information about Users whenever they use and interact with the Services. Non-personal information may include the information other than the Personal Information (as indicated above) and may also include browser name,the type of computer,and technical information about means used by the User to connect to our Services,such as the information about the operating system and the internet service providers utilized and other similar information. This information is aggregated and used to help us provide more useful information to the User and to understand which part of the Services,its products,and services are of most interest. If we do combine non-personal information with Personal Information,the combined information will be treated as Personal Information for as long as it remains combined.

16. Sharing of information with Authorities

We may share Personal Information as well as non-personal information of the User with the courts,police authorities,or any other government/regulatory/statutory authority,in case these are required by them in relation to any proceedings pending before them.

17. Privacy Policy Statement for Contact Information Collection

At Softmint Digital Services Pvt Ltd, we are committed to protecting the privacy and security of our users' personal and sensitive information. This includes the contact information we collect from our users on behalf of Yes Bank Ltd. in order to provide digital banking services.

We collect contact information from our users for the purpose of providing banking services, such as account management, transaction processing, customer support, and fraud prevention on behalf of Yes Bank Ltd. This information may include name, email address, phone number, and other relevant contact details.

We understand that our users may have concerns about sharing their contact information, and we take appropriate measures to safeguard this data. We have implemented strict security measures to protect our users' contact information from unauthorized access, use, or disclosure. We do not sell or share users' contact information with any third-party without their explicit consent, except as required by law or in response to a valid government request.

We are committed to providing clear and transparent disclosures about our data collection and use practices. We understand that our current privacy policy and disclosures may not have met policy requirements and apologize for any confusion or frustration caused. We will review and update our policies to ensure that they meet all applicable policy requirements and provide clear and transparent disclosures to our users.

18. Contacting Us

If You have any queries regarding: (i) this Policy; (ii) information and/or Services available onPlatform, or (iii) Your dealings with Us or believe that We have not adhered to it, You maycontactUs at info@softmintindia.com

19.Email Opt-Out

You can opt out of receiving Our marketing and update emails. To stop receiving Ourpromotional emails, please email care@softmintindia.com. It may take about ten days toprocess Your request. Even if You opt out of getting marketing messages, We will still be sendingYou transactional messages through email and SMS in relation to Your Softmint Account andServices availed by You