Privacy Policy

This privacy policy ("Policy") sets forth the reasonable security practices and procedures adopted by Aditya Birla Capital (“ABC”) Group Companies which include the following entities:

1. Aditya Birla Capital Limited
2. Aditya Birla PE Advisors Private Limited
3. Aditya Birla Financial Shared Services Limited
4. Aditya Birla Trustee Company Private Limited
5. Aditya Birla Money Limited
6. Aditya Birla Housing Finance Limited
7. Aditya Birla Sun Life Trustee Private Limited
8. Aditya Birla Wellness Private Limited
9. Aditya Birla ARC Limited
10. Aditya Birla Sun Life Insurance Company Limited
11. Aditya Birla Sun Life Pension Management Limited
12. Aditya Birla Stressed Asset AMC Private Limited
13. Aditya Birla Capital Digital Limited
14. Aditya Birla Health Insurance Co. Limited
15. Aditya Birla Sun Life AMC Limited

1 to 15 above collectively referred to as "ABC Companies")

and shall apply to use and disclosure of information that identifies you as individual including but not limited to your Name, Date of birth, Bank Account details, Credit Card details, Debit Card details, Phone number, Fax number, email address etc. ( collectively, "Personal Information") provided by You (which means and include a Customer or a User) on the Website www.adityabirlacapital.com/connectedwebpages and its sub-domains; mobile application and m-site of ABC Companies(“hereinafter collectively referred to as "ABC Platform") or otherwise at the time of client acceptance / registration/application in connection with availing products or services or facilities of ABC Companies.

This privacy policy shall be read in conjunction with the Terms of Use(Terms and Conditions) agreed by you while registering on www.adityabirlacapital.com for availing its service

BACKGROUND

• his Privacy Policy (“Policy”) explains the manner in which Aditya Birla Capital Limited (“Company” “us”, “our” or “we”) processes your personal data. We respect your privacy and are committed to safeguarding your personal data. This Policy outlines our practices in relation to the collection, storage, usage, processing, and disclosure of personal data that you have consented to share with us when you access, use, or interact with our website(s) or when you avail our services or products. The website(s), mobile app, services and products shall be collectively referred to as the “Services”. By using the Services offered by us, you confirm that you have read and agree to be bound by this Policy.
• Please note that unless specifically defined in this Policy, capitalised terms shall have the same meaning ascribed to them in our Terms and Conditions, available at Terms and Conditions (“Terms”). Please read this Policy in consonance with the Terms.
• By availing the Services or providing us with the consent or explicit consent (if you choose to avail digital lending services) to process your personal data, you acknowledge that we will collect, store, use, and disclose your personal data in accordance with this Policy.

THE DATA WE COLLECT ABOUT YOU

We may collect, use, store, disclose, transfer, retain, and otherwise process different types of personal data about you, as may be applicable, depending on the Services we provide to you. This includes, but is not limited to:

1. Identity Data: This includes data such as your first and last name, date of birth, voice and video recordings, gender, location data, contact details and address.
2. Profile Data: This includes data such as your username and password, where applicable.
3. Financial and Insurance Data: This includes bank account details, income, assets and investment related information, credit card and debit card information, insurance coverage amounts, insurance claim details and information pertaining to business turnover, business type and industry, to the extent that it contains personal data.
4. Purchase and Payment Related Data: This includes invoice records, records of services availed, payment records, payment method, cardholder data, bank account holder details, payment amount and payment date.
5. Marketing and Communications Data: This includes information posted in service requests, offers, feedback, comments, responses to user surveys and polls, your preferences in receiving marketing communications from us and third parties, and your communication preferences.
6. KYC data: This includes identification documents issued by the government or other authorities, in line with RBI’s Officially Valid Documents (OVDs). It covers proof of possession of Aadhaar number (in masked or redacted format, as applicable), Passport, Driving Licence, Voter’s Identity Card, Job Card issued under NREGA, and Letter issued by the National Population Register (NPR). Additionally, it includes PAN card (or Form 60, where applicable) for tax identification purposes.
7. Technical Data: This includes data such as your internet protocol address, time zone settings, operating systems, location data, device information and other technology that you use to access and use the Services.
8. Usage Data: This includes information about how you use the Services, your activity on the website, user taps and clicks, user interests, time spent on the site, details about user journey, and page views.

We do not access your mobile phone resources such as file and media (except as disclosed under this Policy in order to enable you to upload documents), contact list, call logs and telephony functions. However, we may require a one-time access to your camera, microphone, location or any other facility solely for the purpose of onboarding or KYC checks, after obtaining your explicit consent. We do not collect your biometric data. In case you do not provide us with the access to the specified data for conducting KYC checks, we will not be able to provide you with the required Services.

We also collect, use, and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data under law as it is not directly or indirectly linked to your identity. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data, which will be used in accordance with this Policy.

We are required to collect certain personal data to provide you with the Services. If you fail to provide us that data as and when requested by us, we will not be able to perform our obligations under the arrangement we have with you or wish to enter into with you. In this case, we may have to cancel or limit your access to our Services (or part thereof).

HOW WE COLLECT DATA ABOUT YOU

We use different methods to collect and process personal data about you. This includes:

• Information you provide us: This is the information (including identity, contact, KYC, financial, and device data) you consent to give us when you use our Services or when you correspond with us (for example, by email or chat, or through our Services). It includes information you provide when you register to use the Services, share data through the Service, or when you report a problem with our Services. If you contact us, we will keep a record of the information shared during the correspondence.
• Information we collect about you and your device: Each time you use the Services, we will automatically collect personal data through the use of tools like cookies.
• Information we receive from other sources including third parties and publicly available sources: We will receive personal data about you from various third parties and public sources including our third parties for advertising and user analytics purposes, and other publicly available sources.
• Please note that we do not have any control over personal data that you may choose to make publicly available. For example, if you post reviews, comments, or messages on public sections of the Platform or on an application store (such as the Play Store), you do so at your own risk. We are not liable for third-party misuse of such data.

HOW DO WE USE YOUR PERSONAL DATA?

We will only use your personal data when the law allows us to. We and our partners may use your personal data for the following purposes:

• to fulfil your requests for Services offered and accepted by you and to contact you either through us or our third party service providers through any channel of communication including but not limited to email, telephone, SMS, etc;


• to deliver any administrative notices, alerts, advice and communications relevant to your use of the Service;


• to share your information with our group companies and other third parties in so far as required for joint marketing purposes, or to offer similar Services, or to provide you with various value added services;


• to undertake market research, project planning, troubleshooting problems;


• to improve the functionality of our Services based on the information and feedback we receive from you;


• to improve customer service and to effectively respond to your Service requests and support needs;


• to send periodic notifications to manage our relationship with you including to notify you of changes to our Services, send you information and updates pertaining to our Services that you have availed or sought to avail, and to send updates related to us or our Services;


• to market and advertise our Services to you;


• to respond to court orders, establish or exercise our legal rights, or defend ourselves against legal claims;


• for fraud prevention and detection;


• for compliance with applicable law; and


• to perform our obligations that arise out of the arrangement we may enter or have entered with you.

Service-Related and Marketing Communications: You agree and acknowledge that by using the Services, you authorise us and our service providers to contact you via email, phone, or otherwise. This is to provide the Services to you and ensure that you are aware of all the features of the Services, and for sales and marketing purposes. You can withdraw your consent or opt out of receiving such communications at any time by following the instructions provided in our communications or by contacting us directly. Please note that even if you opt out of marketing communications, we may still send you service-related or transactional messages that are necessary for the performance of our Services.

DISCLOSURE OF INFORMATION

We may share or disclose your personal data with our other corporate entities, affiliates, partners, merchants and other third parties as permitted by applicable laws. Such disclosure may be required for purposes such as providing you access to our Services, for enhancing your experience, to comply with our legal obligations, to enforce our agreement(s) with you, to facilitate our marketing and advertising activities, to prevent, detect, mitigate, and investigate fraudulent or illegal activities related to our services, for providing credit defaults and credit information, for communicating with you, for enhancing your pre-qualified offers if applicable, for data enrichment, to authenticate your KYC information with the relevant authorities such as NSDL, CDSL, UIDAI, CKYCR and also to register you for the Services that you avail.

We may also disclose your personal data to regulators, law enforcement agencies, or any other third party where we, in good faith, believe that that such disclosure is reasonably necessary to enforce our Terms, respond to claims that an advertisement, posting or other content violates the rights of a third party, or protect the rights, property or personal safety of our customers or the general public.

Where you choose to obtain a loan or avail our lending services, we may also share your personal data with certain third parties in connection with the loan or lending service. A list of third parties that we may disclose your personal data to is available at adityabirlacapital.com/loans/third-party .

You agree and acknowledge that we may share your personal data without your consent, when required by law or by any court or a government or regulatory authority.

THIRD PARTY SERVICES

Our Services may, from time to time, contain services provided by our partner networks, advertisers, and affiliates (“Third Party Services”). Please note that the Third Party Services that may be accessible through our site or Services have their own privacy policies. We do not accept any responsibility or liability for the policies or for any personal data that may be collected through the Third Party Services. Please check their policies before you submit any personal data to such websites or use their services.

Your relationship with these third parties and their services and tools is independent of your relationship with us. These third parties may allow you to permit or restrict the information that is collected.

COOKIES

Cookies are small files that a site or its service provider transfers to your device’s hard drive through your web browser (where applicable) that enables the sites or service providers’ systems to recognise your browser, and capture and remember certain information.

We use cookies to help us distinguish you from other users of our Services, understand and save your preferences for future visits, keep track of advertisements, and compile aggregate data about site traffic and site interaction so that we can offer you a seamless user experience. We may contact third party service providers to assist us in better understanding our site visitors. These service providers are not permitted to use the information collected on our behalf, except to help us conduct and improve our business.

Additionally, you may encounter cookies or other similar devices that are placed by third parties. We do not control the use of cookies by third parties.

YOUR RIGHTS IN RELATION TO YOUR PERSONAL DATA

Under certain circumstances and subject to applicable laws, you may have the right to:

• Review and correct your personal data: This enables you to request access to review and and correct inaccurate or deficient data, subject to any applicable laws.


• Request the erasure of your personal data: This enables you to ask us to delete or remove personal data. We shall comply with any request (a) unless we are required to retain such data to continue providing the Services, or (b) subject to the extent required under applicable laws.


• Right to revoke or withdraw consent: This enables you to withdraw consent at any time. We shall comply with any request, subject to the extent required under applicable laws.

If you wish to exercise any of the rights set out above, please write an email to the Data Protection Officer, whose details are mentioned in Section 14 of this Policy. Please also include a description of the personal data you believe we hold or process about you, so that we may be able to locate such personal data. In the event that we need additional information from you, our Data Protection Officer will contact you further.

We will generally reply to your request(s) within 30 (Thirty) days of raising the request. In the event that we are not able to respond to or acknowledge your request within 30 (Thirty) days of receipt due to any reason, we will notify you.

TRANSFER OF PERSONAL DATA

We comply with applicable laws in respect of storage and transfer of personal data. As a part of your use of our Services, the information and personal data you provide to us may be transferred to and stored in countries other than the country you are based in. This may happen if any of our servers are from time to time located in a country other than the one you are based in, or one of our service providers is located in a country other than the one you are based in. Notwithstanding the foregoing, where required by applicable law, we will store specific categories of personal data in connection with lending or insurance related services in India.

In the event we go through a business transition, including but not limited to a merger, acquisition by another organisation, or sale of all or a portion of our assets, your personal data might be among the assets transferred.

By submitting your information and personal data to us, you agree to the transfer, storage, and processing of such information and personal data in the manner described above.

DATA RETENTION

You agree and acknowledge that your personal data will continue to be stored and retained by us for as long as necessary to fulfil our stated purpose(s) in compliance with applicable laws or to meet statutory limitation periods. If we do not have a reason to retain your personal data, it will be deleted or anonymised as per our internal data destruction protocols.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

DATA SECURITY

We implement reasonable security procedures to protect your personal data from unauthorised access and disclosure, including managerial, technical, operational, and physical security control measures that are commensurate with the information assets being protected. We also maintain processes to (a) reasonably prevent the unauthorised use of your personal data, (b) implement data destruction protocols, and (c) maintain standards for handling security breaches relating to your personal data.

CHILDREN DATA

This website is not intended for use by children and minors as defined under the law. Parents & legal guardians are requested to ensure that Personal Information is not provided by minors..

CHANGE IN PRIVACY POLICY

We keep our Policy under regular review and may amend it from time to time at our sole discretion. The terms of this Policy may change, and if they do, these changes will be posted on our website and, where required by applicable laws, notified to you.

DATA PROTECTION OFFICER

If you have any questions about this Policy, or how we process or handle your personal data, or otherwise seek to enforce any of your legal rights with respect to your personal data, please reach out to our Data Protection Officer whose details are provided below:

Name: Alok Arora

Email Address: abcl.dpo@adityabirlacapital.com

Address: One World Centre, Tower 1, 18th Floor, Jupiter Mills Compound, 841 Senapati Bapat Marg, Elphinstone Road, Mumbai 400 013