Cholamandalam Investment and Finance Company Limited (hereinafter referred to as “CIFCL”) is concerned about the privacy of data and information of the Users (as defined below) accessing, selling, offering or purchasing products or services on the website www.gaadibazaar.in (“Website”), or mobile application GaadiBazaar (“App”) or otherwise doing business with CIFCL. The Website and App are, together, referred to as “Platform”.

The Platform is made available by CIFCL (also referred to as “our”, “us”, “we”, “Company”), having its registered office at Chola Crest, C54-55 & Super B-4, Thiru-Vi-Ka Industrial Estate, Guindy, Chennai – 600032, Tamil Nadu, through which CIFCL, which is a non-banking financial company registered with the Reserve Bank of India (“RBI”). CIFCL will, through the Platform, provide (a) an e-commerce marketplace permitting sale and purchase of vehicles; and (b) provide lending services to customers of CIFCL (together, “Services”).

In order to facilitate and provide you (and co-applicants, members, nominees, if any) with the Services through the Platform, CIFCL (and, where applicable, its affiliates) need to collect various data and information from you with your prior and explicit consent. The manner in which, and the purpose for which, this data and information is collected, retained, shared, stored, and processed by us is addressed in this Privacy Policy (“Privacy Policy” or “Policy”). By setting up an account on this Platform, you agree to the processing, storage, usage and sharing of the data provided by you pursuant to this Privacy Policy.

We will revise this Policy as well as update the Services and the App from time to time, so please keep visiting this page regularly to take notice of any changes we make. If you do not agree with any part of this Policy, please do not use our Services or, if applicable, stop using our Services immediately. Please also read our User Agreement (“Agreement”), which describe the terms under which we provide our Services and each of our affiliates provide their Services.

This Privacy Policy is an electronic contract formed under the Information Technology Act, 2000 and Rules made thereunder and the relevant amendments made thereon. This Privacy Policy does not require any physical, digital, or electronic signature, provided that if a User avails a loan from CIFCL through the Platform, then such User will be provided with a digitally signed copy of this Privacy Policy for his/her/its records.

This Privacy Policy is published in accordance with requirements under applicable laws, including, without limitation. the provisions of

a) Rule 3 of the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021, which requires intermediaries to publish the rules and regulations, privacy policy and user agreement for access or usage of its computer resource by any person; and

b)  The regulations, master directions, master circulars, circulars, and guidelines issued by the Reserve Bank of India (“RBI”), including without limitation, the Guidelines on Digital Lending dated 02 September 2022

in each case, as amended and in force from time to time.

This Privacy Policy of the Platform, available at https://apps.gaadibazaar.in/privacy-policy, is applicable to the guest users or registered users of the Platform (each, hereinafter referred to as the "User").

The User is advised to read this Privacy Policy to learn more about the ways in which CIFCL shall use and protect the personal information of the User. By visiting this Platform, the User agrees to be bound by the terms and conditions of this Privacy Policy. If the User disagrees with the terms and conditions of the Privacy Policy, the User shall not use or access this Platform.

By accepting this Privacy Policy, the User expressly consents to (i) be bound by the terms and conditions of this Privacy Policy; and (ii) CIFCL's use and disclosure of the User's Personal Information (as defined below) and Sensitive Personal Information (as defined below) in accordance with this Privacy Policy. This Privacy Policy shall be read along with the terms of User Agreement - www.gaadibazaar.in/user-agreement (“Agreement”) available on the Website and on the App.

CIFCL may develop new or offer additional services. If the introduction of these new or additional services results in any material change to the way CIFCL collects or processes the User Personal Information and Sensitive Personal information, CIFCL will provide the User with more information or additional terms and policies, as may be required from time to time. User is requested to review this page periodically, to remain aware of any changes.

To the extent any Services by CIFCL are provided in partnership with third parties, your data or information may be shared with such third parties. This Privacy Policy contains details of all such third parties to whom data may need to be shared from time to time, and by using any of the Services, you hereby expressly consent to such sharing. Please also read this Privacy Policy for further details.

SECTION A

If you are a visitor to this Website or App, a Registered User, a bidder or a seller on the Platform, Section A applies to you solely with respect to your activities in the e-commerce marketpalce, irrespective of whether or not you have availed of any loan products from Cholamandalam Investment and Finance Company Limited or its Affiliates.

1. Nature of Information collected on the Platform

I. Information provided by the User:

a) All information provided to CIFCL when the User registers, subscribes to services or purchase goods or services on the Platform, including name, address, telephone number, email address, gender, and any other information, either directly or indirectly, in combination with other information available or likely to be available with CIFCL, which is capable of identifying such User (collectively referred to as “Personal Information”).

b) All information that the User chooses to share on the Platform such as photos, videos, comments, events, tags or other user generated content that the User may upload on the Platform.

c) “Sensitive Personal Information”, i.e., passwords and all financial information provided at the time of purchase of goods and services on the Platform, such as credit card, debit card or other payment instrument information etc.

The User can browse the Platform without providing their information, including Personal or Sensitive Personal Information. When the User provides his/her Personal Information, he/she is not an anonymous User of the Website.

II. Information collected by CIFCL:

III.   For fully using the Platform and availing the product/Services provided therein, the User needs to register with the Platform by providing his/her contact, identity information and other personal information as indicated on the Website. If the User is not willing to provide his/her personal information, he/she must opt out from registering with the Platform.

III. Cookies

CIFCL shall use data collection devices such as "cookies" on certain pages of the Platform to analyze such web page flow, measure effectiveness of promotional activities and promote safety and trust. "Cookies" are small files placed on the hard drive, which will assist CIFCL in providing better services. CIFCL offers certain features that are only available through the use of "cookies". CIFCL also uses cookies to allow the User to enter his/her password less frequently during a session. Further, cookies also help CIFCL in providing information that is targeted to the interests of the User. Most of the cookies are "session cookies", which will be deleted automatically from the hard drive at the end of a session. The User is always free to decline the cookies, if his/her browser permits, although in that case the User may not be able to use certain features of the Platform and the User may be required to re-enter his/her password more frequently during a session.

CIFCL shall retain information as necessary to resolve disputes, troubleshoot problems and provide customer support to the extent permitted by law. If a User sends personal correspondence to CIFCL, such as emails or letters, or if other users or third parties send correspondence to CIFCL about the activities of User or postings on the Site, CIFCL may collect and store such information into a file specific to the said User.

2. Purpose of Collection and Use of User Information:

CIFCL uses the Personal Information and Sensitive Personal Information of the User in the following ways and for the following purposes:

a)  To improve the services/products offered on the Platform.

b)  The Personal Information and other information of the User, which CIFCL obtains from the User's current and past activities on the Platform, shall be used by CIFCL to measure User's interest in the services/products provided on the Platform.

c)  To inform the User about online and offline offers, products, services, and updates.

d)  To customize User experience; help promote safe trading; detect and protect CIFCL against error, fraud, and other criminal activity; resolve disputes; troubleshoot problems and collect fees owed.

e)  To enforce our User Agreement.

f)  To analyze the information shared by various Users to identify the Users using multiple User IDs. CIFCL may compare and review User's Personal Information for errors, omissions and for accuracy.

g)  To bill the User and provide required support if the User chooses to list a vehicle/equipment for sale on the Platform.

h)  To analyze usage of the Platform.

i)  To improve CIFCL's marketing and promotional efforts.

j)  To improve the Platform's content and product/service offerings and customize the Platform's content, layout and services.

k)  To contact the User and deliver information such as targeted banner advertisements, administrative notices, product offerings and communications relevant to his/her use of the Platform. The User agrees to receive the said information on acceptance of the User Agreement and Privacy Policy. The User may opt out of the receipt of the said communications in his/her profile. The User may make changes to his/her profile at any time.

l)  For internal operations such as troubleshooting, data analysis, research, testing and quality improvement of our service;

m)  To respond to judicial process and provide information to law enforcement agencies or in connection with an investigation on matters related to public safety, as permitted by law;

n)  For any other purpose a described to the User at the time of collection of information. By visiting, accessing and/or using the Platform and/ or submitting Personal Information or Sensitive Personal Information, the User consents to such use of his/her Personal Information and Sensitive Personal Information by CIFCL.

By using the Platform and providing the required information, the User authorizes CIFCL & both its present and future associates to communicate with him/her via Email, Phone, SMS or any other means to offer the User their and CIFCL's services, offer promotional offers, impart product knowledge as listed on the Platform & offers of CIFCL's associates regardless of the User's DNC or DND status.

3. Disclosure of User information

CIFCL may reveal the general statistical information about the Platform and Users, such as number of Users, number and type of products and services provided, etc from time to time.

CIFCL may also use the information collected from the User to deliver information to User that are targeted to User's interests, such as new services and promotions.

The following are examples of some categories of persons to whom CIFCL may share User's information, including Personal Information, Sensitive Personal Information, from time-to-time.

a. Listing of Advertisements

a.  Where the User enters information on any form hosted by an advertiser on the Platform, such information shall simultaneously be collected by CIFCL and the advertiser (including dealers, car manufacturers, valuers, insurers etc). The information shall be used by CIFCL in accordance with this Privacy Policy and the advertiser shall be bound to use such information as per its prevalent privacy policies. As CIFCL cannot have control over the privacy policies/practices of the advertisers, the User should evaluate the advertiser's privacy policy/practices before deciding to provide the said information.

CIFCL may aggregate the Personal Information of Users available on the Platform and share such information in a non-personally identifiable manner to the advertisers and third parties for marketing and promotional purposes of Website. The User can opt out of sharing such information by reaching out to support@gaadibazaar.in

b. Listing of Classifieds

a.  On the listing of a classified advertisement by a User, and another User expressing his interest on the advertisement, the User who expresses interest over the advertisement will be provided with the contact information of the User listing the classified advertisement.

b.  Likewise, the contact information of a User who expresses interest in a classified advertisement shall be shared with the User who has listed the said advertisement.

c. Third Party Products and Services offered on the Platform

There are certain services for which third parties may request the information of User before rendering the service (example: Personal Information and Sensitive Personal Information, vehicle particulars for valuation of such Vehicle), such information shall simultaneously be collected by CIFCL and the third party. The information shall be used by CIFCL in accordance with this Privacy Policy and the third party shall be bound to use such information as per its prevalent privacy policies. As CIFCL cannot have control over the privacy policies/practices of third parties, the User should evaluate such third party's privacy policy/practices before deciding to provide the said information.

d. Third Parties as Internal Service Providers of CIFCL

To facilitate or outsource certain aspects of the business, service operations and products which are provided by CIFCL to the User through this Platform (e.g., search technology, rewards programs etc.,), CIFCL may use third parties who will be referred to as internal service providers and therefore CIFCL may share the information, including Personal Information and Sensitive Personal Information, of User directly to these internal service providers. The internal service providers are subject to nondisclosure agreements with CIFCL and other legal restrictions that prohibit their use of the information which shall be provided to them to perform the specific outsourced Platform related operation, unless the User has explicitly agreed or given his/her prior permission to the internal service providers for additional uses. On certain occasions, the internal service provider may collect information directly from the User. In such event, the User will be notified of the involvement of the internal service provider, and all additional information the User shall provide to the internal service provider/s and their additional uses will be up to the discretion of the User. If the User provides additional information to an internal service provider directly, then the use of such additional information is governed by the privacy policy of such internal service provider.

e. Affiliates and Subsidiaries

CIFCL shall share the User information, including their Personal Information and Sensitive Personal Information, with its affiliates, subsidiaries, and joint ventures that are committed to serve the User through the Platform and other modes. These entities shall protect the information on par with the information which they obtain from their users.

CIFCL, its affiliates, subsidiaries, joint ventures, or any combination of such, may share some or all of Personal Information and Sensitive Personal Information of User with another business entity with whom CIFCL, its affiliates, subsidiaries and/or joint ventures plan to, merge with, or be acquired by that business entity. On happening of such merger of acquisition, CIFCL shall request the new entity to follow this Privacy Policy with respect to such User's Personal Information.

f. Sharing of Information on Legal/Regulatory Requirements

CIFCL may share the User's information, including Personal Information and Sensitive Personal Information, to third parties if CIFCL is under a duty to disclose or share such information, in order to comply with any legal obligation, or where CIFCL believes in good faith that the law requires it, or at the request of Governmental authorities conducting an investigation or in order to enforce, verify or apply our User Agreement and other agreements or policies, or to protect CIFCL's rights, property, or safety and the rights, property or safety of the other Users.

If there are any cyber security incidents, CIFCL may share the User's Information, including Personal Information and Sensitive Personal Information, with the Indian Computer Emergency Response Team in accordance with the policies and procedures mentioned in the Information Technology (The Indian Computer Emergency Response Team and Manner of Performing Functions and Duties) Rules, 2013.

CIFCL shall comply with the directions of law enforcement agencies, statutory, judicial and non-judicial authorities and cooperate in the inquiries. Therefore, in response to a direction of law enforcement, regulatory or other such government authority, relating to an investigation, we shall disclose the User's name, contact details, his/her behaviour/ activity on the Platform with or without a subpoena or summon.

CIFCL ensures that the Platform is secured through reasonable security practices as enumerated in clause 12 of this Privacy Policy. However, third parties may unlawfully intercept or access transmissions or private communications or other Users may abuse or misuse Personal Information of a User that they access in the Platform. Therefore, CIFCL does not promise, and User shall not expect, that his/her Personal Information or private communications will always remain confidential.

4. Transfer to other countries

CIFCL may share a copy of the User's Personal Information and Sensitive Personal Information globally in order to carry out various activities specified in this Privacy Policy. The User's Personal Information and Sensitive Personal Information may therefore be subject to the privacy laws that are different from the User country. CIFCL shall ensure that the transfer of User's Personal Information and Sensitive Personal Information is carried out in accordance with the applicable privacy laws and is in compliance with the provisions applicable for transfer of Sensitive Personal Information and any other appropriate contractual, technical, and organisational measures that are in place, such as, for example, the Standard Contractual Clauses approved by the EU Commission. Provided that CIFCL may, during its business and for the various activities specified in this Privacy Policy, enter into agreement(s) with third-party vendors that involves the transfer of User's Personal Information and Sensitive Personal Information globally. In this case, CIFCL shall take all steps, that are within its control, to ensure that the transfer of User's Personal Information and Sensitive Personal Information complies with the applicable privacy laws.

By visiting, accessing and/or using this Platform and/or submitting the information, the User consents to such transfer and disclosure of Personal Information and Sensitive Personal Information.

5. Obligations of User

The User agrees, undertakes and confirms that while providing his/her information on the Platform, the User shall not upload, display, host, publish, modify, update, transmit or share any information that:-

a)  belongs to another person and to which the User does not have any right;
b)  is defamatory, obscene, pornographic, paedophilic, invasive of another's privacy, including bodily privacy, insulting or harassing on the basis of gender, libellous, racially or ethnically objectionable, relating or encouraging money laundering or gambling, or otherwise inconsistent with or contrary to the laws in force;
c)  is harmful to a child/children;
d)  infringes any patent, trademark, copyright or other proprietary rights;
e)  violates any law for the time being in force;
f)  deceives or misleads the addressee about the origin of the message or knowingly and intentionally communicates any information which is patently false or misleading in nature but may reasonably be perceived as a fact;
g)  impersonates another person;
h)  threatens the unity, integrity, defence, security or sovereignty of India, friendly relations with foreign States, or public order, or causes incitement to the commission of any cognisable offence or prevents investigation of any offence or is insulting other nation;
i)  contains software virus or any other computer code, file or program designed to interrupt, destroy or limit the functionality of any computer resource; or
j)  is patently false and untrue, and is written or published in any form, with the intent to mislead or harass a person, entity or agency for financial gain or to cause any injury to any person;

6. Storage and Retention of information

a)  The User's information collected by CIFCL is stored in India by CIFCL or its affiliates, business partners, suppliers and sub-contractors, in an easily retrievable format.

b)  The User's Personal Information shall be stored only for the period necessary for the purposes specified in clause 2 above, and shall be retained in the manner prescribed under applicable law.

c)  Records containing Personal Information and Sensitive Personal Information will only be retained as long as necessary to provide the User with CIFCL Services and for legitimate and essential business purposes, such as maintaining the performance of the service, making data-driven business decisions about new features and offerings, complying with legal obligations and resolving disputes. (“Information Retention Obligation”). Some Personal Information may be retained as long as a person is the User of a Service. CIFCL shall retain the information shared by the User, including Personal Information, only for a period of one hundred and eighty days (180) days after any cancellation or withdrawal of his/her registration or for such longer period as may be required under applicable laws, including laws applicable to non-banking financial companies.

d)  In accordance with the Information Retention Obligation, all Personal Information and Sensitive Personal Information collected and processed by CIFCL shall be deleted when the retention is no longer necessary.

e)  Upon User's request, CIFCL will delete or anonymise User Personal Information and Sensitive Personal Information, so that it no longer identifies the User, except in the following circumstances:

i)  CIFCL is legally allowed to or maintain certain Personal Information or Sensitive Personal Information;
ii)  Requirement to retain the Personal information or Sensitive Personal Information on legitimate business; interests such as fraud prevention or maintaining the security of the users
iii)  Retention for legal, tax, audit and accounting obligations for the period allowed by law.

f)  By visiting, accessing and/or using this Website and/or submitting information, the User consents to such storage of information, including Personal Information and Sensitive Personal Information.

7. User's Rights

a)  Right to access: User has the right to be informed of and request access to, the Personal Information and Sensitive Personal Information processed about the User.

b)  Right to Opt Out: The User has the right to opt out of providing any of the information mentioned in clause 1. I However, in such event CIFCL reserves the right to refuse or limit the User's access and use of the Platform and its features, including goods and services offered on the Platform.

c)  Right to Withdraw Consent: The User has the right to withdraw consent to the use, disclosure, or transfer of his/her information mentioned in clause 1.I. However, in such event CIFCL reserves the right to refuse or limit the User's access and use of the Platform and its features, including goods and services offered on the Platform.

d)  Right to rectification: The User has the right to update or correct his/her information provided under clause 1.I. The User may exercise such right by raising service request in gaadibazaar application or mail to support@gaadibazaar.in

e)  Right to unsubscribe: The User has the right to unsubscribe from any commercial communication, which is not essential for CIFCL to provide its goods or services. You may exercise such right by clicking on the following link support@gaadibazaar.in

f)  Right to seek deletion and right to be forgotten: The User has the right to require CIFCL to delete of his/her information mentioned in clause 1.I and to cause the Platform to “forget' the User. However, in such event CIFCL reserves the right to refuse or limit the User's access and use of the Platform and its features, including goods and services offered on the Platform.

8. Usage of Other Users' Information

To facilitate the communication and interaction among the Users of Platform, CIFCL allows the User to access other Users' contact details. As a Seller, a User shall receive the contact details of the intending Buyer(s) via email/ short messaging service (SMS) and as an intending Buyer; a User shall receive the contact details of the Seller(s) via email/SMS. By entering into the User Agreement hosted in this Platform, the User agrees that, with respect to other User's Personal Information or Sensitive Personal Information that the User obtains through the Platform or through a related communication from Platform or Platform facilitated transaction, the Website hereby permits the User a license to use such information only for:

a)  availing services offered through the Platform,

b)  any other purpose that the User expressly opts by providing adequate disclosures. The User shall give adequate opportunity to other Users to remove themselves from his/her database and an option to review the information collected by such User about other Users.

No User shall disclose Personal Information or Sensitive Personal Information of another User to a third party without the specific consent of that another User and CIFCL.

The Platform shall not tolerate spam. Hence, no User shall add another User to his/her email or physical mail lists in any circumstance without the express consent of that another User.

9. Change of Personal Information by User

CIFCL shall verify the identity of User before granting access or making changes to his/her Personal Information. Subsequent to the registration of profile by a User on the Platform, the User ID and Password will be required by the Platform to access the said User's profile.

10. User's consent

By using the Platform, the User consents to the collection and use of information disclosed by him/her in the Platform.

a) Personal Information of children:

CIFCL does not knowingly collect, maintain or use Personal Information or Sensitive Personal Information from children under 18 years of age. If the User is under the age limit of their respective local legislations, the User is requested to not provide their Personal Information to CIFCL. If the User is a parent of a child under the age limit of their respective local jurisdiction and become aware that their child has provided Personal Information or Sensitive Personal Information to this Platform without their consent, the User needs to contact CIFCL through the mode described under paragraph 14(a) . CIFCL will promptly take steps to delete such Personal Information or Sensitive Personal Information and terminate the child's account.

If the User is a parent of a child under the age limit of their respective local jurisdiction and become aware that their child has provided Personal Information or Sensitive Personal Information to this Website without their consent, the User needs to contact CIFCL through the mode described under paragraph 14(a) . CIFCL will promptly take steps to delete such Personal Information or Sensitive Personal Information and terminate the child's account.

11. Grievance Officer

The name and contact details of the Grievance Officer of CIFCL is as provided below:
Name: Krishnakumar.K.P
Designation: Sr. Associate VP-Operations
Contact number: 1800-102-4565
Customer Care Email ID: customercare@chola.murugappa.com

The Grievance Officer may be contacted with respect to any complaints or concerns including those pertaining to breach of our User Agreement and Privacy Policy.

12. Security Practices

a.  CIFCL strives to ensure the security, integrity, and privacy of the User's information and to protect the User's information against unauthorized access or disclosure, alteration, or destruction.

b.  For the above purpose, CIFCL has adopted internal reviews of the data collection, storage, and processing practices and security measures, including appropriate encryption and physical security measures to guard against unauthorized access to systems where the User's information is stored.

c.  CIFCL also has a comprehensive and robust information and cyber security policy, information technology and other mechanisms in accordance with the applicable law to ensure the security of the User's information.

13. Amendment to Privacy Policy

On amending the Privacy Policy, CIFCL shall notify the User, in the Website, at least 10 days in advance of implementation, about the details of such amendment.

This privacy policy was last updated on 10 February 2023

14. Notices

Except when explicitly stated otherwise, any notices shall be sent by email to customercare@chola.murugappa.com

Notice/any communication shall be sent to the User either to the email address, if any provided by the User on the Platform.

SECTION B

If you avail any loans from CIFCL through the Platform, then the provisions of Section B apply to you for the limited purpose of such loans borrowed through the Platform, irrespective of whether or not you have acquired a vehicle through the Platform.

1. Nature of Information collected on the Platform

By using the App, you are hereby providing us with your prior and explicit consent, to collect, store, process and share your data in the manner set out below. We collect the data you provide to enable us to fulfil our regulatory obligations under applicable laws (including KYC requirements) and to ensure that we can provide you Services in the best manner possible.

The data being asked from you is strictly need-based, i.e., we only collect the data we require to helps us comply with applicable laws and to provide services to you in a robust and user-friendly manner.

Please note: When you apply for a loan, a pop-up will name and mention the names of the lender and co-lending parties (if any) from whom your loan will be disbursed and you will be required to provide specific consent to provide information to, and share information with, such lender/co-lenders.

For fully using the Website and the App, and for availing the product/Services provided therein, the User needs to register with the Platform by providing his/her contact, identity information and other personal information as indicated on the Platform. If the User is not willing to provide mandatory personal information (as required under applicable laws), he/she must opt out from registering with the Platform and will not be able to avail Services thereunder.

We have detailed the data being collected from you and the manner of collection below:

I  Information provided by the User:

a)  All information provided to CIFCL when the User registers or subscribes to services on the Website or the App, including name, address, telephone number, email address, PAN, date of birth, pincode, nature of employment, gender, and any other information, which is capable of identifying such User (collectively referred to as “Personal Information”).

b)  All information that the User chooses to share on the Platform.

c)  “Sensitive Personal Information”, i.e., passwords and all financial information provided at the time of applying for or availing loans through the Platform.

d)  An unregistered User can browse the Platform without providing their information, including Personal or Sensitive Personal Information. However, please note that the Platform does collect [technical information such as the User's IP Address] from Users who access the Platform without registration.

e)  Once the User provides his/her Personal Information, he/she is no longer an anonymous User of the Platform.

Purpose of use of information provided by the User: For Enabling the Platform and its Services; For Loan Processing and KYC Authentication and For Legal Compliance and Requirements.

II  Information collected by CIFCL:

Please note, AT NO TIME do we access or request access to your mobile phone resources like file and media, contact list, call logs, telephony functions, etc. We may request a one-time access to your mobile's camera, microphone, and location solely for the purpose of on-boarding/ KYC requirements only. Your specific consent will be sought to provide us with such access. We will neither ask for, nor retain, such access once the onboarding and KYC verification processes are complete.

AT NO TIME DO WE ASK FOR OR STORE ANY OF YOUR BIOMETRIC INFORMATION.

Other Data: You may be required to provide further information to us for the purposes of processing your loan application. Such additional information may include (without limitation) bank statements, goods and services tax returns, salary and income statements, insurance certificate, Vehicle images and title documents for the property being financed. Specific details of any such additional data required will be shared with you at the relevant time, and your specific consent will be obtained at that stage. You may also be required to provide this information to us via physical documents, e-mail or other digital and offline methods, as may be communicated to you.

How we use this data: For Enabling the Platform and its Services; For Loan Processing and KYC Authentication; For assessing the quantum and interest rate of loan to be extended; For Legal Compliance and Requirements.

Feedback Data and Other Data: This includes the following:

.  If you call our call centres, we may record information provided by you to service you or record the calls for quality and training purposes.

.  Data you input when you participate in our referral programs or use any discount codes offered by us.

.  If you provide any feedback or comments to us on the App or as part of our research programs for improving the Platform.

How we use this data: For Enabling the Platform and its Services; For Loan Processing and KYC Authentication; For Legal Compliance and Requirements.

We may also be working closely with third parties (including, for example, credit information bureaus, business partners, partner banks and non-banking financial companies, sub-contractors, agents and service providers. and may lawfully receive information about you and your co-applicant from such sources, provided that you have consented to provide this information to the relevant third parties and have permitted them to share such information with us (such consents would have been obtained from you by the relevant third parties). Such data may be shared internally and combined with data collected on the Platform. We may also use the content you have shared publicly, including on third party platforms or applications, to promote our Services (including by quoting your content, reviews and/ or recommendations, or displaying screenshots of your content, reviews and/ or recommendations, in each case, with your permission).

How we use this data: For Enabling the Platform and its Services; For Loan Processing and KYC Authentication; For Enabling Customer Support; For Research and Development; For Enabling Communications Between You and Us; For enabling Marketing and Outreach; For Automated Decisions; and For Legal Compliance and Requirements

III  Cookies

CIFCL/its Affiliates shall use data collection devices such as “cookies” on certain pages of the Platform to analyze such web page flow, measure effectiveness of promotional activities and promote safety and trust. “Cookies” are small files placed on the hard drive, which will assist CIFCL/Affiliates in providing better services.

CIFCL offers certain features that are only available through the use of "cookies". CIFCL also uses cookies to allow the User to enter his/her password less frequently during a session. Further, cookies also help CIFCL in providing information that is targeted to the interests of the User. Most of the cookies are "session cookies", which will be deleted automatically from the hard drive at the end of a session.

The User is always free to decline the cookies, if his/her browser permits, although in that case the User may not be able to use certain features of the Platform and the User may be required to re-enter his/her password more frequently during a session.

CIFCL shall retain information as necessary to resolve disputes, troubleshoot problems and provide customer support to the extent permitted by law. If a User sends personal correspondence to CIFCL, such as emails or letters, or if other users or third parties send correspondence to CIFCL about the activities of User or postings on the Site, CIFCL may collect and store such information into a file specific to the said User.

2. Purpose of Collection and Use of User Information:

CIFCL uses the Personal Information and Sensitive Personal Information of the User in the following ways and for the following purposes:

a)  To improve the services/products offered on the Platform.

b)  To inform the User about online and offline offers, products, services, and updates.

c)  To customize User experience detect and protect CIFCL against error, fraud, and other criminal activity; resolve disputes; troubleshoot problems and collect fees owed.

d)  To enforce our User Agreement.

e)  To analyze the information shared by various Users to identify the Users using multiple User IDs. CIFCL may compare and review User's Personal Information for errors, omissions and for accuracy.

f)  To levy any applicable charges on the User and provide required customer support to the User.

g)  To analyze usage of the Platform.

h)  To improve CIFCL's marketing and promotional efforts.

i)  To improve the Website's/App's content and product/service offerings and customize the Website's/App's content, layout and services.

j)  For internal operations such as troubleshooting, data analysis, research, testing and quality improvement of our service;

k)  To respond to judicial process and provide information to law enforcement agencies or in connection with an investigation on matters related to public safety, as permitted by law;

l)  For any other purpose a described to the User at the time of collection of information. By visiting, accessing and/or using the Platform and/ or submitting Personal Information or Sensitive Personal Information, the User consents to such use of his/her Personal Information and Sensitive Personal Information by CIFCL.

By using the Platform and providing the required information, the User authorizes CIFCL & both its present and future associates to communicate with him/her via Email, Phone, SMS or any other means to offer the User their and CIFCL's services, offer promotional offers, impart product knowledge as listed on the Website & offers of CIFCL's associates, subject to the User's DNC or DND status.

3. Disclosure of User information

CIFCL may reveal the general statistical information about the Website, Apps and Users (in an anonymised or pseudonymised form), such as number of Users, number and type of products and services provided, etc from time to time.

CIFCL may also use the information collected from the User to deliver information to User that are targeted to User's interests, such as new services and promotions.

We are very protective about your data. We may enter into data-sharing agreements or disclose the collected data in order to provide the Services and new product offerings to you. However, we will ensure that we obtain your specific consent before sharing any non-anonymised/non-pseudonymised information with any third party. We have detailed the manner in which we share the collected data below:

4. Transfer to other countries

Any personal data we store is done only in India. Neither CIFCL nor its Affiliates or co-lending partners will share your information with persons resident outside India or store your information in data servers outside India. Details of third party storage service providers used by us, and the data shared with them, are listed in S. No. 3(1) above.

5. Obligations of User

The User agrees, undertakes and confirms that while providing his/her information on the Platform, the User shall not upload, display, host, publish, modify, update, transmit or share any information that:-

a)  belongs to another person and to which the User does not have any right;

b)  is defamatory, obscene, pornographic, paedophilic, invasive of another's privacy, including bodily privacy, insulting or harassing on the basis of gender, libellous, racially or ethnically objectionable, relating or encouraging money laundering or gambling, or otherwise inconsistent with or contrary to the laws in force;

c)  is harmful to a child/children;

d)  infringes any patent, trademark, copyright or other proprietary rights;

e)  violates any law for the time being in force;

f)  deceives or misleads the addressee about the origin of the message or knowingly and intentionally communicates any information which is patently false or misleading in nature but may reasonably be perceived as a fact;

g)  impersonates another person;

h)  threatens the unity, integrity, defence, security or sovereignty of India, friendly relations with foreign States, or public order, or causes incitement to the commission of any cognisable offence or prevents investigation of any offence or is insulting other nation;

i)  contains software virus or any other computer code, file or program designed to interrupt, destroy or limit the functionality of any computer resource; or

j)  is patently false and untrue, and is written or published in any form, with the intent to mislead or harass a person, entity or agency for financial gain or to cause any injury to any person;

6. Storage and Retention of information

a)  The User's information collected by CIFCL is stored in India by CIFCL or its affiliates, business partners, suppliers and sub-contractors, in an easily retrievable format.

b)  The User's Personal Information shall be stored only for the period necessary for the purposes specified in clause 2 above, and shall be retained in the manner prescribed under applicable law.

c)  Records containing Personal Information and Sensitive Personal Information will only be retained as long as necessary to provide the User with CIFCL Services and for legitimate and essential business purposes, such as maintaining the performance of the service, making data-driven business decisions about new features and offerings, complying with legal obligations and resolving disputes. (“Information Retention Obligation”). Some Personal Information may be retained as long as a person is the User of a Service. CIFCL shall retain the information shared by the User, including Personal Information, only for a period of one hundred and eighty days (180) days after any cancellation or withdrawal of his/her registration or for such longer period as may be required under applicable laws, including laws applicable to non-banking financial companies.

d)  In accordance with the Information Retention Obligation, all Personal Information and Sensitive Personal Information collected and processed by CIFCL shall be deleted when the retention is no longer necessary.

e)  Upon User's request, CIFCL will delete or anonymise User Personal Information and Sensitive Personal Information, so that it no longer identifies the User, except in the following circumstances:

i)  CIFCL is legally allowed to or maintain certain Personal Information or Sensitive Personal Information;
ii)  Requirement to retain the Personal information or Sensitive Personal Information on legitimate business; interests such as fraud prevention or maintaining the security of the users
iii)  Retention for legal, tax, audit and accounting obligations for the period allowed by law.

7. User's Rights

a)  Right to access: User has the right to be informed of and request access to, the Personal Information and Sensitive Personal Information processed about the User.

b)  Right to Opt Out: The User has the right to opt out of providing any of the information mentioned in clause 1. I However, in such event CIFCL reserves the right to refuse or limit the User's access and use of the Platform and its features, including goods and services offered on the Platform.

c)  Right to Withdraw Consent: The User has the right to withdraw consent to the use, disclosure, or transfer of his/her information mentioned in clause 1.I. However, in such event CIFCL reserves the right to refuse or limit the User's access and use of the Platform and its features, including goods and services offered on the Platform.

d)  Right to rectification: The User has the right to update or correct his/her information provided under clause 1.I. The User may exercise such right by raising service request in gaadibazaar application or mail to support@gaadibazaar.in

e)  Right to unsubscribe: The User has the right to unsubscribe from any commercial communication, which is not essential for CIFCL to provide its goods or services. You may exercise such right by clicking on the following link support@gaadibazaar.in

f)  Right to be forgotten: The User has the right to ask us to delete all personal information of the User provided to us, as long as there is no loan outstanding from such User to CIFCL, and as long as such deletion is not contrary to applicable laws.

Personal Information of children:

CIFCL does not knowingly collect, maintain or use Personal Information or Sensitive Personal Information from children under 18 years of age. If the User is under the age limit of their respective local legislations, the User is requested to not provide their Personal Information to CIFCL.

If the User is a parent of a child under the age limit of their respective local jurisdiction and become aware that their child has provided Personal Information or Sensitive Personal Information to this Website without their consent, the User needs to contact CIFCL through the mode described under paragraph 14(a). CIFCL will promptly take steps to delete such Personal Information or Sensitive Personal Information and terminate the child's account.

8. Grievance Officer

The name and contact details of the Grievance Officer of CIFCL is as provided below:
Name: Krishnakumar.K.P
Designation: Sr. Associate VP-Operations
Contact number: 1800-102-4565
Customer Care Email ID: customercare@chola.murugappa.com

The Grievance Officer may be contacted with respect to any complaints or concerns including those pertaining to breach of our User Agreement and Privacy Policy.

9. Security Practices

a.  CIFCL strives to ensure the security, integrity, and privacy of the User's information and to protect the User's information against unauthorized access or disclosure, alteration, or destruction.

b.  For the above purpose, CIFCL has adopted internal reviews of the data collection, storage, and processing practices and security measures, including appropriate encryption and physical security measures to guard against unauthorized access to systems where the User's information is stored.

c.  CIFCL also has a comprehensive and robust information and cyber security policy, information technology and other mechanisms in accordance with the applicable law to ensure the security of the User's information.

10. Amendment to Privacy Policy

On amending the Privacy Policy, CIFCL shall notify the User, in the Website, at least 10 days in advance of implementation, about the details of such amendment.

This privacy policy was last updated on 10 February 2023

11. Notices

Except when explicitly stated otherwise, any notices shall be sent by email to customercare@chola.murugappa.com

Notice/any communication shall be sent to the User either to the email address, if any provided by the User on the Platform.