This Privacy Policy document ("Privacy Policy") is published in accordance with the provisions of Rule 4 (1) of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 which requires the publishing of a privacy policy for handling of or dealing in personal information including sensitive personal data or information.

By visiting the website, www.dhanlap.com ("Website") or the DhanLAP mobile and/or web application (the "App") (collectively, the "Platform") and availing the services provided by us ("Services") you agree to be bound by the terms and conditions of this Privacy Policy.

By mere access to the Platform or any part thereof, you signify your assent to this Privacy Policy and consent to the processing of your personally identifiable information (Personal Information, Sensitive Personal Data or Information) to ArkNeo Finance Private Limited ("we" or "our" or "us" or "ArkNeo"). This Privacy Policy is incorporated into and subject to the Terms of Use of the Platform.

For the purpose of this Privacy Policy, the users of the Services may be customer/consumers/ buyers, or any other persons using Services or accessing our Platform ("user" or "you" or "your").

If you do not agree to this Policy or any part thereof, please do not use/ access/ download or install the Platform or any part thereof.

When you use our Platform, we collect and store your information which is provided by you from time to time by explicitly seeking permissions from YOU to get the required information. Our primary goal in doing so is to provide you a safe, efficient, smooth and customized experience and Services. This allows us to provide services and features that meets your needs, and to customize our Platform to make your experience safer and easier and to improve the Services provided by us. More importantly, we collect personal information from you that we consider necessary for achieving the aforementioned purpose.

In general, you can browse the Website or App without telling us who you are or revealing any information about yourself. However, to create an account on the Platform, you must provide us with certain basic information required to provide customized services. The information we collect from you, inter alia, includes:

Wherever possible, we indicate the mandatory and the optional fields. You always have the option to not provide any information by choosing not to use a particular service or feature on the Platform. We also collect user account data which includes email address and user public profile information like name, photo, depending on the platform used by You to log-into the App. This information is required as a part of registration process to access our Service and it is also used to auto-populate relevant fields in the course of the interface of the App. We further collect other identifiable information such as your transactions history on the Platform when you set up a free account with us as further detailed below. While you can browse some sections of our Platform without being a registered member as mentioned above, certain activities (such as availing of loans from the third party lenders on the Platform) require registration and for you to provide the above details. The Platform will clearly display the personal information it is collecting from you, and you have the option to not provide such personal information. However, this will limit the services provided to you on the Platform.

Our App also collects mobile number for verification to check the active SIM status on the device, uniquely identify you and prevent frauds and unauthorised access.

As a part of our Video Know Your Customer (Video KYC) process, collection of your personal information has become mandatory to ensure the completion and authentication of your KYC. In this regard, permissions for microphone, camera will be mandatorily required.

We don’t collect, read or store your personal SMS from your inbox.

We collect and monitor only financial SMS sent by 6-digit alphanumeric senders from your inbox which helps us in identifying the various bank accounts that you may be holding, cash flow patterns, description and amount of the transactions undertaken by you as a user to help us perform a credit risk assessment which enables us to determine your risk profile and to provide you with the appropriate credit analysis. This process will enable you to take financial facilities from the regulated financial entities available on the Platform. This Financial SMS data also includes your historical data.

While using the app, it periodically sends the financial SMS information to our affiliate server and to us.

We collect and monitor the information about the location of your device to provide serviceability of your loan application, to reduce risk associated with your loan application and to provide pre-approved customised loan offers. This also helps us to facilitate verification the address, making a better credit risk decision and know your customer (KYC) process.

The information we collect from your device includes the hardware model, build model, RAM, storage, unique device identifiers like IMEI, serial number, SSAID, AAID, SIM information that includes network operator, roaming state, MNC and MCC codes, WIFI information that includes MAC address and mobile network information to uniquely identify the devices and ensure that no unauthorized device acts on your behalf to prevent frauds.

We collect information about your device to provide automatic updates and additional security so that your account is not used in other people’s devices. In addition, the information provides us valuable feedback on your identity as a device holder as well as your device behaviour, thereby allowing us to improve our services and provide an enhanced customized user experience to you.

We collect a list of the installed applications’ metadata information which includes the application name, package name, installed time, updated time, version name and version code of each installed application on your device to assess your credit worthiness and enrich your profile with pre-approved customized loan offers.

We may require camera access to scan and capture the required KYC documents and customer verification processes thereby allowing us to auto-fill relevant fields.

As a part of facilitation of the KYC journey, we require access to your camera to enable you to initiate your KYC process. This permission allows us or our authorised agents to perform your Video KYC while also taking screenshots of your original Officially Verified Documents that you present during your Video KYC journey. Video KYC enables you to complete your KYC digitally, smoothly and efficiently. Your video shall be recorded and retained for regulatory purpose along with the screenshots of original Official Verified Documents.

We require microphone permissions to enable a two-way communication between our authorised agent and you for the purpose of performing and completing your Video KYC. Your audio shall be recorded for regulatory purpose.

STORAGE

We require storage permission so that your KYC and other relevant documents can be securely downloaded and saved on your computer and phone. You can then easily upload the correct KYC related documents for faster loan application details filling and disbursal process. This ensures that you are provided with a seamless experience while using the application.

We automatically track certain information about you based upon your behaviour on our Platform. We use this information to do internal research on our users’ demographics, interests, and behaviour to better understand, protect and serve our users and improve our services. This information is compiled and analysed on an aggregated basis. We also collect your Internet Protocol (IP) address and the URL used by you to connect your computer to the internet, etc. This information may include the URL that you just came from (whether this URL is on our Website or not), which URL you next go to (whether this URL is on our Website or not), your computer browser information, and your IP address.

Cookies are small data files that a Website stores on Your computer. We will use cookies on our Website similar to other lending websites / apps and online marketplace websites / apps. Use of this information helps Us identify You in order to make our Website more user friendly. Most browsers will permit You to decline cookies but if You choose to do this it might affect service on some parts of Our Website.

We retain information as necessary to resolve disputes, provide customer support and troubleshoot problems as permitted by law.

If you send us personal correspondence, such as emails or letters, or if other users or third parties send us correspondence about your activities or postings on the Website, we collect such information into a file specific to you.

We understand the importance of your information and ensure that it is used for the intended purpose only. We access, store and use the information we collect from you in accordance with the applicable laws to provide our Services, to research and develop new ones subject to the limitations set out in this Privacy Policy.

We use the information to:

1. resolve disputes;
2. troubleshoot problems;
3. help promote a safe service;
4. analytical analysis;
5. marketing and promotional purposes including sending you promotional SMS, Email and Whatsapp;
6. measure consumer interest and satisfaction in our products and services;
7. inform you about online and offline offers, products, services, and updates;
8. customize your experience;
9. detect and protect us against suspicious or illegal activity, fraud and other criminal activity;
10. enforce our terms and conditions;
11. improvement of our services and as otherwise described to you at the time of collection

In our efforts to continually improve our product and service offerings, we collect and analyze demographic and profile data about our users' activity on our Platform.

The intended purpose of collecting information provided by you is to:

1. establish identity and verify the same;
2. to facilitate your KYC;
3. monitor, improve and administer our Platform;
4. provide our service i.e. perform credit profiling for the purpose of facilitating loans to You.
5. design and offer customized products and services offered by our third party financial partners;
6. analyse how the Platform is used, diagnose service or technical problems and maintain security;
7. send communications notifications, information regarding the products or services requested by You or process queries< and applications that You have made on the Platform;
8. manage Our relationship with You and inform You about other products or services We think You might find of some use;
9. conduct data analysis in order to improve the Services / Products provided to the User;
10. use the User information in order to comply with country laws and regulations;
11. conduct KYC for our third party lending partners based on the information shared by the User;
12. use the User information in other ways permitted by law to enable You to take financial services from our lending
partners.

We use Digiotech Solutions Pvt. Ltd. for KYC verification, Experian Credit Information Company of India Pvt. Ltd. to fetch credit score, MFCentral to fetch user CAS, Signzy for Vkyc, CAMS and Kfintech for scheme pledge, NSDL for Share pledge and NESL e-governance for esigning loan agreement.

We will use and retain the information for such periods as necessary to provide You the Services on the Platform, to comply with our legal obligations, to resolve disputes, and enforce our agreements.

We will share Your information with only our registered third parties including our regulated financial partners for provision of Services on the Website/ App. We will share Your information with third parties only in such manner as described below:

1. We disclose and share Your information with the financial service providers, banks or NBFCs and our third party partners for facilitation of a loan or facility or line of credit or purchase of a product;
2. We share Your information with our third party partners in order to conduct data analysis in order to serve You better and provide Services on our Platform;
3. We may disclose Your information, without prior notice, if we are under a duty to do so in order to comply with any legal obligation or an order from the government and/or a statutory authority, or in order to enforce or apply Our terms of use or assign such information in the course of corporate divestitures, mergers, or to protect the rights, property, or safety of Us, Our users, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
4. We will disclose the data / information provided by a User with other technology partners to track how the User interact with the Platform on Our behalf.
5. We and our affiliates may share Your information with another business entity should we (or our assets) merge with, or be acquired by that business entity, or re-organization, amalgamation, restructuring of business for continuity of business. Should such a transaction occur than any business entity (or the new combined entity) receiving any such information from Us shall be bound by this Policy with respect to your information.
6. We will disclose the information to our third party technology and credit partners to perform credit checks and credit analysis like Credit Bureaus or third party data source providers;
7. We will share Your information under a confidentiality agreement with the third parties and restrict use of the said Information by third parties only for the purposes detailed herein. We warrant that there will be no unauthorised disclosure of your information shared with third parties.
8. By using the Platform, you hereby grant your consent to the Company to share/disclose your Personal Information (i) To the concerned third parties in connection with the Services; and (ii) With the governmental authorities, quasi-governmental authorities, judicial authorities and quasi-judicial authorities, in accordance with applicable laws of India.
9. We shall disclose your KYC journey or any data with respect to the same to the relevant regulatory authorities as a part of our statutory audit process. Please note that your Aadhaar number shall never be disclosed.