Vistaar Financial Services Private Limited (“Vistaar Finance” or “We”) maintains the website www.vistaarfinance.com. This Website Private Policy (“Privacy Policy”) governs the receipt, collection, processing, storage, usage, transfer and disclosure of Your Information (as defined below) through this website or other Platforms (as defined below).

We are firmly committed to ensuring compliance with our data protection obligations under the Information Technology Act, 2000 (the "IT Act"), the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 (the “SPDI Rules”) and the Information Technology (The Indian Computer Emergency Response Team and Manner of Performing Functions and Duties) Rules, 2013. This Privacy Policy is applicable to users of this website and/or of any mobile applications/software applications and/or communication channels including but not limited to e-mail, SMS, Whats App, tele-calling, etc. (collectively as "Platforms") who seek to avail any of our Services (as defined below) through the Platforms (“You” or “Users”).

By visiting the Website or using any of our services, You agree to this Privacy Policy. To help us in protecting Your privacy, You should maintain secrecy of Your login ID and password, if any, provided to You in connection with Your account with us and You should not share the same with anyone else nor will any of our representative(s) shall ask You for the same.

1. Acknowledgment and Acceptance of Terms

During the course of using this website, mobile applications or its custom extensions or availing the products and services vide the online application forms or in any other form, Vistaar Finance may become privy to the personal information of the Users, including information that of a confidential or sensitive nature.

Vistaar Finance is strongly committed to protect the privacy of its Users and has taken all necessary and reasonable measures to protect the confidentiality of Your information and its transmission through the world wide web and it shall not be held liable for disclosure of the confidential information when such disclosure is in accordance with this Private Policy or in terms of the agreements, if any, with the Users. You further agree that no claim to the contrary in this regard shall be or be caused to be brought upon Vistaar Finance in any manner whatsoever.

This Privacy Policy sets forth our current privacy practices with regard to the information we collect when You visit our website. By accessing or using or submitting any Information on our Platforms You agree that You have read and understood this Privacy Policy. You further agree to be bound by this Privacy Policy and explicitly consent to our collection, processing, use, storage, transfer, and disclosure, of Your Information, in accordance with the practices and procedures laid down in this Privacy Policy. You hereby expressly authorize Vistaar Finance to exchange, share, transfer, disclose, part with any and all parts of Your information related to the details and transaction history to its Affiliates / Subsidiaries / 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 in accordance with the practices and procedures laid down in this Privacy Policy and shall not hold Vistaar Finance liable for sharing/usage/transfer or disclosure of such Personal information.

You can always elect not to disclose Information to Us. However, please keep in mind that if You choose not

to provide that Information, Your ability to use our Services may be limited or restricted.

You have an option to always access Your Information in order to view, add, alter, update and/or modify Information provided to Vistaar Finance.

2. Use of web beacons or GIF files:

Vistaar Finance web pages may contain electronic images known as Web beacons – sometimes also called single-pixel GIFs – that allow Vistaar Finance to count Users who have visited those pages.

3. Security:

Vistaar Finance shall use commercially reasonable security measures (including physical, electronic and procedural measures) to safeguard personal information against loss, misuse, damage or modification and unauthorized access or disclosure. However, no system for transmitting or storing information electronically can be completely secure. Therefore, we cannot guarantee that personal information or other communications will always remain secure.

4. No Contractual Obligation

Please note that this Privacy Policy does not create any contractual or other legal rights in or on behalf of any party, nor is it intended to do so.

5. Cookies:

Cookies are small data files that a website stores on Your computer/electronic device. While cookies have unique identification nos., personal information (name, account number, contact numbers. etc.) SHALL NOT be stored on the cookies. Vistaar Finance may use cookies and tracing technology:

a) which are permanently placed on Your computer to store non- personal (Browser, ISP, OS, Clickstream information etc.) and profiling information (age, gender, income etc.);

b) to improve Your experience by throwing up relevant content where possible;

c) to store Your preferences to ease Your navigation on the website / electronic / mobile application.

However, if You previously provided personally identifiable information, cookies may be tied to such information. Aggregate cookie and tracking information may be shared/transferred/disclosed [in anonymized form] with third parties.

6. Data Governance and training:s

Securing User’s Information is of paramount importance to Vistaar Finance. Following are some of the initiatives by Vistaar Finance to security privacy of the User’s Information:

a) Vistaar Finance has reasonable management, technical and administrative measures in place to protect information maintained within Vistaar Finance.

b) Sound technical controls around Information and underlying systems are in place.

c) Vistaar Finance adheres to multiple regulatory and statutory requirements like RBI’s Master Direction for NBFC, NPCI guidelines for Data localization, etc.

d) Vistaar Finance conducts periodic internal and external audits of its systems.

e) Updates on information security position is updated at regular intervals to Board members, senior management of Vistaar Finance via IT strategy committee as well as Risk Management Committee.

f) Following acts shall warrant appropriate disciplinary action as per Vistaar Finance’s internal policies:

i. Unauthorized usage/ sharing of Information,

ii. Breach of security procedures;

iii. Usage of Information for unlawful gain

iv. Breach of IT policy/procedure; and

v. Breach of confidentiality.

7. Your information received from Third parties:

We may also be working closely with third parties (including, for example, business partners, search information providers and service providers) and may lawfully receive and process information about You. Such data may be shared/transferred/disclosed internally and combined with data collected and in accordance with this Privacy Policy.

8. Website & links to Other Sites

Vistaar Finance’s website/ electronic/mobile application may contain links to other sites. If You click on a third- party link, You may be directed to that site. It may be noted that such external sites are not operated by Vistaar Finance and are beyond the control of Vistaar Finance. Therefore, We strongly advises You to review the privacy terms/policy of such external websites/electronic applications before browsing. Vistaar Finance has no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

Listed below are the detailed terms and conditions of this Policy.

Section 1: Contact Information

You may please get in touch with us over email address: contactus@vistaarfinance.com to enquire about the treatment of Your data by us

Section 2: What Data is collected?

When You visit, we will request some personal information such as name, address, email, telephone number, account number and other relevant information and sensitive personal information such as financial information i.e. Bank account or debit card or other payment instrument details if You are making a payment, we will request financial information. Any financial information we collected is used only with respect to the collection of monthly installments or for the purpose of repayment of Loan. You may also be asked to disclose personal information to us so that we can provide assistance and information to you.

There may be instances when we disclose Your information to other parties (including government/regulatory bodies or agencies):

* to comply with the law or respond to compulsory legal process (such as a search warrant or other court order) or when we believe release is appropriate to comply with applicable law, enforceable governmental request, enforce our Site policies and terms of Service (including investigation of potential violations), detect, prevent, or otherwise address fraud, security or technical issues or protect ours or other’s rights, or safety as permitted by law;

* for the purposes of verification of identity or for prevention, detection, investigation including cyber incidents, prosecution and punishment of offenses;

* to protect the rights, property, or safety of Vistaar Finance, representatives or employees. However, this does not include use of Your information (including sensitive data or information) for any commercial purposes which is inconsistent with any of the practices described in this Website Privacy Statement);

* to investigate, prevent, or take other action regarding illegal activity, suspected fraud, or other wrongdoing.

Any information including Your personal information provided by You on the Application, shall be deemed as an authorization given by You to us to use such information for the purpose of provision of services.

The data will be used for providing better quality services, enabling seamless communication and marketing outreach.

Data we collect from Your usage of our Services:

1. Location data:

We collect the location data from You in two ways i.e. (i) when You add the pin code as part of Your account information and (ii) from Your mobile device when You have consented to collection of such data which is collected when the Application is running in the background from Your device.

2. Payment and Billing Information:

If required, we might collect Your billing name, billing address and payment method when You avail our services. This is to ensure seamless payments that might be required to be made to You in the course of provision of services.

3. Application Data:

We collect the data about Your installed applications, including the applications that You have installed on and from the date You create Your account on the Application and the manner in which You use them. This includes having access and permission to send You messages and notifications via Your social media and instant messaging applications.

4. Feedback Data and Other Data:

Any information provided by the customers during a telephonic call with our call centers may be recorded for training and quality improvement purposes. We may also collect any information You provide on the Application chat bot.

5. Usage and disclosure of Personal & Financial information:-

Vistaar Finance will use the customer information/data to improve the visitor experience on the site and make subsequent offers to the visitor on products which may be of interest to him / her. The data is used for providing better quality services, enabling seamless communication and marketing outreach.

Vistaar Finance will protect Your personal information against unauthorized use, dissemination or publication in the same manner in which we would protect our own confidential information of like nature. We may share information in the course of normal business operations, such as providing services You have subscribed for, and any activity related to these services such as collection of fee. It may become necessary for Vistaar Finance to disclose Your personal information to its agents and contractors in the course of normal business operations for the above-referred purpose. However, these parties would be required to use the information obtained from Vistaar Finance for such purposes exclusively. Vistaar Finance will endeavor to take all reasonable steps to ensure that the confidentiality of Your information is maintained by imposing strict confidentiality standards on all the third parties to whom it discloses such information.

If one desires Vistaar Finance to limit such sharing whereby one would not like to be informed of offers available one may contact us at contactus@vistaarfinance.com.

6. Limited Demographic Information:

We may collect limited demographic information about You as specified above. This information maybe collected as part of a survey also.

7. Transaction information:

We collect transaction information related to the use of our Services, including the type of Services requested, date and time the Service was provided and payment method. Additionally, if someone uses Your promotion code, we may associate Your name with that person and their usage of the Application.

8. Device data:

We collect data about the devices used to access our Services, including the hardware models, device IP address, operating systems and versions, software, preferred languages, unique device identifiers,advertising identifiers, serial numbers, device motion data, and mobile network data.

9. Storage:

This permission is required so that users' documents can be securely downloaded and saved on users phones and upload the right documents for a faster approvals and provision of services. This helps provide a very smooth and seamless experience while using the Application.

10. Information we receive from other sources:

We may also be working closely with third parties (including, for example, business partners, search information providers and service providers and may lawfully receive information about you. Such data may be shared internally and combined with data collected.

Section 3: How and why is the Collected Data Used?

The data that is collected in accordance with this Privacy Policy will be used in the manner detailed below. Any information collected shall be used for the purpose for which it has been collected.

1. For enabling the application and provision of services:

We use the data collected to personalize, maintain and improve our Services. This includes using the data to

- communicate to You various information and/or offers regarding existing products and services and/or various Services /facilities which We may, from time to time, launch.

- Create and update the Application or our processes,

- Analyse Your eligibility for a loan and estimate the terms of such loan,

- Track Equated Monthly Instalment (EMI) payments.

- Enable features that allow You to add and remove bank accounts for payment of EMI by You and amounts disbursed, from time to time

- Enable features that help You check Your repayment history and other features as may be added from time to time.

- Perform internal operations necessary to provide our Services, including to troubleshoot software bugs and operational problems; to conduct data analysis, testing, and research; and to monitor and analyse usage and activity trends.

- To improve our products and service

- To share/transfer/disclose with bankers/financial institutions.

- To provide You with loan You explicitly requested for.

- Assess Your interest in our Services, inform You about offers, products, services, updates, customize Your experience

- Detect and protect us against errors, fraud and other criminal activity, enforce our terms and conditions, etc.

We may add features that allow You to call us and similarly, we may also need to contact You (through the mobile application or any other channels that You give us access to, such as WhatsApp or any other interface).

2. For Enabling Communications between You and us:

We might use the information you provide:

- To contact you for confirmation of disbursal of loan sanctioned.

- Respond to your pre-sale and post-sale service requests.

- Support your needs efficiently and without delay.

- To send you updates about services or products of relevance to you, or for other promotional purposes.

- To respond to your requests or questions.

- We use information to send you transactional communications. We might send you emails or SMS about your account.

3. For Enabling Customer Support:

We use the information to provide customer support, including to resolve your concerns from the use of the Services, and train our customer service executives.

4. For Marketing and Outreach:

We may use the information and data we collect to market our products and services. This includes sharing Your feedback, ratings and screen names for purely promotion and marketing purposes. Such promotion and marketing may be done via hoardings, banners, pamphlets, flyers etc. Further, we might send Your information about special promotions or offers. We might also tell You about features or products which we think you might find interesting. If You avail a loan from us, we'll enroll You in our newsletter. We use Your Information to customize Your experience at Vistaar Finance.

5. For Legal Compliance and Requirements:

We may use the data we collect to investigate or address claims or disputes relating to use of our Services, or as otherwise allowed by applicable law, or as requested by regulators, government entities, and official inquiries.

6. For Product Innovation:

We may use the data we collect to offer new products and services for your use. We use information to look at site trends and customer interests. We may use your information to make our Application and products better to suit your needs. We may combine information we get from you with information about you we get from third parties.

Section 4: How do we share/transfer/disclose the Collected Information?

Vistaar Finance may share/transfer/disclose Information in the course of normal business operations, such as providing Services You have subscribed for, and any activity related to these Services such as collection of fees. It may become necessary for Vistaar Finance to disclose Your Information to its agents and contractors in the course of normal business operations for the above-referred purpose.

However, these parties would be required to use the Information obtained from Vistaar Finance for such purposes exclusively. Vistaar Finance will endeavor to take all reasonable steps to ensure that the confidentiality of Your Information is maintained by imposing strict confidentiality standards on all the third parties to whom it discloses such Information.

Vistaar Finance take steps to ensure that third parties we share data with, whether in India or outside, also adopt an adequate, reasonable level of security practices and procedures that are at least as protective as those described in this Privacy Policy.

Vistaar Finance shares/transfers/discloses Your Information in the following manner:

i. Affiliates and Group Companies: Subject to applicable law, we may share/transfer/disclose any data we have collected or collect from You with our affiliates and group companies for product research and development, advertising relevant products to You, and to customize the products for Your benefit.

ii. Change in Control: While negotiating or in relation to a change of corporate control such as a acquisition, restructuring, merger or sale of our assets, we may be compelled to disclose our databases and information we have stored in the course of our services.

iii. Sharing with regulators: Notwithstanding any contained in this Privacy Policy, we may share/transfer/disclose information in order to comply with the law of the land. If any governmental authority or law enforcement officers request or require any information, Your information may be disclosed to them to the extent we believe that it is required to comply with the law or respond to legal process (such as a search warrant or other court order or an order from an enforcement authority), and to protect the rights, property, or safety of Vistaar Finance, representatives or employees.

Section 5: What are Your Rights regarding the Data?

It is important for us that You remain in control of Your data. Please write to us at contactus@vistaarfinance.com if You wish to exercise any of Your rights under the Policy. You shall have the following rights:

A. Right of opt-out:

We may use Your email address to send You information about our products. It may also be used to respond to Your inquiries, questions, and/or other post-sale requests.By opting into our mailing list, You may receive emails or promotional messages that could include related product or service information, educational content etc. If at any time You would like to unsubscribe from receiving such communications, You are free to opt out of receiving our marketing emails.

To stop receiving our promotional emails, please email us at contactus@vistaarfinance.com and additionally You may unsubscribe by clicking on the relevant link provided in such promotional emails. Even if You opt out of getting marketing messages, we will still be sending You transactional messages through email and SMS about Your loan facility. We obtain Your permission to post testimonials which may include Your personal information prior to posting on the Website or Vistaar Bandhu Application. If You would like Your testimonial removed, please email us at: contactus@vistaarfinance.com

Section 6: What is Our Data Security Practice?

We maintain information pertaining to You in our business records as per current regulatory requirements. We have secure and appropriate data collection, storage, and processing practices. Our security measures protect against unauthorized access, alteration, disclosure or destruction of Your personal information, username, password, transaction information and data stored on the Application or in our database.

All private information exchange and transactions on the Application happen through secured communication channels and is encrypted and protected.

Section 7: Consent Mechanism

By downloading, installing and setting up an account on the Application or generating request for loan,You agree to our processing, storage, usage, and sharing of the data provided by You pursuant to this Policy. If You do not agree with any of the terms of this Policy or the Terms or wish to revoke any consent You have provided to us please sign out and uninstall the Application immediately or contact as per Section 11 of this Policy.

However, please note that if You revoke any mandatory permission or revoke the consent to process and store information needed to facilitate the provision of services, then we may be compelled to cease the provision of Services to you. You cannot withdraw Your consent once You have availed a loan from us and till the time such loan is repaid in full and all statutory and procedural requirements are fulfilled.

Section 8: Data Retention

We do not retain Your personal data for longer than required for the purpose for which the information may be lawfully used. We may need to retain Your information for a longer period where we need the information for our legitimate purposes for e.g. to help us respond to queries or complaints, fighting fraud and financial crime, responding to requests from regulators, etc. If we do not need to retain information for this period of time, we may destroy, delete or anonymize it promptly.

Section 9: Children’s Privacy

Our Services are not directed at children, and we do not knowingly solicit or collect personal information from persons under the age of 18 (eighteen). If we at any point of time find out that a child has given us personal information, all such information will be deleted and the account will be terminated at one.

Section 10: Revisions to this Privacy Policy

This Privacy Policy is subject to revisions from time to time in compliance with regulatory policies and guidelines without giving notice and we therefore advise You to please keep visiting this page regularly to take notice of any changes that may be done. Any changes or updates will be effective immediately upon posting the same on our web site at www.vistaarfinance.com. Use of our Services after a revision constitutes consent to the updated notice to the extent permitted by law.

Section 11: Grievance Redressal

Any grievance may be reported at contactus@vistaarfinance.com or call us at 080–4666090