1.1 ABSLAMC collects Personal Information about you from a variety of sources, including through:

• Your online and electronic interactions with us, including via our Platform, via chatbot, online campaigns, Transaction link and other new channels as and when they are introduced, such as WhatsApp
• Your offline interactions with ABSL IFSC, including via direct marketing campaigns, hard copy registration/application forms, competition entries and contacts through ABSL IFSC consumer services call centres;
• Your interactions with us through your communications and interactions with us through emails, IVR, recordings at our call centres, etc.;
• Third-parties (including but not limited to analytics providers, Payment Processors, credit information companies, providers of technical and delivery services, advertising networks, third-party software development kits, our distributors, service providers and/or agents); and
• our Affiliates.

The information being collected is the basis of our ability to provide you with good, qualitative, timely and efficient service, while also keeping the information and data provided totally secure and confidential.

2.1 We collect, use, store, transfer, or otherwise process Personal Information about you to the extent permissible under Applicable Laws. Such Personal Information includes but is not limited to:

• Your name and contact information, such as your residential address, business/ office address, email address, telephone number, mobile number or fax number;
• Information relating to your identity, including your date and place of birth, age, gender, nationality, Permanent Account Number (PAN) Details and country of domicile and/or your nationality, etc.;
• Information relating to your work (if self-employed, the nature of the self-employment) and income;
• Financial information such as bank account details, (including information in relation to change in bank accounts), beneficiary account number, type of accounts held, bank statements;
• Purchase and payments-related information such as payment records, payment method, cardholder data, bank account holder details, amount and date of payments, phone number, fax number, email address;
• Generation and storage of passwords (PIN) in encrypted form based on a request from the investor under the online mode of investment;
• Photographs and signature;
• Device data including your internet protocol (IP) address, the internet service provider, your browsing history, device identity, mobile operator, WiFi connection, service set identifier (SSID), International Mobile Subscriber Identity (IMSI),International Mobile Equipment Identity, etc.);
• Location data that describes the precise geographic location of your device;
• Behavioural details regarding how you utilise our products, services, offers, etc.;
• Marital status, gender, occupation;
• Social relationship details such as your father’s name, spouse’s name, mother’s name, anniversary date, nominee details;
• Details of your communications and transactions with us.
• Some sensitive Personal Information such as your health information, Covid-19 vaccination status or certificate in case you avail any part of our Services that requires us to process your health records under Applicable Laws;
• Any other information that you may share with us or that we collect from you while you visit, access or use our Platform or contact us for query resolution; and
• Information that we receive from third parties such as analytics providers, advertising networks, credit information companies, search information providers, and publicly available sources.

2.2 We may also collect, use, and share aggregated data such as statistical or demographic data including your interests, age, general location, language preferences, and gender for any purpose. Aggregated data could be derived from your Personal Information but is not considered Personal Information under Applicable Laws. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific feature of the Platform. All rights, title, and interest in and to such aggregated data, including all intellectual property rights therein shall belong to and with ABSLAMC.

2.3 ABSL IFSC shall not be responsible for verifying the accuracy or completeness of the Personal Information provided by you.

ABSL IFSC and Third Party Services Providers encourage you to update your Personal Information on a regular basis and as and when required. You are also entitled to review the information provided to us. In case any of the data/information is found to be inaccurate or incorrect, please intimate us of the same for immediate amendment. ABSL IFSC and any person acting on its behalf shall not be responsible for the authenticity of the Personal Information or sensitive personal data or information supplied by you.

5.1 We may share or disclose your Personal Information with our other corporate entities, Affiliates, lending partners, technology partners, business partners (such as UPI platforms), merchants and other third parties (credit bureau, recovery teams) as permitted by Applicable Laws. This disclosure may be required for us to provide you access to our Services, use of the Platform, for checking your eligibility for the Products and Services offered on Platform, for enhancing your experience, to comply with our legal obligations, to enforce our agreement(s) with you, to facilitate our marketing and advertising activities, to prevent, detect, mitigate, and investigate fraudulent or illegal activities related to our services, for providing credit defaults and credit information, for communicating with you, for enhancing your pre-qualified offers if applicable, for data enrichment, to authenticate your KYC information with the relevant Authorities such as the IFSCA, UIDAI, and CKYCR, and also to register you for the Products or Services that you would be opting for.

5.2 We may disclose Personal Information if required to do so by law or in good faith belief that such disclosure is reasonably necessary to respond to notices, court orders, or other legal process. We may disclose Personal Information to law enforcement offices, third-party rights owners, or others in the good faith belief that such disclosure is reasonably necessary to enforce our Terms or Privacy Policy, respond to claims that an advertisement, posting or other Content violates the rights of a third party, or protect the rights, property or personal safety of our users or the general public.

5.3 We and our Affiliates will share some or all of your Personal Information with another business entity should we plan to merge with, or be acquired by, that business entity, or undergo re-organisation, amalgamation, or restructuring of business. Should such a Transaction occur, such other business entity (or the new combined entity) will be required to follow this Privacy Policy with respect to your Personal Information.

5.4 Availing your credit information through ABSL IFSC is subject to your passing of appropriate identity authentication for security and privacy purposes.

To the extent permitted under Applicable Law, we may send you marketing communications about our Products, Services, or Updates, either electronically or physically, from time to time. You can withdraw your consent or opt out of receiving such communications at any time by following the instructions provided in our communications or by contacting us directly. Please note that even if you opt out of marketing communications, we may still send you service-related or transactional messages that are necessary for the performance of our Services.

ABSL IFSC shall not retain your Personal Information for longer than necessary to serve the purpose for which it is sought, or is otherwise required to be retained under any Applicable Law or our data retention policies, if any.

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

Cookies are small data files that are stored on your device. We use cookies and other tracking technologies to distinguish you from other users on the Platform and to remember your preferences. This helps us provide you with a good experience when you use the Platform, and allows us to improve the Platform.

We identify you by way of using cookies. The data collected by way of cookies will allow us to provide you with a tailored and user-friendly experience. They also enable you to access certain features of the Platform. Most devices can be set to notify you when you receive a cookie or prevent cookies from being sent. If you prevent cookies from being sent, it may limit the functionality that we can provide when you visit the Platform.

Additionally, you may encounter cookies or other similar technologies on certain pages of the Platform that are placed by third parties. We do not control the use of cookies by such third parties.

Please note that all your Personal Information is only stored on systems located within India or GIFT City, as per the Products and Services availed by you. We do not transfer your Personal Information to any third country.

In case you use any facilities/products/services through the Application, any Additional Terms and Conditions governing the manner of usage of the Application, including collection and disclosure of Personal Information, shall be applicable and the same shall be read in conjunction with this Privacy Policy.

The Platform may contain services provided by or links to and from the websites of Third Party Service Providers. Please note that the Third Party Services that may be accessible through the Platform are governed by their own privacy policies. We do not accept any responsibility or liability for the policies or for any Personal Information that may be collected by providers of such Third Party Services. Please check their policies before you submit any Personal Information to their websites or use their services.

The Platform is not intended for use by children and minors as defined under Applicable Law. Parents and legal guardians are requested to ensure that Personal Information is not provided by minors.

To protect your Personal Information from unauthorised access or disclosure, loss or misuse, we have adopted reasonable security practices and procedures in line with industry standards. The transmission of information is not completely secure for reasons beyond our control. We adopt industry-standard security measures and keep updating our systems from time to time to protect your Personal Information against any hacking or virus dissemination.

ABSL IFSC reserves the right to change the Privacy Policy at any time. Please note that any such changes to the Privacy Policy will be effective from the date of posting the updated version of the Privacy Policy on the Platform.

In case of any grievances, you may contact our investor services centres or our office situated at Unit No 201-A, Second Floor, Hiranandani Signature Building, GIFT SEZ, Villages Phirozpur and Ratanpur, Gandhinagar – 382355, Gujarat, India or reach out to the Complaint Redressal Officer at cro.abslgiftcity@adityabirlacapital.com and crao.abslgiftcity@adityabirlacapital.com. If believe your complaint is not redressed by us satisfactorily, you may lodge a complaint with IFSCA through an email to grievance-redressal@ifsca.gov.in

To the extent permissible under applicable law, the use of the Services and the Platform is at your own risk. You hereby accept full responsibility for any consequences that may arise from your use of the Services or the Platform and expressly agree and acknowledge that ABSL IFSC shall have absolutely no liability with respect to the same to the maximum extent permissible under Applicable Law.

The information provided on the Platform, including information relating to our privacy practices, data processing activities, products, services and regulatory disclosures, is provided for general informational purposes and may be updated, modified, corrected or supplemented from time to time. While ABSL IFSC endeavours to maintain accurate and up-to-date information, it does not warrant that all information available on the Platform will, at all times, be complete, accurate, current or error-free.

You are responsible for ensuring that the personal data and other information provided by you to ABSL IFSC is accurate, complete and not misleading, and for promptly informing ABSL IFSC of any changes to such information where necessary. ABSL IFSC shall process such information in accordance with this Privacy Policy and applicable law.