Last Update: 01.10.2024

PLEASE READ THIS POLICY CAREFULLY BEFORE USING THE APP

This privacy policy (“Privacy Policy”) is incorporated into and subject to the Terms of Use. All capitalized terms for which definitions have not been provided for in this Privacy Policy shall have the meaning ascribed to them in the Terms of Use. The Privacy Policy has been made in compliance with the applicable laws, regulations, guidelines provided by applicable regulatory authorities including but not limited to the RBI. PLEASE READ THIS PRIVACY POLICY CAREFULLY. THIS POLICY DESCRIBES THE WAY WE COLLECT, STORE, SECURE AND USE YOUR INFORMATION INCLUDING YOUR PERSONAL INFORMATION. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, YOU MAY NOT AVAIL THE SERVICES.

This Privacy Policy is subject to change at any time without notice. You (“you”, “user” or “customer”) are responsible for regularly reviewing this Privacy Policy so that you will be apprised of any changes.

SmartCoin Financials Private Limited (“us”, “We”, “Olyv” or “Company”) are committed to protecting and respecting your privacy.

SCOPE OF POLICY

This policy together with our Terms of Use applies to your use of:

1. Olyv mobile application software (“Application” or “App”) available on our site OR hosted on the Google Play Store (“App Site”), once you have downloaded or streamed a copy of the App onto your mobile telephone or handheld device (“Device”).

2. Any of the services accessible through the App (“Services”) those are available on the App Site or other sites of ours (“Services Sites”).

This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.

CONSENT

You hereby expressly consent to provide below mentioned information to us. We may seek your consent through a separate consent form detailing required data points, purpose of collection, disclosure of entities with whom such information might be shared, if so required by regulatory bodies.

By accessing our services, you agree to this privacy policy. This document supersedes any prior communication on this topic and reflects the entire and exclusive policy for this service.

1. Information we collect about you and your device

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

1. We may collect and process the following data about you:

When you install the App, we store the information we collect with unique identifiers tied to the device you are using for registering your profile in the App :Olyv shall collect the following information with Your explicit consent using a specific consent form:

• User Personal Information : Olyv collects and stores your name, mobile number, Date of Birth, PAN No. and email address as part of our registration process upon seeking Your explicit consent in a specific consent form.

How we use this data: We use this data to uniquely identify, register and enable you to use our app. We collect your mobile number for the purpose of checking active SIM status, uniquely identifying you and preventing frauds and unauthorized access. We collect PAN and Date of Birth and share to lenders to verify for eligibility and generate loan offers.

• Social Account Information :Olyv requires you to register using social accounts (Google or Facebook) to access the app, and shall collect only such registered email id during registration/ sign in process in the App.

How we use this data: We may collect and store email id, name and address associated with that account for the purpose of verification and to pre-populate relevant fields in the course of app interface. However, we shall not collect / store account passwords.

• SMS Information: We collect, store and monitor SMS data stored in your device. We filter these messages based on 6 - digit alphanumeric senders to understand your financial profile. We securely store this information and use this to analyze your financial profile, process your loan application and for fraud identification purposes.

How we use this data: We use this data fraud detection and to verify your mobile number via OTP verification or provide you with updates or confirmation of any actions taken in our App during the term of Services.

• Location Data: Subject to your express consent, Olyv may take a one-time access to location data of your device when you enable us to do so.

How we use this data: We use this data for onboarding and KYC purpose only.

•         Camera & Microphone: Subject to your consent, we take one time camera and microphone access.

How we use this data: We require camera access so that you can easily scan or capture required KYC documents to be uploaded and save time by allowing us to auto-prefill relevant data.

• Installed Apps Data: Olyv collects each installed applications metadata information that includes application and package name, installed and updated time, version name and version code for all applications installed on your device.

How we use this information: We use this to assess your creditworthiness and provide you with pre-approved customized loan offers.

• Usage Data: Olyv collects, monitors and stores details of your use of any of our Apps or your visits to any of Our Sites including, but not limited to, traffic data, location data, weblogs and other communication data (Log Information) within the App or with relation to the Services provided through our App. We collect data about how you interact with our services.

How we use this data: We use this data to improve our app performance, to enable support and create better product offerings for you.

2. Information you give us about you

In due course of using our services, you are required to submit data to enable our services. We use this data to create your profile and provide you with the best available services. Mentioned below are the data we collect from you with your consent:

• Data provided by you by filling in forms in the App or on the App Site (together Our Sites).
• Data provided by corresponding with us (for example, by e-mail or chat).
• Data and information you provide when you register to use the App Site, download or register on our App, subscribe to any of our Services (such as applying for a loan), search for a Service, and when you report a problem with our App, our Services, or any of our Sites.
• Data including your name, address, photograph, gender, date of birth, e-mail address, phone number, username, password and other registration information,
• PAN Card, Aadhaar Card, financial information such as employer name, monthly salary, bank account no., bank statements, credit information, copies of identification documents which are forwarded to our financial partners for the onboarding of your application to avail the services.
• Data generated by your usage of our app

How we use this data: This data helps us create your profiles, complete mandatory KYC as per the requirements of our financial partners who offer you the Services, unlock and approve loans and provide you with customized support in case of issues. Please note that we do not store any data provided by you except for the basic information such as name, address, contact details etc.

3. Information we receive from other sources (“Third Party Information”)

We may collect information about you from third parties such as credit bureaus basis your request and consent. We may receive information from third parties like credit information companies, the UIDAI servers for e-KYC and e-Sign services basis your request and consent. Such information with third party sources is subject to and governed by the privacy policies of relevant third party. We/Lender Partner may also collect details of PAN from third parties like Protean eGov Technologies to complete the KYC process.

Lender Partner/Third Party may also obtain such other information (Directly/Indirectly) as may be required to provide the requested service from third party.

How we use this data: This data helps us create your profiles, complete mandatory KYC as part of the preliminary loan onboarding process with our financial partners, and provide you customized support in case of issues.

We under no circumstances and at no point take any biometric data from you for any of our services or operations. In case, if any of our representatives ask for the same from you, we request you to kindly refrain from doing the same and address this concern to our Grievance Officer (the details of the same have been provided below).

We ensure that every data or information that we collect from you is stored in servers located in India and the same is compliance with all the statutory/regulatory obligations.

4. Tracking and Cookies

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.

We may use website cookies to distinguish you from other users of the App, App Site, App Store or

Service Site. The cookies are either used to improve the quality of the portals or for storing your preferences as a user, improving search results and tracking user trends.

You will always have the option of declining cookies but if you choose to do so, it might affect the services rendered in some manner.

5. Third Party SDK

Olyv app has a link to a registered third-party SDK that collects data on our behalf to perform a variety of services such as analyzing your in-app actions, serving retargeting ads, sending personalized push notifications, and performing credit assessment based on your information among others.

We don't allow unauthorized access to your non-public personal contacts or financial transaction SMS data with any third party.

2. User Made of Collected Information

We shall use your information for the aforementioned purpose only. To the extent allowed under applicable laws, information collected / accessed by us may be used for the following:

6. Assist our lender partners and other regulated entities by facilitating their services.
7. Provide effective Services to the customer and assist in the event he/she needs additional support; and
8. Comply with our legal or statutory obligations
9. Analyze the app performance, create and serve best products
10. Send communications, notifications regarding the products, offerings, loans, collections

All the data and other information that is collected by us is on a need basis subject to receipt of your express consent. The same is done for the purposes above and in compliance with applicable laws.

3. Disclosure of Your Information

We may disclose your information to the following:

11. Members of our group, such as subsidiaries, holding company affiliates, associates etc.
12. The information shall be disclosed only if you accept this privacy policy.
13. We may disclose your information to employees, affiliates, vendors, partners and third parties as may be required to offer the Company’s Services.
14. With 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;

15. With other corporate entities and affiliates to help detect identity theft, fraud and other potentially illegal acts, verify your KYC details, retrieve your credit information / bank account details to prevent abuse of our Services as required by our financial partners for the preliminary onboarding on the loan process, provide customer service and support and resolve disputes;
16. In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
17. If Olyv or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets; and/or
18. In order to: enforce our Terms and Conditions and other agreements or to investigate potential breaches; or for the purpose of publishing statistics relating to the use of the App, in which case all information will be aggregated and made anonymous.

Here is the list of entities with whom your information is shared:

We will share the collected data to our Lending Partner (PayU Finance India Private Limited, Vivriti Capital Limited, InCred Financial Services Limited, Northern Arc Capital Limited, Upmove Capital Private Limited or any other regulated entity tied up) to provide credit facility whenever required upon receipt of loan application.

Any disclosure of us to third parties is subject to the following

1. If we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request, we shall not seek your explicit consent however we shall reasonably endeavour to notify the same to you accordingly as the case may be;
2. We shall take your express consent through updated privacy policy if any other third party is added
3. We shall share Your information with third-party only on a need basis and only for the purpose stated hereunder, as per the applicable laws.
4. We shall additionally seek express consent through a separate consent for at appropriate stages of

data collection, if so required under applicable laws.

5. Usage of Your information by such third parties is subject to their privacy policies. We share limited information with them, strictly to the extent required. We recommend you have a look at the privacy policies of such third parties.

4. Security

The Company has stringent security measures in place to protect against the loss, misuse, and alteration of the information under our control. Our servers are accessible only to authorized personnel and your information is shared with employees and authorized personnel on a ‘need to know’ basis. We encrypt your password so that it is not recovered, not even by us. All backups are encrypted. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

Where we have given you (or where you have chosen) a password that enables you to access certain parts of Our Sites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

We follow generally accepted standards (secure techniques over HTTP APIs) to protect the information, during transmission and reception. All communications are encrypted, enabling client and server applications to communicate in a way that is designed to prevent eavesdropping, tampering and forgery. Unfortunately, the transmission of information via the internet is not completely secure. We protect and maintain the security of your Olyv accounts and sessions using firewalls, encryptions, authentications, among others. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to Our Sites; any transmission is at your own risk.

By using this App, you agree that the Company will have no liability for disclosure of your information due to errors in transmission, infrastructure failures by the Company or any intermediary (including telecom and internet service providers), or unauthorized acts of third parties which are not in the reasonable control of the Company.

5. Data Retention and Deletion

We at Olyv make the best effort to protect your personal data from unauthorised access, misuse and disclosure using the appropriate security standards and measures based on applicable laws. We retain the information about you to provide a seamless user experience, to contact you in case of support required and about your account, to detect, mitigate, prevent, and investigate fraudulent or illegal activities during the services to the extent allowed under applicable laws. The information we collect from you shall be retained for a period of time consistent with the purpose of collection of such information. We keep your data for no longer than a reasonable period of time needed for us to pursue our legitimate business interests, conduct audits and comply with our legal obligations. This information is then anonymised so as to destroy any connection or association with you. You have an option to give or deny consent, restrict disclosure to third parties, revoke consent and if required, request to delete/ forget the information, in which case, we shall delete the same, however, this will limit the services provided by us on the platform. However, in case you request deletion of information / data when services are ongoing, we will not be able to delete the information at your request, unless approved by our partners/lenders. Any information we store beyond the service period is treated as data at rest and is encrypted for data protection.

6. Your Rights

1. Deny Consent: You shall have the right to deny consent for use of specific data, restrict disclosure to third parties, data retention, revoke consent already granted to collect personal data and if required, make the App delete/ forget the data.
2. Withdraw Consent: You may withdraw Your consent to contact You, for the continued collection, use or disclosure of Your information, at any time, or request for deletion of your account by raising a request by mailing us at help@smartcoin.co.in or our given address or contacting us at +91-9148 380504. However, if You have availed any loan facilities from Our financing partner, the financing partner shall have the right to continue processing Your information till such credit facility has been repaid in full, along with any interest and dues payable and/or for such period as may be allowed under applicable law. However, We shall not retain Your data and information if it is no longer required by Us and there is no legal requirement to retain the same. Do note that multiple legal bases may exist in parallel, and We may still have to retain certain data and information at any time.
3. Rectification: In the event that any personal data provided by You is inaccurate, incomplete or outdated then You shall have the right to provide Us with the accurate, complete and up to date data and have Us rectify such data at Our end immediately. We urge You to ensure that You always provide Us with accurate and correct information/data to ensure Your use of Our Services is uninterrupted.
4. Report an issue: You have a right to report a security incident to the GRO (detailed mentioned

hereinbelow).You are entitled to prevent unauthorised usage of your information by our personnel/agents by informing us, within 10 days of being informed of the proposed use. You can also exercise the right at any time by contacting us at help@smartcoin.co.in.

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7. Updates to Privacy Policy

We reserve the right to modify this policy at any time, so please review this frequently. Changes and modifications will take effect immediately upon their posting on the portal. Any continued use of the services shall signify your acceptance of such new or updated policy, as the case may be.

8. Grievance Office

Keeping in mind the Information Technology Act 2000 and rules listed, if you have any questions, concerns or grievances regarding this Privacy Policy, please email us at our grievance email-address: grievance@smartcoin.co.in. The details of our Grievance Officer are stated below:

Grievance Redressal Officer: Ravi Kumar Contact Details:

Phone: +91 9148380504

Email: grievance@smartcoin.co.in Address: SmartCoin Financials Pvt Ltd.

IndiQube Gamma, No.293/154/172, 2nd Floor, Outer Ring Road,

Kadubeesanahalli, Bengaluru, Karnataka 560103 Mode of Lodging Complaints:

The complaints can be registered through the following channels:

19. Calling us on the given phone number
20. Writing to us either over email or through postal service at our given address

9. List of Lenders (Lending Partners)

1. Upmove Capital Pvt Ltd: https://upmove.in/
2. Incred Financial Services Limited: https://www.incred.com/
3. Vivriti Capital Ltd: https://www.vivriticapital.com/
4. Northern Arc Capital Ltd: https://www.northernarc.com/
5. PayU Finance India Pvt Ltd: https://www.payufin.in/
6. Poonawalla Fincorp Limited: https://poonawallafincorp.com/