Samavesh Finance India Private Limited (hereinafter referred to as, “Tala” or “our” or “we” or “us“) values and respects your right to privacy. This Privacy Policy (“Policy”) aims to set out the details of the nature of information we collect and how we use, share or otherwise process such information in relation to our services. This Policy complies with inter alia the provisions of Information Technology (Reasonable Security Practices & Procedures & Sensitive Personal Data or Information) Rules, 2011 under the Information Technology Act, 2000 and other applicable laws that require publishing of privacy policies for collection, usage, storage, disclosure and transfer of information.

By using our website at www.tala.co.in (the “Website”), you expressly agree and consent to be bound by the terms of this Policy. If you do not agree with the terms of this Policy, you must immediately discontinue the use of and cease to access the Website. This Privacy Policy does not apply to your use of Tala’s application, accessible here (the “App”) or your use of services in relation to the App, including but not limited to our credit or other financial services. Please click here for the privacy policy applicable to your use of the App and related services.

You must be 18 years of age or above to use the Website.

SCOPE OF POLICY

This Privacy Policy applies to the Website, regardless of whether you have accessed the Website on your mobile telephone, handheld device or any other computer resource (each referred to herein as a “Device”), as well as any email or other electronic messaging between you and the Website.

Policy applies to all concerned Users (a “User” is any person who downloads and/or accesses the Website) whose information is collected, possessed, stored, received or otherwise dealt with by us in the course of accessing the Website.

INFORMATION WE COLLECT

We collect and process various types of information on the Website. The information that we collect or process may fall within the category of “Personal Information” as we define that term below. We limit the collection and processing of Personal Information only to what is necessary for achieving the purposes as identified in this Policy.

• Personal Information means any information pertaining to a natural person by way of which such a person can be identified, either by itself or when it is combined with other information, and includes inter alia name, email, address, telephone number, financial information, recent photograph or any other personal detail that may have been voluntarily provided by the user; provided that any information that is readily available or part of the public domain or has been furnished under the Right to Information Act, 2005 or has been made available to us by virtue of any other applicable law, shall not fall within the meaning of Personal Information.
• You provide us with information on the Website, including Personal Information, either directly when you provide it to us or automatically as you navigate through the Website.

We collect information about you when you access the Website, such as:

• Technical information, including the Internet Protocol (“IP”) address, the type of Device you use, unique device identifiers (for example, your Device’s “IMEI” or serial number), information about the mobile network provider and SIM card used by the Device, mobile network information, your Device’s operating system, the type of browser you use, and your Device’s location and time zone setting;
• Details of your use of the Website, such as page interactions, products or services you view and search for and location data;
• Information that you provide by filling in forms on the Website;
• Records and copies of your correspondence (including email addresses) if you contact us;
• Your responses to surveys that we might ask you to complete for research purposes; and
• Your search queries on the Website.

We may also collect information about you from a limited number of third parties that we may work with from time to time in order to provide the Website, such as business partners, where you have consented to such sharing of information.

The technologies we use for automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to the Website.
• Web Beacons. Pages of the Website may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company or third party business partners, for example, to count users who have visited those pages and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

WHY WE COLLECT INFORMATION

Tala collects information on the Website in order to provide its services and for the following purposes:

• Estimate our audience size and usage patterns;
• Store information about your preferences, allowing us to customize our Website according to your individual interests;
• Troubleshooting issues, detection and protection against error, fraud, or other criminal activity;
• Speed up your searches; and
• Recognize you when you return to our Website.

DISCLOSURE OF INFORMATION

We may share information, including your Personal Information, where such disclosure is necessary and customary to our business practices with certain third parties, including but not limited to any of Tala’s subsidiaries, affiliates, subcontractors, agents, service providers, or financing sources (including their or our employees, directors and officers) for the performance of any contractual obligation we may enter into with such parties or with you.

We may also disclose information, including your Personal Information, in the following limited circumstances:

• As required by law, such as to comply with judicial orders, executive orders, law enforcement authorities, or as required by other legal processes;
• When Tala believes in good faith that disclosure is necessary to protect our rights, your safety or the safety of others, investigate potential fraud or crimes, or respond to a request from a governmental entity;
• If Tala, or any of its subsidiaries or affiliates, is involved in a merger, acquisition, or sale of all or substantially all its assets or equity; or
• To any third party other than those listed in Section 9 herein, with your prior and express consent.
• For any other reason with your prior and express consent.

MARKETING AND ANALYTICS

Tala may send you messages and emails carrying promotional materials and/or marketing surveys where you have provided your express consent to the same. To help Tala provide a user-friendly experience and improve the Website, Tala and our third-party service providers, including our marketing partners and analytics providers, may use mobile tracking technologies and/or website cookies to distinguish you from other users of the Website. Analytics companies may also access anonymized individual data to help us develop and analyze our services.

STORING YOUR INFORMATION

We store all of your information locally in India as well as in the United States as per the applicable laws. All data is encrypted in transit.

RIGHTS OF USERS

You have certain rights related to the information we maintain about you and have the right to access the data records we maintain about you, including the right to obtain the details of how we process it.

You have the right to withdraw your consent from letting us access or process your information at any time, subject to a legitimate reason in certain limited circumstances. You can withdraw your consent by emailing us at hello@tala.co.in.

You have the right the correct or modify any information that has been provided to us or has been made available to us.

You have the right to seek from us your Personal Information, if any has been maintained, to provide to any other company as well as the right to erasure of any Personal Information that we process, in certain limited circumstances.

RETENTION POLICY

Tala will retain your information for as long as it is necessary to fulfil the purposes set forth herein, and for a reasonable time thereafter for the furtherance and completion of any of our services to you, and for such time as may be necessary in order to comply with any legal obligation.

Retention periods for records are based on the type of information, the nature of the activity and the product or service that the same is associated with or linked to. The periods for retention of your information, including Personal Information, vary depending on specific legal business and statutory compliance.

We may be required to retain your information post termination of our business relationship with you for fraud prevention purposes and for the exercises/defense of a legal claim or for providing evidence in legal proceedings.

SECURITY OF INFORMATION

The transmission of information via the internet or mobile service is not completely secure. Tala cannot guarantee the security of your information transmitted by you or a third party in connection with the Website, and any such transmission is at your own risk. Once Tala has received your information, including Personal Information, we use and employ reasonable technical, organizational, logistical, physical and administrative measures to protect your information, including Personal Information, against any unauthorized access, modification or use

TESTIMONIALS, BLOGS, AND OTHER FORUMS

With your express consent, Tala may post your testimonial about our services with your name. In case you want your testimonial to be removed from the Website, please contact hello@tala.co.in

CHANGES & QUERIES

We retain the right to make changes to this Policy in future. We understand that it is or duty to keep you informed of any such changes, therefore the Policy with any such changes to it shall be posted on the Website, and if required you will be notified via email or a notification on the Website.

We advise you to go through our Policy diligently and periodically and accept any modifications prior to any continued use of the Website.

EFFECTIVE DATE: April 1, 2020