The website and mobile application associated with https://mwyninsurance.in (jointly,  “Platform”) are operated by MWYN INSURANCE TECH PRIVATE LIMITED (“MWYN”), a  company incorporated under the provisions of the Companies Act, 2013, and having its  registered office at G-405, 4th Floor – Gamma Block, Sigma Soft Tech Park, Varthur Kodi,  Whitefield Post, Bangalore 560 066.  

 For the purposes of this privacy policy (“Privacy Policy”), “we”, “our” and “us” shall mean  MWYN and “you” and “your” shall mean you as a user of the Platform (“User”), whether  registered or not. This Privacy Policy shall be read along with the relevant terms of use  (each, a “Terms of Use”).  

The capitalized terms that are used in this Privacy Policy but not defined herein shall have  the same meaning as defined in the applicable Terms of Use. This Privacy Policy is  incorporated into, and is subject to, the Terms of Use pertaining to the services provided by  us through the Platform (“Services”). This Privacy Policy sets out what information we  collect and how and why we use it, when you access the Platform, create an account with us  (“Account”) and avail of our Services.  

You are advised to read the Privacy Policy carefully before using this Platform. To access or  use the Platform, you are required to accept the terms of this Privacy Policy. By accepting  this Privacy Policy, you signify that you have read, understood and agree to be bound by this  Privacy Policy. We reserve the right to update or modify this Privacy Policy at any time  without prior notice and such changes shall be effective immediately in accordance with  Clause 10.  

BY ACCEPTING THE PRIVACY POLICY, YOU EXPRESSLY CONSENT TO MWYN’S COLLECTION,  RETENTION, ANALYSIS, USE AND DISCLOSURE OF YOUR PERSONAL INFORMATION IN  ACCORDANCE WITH THIS PRIVACY POLICY.  

1. INFORMATION COLLECTED  

1.1. We will collect personal information of the User, as detailed further in this clause 1  and as expressly set forth in this Privacy Policy. While some User information has to  be mandatorily provided, others are optional and certain portions of the information  will remain private; We shall always let the User know which is which. Additional  information may be gathered during subsequent use of the Platform and availing of  Services, by the User, whenever the User chooses to provide it.  

1.2. Certain mandatory information will be collected at the time of registration on the  Platform which is required to enable the User to login to the Platform and for us to:  (i) verify the User’s identity; (ii) determine the User’s eligibility for taking loans using,  inter alia, our proprietary technology and such additional rules that may be  determined by: (a) us; (b) our banking partners; or (c) both (a) and (b); and (iii)  safeguard against illegal activities like fraud, cheating, misappropriation, etc. 

1.3. For providing the Services, we require certain mandatory User information as  described below:  

1.3.1. For the purposes of registering, we require basic personal information such  as name, date of birth, mobile number, e-mail address, permanent address,  current address, employment details, PAN, salary, etc. and certain  information about your personal identity such as gender, age, etc;  

1.3.2. Once you are duly registered, we, on behalf of our insurance partners, may  also require certain additional information such as your designation, mode  of salary, parent names, educational qualification, bank details etc. for the  purposes of processing your application; and  

1.3.3. Further, we also collect and store your usernames, passwords, email  addresses and other security related information that you use for our sites  in relation to our Services.  

1.4. In order to use the facilities and Services available on the Platform, the User may be  required, from time to time, at the request of MWYN to provide certain additional  personal information after registration on the Platform, which information shall be  collected only upon receiving the User’s express consent.  

1.5. In the event we are required to do a Know Your Customer (“KYC”) verification  process for the purposes of enabling you to avail of the Services, we will do so as per  the guidelines and directions issued by the Reserve Bank of India, as amended from  time to time.  

1.6. We may also automatically receive and collect certain anonymous information in  standard usage logs through the web server, including mobile-identification  information obtained from the equivalent of “cookies” sent to the Platform,  including mobile network information, standard web log information, traffic to and  from our Platform, tracking inside the Platform and any other available information,  from:  

1.6.1. an IP address, assigned to the device used by the User;  

1.6.2. the domain server through which the User accesses the Platform and the  functions and features therein; and  

1.6.3. the type of device used by the User (“Device”).  

1.7. The User may choose to provide us with access to certain personal information  stored by third parties like social networking sites (e.g., Facebook and Twitter). We  will have access to such information to the extent allowed by the User’s privacy  settings on that site and the User’s specific authorization. In the event the User associates a User account managed by us with an account maintained with any third  party to enable us to access certain information maintained in such third party  managed accounts, the User agrees that we may collect, store and use such  information in accordance with this Privacy Policy.  

1.8. After obtaining the User’s specific consent to allow the Platform to access the User’s  SMS inbox, we may collect, store, monitor and transmit to our server, relevant  information from text messages (SMS) received by the Users from providers of  services and/or products (including but not limited to retail outlets, financial  institutions, mobile carriers and utility companies), that will enable us to provide  better access to financial services and products to the Users. We will access business  messages, which shall be used solely for the purposes of providing the Services.  

How we use this information: We shall collect any SMS information for facilitating  you any insurance services and such purposes as may be required by the insurance  partners or as per applicable law.  

1.9. In order to enhance our ability to provide valuable Services and experiences to the  User, we may take one time access to: (i) automatically receive, collect and analyze  your location information which may be accessed through a variety of methods  including, inter alia, GPS, IP address, and cell tower location; and (ii) collect  information pertaining to your Device and your usage thereof, including, inter alia,  the names of the other applications on your mobile Device and how you use them,  information about your Device, and information about your use of features or  functions on your Device; (iii) camera access to scan and capture selfie and the  required documents; (iv) microphone permissions to enable a two-way  communication between our authorised agent and you for the purpose of  performing and completing your video KYC; and (v) file and media in order to enable  you to upload documents solely for the purpose of onboarding or KYC checks or to  raise tickets. Upon completion of the KYC/on-boarding, please ensure that you  revoke access to the aforesaid information through your device settings.  

How we use this information: We shall collect any Files & Media (Images) for  facilitating KYC journey, insurance services and such purposes as may be required by  the insurance partners or as per applicable law.  

1.10. You explicitly consent that we may 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 creditworthiness and enrich your profile  with pre-approved customized loan offers. This also includes having access and  permission to send you messages and notifications via your social media and instant  messaging applications.  

1.11. We may collect information with your consent from your mobile device like device  location, device information (including, model, installed apps, Wi-Fi, mobile network) transactional and promotional SMS, communication information to  provide customized offerings and services.  

1.12. We may need access to your contacts Information to enable you to transact using  Our Services and to facilitate you to send money to your contacts.  

2. METHOD AND MANNER OF USE  

2.1. When the User registers with the Platform, we will use the information supplied by  the User to access credit information from credit bureaus, with User consent, and  identity verification services to facilitate banks and other financial institutions to  evaluate the User’s loan request in the context of the User’s complete financial  situation.  

2.2. We will also use the User information to enable activities and transactions that need  to occur during the process of insurance, such as:  

2.2.1. generating and maintaining User profiles on the Platform;  

2.2.2. provide personalized features;  

2.2.3. aiding financial services organizations to provide better Services;  2.2.4. facilitating collection activities as needed;  

2.2.5. maintaining regular communications with the User concerning transactions  that the User initiates, such as requesting information or assistance,  submitting a loan request, making payments, transferring funds, etc.  

2.2.6. modifying the Platform from time to time to cater to the User’s interests;  

2.2.7. delivering any administrative notices, alerts, advice, notification and  communication relevant to your use of any facilities on the Platform through  WhatsApp, SMS, Facebook and other mediums;  

2.2.8. marketing research, project planning, troubleshooting problems, detecting  protecting against error, fraud or other criminal activity;  

2.2.9. for undertaking KYC authentication;  

2.2.10. resolving disputes in relation to the credit facilities, if any;  

2.2.11. providing the Platform and the functions and features therein, efficiently;  and  

2.2.12. preserve social history as governed by existing law or policy. 

2.3. You acknowledge that if we determine that any information you have provided or  uploaded violates the terms of this Privacy Policy, we have the right, in our absolute  discretion, to delete or destroy such information without incurring any liability to  you.  

2.4. You acknowledge that you are licensing us to use, modify, display, distribute and  create new material from the information you provide through the Platform to  render certain Services on the Platform. By providing such information, you  automatically agree, or promise that the owner of such information has expressly  agreed to allow or license, as the case may be, us to use the information in the  manner set out in this Privacy Policy, without the payment of any fees. We may, to  the extent permitted by law, also use, license, reproduce, distribute disclose, and  aggregate, non-personally identifiable information that is derived through your use  of the Platform and you hereby provide consent for the same.  

2.5. For the avoidance of any doubt, it is hereby clarified that any User information  collected from you and eventually stored by us will be used only for the purposes of  providing our Services.  

3. SHARING OF INFORMATION  

3.1. We will not use User information for any purpose other than in connection with the  Platform. You understand that in order to provide the Services, we will share the  User information with third parties, including entities / organizations / insurance  providers that provide the loans / credits availed through the Platform or otherwise  in connection with the Services (and other functionalities of the Platform) and you  explicitly agree to such User information being shared. Please note that the list of  third parties with whom User information is shared is available at  https://mwyninsurance.in . In the event you are directed to a third-party website  and if you choose to access them (or avail of such third party’s offerings), we will not  be responsible for such third-party websites or applications. Please note that in case  you share any data or information with such third parties, you will be bound their  respective privacy policies and/or terms of use/service. Furthermore, MWYN will not  rent, sell or share User information and will not disclose any of the User’s personally  identifiable information to third parties or affiliates, unless:  

3.1.1. it is pursuant to obtaining the User’s permission;  

3.1.2. it is in connection with disclosure to financial institutions and banks, in  which case, the User hereby gives his express permission;  

3.1.3. it is in connection with the Services being rendered through the Platform; 

3.1.4. it is to help investigate, prevent or take action regarding unlawful and illegal  activities; suspected fraud, potential threat to the safety or security of any  person, violations of our Terms of Use, or as defence against legal claims;  

3.1.5. it is a case of special circumstances such as compliance with court orders,  requests/order, notices from legal authorities or law enforcement agencies  compel us to make such disclosure;  

3.1.6. it forms part of the information we share with advertisers on an aggregate  basis;  

3.1.7. it improves personalization, analysis and for offering new products/services;  3.1.8. it is for promotional purposes for other services being rendered by us; and  

3.1.9. it is required under an arrangement between us and the third party for  product enhancement, analysis, risk and security purposes, communication  purpose, etc.  

3.2. If all or some of the business, stock or assets of MWYN are acquired or merged with  another business entity, we will share all or some of your information with the  acquiring / merged entity to continue to provide the Services to you.  

3.3. If you decline to submit information to us, then we will unfortunately not be in a  position to provide the Services to you.  

4. SERVICE PROVIDERS  

4.1. We may employ third-party service providers and individuals due to the following  reasons:  

4.1.1. To facilitate our Service; or  

4.1.2. To provide the Service on our behalf; or  

4.1.3. To perform Service-related services; or  

4.1.4. To assist us in analyzing how our Services are used.  

4.2. You acknowledge that the third-party service provider/agent/agencies will have  access to your personal information on a need to know basis to assist us in rendering  Services, and the service providers are restricted from using the same for any other  reason. The third-party service providers are obligated not to disclose or use the  information for any other purpose. 

5. YOUR RIGHTS & PREFERENCES AS A DATA SUBJECT IN INDIA  

5.1. This Privacy Policy is intended for Users within the territory of India and govern your  rights as per applicable law within the territory of India. However, in the event you  fall under a jurisdiction outside the purview of Indian law, MWYN will not be liable  for any claim, action and/or right initiated/exercised by you as per the extant laws of  that jurisdiction. Therefore, we request you to kindly use the Platform accordingly.  

5.2. Furthermore, we will always store any data collected from you in our servers located  in India.  

6. DATA RETENTION  

6.1. We take reasonable steps to ensure that User information is available only for so  long as is necessary for the purpose for which it is processed, or longer if required  under any applicable law, subject to appropriate safeguards. Please note that we  ensure that all other information collected and stored is anonymized and aggregated  in an irreversible manner. Furthermore, you explicitly consent and agree that we will  be entitled to use such anonymized data or information freely, without any  restrictions other than those set out under applicable law. Once any portion of the  User information collected by us is no longer necessary for the purpose for which it  is processed, or is no longer required under any applicable law, whichever is later,  such User information shall be forthwith deleted, without retention of any copies.  

7. INFORMATION SECURITY  

7.1. The information provided by the User is stored in access controlled facilities with  restricted access. User information transmitted over the internet is protected  through the use of encryption, using the Secure Socket Layer (SSL) or equivalent  protocols.  

7.2. If a password is used to help protect User accounts and account information, it is the  responsibility of the User to keep the password confidential. You have to ensure that  you always log out, before sharing the device with a third party and it is advised that  the User utilizes a Service to protect access to the User’s Device.  

7.3. We shall use generally accepted industry standards to protect the User information  submitted to us, both during transmission and upon receipt. However, please be  advised that, no method of transmission over the Internet, or method of electronic  storage, is 100% secure. Therefore, even though we strive to use commercially  acceptable means to protect User information, we cannot guarantee its absolute  security and your use of the Platform is at your sole risk and discretion. We also  cannot warrant that such User information may not be misused in the event our  safeguards and protocols are breached by a malicious third-party. Further, we are  not liable to, nor can we fully control the actions of other users with whom you may  choose to share your information. 

7.4. The collection, usage, and sharing of User information by us shall be in compliance  with the Information Technology (Reasonable Security Practices and Procedures and  Sensitive Personal Data or Information) Rules, 2011 and other applicable laws.  

7.5. If any security breach comes to our knowledge, then we may take all steps required  to protect misuse of such information and may attempt to notify you electronically  so that you can take appropriate steps. For the purposes of this Clause 7.5, the  procedure/responses that would be undertaken by us in case of a security breach is  available at https://www.moneytap.com/cyber-security-incident-policy.html.  

7.6. Any of your information which you provide when you use our Services to an open,  public environment or forum or any third party website including (without  limitation) any blog, chat room, community, classifieds or discussion board: (i) will  not be considered confidential; and (ii) is not subject to protection under this Privacy  Policy. Since such public environments are accessible by third parties, it is possible  that third parties may collect or use such information for their own purposes. You  should accordingly be careful when deciding to share any of your information in  such public environments. Please note that we are not liable to you or any third  party for any damages that you or any third party may suffer on account of your  disclosure of Information in any public environment.  

8. PROCEDURE FOR REMOVING USER NAME FROM THE RECORDS  

8.1. If and when a User is desirous of having his/her name and other details: (a)  removed from the records of MWYN or not be used by MWYN; (b) not be shared  with a third party; immediately upon receiving the User’s written request to that  effect we shall, subject to the terms hereof and/or applicable law, remove  and/delete all such information.  

8.2. If the User no longer wishes to receive notifications about our Services, The User  may change his/her notification preferences by contacting us at  pranav@mwyninsurance.in . We reserve the right to close the User account if the  User opts out of receiving certain crucial notices that are required to perform the  Services through the Platform. The User may not opt-out of receiving notifications  about due or past due amounts that the User owes MWYN or any other collections  efforts.  

8.3. Notwithstanding the foregoing, MWYN may retain information of the User if  mandated under applicable law, even after receiving the User’s written request to  remove/delete all such information. 

9. PROCEDURE FOR CORRECTING INACCURACIES IN THE INFORMATION  

9.1. The User may correct or update any information online. In the event of loss of  access details, the User may retrieve the same or receive new access details by  sending an e-mail to: pranav@mwyninsurance.in  

10. PRIVACY POLICY UPDATES  

10.1. We reserve the right to change or update this Privacy Policy at any time. Such  changes shall be effective immediately upon posting on this Platform. Your access  and use of the Platform following any such change constitutes your agreement to  follow and be bound by these Privacy Policy, as updated or modified. For this  reason, we encourage you to review this Privacy Policy each time you access and use  the Platform.  

11. NODAL GREIVANCE REDRESSAL OFFICER  

11.1. As required under applicable guidelines issued by Reserve Bank of India (RBI) and  Information Technology Act, 2000 and rules made there under and for the purposes  of redressing any complaints, you may contact our nodal grievance redressal officer  whose name and contact details are provided below:  

NAME : Pranav Khanna  

ADDRESS: G-406 Gamma Block, Sigma Soft Tech Park, Varthur Road,  

Whitefield, Bangalore, Karnataka, India, 560066  

TEL: +91 6361121526  

EMAIL: pranav@mwyninsurance.in 

12. DISPUTE RESOLUTION  

12.1. In the event of any dispute, difference or claim arising out of this Privacy Policy the  same shall be settled in accordance with the laws of India through regular judicial  process and the courts of Bangalore, India shall have exclusive jurisdiction.  

13. COOKIES  

13.1. When you visit the Platform, one or more cookies will be sent to the  computer/smartphone or other devices being used by you. The cookies are either  used to improve the quality of the Platform or for storing your preferences as a user,  improving search results and tracking user trends. You have the option of disabling  cookies via your browser preferences. However, if you disable cookies on your  browser, some parts of the Platform may not function effectively.