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PRIVACY POLICY

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THIS PRIVACY POLICY (“PRIVACY POLICY“) SETS FORTH THE MANNER OF COLLECTION, USE AND DISCLOSURE OF INFORMATION GATHERED ON THE PLATFORM. PLEASE READ THIS PRIVACY POLICY CAREFULLY. BY CONTINUING TO USE THE SERVICES, OR ACCESS THE PLATFORM YOU AGREE TO THE TERMS OF THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO SAME, YOU MAY NOT ACCESS OR USE THE PLATFORM OR AVAIL THE SERVICES. Access and use of the Platform is subject to the Terms and Conditions (“Terms“) accessible on the Platform.

Introduction

Mossbrae Solutions Private Limited a private limited company with its registered office at Door No. 77, (Old No. 43), Chamiers Road, Chennai – 600028, operating under the brand name “Anthem” (“Company”, “Anthem” “We”, “Us”, “Our” and terms of similar meaning) owns and operates:

  1. https://www.getanthem.co including any subdomains thereof (collectively, “Site“);
  2. all related widgets, tools, applications, data, software, APIs, mobile, tablet and other smart device applications (collectively, “Application“); and
  3. Services (as defined herein below).

The Site and the Application together are hereinafter collectively referred to as the “Platform”

The Platform operated by the Company (i) enables you to collect, track, manage your revenue and receivables paid both offline and online via Payment Gateway or Bharat Bill Pay System (ii) enables You to avail affordable and unsecured digital credit from Lenders (i.e non-banking financial institutions, banks and such other financial entities authorised to disburse loans in accordance with applicable laws) subject to the satisfaction of eligibility criteria and other conditions stipulated by the Lenders; and (iii) facilitates loan origination process, loan disbursement and collection process.

We at Anthem are committed to protecting Your privacy and personal information, and this Privacy Policy outlines how Information (as defined hereinafter) will be collected, used, processed and shared in connection with access by users, applicants, visitors and viewers (hereinafter referred to as “You”, “Your”, “User” as applicable) of Our Platform. By accessing and using the Platform, You consent to the use of Your Information in accordance with this Privacy Policy. We will not share any User Information with any third party without Your consent, except as outlined in this Privacy Policy or as permitted by law. The collection, usage, and sharing of User information by Us shall be in compliance with the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 and other applicable laws, as amended from time to time.

As We update, improve and expand the Platform and with technology and legal changes, this Privacy Policy may change, so please refer back to it periodically as You will deemed to have accepted and be governed by the terms of such modified Privacy Policy, as it comes into effect from time to time. If We make a significant or material change in the way We use or share Your Personal Information (as defined hereinafter), You will be notified via email and/or provided notice vide the Platform, within a reasonable time.

COLLECTION OF INFORMATION

To access/use the Platform, You may be asked to provide certain personal, non-personal and other information or data, as indicated below (such information and correspondences hereinafter collectively referred to as “Information”):

  1. In order for You to access the Platform, We may require You to provide Personal Information. Personal Information means information about any individual, or information from which any individual is directly or indirectly identifiable. Personal Information may be freely provided by You, or, in case of usage data, collected automatically when using the Services such as when You sign in through third party sites (as maybe applicable). Details on each type of Personal Information collected are provided hereunder or by specific explanation texts, displayed prior to such Personal Information collection. “Personal Information” includes the following categories of information: (i) Contact Data (such as Your e-mail address, phone number and account details and password); (ii) Demographic Data (such as Your gender, Your date of birth, nationality, zip code); (iii) Financial information (such as PAN card, bank documents, bank details, salary slips, bank statements, data from credit information companies, data required for Know Your Customer (KYC) compliances); and (iv) Details of consents (records of consents given for collection of information with the date and time and other relevant information). Please note that the above list is not an exhaustive list and is only an illustrative list.

Through some features on Our Platform, You may opt to provide Us Information about yourself if You are interested (a) in availing Our Services as a partner, employer or as an applicant; or (b) in an employment opportunity at Anthem; or (c) through the ‘Contact us’ page; or (d) any other manner. The information requested from You will be based on Your area of interest.

You are responsible for any third-party Personal Information obtained, published or shared through the use of the Platform and confirm that You have the third party’s consent to provide such Information to Us.

  • Non-Personal Information: When accessing the Platform, We may collect certain non-personal information such as Your internet protocol address, operating system, browser type and internet service provider. This type of information does not identify You personally.
  • Automatic Information: To improve the responsiveness of the Platform for You, We may use “cookies”, or similar electronic tools to collect information to understand Your individual interests. A cookie is a small text file that is stored on Your computer that enables Us to recognize You when You visit Our Platform, store Your preferences and settings, enhance Your experience by delivering content and advertising specific to Your interests, perform research and analytics, track Your use of Our Platform, and assist with security and administrative functions. These server logs may include information such as Your web request, Internet Protocol address, browser type, browser language, the date and time of Your request, Your visits to, and interaction and engagement with, the Platform, content and ads on third party websites, applications, platforms and other media channels, log files, web and one or more cookies that may uniquely identify Your browser. By using Our Platform, You signify Your consent to Our use of cookies.
  • Mobile: When You use the Platform through Your mobile, We may receive information about Your location and Your mobile device, including a unique identifier number for Your device. We may use this information to provide You with suggestions in respect of Platform if required.
  • User communications: When You send emails or other communications to Us, We may retain those communications in order to process Your inquiries, respond to Your requests and improve our Platform/Services.

We endeavour to provide You with choices regarding the Personal Information You provide to Us. You can set Your browser or mobile device to refuse all or some browser cookies, or to alert You when cookies are being sent. If You disable or refuse cookies, or choose to decline to submit any Information, We may not be able to provide You access to the Platform or use certain aspects of the Platform. We will not be liable and/or responsible for the denial of providing access to the Platform to You on account of inadequacy of Information provided by You.

Children: Anthem does not knowingly collect any Personal Information from children under the age of 18. If You are under the age of 18, please do not submit any Personal Information through our Platform. Though we have placed appropriate mechanisms, we encourage parents and legal guardians to monitor their children’s internet usage and to ensure no Personal Information is provided through our Service(s). If You have reason to believe that a child under the age of 18 has provided Personal Information to Us through the Platform, please contact Us and We will endeavour to delete that information and terminate the child’s account from Our databases.

HOW WE USE YOUR INFORMATION

We may use the Information We collect from You and about You in any one or more of the following manner:

  1. To create a user account for use of Platform;
  2. To verify Your registration/application details including email address or phone number;
  3. To undertake due diligence of applicant and seek mandatory information required for the purposes of KYC;
  4. To share Personal Information as may be necessary for a Payment Gateway to process and route payments to you or Lender to process an application for any loan/credit facilities requested by You;
  5. To process, fulfil Your request for Services and provide Services;
  6. To perform actions as may be required by the Payment Gateway such as do a penny test, bank account verification including sending you notifications about transactions or a Lender including sending any payment reminders in the frequency and manner as required by the Lender;
  7. To improve our Platform, provide You with superior Services and a range of offers;
  8. To diagnose technical problems, provide customer support;
  9. To contact You including to send You communications that You have requested or that may be of interest to You by way of emails, or courier, or registered post, or telephone calls, or any other mode of communication;
  10. Generate and review reports and data about, and to conduct research on, Our user base and Service usage patterns;
  11. Provide You with policies governing Your account;
  12. Notify You about changes to Our Platform;
  13. Allow You to participate in interactive features offered through Our Platform;
  14. In any other way We may describe when You provide the Information;
  15. To avoid fraud and other prohibited or illegal activities;
  16. We may use and disclose Information, in good faith, wherein the access, use, preservation or disclosure of such information is reasonably necessary to (i) satisfy (which may be without notice to You) any applicable law, regulation, legal process or enforceable governmental request, (ii) enforce this Privacy Policy, including investigation of potential violations thereof, (iii) detect, prevent, or otherwise address fraud, security or technical issues, or (iv) protect against imminent harm to the rights, property or safety of the Company, its users or the public as required or permitted by law;
  17. For any other purpose with Your express consent.

SHARING OF INFORMATION

For the purposes of Our Platform, We shall be sharing Your Personal Information with any of Our business partners (including Payment Gateways and Lenders), administrators, vendors, agents, service providers or affiliates for legitimate business purposes (including operating the Services, and providing Services to You), in accordance with applicable law. For example, companies We have hired to assist in protecting and securing our systems and services may also need access to Personal Information to provide those functions.

However, We do not sell, trade, or otherwise transfer Your Personal Information to outside parties other than for the purpose it is collected for except in the following ways:

  1. legal and regulatory authorities, upon request, or for the purposes of reporting any actual or suspected breach of applicable law or regulation, for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties, including safeguarding against and the prevention of threats to public security;
  2. outside professional advisors (such as accountants, auditors, or lawyers), subject to binding contractual obligations of confidentiality;
  3. any relevant party, law enforcement agency or court, to the extent necessary for the establishment, exercise or defense of legal rights;
  4. If You interact with social media features on Our Platform or use Your social media credentials to log-in or post content (as maybe applicable), these features may collect information about Your use of the Platform, as well as post information about Your activities on the social media service. Your interactions with social media companies are governed by their privacy policies;
  5. Collective information such as demographics and website usage statistics with Our sponsors, advertisers or other third parties whose practices are not covered by this Privacy Policy. When this type of information is shared, such parties do not have access to your Personal Information.
  6. Transfer of sensitive personal information under a contract subject to maintaining the same level of data protection; and
  7. Additionally, in the event of an audit, reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of Our business, assets or stock (including in connection with any bankruptcy or similar proceedings), We may share/transfer/assign the Information We have collected to the relevant third party, subject to such party maintaining the same level of data protection.

SECURITY OF INFORMATION


We use reasonable security measures to protect Information from unauthorized access, maintain data accuracy and help ensure the appropriate use/disclosure of Information. These safeguards take into account the sensitivity of the information that We collect, process and store and the current state of technology. We follow generally accepted industry standards to protect the Personal Information submitted to Us, both during transmission and once We receive it. We host the Platform in a secure server environment that uses firewalls and other advanced technology to prevent interference or access from outside intruders and Our email services have the most advanced security infrastructures. It protects Personal Information with multiple layers of security, including leading encryption technology like HTTPS and Secure Sockets Layer. Although We provide appropriate firewalls and protections, We cannot warrant the security of any Personal Information transmitted as Our systems are not hack proof. Information pilferage due to unauthorized hacking, virus attacks, technical issues is possible and We take no liabilities or responsibilities for it.

Further, please note that You are responsible for maintaining the security and confidentiality of Your account, user ids and passwords or any other Personal Information while accessing the Services. If We receive instructions using Your user name and password, We will consider that You have authorized the instructions.

PROCESSING OF INFORMATION

As outlined in this Privacy Policy, Anthem will not process Your Personal Information without a lawful basis to do so. In general, Anthem may process Your Personal Information on the legal basis of: (i) consent (where We have obtained Your prior, express consent to the processing; (ii) contract (if You have entered into an agreement with Us and/or Lenders and such processing is a necessary part thereof); (iii) compliance with applicable laws; (iv) to protect the vital interests of any individual. Anthem may also process certain Personal Information on the basis of the following legitimate interests, provided that such interests are not overridden by Your privacy rights and interests: (i) delivering and continuing to develop and improve the Services, (ii) learning from Your behaviour on Our Platform to better serve You and other users, helping Us modify or enhance the Services and its content, (iii) receiving insight as to what users like or dislike about our Services or aspects thereof, and (iv) providing a consistent and secure user experience in connection with the Services.

ACCESS AND DELETION OF INFORMATION

When You sign up for Platform, You are opting in to receive emails from Anthem. We will take reasonable steps to accurately record the Personal Information that You provide to Us and any subsequent updates. As a User, You have the right to access, correct, delete or transfer Your Personal Information that We hold, including registration/application details. You also have the right to withdraw any consents that have been previously granted, however, You may not be able to access the Platform or avail the Services in such instances.

You can manage Your email preferences and follow the “unsubscribe” instructions in commercial email messages. If required by You, Anthem will delete the Personal Information provided by You in connection with the Platform. We will remove Your public posts from view and/or dissociate them from Your account profile, but We may retain information about You for the purposes authorized under this Privacy Policy, unless prohibited by law. Thereafter, We will either delete Your Personal Information or de-identify it so that it is anonymous and not attributed to Your identity. Upon deletion of Your Information, copies of Your Information may remain viewable in cached and archived pages.

INFORMATION RETENTION

We retain Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law. The criteria for determining the duration for which We will keep Your Personal Information are as follows: (i) We will retain copies of Your Personal Information in a form that permits identification only for as long as is necessary in connection with the purposes set out in this Privacy Policy, including for the length of time We have an ongoing relationship with You and provide the Platform to You; (ii) if there is a legal obligation to which We are subject (for example, certain laws require Us to keep records of Your transactions for a certain period of time before We can delete them); or (iii) keeping in view the legitimate interests of Anthem (litigation or regulatory investigations). Because these needs can vary for different data types and purposes, actual retention periods can vary significantly.

LINKS TO THIRD PARTY SITES

The Platform may include links to third party applications/websites/platforms (“Third Party Sites”). Such Third Party Sites are governed by their respective privacy policies, which are beyond Our control. Once You leave Our Platform, use of any information You provide is governed by the privacy policy of the operator of the Third Party Site You are visiting and that policy may differ from Ours.

INDEMNIFICATION

You agree to indemnify Us, Our subsidiaries, affiliates, officers, agents, partners, and employees and hold Us harmless from and against any claims and demand, including reasonable attorneys’ fees, made by any third party arising out of or relating to: (i) Personal Information and contents that You submit or share through the Platform; (ii) Your violation of this Privacy Policy, or (iii) Your violation of rights of other person(s).

LIMITATIONS OF LIABILITY

You expressly understand and agree that the Anthem, including its affiliates, directors, officers, employees, representatives, business partners, shall not be liable for any direct, indirect, incidental, special, consequential or exemplary damages, including but not limited to, damages for loss of profits, goodwill, use, data, information, details or other intangible losses (even if the Anthem

has been advised of the possibility of such damages), resulting from; (a) use of, or the inability to use the Platform and/or Services; (b) failure or delay in providing the Services; (c) any loss or damage arising out of Your failure to adhere to Your obligations under the Terms and/or this Privacy Policy and/or; (d) unauthorized access to or alteration of Your Personal Information or otherwise.

YOUR CONSENT

By using the Platform and/ or by providing Your Information, You consent to the collection and use of such Information in accordance with this Privacy Policy, including but not limited to Your consent for sharing Your Information as per this Privacy Policy. You specifically agree and consent to us collecting, storing, processing, transferring and sharing Information (including Personal Information) related to You with third parties, service professionals or to registered business partner/users for the purposes and in accordance with the terms as set out in this Privacy Policy.

GRIEVANCE OFFICER

Any queries, complaints, abuse or concerns with regard to any content, comments or breach of this Privacy Policy shall be immediately addressed to the designated Grievance Officer as mentioned below via in writing or through email:

Details of the Grievance Officer:

  1. Name: Pavee Ramanisankar
  2. Designation: COO
  3. Email: pavee@getanthem.com

Latest update: 7th July, 2020