Privacy Policy

Chapter 1 — INTRODUCTION, SCOPE & PRIVACY COMMITMENT

1.1 Introduction

This Privacy Policy explains how SMARTAXIS PRIVATE LIMITED (“Company”, “SMARTAXIS”, “we”, “our”, or “us”) collects, uses, processes, stores, protects, and handles information relating to Users of the FinDeals Platform.

FinDeals is an online classified platform where Users can publish financial requirement listings, discover relevant listings, and communicate with other Users. The Platform provides digital infrastructure for User-to-User interaction and does not itself provide financial services. This reflects the Company's existing description of FinDeals as a Financial Classifieds Platform operated by SMARTAXIS PRIVATE LIMITED.

1.2 Purpose of This Privacy Policy

The purpose of this Privacy Policy is to clearly explain:

• What information FinDeals may collect;
• How that information is collected;
• Why the information is used;
• How User information is protected;
• When information may be disclosed;
• How User contact information is handled;
• How long information may be retained;
• What privacy choices and rights may be available to Users; and
• How Users can contact FinDeals regarding privacy matters.

1.3 Scope

This Privacy Policy applies to information processed in connection with:

• The FinDeals website;
• User Accounts;
• Financial requirement listings;
• User profiles;
• User-to-User communications;
• Post Highlight services;
• Platform security and fraud prevention;
• Customer support; and
• Other features made available through FinDeals.

1.4 Privacy Commitment

SMARTAXIS PRIVATE LIMITED is committed to handling User information responsibly and implementing reasonable measures to protect personal information against unauthorized access, misuse, alteration, disclosure, or destruction.

The Company will handle personal information in accordance with applicable law and the privacy practices described in this Policy. The Company's existing legal framework similarly establishes privacy, security, transparency, and legal-compliance principles for User information.

1.5 No Sale of Personal Information

FinDeals does not sell, rent, or commercially trade Users' personal information.

FinDeals does not operate a business model based on selling User databases, personal information, leads, or private contact details.

1.6 Private Contact Information

FinDeals does not independently provide or sell a User's private mobile number, email address, or other private contact information to another User.

A User's private contact information will not be commercially offered to another User as a paid contact-access service.

1.7 Voluntary Disclosure by Users

A User may voluntarily disclose their own contact information, including a phone number or email address, by:

• Publishing it in their own listing;
• Including it in their profile where the relevant feature permits;
• Sharing it through chat; or
• Providing it directly to another User.

Such disclosure is made by the User and is not the sale or commercial disclosure of that information by FinDeals.

1.8 Necessary Service Providers and Legal Disclosure

The commitment not to sell or commercially trade User information does not prevent FinDeals from processing or disclosing information where reasonably necessary to operate the Platform or where required or permitted by applicable law.

This may include appropriate disclosures to:

• Hosting and infrastructure providers;
• OTP/SMS or communication providers;
• Payment processors for Post Highlight payments;
• Security and fraud-prevention providers;
• Professional service providers where necessary;
• Courts or competent governmental authorities where legally required; or
• Other parties where the User has expressly authorized the disclosure.

The Company will seek to limit such disclosure to information reasonably necessary for the relevant purpose and applicable legal requirements.

1.9 User Responsibility

Users should carefully consider the information they publish on FinDeals.

Once a User voluntarily publishes or directly shares personal or contact information with another User, FinDeals cannot control how that receiving User may subsequently use information that the User has voluntarily disclosed.

1.10 Relationship With Terms & Conditions

This Privacy Policy should be read together with the FinDeals Terms & Conditions.

The Terms establish the contractual rules governing use of the Platform, while this Privacy Policy explains the Company's information and privacy practices.

1.11 Changes to This Policy

SMARTAXIS PRIVATE LIMITED may update this Privacy Policy when reasonably necessary to reflect changes in:

• Applicable law;
• Platform functionality;
• Technology;
• Security practices;
• Data-processing practices; or
• Business operations.

Material changes will be handled in accordance with applicable law and the change-management provisions of this Privacy Policy.

1.12 User Acknowledgement

By using FinDeals, Users acknowledge that they have been provided with this Privacy Policy and understand that personal information may be processed as reasonably necessary to operate, secure, and maintain the Platform, subject to this Policy and applicable law.

Chapter 2 — INFORMATION WE COLLECT

2.1 Purpose

This Chapter explains the categories of information that SMARTAXIS PRIVATE LIMITED may collect when a User accesses or uses the FinDeals Platform.

FinDeals follows a data-minimization approach and seeks to collect information that is reasonably necessary to operate, maintain, secure, improve, and provide the Platform and its features, subject to applicable law. The previous Privacy Policy similarly established that information collected should be reasonably necessary for Platform operation, security, administration, and legal compliance.

2.2 Information Provided Directly by Users

FinDeals may collect information voluntarily provided by a User when the User:

• Creates an Account;
• Completes or updates a profile;
• Publishes a financial requirement listing;
• Uses Platform chat or communication features;
• Contacts customer support;
• Purchases a Post Highlight;
• Submits feedback or enquiries; or
• Otherwise provides information through the Platform.

2.3 Basic Account Information

Depending on the Platform features used, FinDeals may collect information such as:

• Full name;
• Mobile number;
• Email address, where provided;
• Account ID;
• OTP verification status;
• Account status;
• Registration information; and
• Relevant account-security information.

The previous Privacy Policy identifies name, mobile number, email address, Account ID, OTP verification status, account status, and related account information as categories that may be collected.

2.4 Location Information

FinDeals may collect location-related information voluntarily provided by a User, including:

• Country;
• State;
• District;
• City;
• Postal code; and
• Location associated with a financial requirement listing.

This information may be used to display or organize listings based on geographic relevance.

2.5 Financial Requirement Information

When a User publishes a financial requirement, the User may provide information relating to the requirement, such as:

• Requirement category;
• Type of financial requirement;
• Required amount;
• Purpose of the requirement;
• Preferred location;
• Employment or occupation information;
• Business information;
• Property-related information;
• Vehicle-related information;
• Gold or other collateral-related information; and
• Other information voluntarily included in the listing.

The previous Privacy Policy identifies these categories as information that may be voluntarily provided in Financial Requirement Listings.

2.6 User-Submitted Contact Information

A User may voluntarily provide contact information in a listing, profile, or chat.

This may include:

• Mobile number;
• Email address;
• Alternate contact number; or
• Other contact information voluntarily provided by the User.

FinDeals does not collect this information for the purpose of selling it or commercially providing it to other Users.

The handling of User contact information is further explained in Chapter 5 — User Listings & Contact Information.

2.7 Chat and Communication Information

When Users communicate through FinDeals, the Platform may process information necessary to provide the communication functionality.

This may include:

• Messages;
• Attachments or other content submitted through available communication features;
• Message timestamps;
• User/account identifiers; and
• Technical information associated with the communication.

Such information may also be processed for security, fraud prevention, abuse detection, customer support, and legal compliance where appropriate.

2.8 Post Highlight Payment Information

When a User purchases a Post Highlight, FinDeals or its authorized payment service provider may process payment-related information necessary to complete and record the transaction.

This may include:

• Transaction ID;
• Payment status;
• Payment date;
• Payment method;
• Payment reference;
• Invoice information; and
• Refund status.

FinDeals does not ordinarily need to store sensitive payment authentication information such as UPI PINs, card PINs, or internet-banking passwords. The previous Privacy Policy similarly distinguished transaction information from sensitive payment credentials.

2.9 Technical and Device Information

When Users access FinDeals, certain technical information may be automatically generated or collected, such as:

• IP address;
• Browser type;
• Device type;
• Operating system;
• Device identifiers, where applicable;
• Approximate technical location information;
• Access times;
• Pages or features accessed;
• Session information;
• Error information; and
• Other technical logs necessary for Platform operation and security.

2.10 Usage Information

FinDeals may collect information about how the Platform is used, including:

• Pages viewed;
• Features used;
• Listings viewed;
• Search activity;
• Interaction with Platform features;
• Session duration;
• General usage patterns; and
• Technical events associated with Platform use.

Such information may be used to improve functionality, performance, security, and User experience.

2.11 Security and Fraud-Related Information

FinDeals may collect and retain information necessary to detect, investigate, and prevent:

• Fraud;
• Fake accounts;
• Spam;
• Abuse;
• Unauthorized access;
• Suspicious activity;
• Security incidents; and
• Violations of the Terms & Conditions.

This may include technical logs, account activity, reports, and other information reasonably necessary for security purposes.

2.12 Customer Support Information

If a User contacts FinDeals for support, the Company may collect information necessary to understand and resolve the request.

This may include:

• Name;
• Contact information;
• Account information;
• Description of the issue;
• Screenshots or supporting documents;
• Communication records; and
• Relevant transaction or listing information.

2.13 Information We Do Not Intentionally Require

FinDeals does not ordinarily require Users to provide highly sensitive authentication information such as:

• OTPs for another User's account;
• UPI PINs;
• ATM PINs;
• Internet-banking passwords;
• Card PINs; or
• Similar authentication credentials.

Users should never provide such credentials to another User through FinDeals.

2.14 Information From Other Sources

FinDeals may receive limited information from third-party service providers where reasonably necessary to operate the Platform.

For example, payment providers may provide transaction status or payment confirmation, while communication providers may provide delivery or verification status.

Any such processing will be subject to applicable contractual, technical, and legal requirements.

2.15 Accuracy of Information

Users are responsible for providing information that is accurate, lawful, and reasonably up to date.

Users should not knowingly provide false, misleading, fabricated, or fraudulent information through the Platform.

2.16 Data Minimization

FinDeals seeks to avoid collecting information that is unnecessary for the relevant Platform purpose.

The information actually collected may vary depending on the features a User chooses to use.

For example, a User who only browses public listings may provide considerably less information than a User who creates an Account, publishes a financial requirement, uses chat, or purchases Post Highlight.

2.17 No Collection for Contact-Selling

FinDeals does not collect or maintain User contact information for the purpose of selling contact details, selling leads, or providing paid contact databases to other Users.

There is no Contact Unlock, contact-selling package, membership-based contact access, or similar paid contact-disclosure model under the current FinDeals business model.

2.18 Chapter Summary

FinDeals may collect Account, contact, listing, communication, payment, technical, usage, security, and support-related information as reasonably necessary to operate and protect the Platform.

The specific information collected depends on how a User interacts with FinDeals.

Chapter 3 — HOW WE COLLECT INFORMATION

3.1 Purpose

FinDeals may collect information through different methods depending on how a User interacts with the Platform.

The Company seeks to collect information fairly, transparently, and only to the extent reasonably necessary for the relevant Platform purpose.

3.2 Information Provided Directly by Users

The primary source of User information is information voluntarily provided by the User.

This may occur when a User:

• Creates an Account;
• Completes or updates a profile;
• Publishes a financial requirement;
• Provides information in a listing;
• Uses chat or communication features;
• Purchases a Post Highlight;
• Contacts customer support;
• Submits a complaint or report;
• Provides feedback; or
• Communicates with FinDeals through an official channel.

3.3 Information Collected During Registration

When a User registers for an Account, FinDeals may collect the information required to create and secure that Account.

This may include the User's name, mobile number, email address where provided, and OTP verification status.

3.4 Information Collected When Publishing a Listing

When a User creates a financial requirement listing, the information entered by the User may be collected and stored as part of the listing.

The User determines what information they choose to include, subject to the Platform's required fields and prohibited-content rules.

3.5 Information Collected Through Chat

When Users communicate through FinDeals, information associated with those communications may be collected or processed to provide the chat service.

This may include message content, timestamps, Account identifiers, and technical information associated with the communication.

3.6 Information Collected Through Payments

When a User purchases a Post Highlight, payment-related information may be collected directly by the authorized payment service provider and/or received by FinDeals in connection with confirming and recording the transaction.

FinDeals generally receives transaction information necessary to identify and manage the payment rather than sensitive payment authentication credentials.

3.7 Automatically Collected Information

Certain technical and usage information may be collected automatically when a User accesses or uses FinDeals.

This may include:

• IP address;
• Browser information;
• Device type;
• Operating system;
• Access time;
• Pages or features accessed;
• Session information;
• Technical logs;
• Error information; and
• Other information reasonably necessary for Platform operation and security.

3.8 Cookies and Similar Technologies

FinDeals may use cookies, session technologies, and similar technical mechanisms to:

• Keep the Platform functioning;
• Maintain User sessions;
• Remember relevant preferences;
• Improve performance;
• Understand Platform usage;
• Detect suspicious activity; and
• Improve security.

Further information about cookies and similar technologies is provided in Chapter 10 — Cookies, Tracking & Analytics.

3.9 Information Collected Through Customer Support

When a User contacts FinDeals, the Company may collect information provided during that interaction.

This may include the User's contact details, Account information, description of the issue, screenshots, documents, transaction information, and other information necessary to resolve the request.

3.10 Information From Third-Party Service Providers

FinDeals may receive limited information from service providers used to operate the Platform.

Examples may include:

• Payment confirmation from payment processors;
• OTP or message delivery status from communication providers;
• Technical information from hosting or infrastructure providers; and
• Security or fraud-related information from relevant service providers.

Such information will be used only for legitimate Platform, security, operational, or legal purposes.

3.11 Information From Other Users

FinDeals may process information that one User voluntarily provides about another User through Platform features, such as:

• Chat messages;
• Reports;
• Complaints;
• Fraud reports; or
• Other User-submitted communications.

FinDeals may use such information to investigate complaints, protect Users, enforce Platform rules, and maintain security.

3.12 Information From Public or Lawful Sources

Where reasonably necessary and permitted by applicable law, FinDeals may obtain limited information from publicly available or otherwise lawful sources for purposes such as:

• Fraud prevention;
• Security;
• Verification;
• Investigation of misuse; or
• Legal compliance.

FinDeals does not use such sources as a means of building or selling User contact databases.

3.13 Information Generated Through Platform Use

Some information is generated as a result of a User's interaction with FinDeals.

For example, the Platform may generate:

• Login records;
• Listing activity records;
• Chat timestamps;
• Payment transaction records;
• Security logs;
• Error logs; and
• Records of User actions necessary for Platform operation.

3.14 Information Provided Voluntarily

Users are not required to provide information beyond what is reasonably necessary for a particular Platform feature.

However, if required information is not provided, certain features may not be available.

For example, a User may be unable to create an Account without providing the information required for registration and verification.

3.15 User Responsibility When Providing Information

Users should ensure that information they provide to FinDeals is:

• Accurate;
• Lawful;
• Relevant to the purpose for which it is provided; and
• Permitted to be disclosed by the User.

Users should not provide another person's personal information without appropriate authority or a lawful basis.

3.16 No Hidden Contact Collection for Sale

FinDeals does not collect User contact information through hidden or deceptive methods for the purpose of selling that information to lenders, businesses, advertisers, or other Users.

The Company does not operate a paid contact-unlock or lead-selling model.

3.17 Changes in Collection Methods

As FinDeals develops, the Company may introduce new Platform features that require additional categories or methods of information collection.

Where a new collection practice materially changes how personal information is handled, FinDeals will update this Privacy Policy and obtain any consent required by applicable law.

3.18 Chapter Summary

FinDeals primarily collects information directly from Users, automatically through Platform technology, through User interactions, and from service providers or other lawful sources where reasonably necessary.

The method and amount of information collected depend on the User's interaction with the Platform and the features used.

Chapter 4 — HOW WE USE INFORMATION

4.1 Purpose

This Chapter explains the purposes for which SMARTAXIS PRIVATE LIMITED may process, use, store, and manage information in connection with the FinDeals Platform.

FinDeals processes information only for lawful purposes, in accordance with this Privacy Policy, the FinDeals Terms & Conditions, and applicable law.

4.2 Operating the Platform

FinDeals may use information to:

• Operate and maintain the Platform;
• Provide Platform features;
• Create and manage User Accounts;
• Publish and display financial requirement listings;
• Enable Users to communicate through available Platform features;
• Process Post Highlight services; and
• Maintain the overall functionality and performance of FinDeals.

4.3 Account Management

Information may be used to:

• Create Accounts;
• Authenticate Users;
• Verify mobile numbers;
• Maintain Account information;
• Manage Account security;
• Recover Accounts where applicable; and
• Provide User support.

The previous Privacy Policy identifies Account creation, authentication, mobile verification, profile management, Account recovery, and security management as legitimate uses of User information.

4.4 Publishing and Displaying Listings

FinDeals may process listing information to:

• Publish User listings;
• Display listings to relevant Users;
• Organize listings by category or location;
• Improve search results;
• Prevent duplicate or misleading listings;
• Detect potentially fraudulent listings; and
• Moderate content where reasonably necessary.

These purposes are consistent with the source Privacy Policy's treatment of Financial Requirement Listings.

4.5 Facilitating User Communication

FinDeals may process information to enable communication between Users through available Platform features.

This may include processing information necessary to:

• Deliver messages;
• Maintain chat functionality;
• Identify the relevant Accounts;
• Prevent spam or abuse;
• Investigate reported communications; and
• Maintain Platform security.

4.6 Post Highlight Service

FinDeals may use information to:

• Process a Post Highlight purchase;
• Confirm payment;
• Activate the selected Highlight;
• Apply the applicable geographic reach;
• Maintain transaction records;
• Process refunds where applicable; and
• Provide payment-related support.

Post Highlight is a visibility service only. It does not guarantee a loan, funding, lead, response, or transaction.

4.7 Security and Fraud Prevention

FinDeals may process information to:

• Detect fraud;
• Prevent scams and abuse;
• Detect suspicious activity;
• Protect User Accounts;
• Investigate security incidents;
• Prevent unauthorized access;
• Identify fake or misleading listings;
• Enforce Platform rules; and
• Protect the security and integrity of FinDeals.

The source Privacy Policy specifically identifies fraud detection, abuse prevention, suspicious-activity monitoring, security-incident identification, policy-violation investigation, and Account protection as legitimate processing purposes.

4.8 Customer Support

Information may be used to:

• Respond to User enquiries;
• Resolve technical problems;
• Investigate complaints;
• Handle payment-related questions;
• Address Account issues;
• Respond to privacy requests; and
• Provide general Platform support.

4.9 Platform Improvement

FinDeals may use technical and usage information to:

• Improve Platform performance;
• Identify technical problems;
• Improve User experience;
• Develop new features;
• Understand general usage patterns;
• Improve search functionality; and
• Test and improve Platform functionality.

Where reasonably practicable, analytics and research may use aggregated or de-identified information.

4.10 Analytics

FinDeals may use analytics information to understand how the Platform is used and to improve its performance, functionality, and usability.

Analytics may include information about:

• Pages visited;
• Features used;
• General interaction patterns;
• Device and browser information; and
• Technical performance.

4.11 Personalization and Relevance

Where appropriate, FinDeals may use information to:

• Display geographically relevant listings;
• Improve search relevance;
• Remember selected preferences;
• Organize information according to User-selected criteria; and
• Improve the overall User experience.

Personalization will not be used to create a paid system for selling User contact information.

4.12 Legal and Regulatory Compliance

FinDeals may process information where reasonably necessary to:

• Comply with applicable laws;
• Respond to lawful government requests;
• Comply with tax requirements;
• Maintain legally required records;
• Respond to court orders;
• Cooperate with competent authorities; and
• Fulfil other legal obligations.

These purposes are reflected in the source Privacy Policy's regulatory-compliance provisions.

4.13 Complaints, Disputes and Legal Protection

FinDeals may process information to:

• Investigate complaints;
• Investigate fraud reports;
• Resolve Platform-related disputes;
• Enforce the Terms & Conditions;
• Protect the Company's legal rights;
• Defend legal claims;
• Exercise contractual rights; and
• Comply with legal proceedings or court orders.

4.14 Business Administration

Information may be processed where reasonably necessary for legitimate internal administration, including:

• Accounting;
• Payment reconciliation;
• Internal audits;
• Risk management;
• Security reviews;
• Compliance reviews;
• Business continuity;
• Service monitoring; and
• Operational planning.

4.15 Research and Development

FinDeals may use information to:

• Improve existing Platform services;
• Develop new features;
• Test new technologies;
• Improve security systems;
• Improve fraud detection;
• Improve Platform reliability; and
• Conduct internal research.

Where feasible, research may use aggregated, anonymized, or de-identified information.

4.16 Marketing Communications

Where permitted by applicable law, FinDeals may use appropriate User information to communicate about:

• Platform updates;
• New features;
• Post Highlight services;
• Promotional information;
• Surveys; or
• Other relevant Platform communications.

Users may opt out of promotional communications where applicable.

FinDeals will not use marketing as a means of selling or distributing Users' private contact information to third parties.

4.17 Protecting Users and the Platform

Information may be processed where reasonably necessary to:

• Protect Users;
• Protect the Platform;
• Protect Company property;
• Protect Intellectual Property;
• Prevent abuse;
• Detect unlawful activity;
• Improve cybersecurity; and
• Protect public safety where appropriate.

The source Privacy Policy includes these protection-related purposes.

4.18 No Contact-Selling Purpose

FinDeals does not use personal information for the purpose of selling contact details, selling lead databases, or commercially providing private User contact information to lenders or other Users.

In particular, FinDeals does not process personal information to operate:

• Contact Unlock;
• Paid contact-access packages;
• Membership-based contact access;
• Lead-selling packages; or
• Contact-detail databases for sale.

These are not part of the current FinDeals business model.

4.19 No Processing for Incompatible Purposes

FinDeals will not intentionally process personal information for purposes materially incompatible with those described in this Privacy Policy unless:

• Required by applicable law;
• The User provides additional consent where required; or
• Another lawful basis permits such processing.

This principle is also reflected in the source Privacy Policy.

4.20 Data Minimization

FinDeals seeks to use only the information reasonably necessary for the relevant purpose.

The Company does not intend to collect or use additional personal information merely because it is technically possible to do so.

4.21 Chapter Summary

FinDeals uses information primarily to operate the Platform, manage Accounts, publish and organize listings, enable User communication, process Post Highlight payments, provide support, maintain security, prevent fraud, improve the Platform, and comply with applicable law.

Most importantly, User information is not used as a commercial contact database or as a product for sale.

Chapter 5 — USER LISTINGS & CONTACT INFORMATION

5.1 Purpose

This Chapter explains how FinDeals handles information that Users include in their financial requirement listings and, in particular, how User contact information is treated.

FinDeals is designed to allow Users to publish their requirements and communicate with interested Users without operating a business model based on selling personal information or private contact details.

5.2 User-Controlled Listings

Users are responsible for the information they choose to include in their listings.

A listing may contain information such as:

• Requirement category;
• Required amount;
• Location;
• Purpose of the requirement;
• Property or asset details;
• Business information;
• Supporting information;
• Images; and
• Other information voluntarily submitted by the User.

The previous Privacy Policy confirms that listing information is voluntarily entered by Users.

5.3 Public Listing Information

Information that a User voluntarily places in a listing may be displayed to other Users according to the visibility and functionality of the FinDeals Platform.

Users should therefore avoid publishing information they do not wish other Users to see.

5.4 Private Contact Information

FinDeals may collect a User's mobile number, email address, or other contact information for Account creation, verification, security, support, and other legitimate Platform purposes.

FinDeals does not sell, rent, commercially trade, or provide a User's private contact information to another User as a paid service.

5.5 No Contact-Selling Model

FinDeals does not operate:

• Contact Unlock;
• Paid access to private phone numbers;
• Contact-detail packages;
• Lead databases for sale;
• Membership-based contact access;
• Credits for obtaining contact details; or
• Any similar service through which private User contact information is commercially provided to other Users.

This is a deliberate part of the current FinDeals business model.

5.6 Voluntary Contact Disclosure by a User

A User may choose to disclose their own contact information by:

• Adding a phone number to their listing;
• Adding an email address to their listing;
• Sharing contact information through chat;
• Sending contact information directly to another User; or
• Using another Platform feature that expressly allows the User to publish or share such information.

Where a User voluntarily makes their own contact information available, that disclosure is made by the User and is not a sale or commercial disclosure by FinDeals.

5.7 Contact Information Shared Through Chat

If a User voluntarily sends their phone number, email address, or other contact information through chat, the information may be received by the other User.

FinDeals does not control how the receiving User subsequently uses information that the original User voluntarily chose to share.

Users should therefore exercise caution before sharing personal or sensitive information.

5.8 FinDeals Does Not Independently Reveal Private Numbers

A User's private mobile number or email address stored by FinDeals for Account, verification, security, or operational purposes will not be independently disclosed to another User merely because that User is interested in the listing.

Being an interested User, lender, or potential counterparty does not by itself create a right to obtain another User's private contact information.

5.9 No Automatic Contact Access

Viewing, searching, responding to, or interacting with a financial requirement listing does not automatically give another User access to private contact information maintained by FinDeals.

Any contact information available to another User must come from information the User has voluntarily made available or from a disclosure expressly authorized by the User, subject to applicable law.

5.10 User Responsibility for Published Information

Before publishing a listing, Users should review the information carefully and determine whether they are comfortable making that information visible to other Users.

Users should not publish:

• Passwords;
• OTPs;
• UPI PINs;
• Banking passwords;
• Card PINs;
• Confidential financial credentials; or
• Sensitive information that is unnecessary for the listing.

5.11 Accuracy of Listings

Users are responsible for ensuring that information included in their listings is accurate and not intentionally misleading.

FinDeals does not guarantee the accuracy, completeness, authenticity, or current status of User-generated listings.

5.12 Removal or Modification of Listings

Subject to Platform functionality and applicable law, Users may be able to edit, withdraw, or remove their listings.

Removal of a listing does not necessarily mean that every copy, backup, security record, communication, or legally required record relating to that listing is immediately deleted.

Data retention is addressed separately in Chapter 8 — Data Retention & Deletion.

5.13 Contact Information and Platform Security

FinDeals may process contact information for legitimate purposes such as:

• Account verification;
• Security;
• Fraud prevention;
• Customer support;
• Important Platform communications;
• Legal compliance; and
• Protection of the Platform.

Such processing does not constitute the sale of contact information.

5.14 Service Provider Processing

Where necessary to operate FinDeals, certain authorized service providers may process limited information on behalf of the Company, such as hosting providers, OTP/SMS providers, communication providers, payment processors, and security providers.

Such processing does not give those providers a commercial right to sell or independently exploit User contact information.

5.15 Legal Disclosure

Nothing in this Chapter prevents FinDeals from disclosing information where disclosure is:

• Required by applicable law;
• Required by a valid court order;
• Requested by a competent governmental or law-enforcement authority;
• Necessary to investigate or prevent serious fraud or unlawful activity; or
• Otherwise permitted by applicable law.

Where legally permitted, FinDeals will seek to limit disclosure to information reasonably necessary for the relevant purpose.

5.16 No Responsibility for Voluntary Disclosure

Once a User voluntarily publishes or directly shares contact information with another User, FinDeals cannot guarantee how that receiving User will store, copy, forward, or otherwise use the information.

Users should therefore exercise independent judgment before sharing contact information.

5.17 No Endorsement Through Contact

The fact that Users communicate with each other through FinDeals does not mean that FinDeals has:

• Verified the other User;
• Recommended the other User;
• Endorsed the other User;
• Guaranteed the other User;
• Guaranteed the accuracy of their information; or
• Guaranteed any resulting transaction.

5.18 No Contact Information Monetization

FinDeals does not monetize private User contact information.

The Company's current paid Platform service is limited to Post Highlight, which provides additional visibility to a User's listing.

Payment for Post Highlight does not provide the purchaser with access to another User's private contact information.

5.19 Protection of User Privacy

SMARTAXIS PRIVATE LIMITED will take reasonable measures appropriate to the nature of the information and applicable law to protect private User information against unauthorized access, misuse, alteration, or disclosure.

5.20 Chapter Summary

FinDeals allows Users to publish financial requirement listings and communicate with interested Users.

Users control what contact information they voluntarily publish or share. FinDeals does not sell, rent, commercially trade, or independently provide private User contact information to other Users.

The Platform's Post Highlight service is a visibility service, not a contact-information or lead-selling service.

Chapter 6 — INFORMATION SHARING & DISCLOSURE

6.1 Purpose

This Chapter explains when and why SMARTAXIS PRIVATE LIMITED may share or disclose information collected through the FinDeals Platform.

The Company's basic principle is simple:

FinDeals does not sell, rent, or commercially trade Users' personal information or private contact information.

Information may nevertheless need to be shared in limited circumstances to operate the Platform, provide requested services, maintain security, process payments, or comply with applicable law.

6.2 No Sale of Personal Information

FinDeals does not sell, rent, lease, or commercially trade User personal information to third parties.

FinDeals does not operate a business model based on selling:

• User databases;
• Phone numbers;
• Email addresses;
• Private contact details;
• Leads; or
• Personal information.

The previous Privacy Policy also establishes the principle that personal information is not sold to third parties.

6.3 No Private Contact Sharing With Other Users

FinDeals does **not independently provide a User's private contact information to another User merely because that User is interested in a listing.

There is no paid Contact Unlock, contact package, membership-based contact access, or similar service under the current FinDeals model.

If a User voluntarily publishes or directly shares their own contact information, that disclosure is made by the User and is addressed separately in Chapter 5 — User Listings & Contact Information.

6.4 Sharing With Platform Service Providers

FinDeals may share limited information with service providers that help operate the Platform.

These providers may include:

• Hosting providers;
• Cloud infrastructure providers;
• Database and storage providers;
• Security providers;
• Technical service providers;
• Software service providers; and
• Platform maintenance providers.

Such providers should receive only information reasonably necessary to perform their contracted services. The previous policy follows the same principle for technology and cloud providers.

6.5 Payment Service Providers

For Post Highlight payments, FinDeals may share or receive limited information from authorized payment service providers to:

• Process payments;
• Confirm transactions;
• Verify payment status;
• Process eligible refunds;
• Maintain transaction records; and
• Prevent payment fraud.

Payment providers may independently process payment information under their own legal and privacy obligations.

6.6 Communication Service Providers

FinDeals may use third-party communication providers for services such as:

• OTP delivery;
• SMS;
• Email;
• WhatsApp communications;
• Push notifications; and
• Transactional notifications.

Only information reasonably necessary for the relevant communication should be shared.

6.7 Security and Fraud-Prevention Providers

FinDeals may share limited information with security, fraud-prevention, cybersecurity, or technical providers where reasonably necessary to:

• Detect suspicious activity;
• Prevent fraud;
• Protect Accounts;
• Investigate security incidents;
• Prevent abuse; and
• Protect the Platform.

6.8 Customer Support Providers

Where third-party providers assist FinDeals with customer support, limited information may be shared where reasonably necessary to:

• Respond to enquiries;
• Resolve complaints;
• Investigate technical issues; or
• Provide support.

Access should be limited to authorized personnel with a legitimate business need.

6.9 Analytics and Technical Providers

FinDeals may share limited technical or usage information with analytics providers to understand:

• Platform performance;
• Usage patterns;
• Technical problems;
• Search functionality; and
• User experience.

Where reasonably practicable, analytics information may be aggregated or de-identified.

6.10 Professional Advisors

Where reasonably necessary, FinDeals may disclose relevant information to professional advisors such as:

• Advocates;
• Chartered Accountants;
• Company Secretaries;
• Auditors; and
• Other professional consultants.

Such disclosures may be subject to applicable confidentiality obligations.

6.11 Government and Law-Enforcement Authorities

FinDeals may disclose information to competent authorities where required or permitted by applicable law.

This may include:

• Courts;
• Police authorities;
• Cybercrime authorities;
• Regulatory authorities;
• Tax authorities; and
• Other government departments.

Where appropriate, disclosure will be limited to what is reasonably necessary to comply with the applicable legal requirement or lawful request.

6.12 Legal Proceedings

FinDeals may disclose information where reasonably necessary to:

• Comply with a court order;
• Respond to legal proceedings;
• Protect the Company's legal rights;
• Defend legal claims;
• Enforce the Terms & Conditions;
• Investigate fraud; or
• Prevent unlawful activity.

6.13 User-Authorized Disclosure

FinDeals may disclose information where the User has expressly authorized or consented to that disclosure, where such authorization is legally valid.

A User may voluntarily choose to share their own information with another User through Platform functionality or direct communication.

6.14 Aggregated or De-identified Information

FinDeals may use or share information that has been aggregated or de-identified so that it does not reasonably identify an individual User.

Such information may be used for:

• Statistical analysis;
• Platform improvement;
• Business reporting;
• Research; and
• Product development.

6.15 Corporate Transactions

If SMARTAXIS PRIVATE LIMITED undergoes a legitimate corporate transaction, such as:

• Merger;
• Acquisition;
• Business transfer;
• Corporate restructuring; or
• Sale or transfer of relevant assets,

personal information may be transferred as part of that transaction, subject to applicable law and appropriate confidentiality and data-protection requirements.

6.16 International Processing

Some Platform infrastructure or service providers may operate outside India.

Where personal information is processed or stored internationally, FinDeals will take reasonable steps to comply with applicable legal requirements and maintain appropriate safeguards.

The previous policy similarly contemplated international cloud and service-provider infrastructure.

6.17 What FinDeals Does Not Share

Except where permitted or required under this Privacy Policy or applicable law, FinDeals does not intentionally disclose private User information to unrelated third parties for their independent marketing purposes without appropriate authorization.

FinDeals also does not intentionally disclose sensitive authentication credentials such as passwords, PINs, or similar security credentials.

6.18 No Sale Through Third-Party Providers

The use of payment processors, hosting companies, communication providers, analytics providers, or other service providers does not mean that FinDeals sells User information to those providers.

Such providers receive information only to the extent reasonably necessary for the services they provide, subject to applicable agreements and law.

6.19 Protection During Disclosure

FinDeals seeks to use reasonable technical, organizational, and contractual safeguards when sharing personal information with authorized recipients.

However, no electronic system can guarantee absolute security.

6.20 User-to-User Voluntary Sharing

If a User voluntarily shares their own contact information or other personal information with another User through a listing, chat, or direct communication, the receiving User may obtain that information.

FinDeals cannot control how another User subsequently stores, copies, forwards, or uses information that was voluntarily disclosed to them.

6.21 Data Minimization

FinDeals seeks to limit information sharing to what is reasonably necessary for the relevant purpose.

The Company does not intend to disclose additional personal information merely because it is technically available.

6.22 Chapter Summary

FinDeals follows a limited-disclosure model.

We do not sell User data, private contact numbers, email addresses, or leads.

Information may be shared only where reasonably necessary for Platform operations, payment processing, communications, security, support, authorized disclosures, corporate operations, or compliance with applicable law.

Chapter 7 — DATA SECURITY & PROTECTION

7.1 Purpose

SMARTAXIS PRIVATE LIMITED takes reasonable measures to protect personal information processed through the FinDeals Platform against unauthorized access, misuse, loss, alteration, disclosure, or destruction.

The Company may use administrative, technical, organizational, and physical safeguards appropriate to the nature of the information and the risks involved.

7.2 Security Principles

FinDeals seeks to maintain security based on the following principles:

• Confidentiality;
• Integrity;
• Availability;
• Accountability;
• Least-privilege access;
• Security by design;
• Risk-based protection; and
• Continuous improvement.

7.3 Administrative Safeguards

Where appropriate, the Company may maintain administrative safeguards including:

• Information security policies;
• Confidentiality obligations;
• Employee or contractor security training;
• Access-management procedures;
• Incident-reporting procedures;
• Vendor security assessments;
• Internal security reviews; and
• Compliance and risk-management procedures.

7.4 Technical Safeguards

Depending on the Platform's technical requirements, FinDeals may use security controls such as:

• Secure authentication;
• Encryption where appropriate;
• Firewalls;
• Web application firewalls;
• Anti-malware protection;
• Intrusion detection or prevention systems;
• Network monitoring;
• Security logging;
• Secure configuration;
• Software patching;
• Vulnerability assessments; and
• Endpoint protection.

7.5 Encryption

Where appropriate and reasonably practicable, encryption may be used to protect:

• Data transmitted over networks;
• Stored personal information;
• Authentication credentials;
• Backup data; and
• Administrative communications.

Security technologies may be updated as security standards and technology evolve.

7.6 Access Control

Access to personal information is generally restricted to authorized personnel who have a legitimate need to access that information for their responsibilities.

Depending on the system, FinDeals may use:

• Role-Based Access Control;
• Multi-Factor Authentication where available;
• Password controls;
• Session management;
• Device authentication;
• Login monitoring;
• Account-lockout mechanisms; and
• Access logging.

7.7 Employee and Contractor Confidentiality

Employees, contractors, consultants, and other authorized persons who may access personal information are expected to:

• Maintain confidentiality;
• Access information only when necessary;
• Follow applicable security procedures;
• Protect User information; and
• Report suspected security incidents.

Unauthorized access or misuse may result in appropriate disciplinary or legal action.

7.8 Data Storage Security

Personal information may be stored using infrastructure incorporating reasonable safeguards such as:

• Secure servers;
• Controlled access;
• Encrypted storage where appropriate;
• Backup systems;
• Disaster-recovery infrastructure; and
• Redundancy mechanisms.

7.9 Backup and Disaster Recovery

FinDeals may maintain backup and recovery systems to support:

• Business continuity;
• Disaster recovery;
• System restoration;
• Data recovery; and
• Infrastructure resilience.

Backups may be retained for periods reasonably necessary for operational, legal, and security purposes.

7.10 Security Monitoring

FinDeals may monitor Platform activity using automated systems and, where appropriate, manual review to:

• Detect unauthorized access;
• Identify suspicious activity;
• Detect malware or cyberattacks;
• Investigate fraud;
• Prevent abuse; and
• Protect Platform infrastructure.

7.11 Vulnerability Management

The Company may periodically conduct or arrange:

• Security testing;
• Vulnerability assessments;
• Penetration testing;
• Configuration reviews;
• Software updates;
• Security patch deployment; and
• Risk assessments.

Security issues may be addressed according to their severity and operational priorities.

7.12 Third-Party Security

Where third-party service providers process personal information on behalf of FinDeals, the Company seeks to use providers that maintain appropriate security measures.

Where reasonably appropriate, the Company may assess such providers through contractual requirements, security assessments, or other due-diligence measures.

7.13 User Security Responsibilities

Users also have an important role in protecting their Accounts and information.

Users should:

• Keep Account credentials confidential;
• Use strong passwords where passwords are applicable;
• Avoid reusing passwords;
• Never share passwords or OTPs;
• Keep devices and software reasonably updated;
• Avoid suspicious links and phishing attempts;
• Verify communications claiming to be from FinDeals;
• Log out from shared devices; and
• Report suspected Account compromise promptly.

FinDeals will not ask Users for their passwords, UPI PINs, card PINs, or similar banking authentication credentials through email, SMS, WhatsApp, or Platform messaging.

7.14 Security Incident Response

If FinDeals becomes aware of a security incident affecting the Platform, the Company may take reasonable steps to:

• Identify the incident;
• Contain the incident;
• Investigate its cause;
• Assess potential impact;
• Restore affected services;
• Preserve relevant evidence;
• Implement corrective measures; and
• Cooperate with competent authorities where required.

7.15 Data Breach Notification

Where a personal data breach occurs and notification is required under applicable law, FinDeals may notify affected Users and/or relevant authorities in accordance with the applicable legal requirements.

Where appropriate, information regarding the incident and recommended protective measures may also be provided.

7.16 Fraud and Abuse Prevention

FinDeals may use security measures to detect and prevent:

• Fake Accounts;
• Identity theft;
• Fraudulent listings;
• Suspicious payment activity;
• Automated abuse;
• Spam; and
• Other misuse of the Platform.

7.17 Business Continuity

The Company may maintain reasonable measures designed to reduce interruptions resulting from:

• Infrastructure failures;
• Hardware failures;
• Cybersecurity incidents;
• Natural disasters;
• Power interruptions; and
• Network failures.

7.18 No Absolute Security Guarantee

Although FinDeals seeks to maintain reasonable security safeguards, no internet-connected system, electronic transmission, storage system, or security measure can be guaranteed to be completely secure.

Accordingly, the Company cannot guarantee that:

• A security incident will never occur;
• Unauthorized access will never happen;
• Data will never be lost;
• The Platform will always be uninterrupted; or
• Every security threat can be prevented.

7.19 Protection of Private Contact Information

FinDeals' security measures also apply to private contact information held by the Company.

Private contact information is not maintained for the purpose of selling it, providing contact databases, or operating a paid contact-access service.

7.20 Security Improvements

Security measures may be modified, strengthened, or replaced as technology, Platform architecture, security threats, and applicable legal requirements evolve.

The Company may introduce additional safeguards where reasonably necessary.

7.21 Chapter Summary

FinDeals uses reasonable administrative, technical, and organizational safeguards to protect User information.

Security is treated as an ongoing process, not as a guarantee of absolute protection.

Users must also protect their Account credentials and promptly report suspicious activity.

Chapter 8 — DATA RETENTION & DELETION

8.1 Purpose

This Chapter explains how SMARTAXIS PRIVATE LIMITED retains, archives, deletes, or otherwise manages information collected through the FinDeals Platform.

FinDeals seeks to retain personal information only for as long as reasonably necessary for the purpose for which it was collected, subject to legal, security, operational, and legitimate business requirements. The uploaded Privacy Policy follows the same retention principle.

8.2 Retention Principle

FinDeals does not intend to retain personal information indefinitely without a legitimate reason.

Information may be retained for periods reasonably necessary to:

• Provide and maintain the Platform;
• Maintain User Accounts;
• Provide requested services;
• Maintain security;
• Prevent fraud and abuse;
• Resolve complaints and disputes;
• Process payments;
• Maintain accounting and tax records;
• Comply with applicable law; or
• Protect the Company's legal rights.

8.3 Account Information

Account-related information may be retained while an Account remains active.

After Account closure or deletion, certain information may continue to be retained where reasonably necessary for legal, security, fraud-prevention, accounting, dispute-resolution, or other legitimate purposes.

8.4 User Listings

Financial requirement listings may be retained while they are active or for a reasonable period after removal where necessary for:

• Platform operation;
• Fraud prevention;
• Security;
• Complaint investigation;
• Dispute resolution;
• Legal compliance; or
• Maintaining appropriate Platform records.

8.5 Chat and Communication Records

Chat or communication records may be retained for a reasonable period where necessary for:

• Providing the communication service;
• Investigating reported abuse;
• Fraud prevention;
• Security investigations;
• Resolving disputes;
• Customer support; or
• Legal compliance.

Retention will not mean that FinDeals uses private communications as a commercial contact database.

8.6 Post Highlight Records

Information relating to Post Highlight purchases may be retained as reasonably necessary for:

• Payment verification;
• Transaction records;
• Invoicing;
• Refund processing;
• Accounting;
• Tax compliance;
• Fraud prevention;
• Customer support; and
• Dispute resolution.

8.7 Payment and Financial Records

Certain payment-related records may need to be retained after an Account is closed.

These may include:

• Transaction references;
• Payment confirmations;
• Invoices;
• Receipts;
• Refund records;
• Chargeback information; and
• Tax or accounting records.

Such records may be retained for the period reasonably required by applicable law and legitimate accounting, tax, audit, fraud-prevention, or dispute-resolution requirements.

8.8 Security and Fraud Records

FinDeals may retain information relating to:

• Security incidents;
• Fraud investigations;
• Suspicious activity;
• Fake Accounts;
• Abuse reports;
• Unauthorized access;
• Platform violations; and
• Related investigations.

Such information may be retained for as long as reasonably necessary to protect Users and the Platform, investigate incidents, enforce Platform rules, or comply with legal obligations.

8.9 Legal and Regulatory Retention

Certain information may be retained when continued retention is required or permitted by applicable law.

This may include records required for:

• Legal proceedings;
• Government investigations;
• Regulatory enquiries;
• Court orders;
• Tax compliance;
• Audits; or
• Other statutory obligations.

8.10 Account Deletion Requests

Users may request deletion of their Account through available Platform functionality or by contacting FinDeals through its official support or privacy channels.

The Company may reasonably verify the identity of the requesting User before processing a deletion request to prevent unauthorized deletion.

The uploaded Privacy Policy similarly provides for Account deletion requests and reasonable identity verification.

8.11 What Happens After a Deletion Request

Where a valid deletion request is accepted, FinDeals will take reasonable steps to delete, anonymize, or otherwise remove personal information that is no longer required.

However, deletion may not result in immediate removal of every copy of information from all systems.

8.12 Information That May Remain After Deletion

Certain information may continue to be retained after Account deletion where reasonably necessary, including:

• Transaction records;
• Payment records;
• Tax records;
• Audit logs;
• Fraud-prevention records;
• Security investigation records;
• Legal correspondence;
• Court-related records; and
• Regulatory compliance records.

Such retention will be limited to the relevant purpose and applicable requirements.

8.13 Backup Copies

Information may continue to exist temporarily in secure backup systems after it has been deleted from active systems.

Backups may be maintained for:

• Disaster recovery;
• System restoration;
• Business continuity; and
• Security resilience.

Backup copies will remain subject to appropriate security protections.

8.14 Secure Deletion

When information is no longer required, FinDeals seeks to:

• Securely delete it;
• Anonymize it; or
• Otherwise render it inaccessible,

using methods appropriate to the nature of the information and the Company's available technology.

Deletion procedures may vary depending on system architecture, storage systems, backup processes, operational requirements, and legal obligations.

8.15 Anonymization

Where appropriate, FinDeals may anonymize information so that it can no longer reasonably identify an individual.

Effectively anonymized information may subsequently be used for purposes such as:

• Statistical analysis;
• Platform improvement;
• Research;
• Business reporting; and
• Service development.

8.16 Legal Hold

Where information is relevant to:

• Legal proceedings;
• Government investigations;
• Regulatory enquiries;
• Arbitration;
• Fraud investigations; or
• Court orders,

FinDeals may suspend routine deletion until the relevant matter has been resolved or the applicable legal obligation has been satisfied.

8.17 Platform Closure

If FinDeals is permanently discontinued, personal information will be handled in accordance with applicable law.

Depending on the circumstances, the Company may:

• Securely delete information that is no longer required;
• Retain information where legally necessary;
• Transfer information as part of a lawful corporate transaction; or
• Provide notices where required by applicable law.

8.18 User Responsibility

Users should understand that deletion of an Account does not automatically delete information that the User has voluntarily shared with another User.

For example, if a User voluntarily provides a phone number through chat or publishes it in a listing, another User may already have copied or retained that information.

FinDeals cannot remotely delete information that another User has independently retained.

8.19 Retention Review

FinDeals may periodically review its retention practices to identify information that is no longer reasonably required and determine whether it should be deleted or anonymized.

8.20 No Indefinite Retention Commitment

FinDeals does not promise that every category of information will be deleted after a fixed number of days or months.

Retention periods may vary depending on:

• The type of information;
• The purpose for which it was collected;
• Account status;
• Security requirements;
• Payment or accounting requirements;
• Legal obligations;
• Disputes or investigations; and
• Technical limitations of backup and archival systems.

8.21 Chapter Summary

FinDeals follows a purpose-based retention approach.

Information is retained only for as long as reasonably necessary for Platform operation, security, fraud prevention, payments, support, legal compliance, dispute resolution, or other legitimate purposes.

When information is no longer required, FinDeals seeks to delete, anonymize, or otherwise securely dispose of it, subject to applicable legal and operational requirements.

Chapter 9 — USER PRIVACY RIGHTS & CHOICES

9.1 Purpose

This Chapter explains the privacy rights and choices that may be available to Users regarding personal information processed by SMARTAXIS PRIVATE LIMITED through the FinDeals Platform.

These rights are subject to applicable law and may vary depending on the User's circumstances and the nature of the information concerned.

9.2 Right to Access Information

Where provided by applicable law, a User may request information about personal information held or processed by FinDeals.

A request may include information concerning:

• Categories of personal information processed;
• Purposes for which information is used;
• Categories of recipients;
• Retention practices; and
• Available privacy rights.

The existing Privacy Policy expressly provides for requests concerning these categories.

9.3 Right to Request a Copy

Where applicable law provides such a right, a User may request a copy of certain personal information maintained by FinDeals.

FinDeals may reasonably:

• Verify the User's identity;
• Exclude information protected by law;
• Protect the rights and privacy of other individuals; and
• Provide the information in a commonly used electronic format where reasonably practicable.

9.4 Right to Correct Information

Users may request correction or updating of inaccurate or incomplete personal information.

Users are also encouraged to keep their Account information reasonably accurate and current.

9.5 Right to Update Account Information

Where Platform functionality permits, Users may update certain Account information directly through their Account.

For information that cannot be changed through the Platform, Users may contact FinDeals through the designated support or privacy channel.

9.6 Right to Request Deletion

Subject to applicable law, Users may request deletion of certain personal information or closure of their Account.

Deletion may not apply to information that FinDeals is required or permitted to retain for:

• Legal compliance;
• Tax or accounting requirements;
• Fraud prevention;
• Security;
• Dispute resolution;
• Legal proceedings; or
• Protection of legal rights.

The retention and deletion rules are explained in Chapter 8 — Data Retention & Deletion.

9.7 Right to Withdraw Consent

Where processing is based on User consent and applicable law provides a right to withdraw that consent, the User may request withdrawal.

Withdrawal of consent does not necessarily affect processing that:

• Was already lawfully completed;
• Is required by law;
• Is necessary to perform a contract;
• Is necessary for security or fraud prevention; or
• Has another lawful basis.

9.8 Right to Request Information About Processing

Where recognized by applicable law, Users may request information regarding:

• Categories of personal information processed;
• Purposes of processing;
• Categories of recipients;
• Retention practices;
• Available privacy rights; and
• Contact details for privacy enquiries.

9.9 Right to Object to Certain Processing

Where applicable law provides such a right, a User may object to certain processing activities.

FinDeals may continue processing where reasonably necessary for:

• Legal obligations;
• Contractual performance;
• Fraud prevention;
• Security;
• Protection of legal rights; or
• Other lawful purposes.

9.10 Right to Restrict Processing

Where recognized by applicable law, Users may request restriction of certain processing while FinDeals reviews matters such as:

• Accuracy disputes;
• Identity verification;
• Legal objections;
• Privacy complaints; or
• Other eligible circumstances.

Restriction may not apply where continued processing is legally required or necessary to protect the Company's or another person's legal rights.

9.11 Right to Lodge a Privacy Complaint

Users who believe their privacy rights have been affected may submit a complaint through the Company's designated privacy or grievance channel.

Complaints may concern:

• Improper disclosure;
• Unauthorized access;
• Incorrect personal information;
• Account-related privacy concerns;
• Security incidents; or
• Other privacy-related matters.

9.12 Privacy and Communication Choices

Users may have choices regarding certain optional communications from FinDeals, subject to applicable law and Platform functionality.

Users may be able to manage or opt out of certain promotional communications.

However, essential communications relating to:

• Account security;
• Transactions;
• Payments;
• Important Platform changes;
• Legal notices; or
• Other necessary service matters

may continue where reasonably necessary.

9.13 Identity Verification

To protect Users from unauthorized access to their information, FinDeals may require reasonable identity verification before processing requests relating to:

• Account access;
• Information correction;
• Account deletion;
• Data access;
• Consent withdrawal; or
• Privacy complaints.

9.14 Authorized Representatives

Where permitted by applicable law, an authorized representative may submit a privacy request on behalf of a User.

FinDeals may request:

• Written authorization;
• Proof of authority;
• Identity verification; and
• Additional information reasonably necessary to process the request.

9.15 Response to Privacy Requests

FinDeals aims to respond to eligible privacy requests within the timeframe required by applicable law.

Where a request is complex, requires additional verification, or involves multiple issues, additional time may be permitted by applicable law.

9.16 Circumstances Where a Request May Be Limited or Declined

FinDeals may limit or decline a request where permitted by applicable law, including where:

• The request is fraudulent;
• The User's identity cannot reasonably be verified;
• Disclosure would violate applicable law;
• Disclosure would affect another person's rights;
• Information is protected by legal privilege;
• The request is excessive or repetitive;
• The Company is legally required to retain the information; or
• Processing remains necessary for fraud prevention or security.

Where appropriate, FinDeals may explain the reason for limiting or declining a request.

9.17 Ordinary Privacy Requests

FinDeals generally does not intend to charge Users for reasonable ordinary privacy requests.

Where permitted by applicable law, the Company may charge a reasonable administrative fee or take other appropriate action in relation to manifestly unfounded, excessive, repetitive, or technically unreasonable requests.

9.18 How to Submit a Privacy Request

Users may submit privacy-related requests through the official FinDeals privacy, support, or grievance contact channel published on the Platform.

A request should contain enough information for FinDeals to understand the request and identify the relevant Account.

9.19 No Effect on Other Legal Rights

The rights described in this Chapter do not limit any additional rights a User may have under applicable law.

If applicable law provides a broader or different privacy right, that legal requirement will apply to the extent required.

9.20 Chapter Summary

FinDeals aims to provide Users with meaningful control over their personal information.

Depending on applicable law, Users may have rights to access, correct, update, delete, obtain information about processing, withdraw consent, object to certain processing, restrict processing, and submit privacy complaints.

FinDeals may reasonably verify identity and may limit certain requests where legally permitted or necessary to protect security, legal obligations, or the rights of others.

Chapter 10 — COOKIES, TRACKING & ANALYTICS

10.1 Purpose

This Chapter explains how SMARTAXIS PRIVATE LIMITED may use cookies and similar technologies when Users access or use the FinDeals Platform.

These technologies may support Platform functionality, authentication, security, performance, analytics, and User preferences. The previous Privacy Policy identifies cookies, session cookies, persistent cookies, pixel tags, local storage, device identifiers, and similar technologies for these purposes.

10.2 What Are Cookies?

Cookies are small data files stored on a User's browser or device when visiting a website.

They may allow the Platform to recognize a browser or maintain information between different visits or pages.

10.3 Types of Cookies

Depending on the Platform's implementation, FinDeals may use:

• Essential Cookies — necessary for core Platform functionality and security;
• Session Cookies — generally used during a particular browsing session;
• Persistent Cookies — may remain on a device for a defined period;
• Preference Cookies — may remember selected settings or preferences;
• Analytics Cookies — may help understand Platform usage and performance; and
• Security Cookies — may assist with authentication, fraud prevention, and security.

10.4 Essential Cookies

Essential cookies may be required to:

• Maintain User sessions;
• Support login and authentication;
• Protect Account security;
• Maintain Platform functionality;
• Prevent fraudulent activity; and
• Support basic website operations.

Because these cookies may be necessary for the Platform to function, disabling them may affect access to certain features.

10.5 Session Cookies

Session cookies may be used temporarily while a User is browsing FinDeals.

They may help the Platform:

• Maintain a User session;
• Keep navigation working correctly;
• Preserve temporary settings; and
• Support authentication and security.

10.6 Persistent Cookies

Persistent cookies may remain on a User's device for a defined period after a browsing session ends.

They may be used to:

• Remember preferences;
• Improve User experience;
• Support authentication where appropriate;
• Understand returning visits; and
• Maintain selected settings.

10.7 Analytics

FinDeals may use analytics technologies to understand general Platform usage and performance.

Analytics information may include:

• Pages viewed;
• Features used;
• Search activity;
• Click activity;
• Navigation patterns;
• Session duration;
• Listing views;
• Device information;
• Technical performance; and
• Error or crash information.

The previous Privacy Policy identifies similar usage and performance information as part of Platform analytics.

10.8 Purpose of Analytics

Analytics may help FinDeals:

• Identify technical problems;
• Improve Platform performance;
• Understand how Users interact with features;
• Improve navigation;
• Improve search and listing presentation;
• Measure general Platform performance; and
• Develop and improve Platform functionality.

Analytics should not be used as a mechanism for selling User contact information.

10.9 Security and Fraud Prevention

Cookies and similar technologies may also be used to:

• Detect suspicious activity;
• Prevent fraudulent access;
• Protect User Accounts;
• Detect automated abuse;
• Maintain secure sessions; and
• Investigate security incidents.

The existing policy specifically identifies fraud detection and security enhancement as cookie-related purposes.

10.10 Device and Similar Technologies

In addition to conventional cookies, FinDeals may use technologies such as:

• Pixels;
• SDKs;
• Local Storage;
• Session Storage;
• Authentication Tokens;
• API-based tracking; and
• Device-recognition technologies.

These technologies may support Platform functionality, security, and analytics.

10.11 Log and Technical Information

FinDeals may automatically collect technical information associated with Platform access, including:

• IP address;
• Access time;
• Login activity;
• Error logs;
• Security events;
• Referral URLs; and
• Technical performance information.

Such information may be used for troubleshooting, performance monitoring, security, and compliance.

10.12 Consent for Non-Essential Technologies

Where applicable law requires User consent before placing or accessing non-essential cookies or similar technologies, FinDeals will seek such consent through an appropriate mechanism.

This may include:

• A cookie banner;
• Cookie preference controls;
• Accept/reject options; or
• Other consent mechanisms.

Essential cookies may continue where they are necessary for Platform functionality or security.

10.13 Managing Cookie Preferences

Where available, Users may manage cookie preferences through:

• FinDeals cookie settings;
• Browser settings;
• Mobile device settings;
• Operating-system controls; or
• Applicable third-party preference tools.

Disabling certain cookies may affect Platform functionality or limit some features.

10.14 Browser Controls

Most modern browsers allow Users to:

• View stored cookies;
• Delete cookies;
• Block cookies;
• Restrict certain third-party cookies;
• Receive cookie notifications; and
• Clear browsing data.

Available controls vary between browsers and devices.

10.15 Do Not Track

Some browsers provide a "Do Not Track" (DNT) setting.

Because there is not necessarily a universally accepted technical standard for interpreting DNT signals, FinDeals may not respond uniformly to every DNT signal unless required by applicable law.

10.16 Third-Party Technologies

Certain Platform services may involve third-party technologies, such as analytics, payment, communication, hosting, or security providers.

Where such providers use cookies or similar technologies, their processing may also be governed by their own privacy policies and applicable legal requirements.

10.17 Third-Party Websites

FinDeals may contain links to third-party websites or services.

Those websites may use their own cookies and tracking technologies.

Their practices are governed by their respective privacy policies, and FinDeals is not responsible for tracking technologies operated independently by third-party websites.

10.18 No Contact-Tracking for Sale

FinDeals does not use cookies, analytics, pixels, or similar technologies for the purpose of creating or selling private User contact databases.

Analytics and tracking are intended for legitimate Platform purposes such as functionality, security, performance, and improvement.

10.19 Changes to Cookie Technologies

FinDeals may introduce, modify, or discontinue cookies and similar technologies as:

• Platform features evolve;
• Security requirements change;
• Technology develops;
• Industry practices change; or
• Applicable laws are updated.

Material changes will be reflected in this Privacy Policy or, where appropriate, a separate Cookie Policy.

10.20 Separate Cookie Policy

FinDeals may publish a separate Cookie Policy in the future providing additional details regarding:

• Specific cookies;
• Cookie categories;
• Retention periods;
• Third-party providers;
• Preference management; and
• Consent mechanisms.

If a separate Cookie Policy is published, it should be read together with this Privacy Policy.

10.21 Effect of Disabling Cookies

Disabling cookies or similar technologies may:

• Affect Platform functionality;
• Prevent automatic login;
• Reset preferences;
• Reduce personalization;
• Affect security features; or
• Limit certain Platform services.

Users remain responsible for configuring their own browser and device privacy settings.

10.22 Chapter Summary

FinDeals may use cookies and similar technologies to operate, secure, analyze, and improve the Platform.

Essential technologies may be required for basic functionality, while non-essential technologies will be handled according to applicable consent requirements.

FinDeals does not use cookies, tracking, or analytics as a means of selling User contact information or personal-data databases.

Chapter 11 — CHILDREN'S PRIVACY & AGE RESTRICTIONS

11.1 Purpose

This Chapter explains FinDeals' approach to children, minors, age eligibility, and the handling of personal information relating to individuals who are not legally eligible to use the Platform.

SMARTAXIS PRIVATE LIMITED recognizes the importance of protecting children's privacy and will handle children's personal information in accordance with applicable law.

11.2 Platform Intended for Adults

FinDeals is a financial classifieds platform intended for individuals who are legally capable of using the Platform and entering into applicable agreements.

The Platform is not designed or marketed for children.

11.3 Minimum Age Requirement

A User must satisfy the minimum legal age and legal-capacity requirements applicable to the use of FinDeals.

By creating an Account, a User represents that:

• They meet the applicable minimum age requirement;
• They have the legal capacity required to use the Platform;
• The age-related information they provide is accurate; and
• They will not knowingly misrepresent their age.

The previous Privacy Policy similarly requires Users to satisfy the applicable minimum legal age and legal capacity requirements.

11.4 No Intentional Collection of Children's Information

FinDeals does not knowingly or intentionally collect, solicit, or process personal information from children who are not legally eligible to use the Platform, except where such processing is expressly permitted or required by applicable law.

11.5 Discovery of an Ineligible Child Account

If FinDeals becomes aware that an Account belongs to a child who is not legally eligible to use the Platform, the Company may take appropriate action, including:

• Restricting the Account;
• Suspending Platform access;
• Requesting reasonable age verification;
• Removing associated listings;
• Closing the Account; and
• Deleting eligible personal information where required by applicable law.

11.6 Age Verification

Where reasonably necessary and permitted by applicable law, FinDeals may request information to verify a User's age.

Age verification may be requested where:

• There is uncertainty regarding eligibility;
• Misuse is suspected;
• Fraud is being investigated;
• A particular feature requires age verification; or
• Applicable law requires verification.

Failure to provide reasonable verification may result in restriction of Platform access.

11.7 Parents and Legal Guardians

If a parent or legal guardian believes that a child has provided personal information to FinDeals without appropriate authorization or contrary to applicable law, they may contact FinDeals through the official contact details provided in this Privacy Policy.

After receiving a reasonably verifiable request, FinDeals may:

• Investigate the matter;
• Verify the identity and authority of the requester;
• Restrict or remove the relevant Account;
• Delete eligible personal information; and
• Provide an appropriate response in accordance with applicable law.

11.8 Removal of Children's Information

If FinDeals determines that it has unintentionally collected personal information from a child in circumstances where such collection is not permitted, the Company will take reasonable steps, as appropriate, to:

• Delete the information from active systems;
• Restrict further processing;
• Prevent continued collection through the same mechanism; and
• Review relevant internal procedures.

Certain information may still need to be retained where required or permitted by law, including for fraud prevention, regulatory compliance, security, or legal proceedings.

11.9 No Financial Requirement Listings by Children

FinDeals is not intended to facilitate financial requirement listings, financial arrangements, or User-to-User financial discussions involving children who are not legally eligible to use the Platform.

11.10 User Responsibility

Users must not:

• Create an Account on behalf of an ineligible child;
• Misrepresent a child's age;
• Use a child's personal information to create an Account without lawful authorization; or
• Allow an ineligible child to use an Account in violation of applicable requirements.

11.11 No Guaranteed Age Verification

FinDeals may use reasonable measures to determine whether Users satisfy applicable age requirements, but no electronic verification method can guarantee that every User accurately represents their age.

Users remain responsible for providing truthful information.

11.12 Chapter Summary

FinDeals is not intended for children and requires Users to meet the applicable minimum age and legal-capacity requirements.

FinDeals does not knowingly collect personal information from children who are not legally eligible to use the Platform. If the Company becomes aware of such information being collected contrary to applicable law, it may restrict the Account and take appropriate steps to delete or otherwise handle the information as legally required.

Chapter 12 — CHANGES, CONTACT, GRIEVANCE & LEGAL COMPLIANCE

12.1 Purpose

This Chapter explains how SMARTAXIS PRIVATE LIMITED may update this Privacy Policy, how Users may contact the Company regarding privacy matters, how privacy grievances may be submitted, and how applicable legal requirements are addressed.

12.2 Changes to This Privacy Policy

SMARTAXIS PRIVATE LIMITED may revise, amend, modify, replace, or update this Privacy Policy when reasonably necessary to reflect changes in:

• Applicable laws;
• Regulatory requirements;
• Court decisions;
• FinDeals Platform features;
• Technology;
• Security practices;
• Data-processing practices; or
• Business operations.

The Company will seek to keep the Policy reasonably consistent with its actual privacy practices.

12.3 Effective Date

This Privacy Policy becomes effective from the Effective Date stated at the beginning of the published Policy.

Unless otherwise stated, an updated version becomes effective when published on the official FinDeals Platform, subject to any additional notice or consent required by applicable law.

12.4 Version Control

FinDeals may maintain:

• Privacy Policy version number;
• Effective date;
• Last updated date; and
• A summary of material changes.

Previous versions may be retained for appropriate legal, compliance, and record-keeping purposes.

12.5 Notice of Material Changes

Where required by applicable law, or where the Company considers a change material, FinDeals may notify Users through appropriate Platform communication channels.

Depending on the circumstances, notification may include:

• Email;
• SMS;
• WhatsApp;
• In-App notification;
• Platform announcement; or
• Website notice.

12.6 User Responsibility

Users are encouraged to periodically review the latest version of this Privacy Policy.

Continued use of FinDeals following the effective date of an updated Policy may constitute acknowledgement of the updated Policy to the extent permitted by applicable law.

Where applicable law requires fresh consent for a particular processing activity, FinDeals will obtain such consent where required.

12.7 Contact Information

Users may contact SMARTAXIS PRIVATE LIMITED regarding privacy-related matters through the official contact details published on the FinDeals Platform.

Official contact channels may include:

• Registered office address;
• Customer support email;
• Privacy-related email address;
• Customer support telephone number; or
• Official website contact form.

The Company may update its contact details from time to time.

12.8 Privacy Requests

Users may contact FinDeals regarding matters including:

• Access to personal information;
• Correction of information;
• Deletion requests;
• Consent withdrawal where applicable;
• Privacy complaints;
• Security concerns; and
• Questions regarding processing of personal information.

FinDeals may reasonably verify the identity of the requester before processing such requests.

12.9 Grievance Officer

SMARTAXIS PRIVATE LIMITED shall designate a Grievance Officer or other authorized officer as required by applicable law.

The published details may include:

• Name;
• Designation;
• Email address;
• Postal address; and
• Other relevant contact information.

The designated officer will handle privacy-related grievances and complaints in accordance with applicable law.

Important before publication: The actual Grievance Officer details must be inserted here. Do not publish placeholders or invented details.

12.10 Privacy Complaint Process

Upon receiving a privacy complaint, FinDeals may:

• Acknowledge receipt;
• Verify the complainant's identity where appropriate;
• Review the complaint;
• Investigate the relevant circumstances;
• Request additional information where necessary;
• Respond within the timeframe required by applicable law; and
• Implement appropriate corrective measures where necessary.

12.11 Escalation

If a User is dissatisfied with the Company's response, the User may pursue remedies available under applicable law, including approaching an appropriate regulatory authority, tribunal, or court having jurisdiction.

Nothing in this Privacy Policy limits statutory rights available to Users.

12.12 Compliance With Applicable Law

SMARTAXIS PRIVATE LIMITED seeks to comply with applicable laws governing the processing and protection of personal information.

Depending on their applicability to the Platform and its operations, these may include:

• Digital Personal Data Protection Act, 2023;
• Information Technology Act, 2000;
• Rules and regulations issued under applicable legislation;
• Applicable cybersecurity requirements;
• Electronic-record requirements; and
• Other applicable Indian laws concerning privacy and consumer protection.

Where applicable laws or regulatory requirements change, FinDeals may update this Privacy Policy accordingly.

12.13 Governing Law

This Privacy Policy shall be governed by and interpreted in accordance with the laws of India, subject to applicable law.

Privacy-related disputes shall be handled in accordance with the dispute-resolution provisions contained in the FinDeals Terms & Conditions, unless applicable law requires otherwise.

12.14 Severability

If any provision of this Privacy Policy is determined by a competent court or authority to be invalid, unlawful, or unenforceable, the remaining provisions shall continue to apply to the fullest extent permitted by law.

12.15 No Waiver

Failure or delay by SMARTAXIS PRIVATE LIMITED to enforce any provision of this Privacy Policy shall not constitute a waiver of that provision or of any rights available to the Company under applicable law.

12.16 Entire Privacy Policy

This Privacy Policy represents the Company's current privacy practices relating to the FinDeals Platform and supersedes previous versions of the FinDeals Privacy Policy.

It does not replace the FinDeals Terms & Conditions, which separately govern the contractual relationship between SMARTAXIS PRIVATE LIMITED and Users.

12.17 Survival

Certain provisions relating to privacy and information handling may continue to apply after an Account is closed where their nature requires continued application.

This may include provisions concerning:

• Data retention;
• Security;
• Fraud prevention;
• Legal compliance;
• Dispute resolution;
• Regulatory obligations; and
• Protection of legal rights.

12.18 Electronic Records

This Privacy Policy is published electronically.

The electronic version published by SMARTAXIS PRIVATE LIMITED shall constitute the official version, subject to applicable law.

12.19 Final Privacy Commitment

SMARTAXIS PRIVATE LIMITED is committed to handling personal information responsibly, lawfully, fairly, and transparently.

FinDeals does not sell or commercially trade User personal information or private contact details, and the Company will continue to review its privacy and security practices as the Platform develops.

Users are encouraged to contact FinDeals whenever they have questions, concerns, or complaints relating to the processing of their personal information.

12.20 Chapter Summary

This Chapter establishes the framework for Privacy Policy updates, User contact, privacy requests, grievance handling, legal compliance, governing law, and the official electronic version of the Policy.