Personal information will be collected on company’s Website/App/Platforms-

(www.moneyboxxfinance.com) and includes information received via email by

company. Company may collect, store, access and use Personal Information solely to

the extent required for Company for assessing your credibility for the purpose of

rendering services to Company. Company shall not publish, sell, give on rent, trade or

otherwise transfer Personal Information to third parties, except as may be required by

law, or pursuant to the order of a court or regulatory authority, or in order for Company

to enforce its rights, or expressly permitted by clients/customers or as expressly stated

by this Policy. In the event Company needs to share Personal Information with third

parties, Company shall enter into non-disclosure agreements or equivalent covenants

that are, at the least, as protective as the provisions of this Policy. Company

reasonably presumes that Services Partners / Agencies who make available Personal

Information to Company are doing so out of their own volition. Company does not

compel anyone to disclose Personal Information. Company shall take all reasonable

precautions by way of using current industry standard technologies such as archiving

mails and storing them with 128-bit encryption to protect personal information from

loss, misuse and unauthorized access, disclosure, alteration and destruction.

Company shall always cooperate with regulatory authorities and investigating

agencies in India in the matter of treatment of Personal Information. Company may

modify this Policy in its sole discretion at any time.

This privacy policy has been drafted in accordance with the Information Technology

Act, 2000 and the Information Technology (Reasonable security practices and

procedures and sensitive personal data or information) Rules, 2011.

"Personal Data" means data relating to you and any of your employees, agents and

representatives, that is directly or indirectly identifiable, having regard to any

characteristic, trait, attribute or any other feature of your identity or any combination of

such features with any other information. Personal Data does not mean information

that is freely available or accessible in public domain or furnished under the Right to

Information Act, 2005 or any other law for the time being in force. Personal Data

includes Sensitive Personal Data, which relates to password, financial information

such as bank account or credit card or debit card or other payment instrument details,

physical, physiological and mental health condition, biometrics or any other data

categorised as sensitive under applicable law in India.

Personal information will be collected on Company’s website/App/Platform-

(www.moneyboxxfinance.com/MBCollect) includes information received via email by

the Company. Company may collect, store, access and use Personal Information

solely to the extent required for Company for accessing credibility of customers for the

purpose of Moneyboxx services. Company shall not publish, sell, give on rent, trade

or otherwise transfer Personal Information to third parties, except as may be required

by law, or pursuant to the order of a court or regulatory authority, or in order for

Company to enforce its rights, or expressly permitted by clients/customers or as

expressly stated by this Policy. In the event Company needs to share Personal

Information with third parties, Company shall enter into non-disclosure agreements or

equivalent covenants that are, at the least, as protective as the provisions of this

Policy. Company reasonably presumes that Clients who make available Personal

Information to Company are doing so out of their own volition. Company does not

compel Clients to disclose Personal Information. Company shall take all reasonable

precautions by way of using current industry standard technologies such as archiving

mails and storing them with 128-bit encryption to protect personal information from

loss, misuse and unauthorized access, disclosure, alteration and destruction.

Company shall always cooperate with regulatory authorities and investigating

agencies in India in the matter of treatment of Personal Information. Company may

modify this Policy in its sole discretion at any time.

I. Types of Information we collect

We may collect following information from you, as you may have disclosed to us/as

may have been disclosed to us:

1. Collection Agent’s Personal Details such as PAN Card/ Identity Card / Passport

details / Aadhaar details / Voter ID / Driving License/Mobile.

2. Information obtained from mobile device by way of using the app like device

location/geolocation, device information (including storage, model). If you’re a

Corporate, then Number of Directors/Proprietor/Partner.

3. Name and other details of the Collection agency including details about

address, gst certificates if applicable, due diligence, shops and establishment

documents, phone number & email ID.

4. Name details and contact number of Tele callers who shall be calling the

Customers, Field Staff /Number of field-staff, Cities in which collections services

shall be provided.

5. Collection Agent’s photograph, Name, Phone Number, Geo Location, Device

Data, Other details as required. (applicable in case of field agent)

6. Voice recordings of the conversations between the Collection Agency /

Agents/representatives and the Customers as audit, regulatory and quality

compliance 6. Voice recordings of our conversations with our customer care

agent with you to address your queries/grievances

7. Access to mobile camera device for the functioning of many in- app

functionalities including uploading images or videos that borrower is willing to

share that will benefit the collections purposes but not limited to scan and pay

etc. access to device camera is required. Access to files from mobile device

such as audio, video files for the functioning of many in-app functionalities

including but not limited to in-app chat, access to user’s contacts, files, images,

audios and videos is required, Access to User’s Message / WhatsApp for the

functioning of many in-app functionalities including, but not limited to device

binding for user authentication. Permission is sought for the same at

appropriate stage during app usage.

II. Sharing and Storage of your Personal Data

Any Personal Data that we have access to shall never be shared without your consent.

In various processes / / availing of product / service offerings, we even seek your

explicit consent to use / share your Personal Data.

In our business and operational processes, we only share the data on a partial and

“need-to-know” basis to designated personnel or partners or service providers.

We may process, store and retain your Personal Data on our servers where the data

centers are located, and/or on the servers of third parties having contractual

relationships with us. All Sensitive Personal Data is stored in India. We will retain your

data for the period that you continue to be our Platform/App User and for such period

as required to comply with any obligation under any law for the time being in force.

We will share your data with competent / legal / statutory / regulatory agencies /

authorities /auditors or partners / service providers acting on our behalf (as the case

may be) in following cases:

 For enabling the provision of the products / services availed by you, strictly on

a “need to know” basis and subject to applicable laws.

 Where it is directed or required by legal / regulatory / statutory / governmental

authorities / judiciary under any applicable laws / regulations or judicial

pronouncement though a legally obligated request.

 Where it is required by financial institutions to verify, mitigate or prevent fraud

or to manage risk or recover funds in accordance with applicable laws /

regulations.

III. Usage of Your Personal Data

We use your Personal Data in our business activities for providing our products/

services and to perform, among other actions, the following:

1. To facilitate the collections related activities or report on these activities ;

2. To undertake research and analytics for offering or improving our products /

services and their security and service quality;

To check and process your requirements submitted to us for products / services

and / or instructions or requests received from you in respect of these products

/ services;

3. To share with you, updates on changes to products / services and their terms

and conditions including platform’s terms and conditions;

4. To take up or investigate any complaints / claims / disputes;

5. To respond to your queries or feedback submitted by you;

6. To verify your identity for us to provide products / services to you;

7. To carry, screenings or due diligence checks as lawfully required by us;

8. To monitor and review products / services from time to time;

9. To undertake financial / regulatory / management reporting, and create and

maintain various risk management models;

10. To conduct audits and for record keeping purposes;

11. To comply with the requirements of applicable laws / regulations and / or court

orders / regulatory directives received by us;

12. For the purpose of monitoring and managing all digital, calling & field activities

within the Platform we may keep a track of the following information at a

Collection Agency or individual agent-level:

 Total Calls made; Total Successful calls made

 Total borrowers contacted, Contact ability ratio/Answer rates

 Total digital communication sent

 Click rates on digital campaigns, SMS campaigns

 Total Field visits

 Call recordings

 Dispositions

 Location tracker & cash pickup tracker for field agents

 Total Payments received

a. Via Digital

b. Via Tele-calling

c. Via field

IV. Reasonable Security Practices and Procedures

We take various steps and measures to protect the security of your Personal Data

from misuse, loss, unauthorised access, modification or disclosure. We use latest

secure server layers encryption and access control on our systems. Our safety and

security processes are audited by a third-party cyber security audit agency from time

to time.

We have provided multiple levels of security to safeguard your app by Login / Logout

option, that can be enabled by you. We also ensure the device binding so that the

same login cannot be used on different device without any additional authentication /

OTP. It is secured by an OTP login. Please do not share your Account’s login,

password and OTP details with anybody.

While we observe reasonable security measures to protect your Personal Information

on all our digital platforms, security risks may still arise for reasons outside of our

control such as hacking, virus dissemination, force majeure events, breach of firewall

etc. Please note that the above-mentioned measures do not guarantee absolute

protection to the Personal Information.

V. Contact us

You may contact us on any aspect of this policy or for any discrepancies / grievances

with respect to your Personal Data, by writing to our Grievance Officer as per the

details provided below:

Name: Mr. Rohit Paigwar

Designation: Head Of Operations

Email ID: customer.complaints@moneyboxxfinance.com

VI. Policy Review & Updates

This policy will be reviewed by us as and when required and the same may be subject

to change at any point in time. The latest & most updated policy can always be found

on the App. While we will make reasonable efforts to keep you posted on any updates

to this privacy policy, to make sure that you are aware of any changes, we recommend

that you review this policy periodically.

VII. Governing

This policy will be governed by and construed in accordance with the laws of India and

subjected to the exclusive jurisdiction of Courts of New Delhi.