Privacy Policy

This privacy policy (“Policy”) sets forth the modes of collection, use and disclosure of your information gathered through any Digital Lending App used by us. This Policy applies only to personal information collected on the platform. Please read this Policy carefully. By continuing to use the services you agree to this Policy. If you do not agree to this Policy, you may choose to not avail the services. Access to any Platform is subject to the Terms and Conditions (Terms) accessible on that Platform.

INTRODUCTION

We, EarlySalary Services Private Limited (Company; We; us; our) have an in-house Digital Lending App (“DLA”) called Fibe (Formerly known as EarlySalary) (Application/ App), offered through our Lending Service Provider, Social Worth Technologies Private Limited through which you may apply for a loan (Loan), which shall be granted based on the loan agreement executed. Customer (hereinafter referred to as ‘Customer’, ‘You’, as the reference maybe) authorize us to collect, store, authenticate, verify and distribute the Personal Information (defined below) as may be required to sanction the Loan. Personal Information shall be collected through the mobile application form (Mobile Application Form) available on the Application.

We are committed to protecting your privacy and have made this Privacy Policy to describe the procedures we adhere to for collecting, using, and disclosing the Personal Information. We recommend you read this Privacy Policy carefully so that you understand our approach towards the use of your Personal Information.

PERSONAL INFORMATION COLLECTED

In order to avail the Services, you are required to register with the Company by logging in the Platform (User Account). For the purpose of this Policy, Services shall mean the services of granting, sanctioning, lending of loans, through the platform. During the application process, you shall be required to share/ upload certain personal information, your name, e-mail address, gender, date of birth, mobile number, passwords, photograph, mobile phone information, SMS and browsing history, data , financial information such as bank documents, salary slips, bank statements, PAN card, bank account no., data from Credit Information Companies, data required for Know Your Customer compliances, requirement and other relevant details (together hereinafter referred to as ‘Personal Information”). You undertake that you shall be solely responsible for the accuracy and truthfulness of the Personal Information you share with us.

You understand and acknowledge that the Company reserves the right to track your location (Track) during the provision of the Services, and in the event that you stop, cease, discontinue to use or avail the Services, through the deletion or uninstallation of the Mobile App or otherwise, till the event that your obligations to pay the Outstanding Amount(s) exist. Deletion, uninstallation of the DLA, and/or discontinuation of our Services shall not release you from the responsibility, obligation, and liability to repay the Outstanding Amount(s).

You further understand and acknowledge that provision of the information provided herewith is voluntarily and you may choose to provide and/or withhold provision of any data. However, in case of non-provision of any data you may not be eligible for certain services for which the data needs to be collected.

GOVERNING STATUTE

This Privacy Policy is governed by and is compliant with the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules 2011, which is designed to protect Personal Information of the End-User(s) of the Services; and other applicable rules and regulations related to privacy.

COOKIES

We may set cookies to track your use of the Platform. Cookies are small, encrypted files, that a site or its service provider transfers to your device’s hard drive that enables the sites or service provider’s systems to recognize your device and capture and remember certain information. By using the Application, you signify your consent to our use of cookies.

DISCLOSURES

We do not sell, rent, lease your Personal Information to anybody and will never do so. Keeping this in mind, we may disclose your Personal Information in the following cases:

• Administrators: We shall provide access to your Personal information to our authorized administrative(s) for internal business purposes, who shall be under confidentiality obligations towards the same.
• Affiliates: We may provide Personal Information we collect to our affiliates. For example, we may disclose Personal Information to our affiliates to respond to your requests for information or the Services, or to help limit your receipt of marketing materials you have requested not to receive.
• Business Partners: We may use certain trusted third-party companies and individuals to help us provide, analyse, and improve the Services including but not limited to data storage, maintenance services, database management, credit bureaus, rating agencies, web analytics, payment processing. These third parties may have access to your information only for the purposes of performing these tasks on our behalf and under obligations like those in this Privacy Policy. Please be assured that all your data is stored only in servers located in India.
• Service Providers: We may share your Personal Information with the service providers, including LSP's and DLA's, who are working with us in connection with the operation of the Services or the Platform, so long as such service providers are subject to confidentiality restrictions consistent with this Privacy Policy.
• Joint Marketing Arrangements: Where permitted by law, we may share your Personal Information with joint marketers with whom we have a marketing arrangement, we would require all such joint marketers to have written contracts with us that specify the appropriate use of your Personal Information, require them to safeguard your Personal Information, and prohibit them from making unauthorized or unlawful use of your Personal Information.
• Persons Who Acquire Our Assets or Business: If we sell or transfer any of our business or assets, certain Personal Information may be a part of that sale or transfer. In the event of such a sale or transfer, we will notify you.
• Legal and Regulatory Authorities: We may be required to disclose your Personal Information due to legal or regulatory requirements. In such instances, we reserve the right to disclose your Personal Information as required in order to comply with our legal obligations, including but not limited to complying with court orders, warrants, or discovery requests. We may also disclose your Personal Information (a) to law enforcement officers or others; (b) to Credit Information Companies; (c) to comply with a judicial proceeding, court order, or legal process served on us or the Platform; (d) to enforce or apply this Privacy Policy or the Terms of Service or our other policies or Agreements; (e) for an insolvency proceeding involving all or part of the business or asset to which the information pertains; (f) respond to claims that any Personal Information violates the rights of third-parties; (g) or protect the rights, property, or personal safety of the Company, or the general public. You agree and acknowledge that we may not inform you prior to or after disclosures made according to this section.

Notwithstanding anything mentioned hereinabove, the Company shall not be responsible for the actions or omissions of the service providers or parties with whom the Personal Information is shared, nor shall the Company be responsible and/or liable for any additional information you may choose to provide directly to any service provider or any third party.

DATA RETENTION

We shall retain your Personal Information for as long as your registration with us is valid and the Outstanding Amount(s) is due and payable. We may also retain and use your Personal Information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

You may choose to delete and/or change/ withdraw your consent for use of your data at any point. You may reach out to us by email specifying such a change. Upon receiving such a request, we will delete your Personal Information subject to receiving written request for the same through your registered email-id. Please note, however, that there might be latency in deleting Personal Information from our servers and we shall have right to retain copies of the information if required for Legal, Regulatory, Complaince or audit purpose.

Also, upon withdrawal of such a request you might not be eligible for any services, and it shall be at the sole discretion of the Company. Further, all your data shall be stored only in servers located within the territory of India.

SECURITY

We value your Personal Information, and protect it on the Platform against loss, misuse, or alteration by taking extensive security measures. In order to protect your Personal Information, we have implemented adequate technology and will update these measures as new technology becomes available, as appropriate. All Personal Information is securely stored on a secure cloud setup and all communication happens via bank-grade secure SSL communication channels. The Personal Information is stored on Amazon Web Services (AWS) cloud. Although we provide appropriate firewalls and protections, Personal Information transmitted as our systems are not hack proof and data pilferage due to unauthorized hacking, virus attacks, technical issues could be possible, though we shall take all the care and caution to protect the data to atleast the limit of care and precaution accorded to our own data.

You are responsible for all actions that take place under your User Account. If you choose to share your User Account details and password or any Personal Information with third parties, you are solely responsible for the same. If you lose control of your User Account, you may lose substantial control over your Personal Information and may be subject to legally binding actions.

ACCESSING AND MODIFYING PERSONAL INFORMATION

In case you need to access, review, revoke and/or make changes to the Personal Information, you shall have to login to your User Account and change the requisite details. You shall keep your Personal Information updated to help us better serve you.

ANCILLIARY SERVICES

We may provide you with certain ancillary services such as chat rooms, blogs and reviews for the Services. Subject to any applicable laws, any communication shared by you via the Platform or through the blogs, reviews or otherwise to us (including without limitation contents, images, audio, financial information, feedback etc. collectively Feedback) is on a non-confidential basis, and we are under no obligation to refrain from reproducing, publishing or otherwise using it in any way or for any purpose. You shall be responsible for the content and information contained in any Feedback shared by you through the Platform or otherwise to us, including without limitation for its truthfulness and accuracy. Sharing your Feedback with us, constitutes an assignment to us of all worldwide rights, titles and interests in all copyrights and other intellectual property rights in the Feedback and you authorize us to use the Feedback for any purpose, which we may deem fit.

COMMUNICATIONS FROM THE PLATFORM

• Special Offers and Updates: We may send you information on products, services, special deals, and a newsletter of the Company. Out of respect for your privacy, we present you with the option of not receiving these types of communications. You may unsubscribe via the unsubscribe mechanism provided in each such communication or by emailing us at care@earlysalary.com
• Service Announcements: On certain occasions or under law, we are required to send out Service or Platform related announcements. We respect your privacy, however you may not opt-out of these communications. These communications would not be promotional in nature.
• Customer Service: We communicate with Customer(s) on a regular basis to provide requested services and in regards to issues relating to their User Account, we reply via email or phone,based on Customer(s) requirements and convenience

INDEMNIFICATION

You agree to indemnify us, our subsidiaries, affiliates, officers, agents, co-branders or other partners, and employees and hold us harmless from and against any claims and demand, including reasonable attorneys fees, made by any third party arising out of or relating to: (i) Personal Information and contents that you submit or share through the Platform; (ii) your violation of this Privacy Policy, (iii) or your violation of rights of another Customer(s).

LIMITATIONS OF LIABILITY

You expressly understand and agree that the Company shall not be liable for any direct, indirect, incidental, special, consequential or exemplary damages, including but not limited to, damages for loss of profits, goodwill, use, data, information, details or other intangible losses (even if the Company has been advised of the possibility of such damages), resulting from: (i) the use or the inability to use the Services; (ii) unauthorized access to or alteration of your Personal Information.

GOVERNING LAWS AND DUTIES

You expressly understand and agree that the Company, including its directors, officers, employees, representatives or the service provider, shall not be liable for any direct, indirect, incidental, special, consequential or exemplary damages, including but not limited to, damages for loss of profits, goodwill, use, data or other intangible losses (even if the Company has been advised of the possibility of such damages), resulting from; (a) use or the inability to avail the Services (b) inability to use the Platform (c) failure or delay in providing the Services or access to the Platform (d) any performance or non- performance by the Company (e) any damages to or viruses that may infect your electronic devices or other property as the result of your access to the Platform or your downloading of any content from the Platform and (f) server failure or otherwise or in any way relating to the Services.

FORCE MAJEURE

This Agreement shall be construed and governed by the laws of India and courts of law at Pune shall have exclusive jurisdiction over such disputes without regard to principles of conflict of laws.

CHANGES TO THIS POLICY

We may update this Privacy Policy without prior notice to you. You are encouraged to check this Privacy Policy on a regular basis to be aware of the changes made to it. Continued use of the Services and access to the Platform shall be deemed to be your acceptance of this Privacy Policy. The Privacy Policy is available for your reference on our website https://www.earlysalary.in/ .

CONTACT US

If you have questions, concerns, or grievances regarding this Privacy Policy, you can reach out to our Principal Officer Mr. Vinay Dubey at our grievance email-address: care@earlysalary.com.

Version History:

CERTIFIED TRUE COPY

FOR EarlySalary Services Private Limited

Sd/-

Jayesh Kulkarni

Company Secretary