PRIVACY POLICY

1.

INTRODUCTION

1.1

The domain name http://zetapp.in/ and the associated mobile application titled ‘ZET’ along with all upgrades, updates, enhancement and modifications thereto (“Domain”) is owned and managed by Vistas Technolabs Private Limited, a company incorporated under the provisions of the Companies Act, 2013 and having its registered office address at 1105, Rawal Ji Ka Bazar, Near Hotel Sun City, Ganga Pol Jaipur, Rajasthan, 302002 (hereinafter referred to as “ZET” which expression shall, unless it be repugnant to the context or meaning thereof, be deemed to include its successors, affiliates, and permitted assigns).

1.2

ZET is committed to respecting your online privacy and recognizes your need for appropriate protection and management of any information that you share with ZET on the Domain. This privacy policy (“Policy”) explains how ZET will collect, use, share and process information in relation to the Services provided on the Domain.

1.3

This Policy shall be deemed to be incorporated into the terms of use applicable to you as a user/visitor of the Domain (“Terms”) and shall be read in addition to the Terms. In the event of any conflict between this Policy and the Terms, the interpretation placed by ZET shall be final and binding on you. All words used in capitalized form herein but not defined shall have the meaning ascribed to the term in the Terms.

1.4

By accepting this Policy, through an affirmative action, you provide free, specific, informed, unconditional and unambiguous consent to ZET and agree to the collection, use, sharing and processing of personal information as described herein. If you provide ZET with personal information about someone else, you confirm that (a) such information is accurate and up to date; (b) such person is aware that you have provided their information; and (c) they consent to both the disclosure and the use/processing of their information in accordance with this Policy. This Policy applies to all the current and former visitors, users and others who access the Domain.

2.

SCOPE

2.1

This Policy is an electronic record in the form of an electronic contract formed under the Information Technology Act, 2000 and the rules made thereunder. This Policy does not require any physical, electronic or digital signature.

2.2

By agreeing, accessing or using the Domain or giving ZET your information or otherwise clicking to accept this Policy, if and when prompted on the Domain, you undertake that you have the capacity to enter into a legally binding contract vide. this Policy, which constitutes a legally binding document between you and ZET under applicable law, in particular, the Indian Contract Act, 1872. ZET will collect and process your personal and third-party data carefully, only for the purposes described in this Policy and only to the extent necessary as defined herein and within the scope of the applicable legal regulations. This Policy seeks to ensure that any personal information or third-party information handled by ZET is managed in a way that is ethical, compliant and adheres to best industry practices.

2.3

Please read the terms and conditions of this Policy carefully, before accepting the same and/or accessing or using the Domain. By accessing or using the Domain including its Services or otherwise clicking to accept this Policy, if and when prompted on the Domain, you agree to the terms of this Policy. If you are accepting this Policy on behalf of another person, you represent and warrant that you have full authority to bind such person to these terms. If you are accepting this Policy on behalf of a child or person with disability, you represent and warrant that you are a parent or legal guardian of such a child or person with disability, as the case may be.

2.3

This Policy describes the types of information ZET collects, why and how ZET uses the information, with whom ZET shares it, and the choices you can make about ZET’ use of the information. This Policy also describes the measures ZET takes to protect the security of the information and how you can contact ZET about its privacy practices.

2.4

Further, this Policy describes ZET’ current data protection policies and practices and may be amended/updated from time to time. ZET will notify you at least once in a year, or whenever there is a change in the Policy, by email or by posting a conspicuous notice on the Domain regarding its then applicable data protection policies. The Policy shall come to effect from the date of such update, change or modification. It is recommended that you regularly check this Policy to apprise yourself of any updates. Your acceptance or continued use of the Domain or provision of data or information thereafter will imply your unconditional acceptance of such updates to this Policy.

3.

CONSENT

By performing the affirmative action, as deem fit by ZET , you expressly, freely, unconditionally, and unambiguously consent to ZET use and disclosure of your Personal Information (as defined below) and third-party information in accordance with this Policy. If you do not agree with the terms of this Policy, please do not use the Domain.

4.

TYPES OF INFORMATION

4.1

Personal Information is defined as any information that relates to a natural person, which, either directly or indirectly, in combination with other information available or likely to be available with a body corporate, is capable of identifying such person.

4.2

Personal Information: Personal Information means any information that may be used to identify an individual, including, but not limited to, the first and last names, telephone number, e-mail address, photograph, or any other contact information, educational qualifications and work experience. ZET limits the collection of Personal Information to that which is necessary for its intended purpose. Further, Sensitive Personal Data or Information (“SPDI”) of a person under applicable law includes Personal Information about that person relating to passwords, financial information including but not limited bank accounts, credit and debit cards or other payment instruments, and physical information. ZET limits the collection of Personal Information (including, SPDI) to that which is necessary for its intended purpose. It is being expressly clarified that ZET neither collects nor stores your biometric information.

4.3

ZET may have one time access to your camera, microphone, location and/or mobile device and store such information only for the purpose of onboarding or KYC requirements of ZET and/or Partners with your explicit consent, in accordance with the Guidelines on Digital Lending, 2022 issued by Reserve Bank of India (RBI) and as amended from time to time.

4.4

Non-Personal Information: Non-personal information means information that does not specifically identify an individual, but includes information from you, such as your browser type, the URL of the previous websites you visited, your Internet Service Provider (ISP), operating system and your Internet Protocol (IP) address. ZET may gather any non-personal information regarding how many people visit the Domain, the pages they visit, their IP address, browser types and versions, time zone settings and locations, operating systems, applications installed on your device, device ID, device manufacturer and type, device, connection information, screen resolution, usage statistics, default communication applications and other technology on the devices you use to access the Domain, and shall include all such Personal Information collected and stored by ZET that undergoes the process of de-identification and is no more identifiable to you or any natural person (hereinafter referred to as “Non-Personal Information”). ZET may also collect Non-Personal Information that you voluntarily provide, such as information included in response to a questionnaire or a survey conducted by ZET.

4.5

Usage Information: Usage Information includes without limitation all data and information collected automatically through the Domain (or through the third party analytics service providers), by use and access of the Domain in the nature of system administrative data, statistical and demographical data, and operational information and data generated by or characterizing use of the Domain including without limitation Non-Personal Information, cookies, Domain traffic, time spent on the Domain, number of visits to the Domain and other similar information and behaviour indicating the mode and manner of use of the Domain (hereinafter referred to as the “Usage Information”).

4.6

Personal Information, SPDI, Non-Personal Information and Usage Information hereinafter shall be referred to as “Information”

5.

COLLECTION OF INFORMATION

5.1

ZET may collect Information from you when you (a) access the Domain by clicking on any link(s) shared by ZET; (b) fill any registration form on the Domain; (c) use the Domain for availing any Services provided on the Domain; (d) provide any information as part of Information on the Domain; (e) voluntarily participate in campaigns conducted by ZET on the Domain or respond to questionnaires published by ZET on the Domain (if any); and (f) voluntarily complete a survey or provide feedback in relation to the Services provided on the Domain.

5.2

You hereby acknowledge and agree that all Information is provided by you to ZET voluntarily and the Information provided by you is not subject to any undue influence.

5.3

ZET may use cookies to monitor the Domain usage including, without limitation, to provide useful features to simplify your experience when you return to the Domain, like remembering your Information and to deliver relevant content based on your preferences, usage patterns and location.

5.4

ZET may also collect Non-Personal Information based on your browsing activity and in relation to your use or access to the Domain like your Internet Protocol address, your Operating System, your prior search results etc., which may or may not be publicly accessible.

5.5

Information collected by ZET from a particular browser or device may be used with another computer or device that is linked to the browser or device on which such information was collected.

5.6

You may use the Domain without providing ZET any Information about yourself. However, you may not be able to access certain services on the Domain in case you choose to do so.

5.7

ZET will collect information from your SMS, upon you giving access rights to ZET for the same.We do not collect, read or store any personal SMSs account details etc.

6.

USE OF INFORMATION

6.1

ZET uses the Information you provide to (a) fulfil your requests for the Services offered on the Domain; (b) provide you with relevant information and/or recommendations with respect to financial products offered by the Partners; (c) share it with its Partners to facilitate your registration for the financial product offered by the Partner; (d) provide you with information about Services available on the Domain and offer you other products and services that ZET believes may be of interest to you and (e) manage ZET’ relationship with you.

6.2

ZET may use the Information to monitor your use of the Services and may review and analyse the Information provided by you to provide you with customized recommendations.

6.3

ZET may use your Non-Personal Information or Usage Information for internal business purposes, such as data analysis, research, developing new products and/or features, enhancing and improving existing services and identifying usage trends.

6.4

Subject to and in accordance with applicable laws, ZET has the right to use your Information for the purpose of conducting promotional/marketing related activities on the Domain, including but not limited to, using your Personal Information for making posters/banners to promote ZET Services.

6.5

When you send an email message or otherwise contact ZET through the Domain, ZET may use the Information provided by you to respond to your communication by way of messages on the Domain, Short Message Service (SMS), email or any other communication channels that ZET may deem fit. ZET may also archive such Information and/or use it for future communications with you to inform you regarding updates, newsletters, offers, new services and promotions.

6.6

With your permission, we collect, transmit and store transactional Short Message Service (SMS) data from your phone on our secured ZET server to verify and analyse your financial position, to determine your cash flow, credits, income, and spending pattern and provide you with customized recommendations with respect to products and services. We do not collect, read or store any personal SMSs account details etc.

7.

INFORMATION SHARING

7.1

ZET maintains your Information in electronic form on its devices and on the equipment of ZET’ employees. The Information is made accessible to employees, agents, Partners and third-parties only on a need-to-know basis.

7.2

ZET shares your Information with third parties, including without limitation, Partners, and such other persons as may be engaged by ZET for the purpose of providing Services to you (for instance, service tools), to the extent so required.

7.3

ZET does not rent, sell, or share Information with other people or with other non-affiliated entities, except with your consent or to provide Services you have requested for or under the following circumstances:

a) ZET may share Information with ZET’ Partners, and affiliates to contact you via email, phone, or otherwise for the provision of services being availed by you on the Domain.

b) ZET may engage third party vendors and/or contractors, to perform certain support services, who may have limited access to Information.

c) ZET may share your Information, including Personal Information, with Partners to enable such Partners to contact you via. email or phone for the purpose of providing you with financial products.

d) ZET may rent, sell or share Non-Personal Information or Personal Information in an aggregate form after it undergoes the process of de-identifications and is no more identifiable to you, with any third party.

e) ZET may share Information with government authorities in response to subpoenas, court orders, or other legal process; to establish or exercise legal rights; to defend against legal claims; or as otherwise required by law. This may be done in response to a law enforcement agency's request.

8.

THIRD PARTY SERVICE PROVIDERS

8.1

In addition to the Partners, ZET may engage other third party vendors and/or contractors to perform certain support services, including, without limitation, fulfilment of your service requests, software maintenance services, advertising and marketing services, web hosting services and such other related services which are required by ZET to provide its Services efficiently. These third parties may have limited access to Information. If they do, this limited access is provided so that they may perform these tasks for ZET and they are not authorized by ZET to otherwise use or disclose Information, except to the extent required by law. ZET does not make any representations concerning the privacy practices or policies or terms of use of such websites, nor does it control or guarantee the accuracy, integrity, or quality of the information, data, text, software, music, sound, photographs, graphics, videos, messages or other materials available on such websites. The inclusion or exclusion does not imply any endorsement by ZET of the website, the website's provider, or the information on such website/app.

8.2

The Domain may contain links and interactive functionality interacting with the websites of third parties. ZET is not responsible for and has no liability for the functionality, actions, inactions, privacy settings, privacy policies, terms, or content of any such websites. Before enabling any sharing functions to communicate with any such websites or otherwise visiting any such websites, ZET strongly recommends that you review and understand the terms and conditions, privacy policies, settings, and information-sharing functions of each such third-party websites.

9.

THIRD PARTY SERVICE PROVIDERS

ZET may disclose and/or transfer Information to an investor, acquirer, assignee or other successor entity in connection with a sale, merger, or reorganization of all or substantially all of ZET’ equity, business or assets.

10.

CONTROL OVER YOUR PERSONAL INFORMATION

10.1

You have the right to withdraw your consent at any point, provided such withdrawal of the consent is intimated to ZET in writing through an email at care@zetapp.in requesting the same. If you at any time wish to rectify your Personal Information, you may write to ZET as per paragraph 11 of this Policy.

10.2

Once you withdraw your consent to share the Personal Information, ZET shall have the option not to fulfil the purposes for which the said Personal Information was sought and ZET may restrict you from using the Services on the Domain and/or the Domain itself.

10.3

If you wish to discontinue using the Services provided by ZET on the Domain, you may do so at any time, in accordance with the Terms, by discontinuing your use of the Domain. In other cases, you may discontinue using the Services provided by ZET on the Domain by writing to ZET at care@zetapp.in. However, the Partners who have received your information during the term of your use of the Domain, may continue to retain your Information for such purposes as they may deem fit. Such deletion of Information available with the Partners shall be as per the privacy policy practices of the Partners.

11.

RECTIFICATION/CORRECTION/ERASURE OF PERSONAL INFORMATION

11.1

Except for the Information shared with the Partners, you shall have the right to review your Personal Information submitted by you to ZET on the Domain and to modify, correct, erase or delete any Personal Information provided by you directly on the Domain. You hereby understand that any such modification, correction, erasure or deletion may affect your ability to use the Domain. Further, it may affect ZET’ ability to provide its Services to you. Further, you understand that such modification shall not automatically result in the modification of the Information shared with the Partners.

11.2

ZET reserves the right to verify and authenticate your identity and your Information in any manner in order to ensure accurate delivery of Services. Access to or correction, erasure, updation or deletion of your Personal Information and/or SPDI (as the case may be) may be denied or limited by ZET if it would violate another person’s rights and/or is not otherwise permitted by applicable law.

11.3

If you need to update, erase or correct your Personal Information that ZET may have collected to offer you personalized services and offers, you may send updates , request for erasure and corrections to ZET at care@zetapp.in citing the reason for such rectification or erasure of Personal Information. ZET will take all reasonable efforts to incorporate the changes within a reasonable period of time.

12.

RECTIFICATION/CORRECTION/ERASURE OF PERSONAL INFORMATION

12.1

ZET shall store your Personal Information at least for such period as may be required and permitted by law or for a period necessary to satisfy the purpose for which the Personal Information has been collected. These periods vary depending on the nature of the information and your interactions with ZET.

12.2

ZET may store Non-Personal Information and Usage Information received from you till such time it requires provided such storage and retention is in accordance with applicable law.

12.3

You agree that you will not submit any false information or any illegal or damaging content to the Domain, including while using the Services. ZET reserves the right to terminate access to or the ability to interact with the Domain in response to any concerns ZET may have about false, illegal, or damaging content, or for any other reason, in its sole discretion.

13.

COOKIES

13.1

ZET uses cookies and/or other tracking technologies to distinguish you from other users of the Services and to remember your preferences on the Domain. This helps ZET to provide you with a good experience when you use the Services on the Domain and also allows ZET to improve such Services. Cookies are text files that ZET places in your mobile phone, tablet or other devices to store your preferences. Cookies, by themselves, do not tell ZET your e-mail address or other personally identifiable information unless you choose to provide this information to ZET by, for example, registering on the Domain. They are designed to hold a marginal amount of data specific to a particular user. However, once you choose to furnish the Domain with personally identifiable information, this information may be linked to the data stored in the cookie. ZET uses cookies to understand Domain usage and to improve the content and offerings on the Domain. For example, ZET may use cookies to personalize your experience on the Domain (e.g., to recognize you by name when you return to the Domain). ZET may also use cookies to offer you products, programs, or services. Cookies may be placed on the Domain by third-parties as well, the use of which ZET does not control.

13.2

Session cookies are automatically deleted from your hard drive once a session ends, and most cookies are session cookies. You may decline the cookies, however, if you decline the cookies, you may be unable to use certain features on the Domain and you may be required to re-enter your password frequently. You may opt to leave the cookie turned on.

14.

PROTECTION OF INFORMATION

14.1

ZET has taken adequate measures to protect the security of Information and to ensure that your choices for its intended use are honoured. ZET takes robust precautions to protect your data from loss, misuse, unauthorized access or disclosure, alteration, or destruction.

14.2

ZET considers the confidentiality and security of your information to be of utmost importance. It therefore uses industry standards, and physical, technical and administrative security measures to keep Information confidential and secure and ZET will not share your Information with third parties, except as otherwise provided in this Policy. Please be advised that, however, while ZET strives to protect Information and privacy, ZET cannot guarantee or warranty its absolute security when Information is transmitted over the internet into the Domain. ZET will periodically evaluate this necessity considering your privacy and our relationship while keeping the applicable legislation in mind.

14.3

For any loss or theft of Information, due to unauthorized access to your device through which you use the Domain or other reasons solely attributable to you, ZET shall not be held liable or responsible under any circumstance whatsoever. Further, ZET shall not be responsible for any breach of security or for any actions of any third parties (including, Partners) or events that are beyond ZET’ reasonable control including but not limited to acts of government, computer hacking, unauthorized access to computer data and storage device, computer crashes, breach of security and encryption, poor quality of Internet service or telephone service of the user, etc.

15.

MINOR AND USAGE ON BEHALF OF OTHER PERSON

ZET does not intend to attract anyone under the relevant age of consent or person with disability to enter into binding legal contracts under the laws of their respective jurisdictions. ZET does not intentionally or knowingly collect Personal Information through the Domain from anyone under that age or person with disability. ZET encourages parents and guardians to be involved in the online activities of minor or person with disability to ensure that no Personal Information is collected from a minor or person with disability without their prior consent. If you are using the Domain on behalf of someone else, including but not limited to, on behalf of your minor child/children, you represent and warrant that you are authorised by such person to accept this Policy on their behalf and to give consent on behalf of such person to ZET’ use of such person’s Personal Information as described in this Policy. If you are accepting this Policy on behalf of a child or person with disability, you represent and warrant that you are a parent or legal guardian of such a child or person with disability, as the case may be.

16.

LIMITATION OF ABILITY

16.1

ZET shall not be liable to you for any loss of profit, production, anticipated savings, goodwill or business opportunities or any type of direct or indirect, incidental, economic, compensatory, punitive, exemplary or consequential losses arising out of performance or non-performance of its obligations under this Policy.

16.2

ZET is not responsible for any actions or inactions of any third parties that receive your Information.

16.2

Notwithstanding anything contained in this Policy or elsewhere, ZET shall not be held responsible for any loss, damage or misuse of your Information, if such loss, damage or misuse is attributable to a Force Majeure Event. The term “Force Majeure Event” shall mean any event that is beyond ZET’ reasonable control and shall include, without limitation, sabotage, fire, flood, explosion, acts of God, civil commotion, strikes, lockouts or industrial action of any kind, riots, insurrection, war, acts of government, computer hacking, civil disturbances, unauthorized access to computer data and storage device, computer crashes, breach of security and encryption, pandemic or national/state lockdown due to any reason and any other similar events not within ZET’ control and which ZET is not able to overcome.

17.

OPT-OUT

You may receive communication, including but not limited to messages on the Domain, Short Message Service (SMS) and phone calls from ZET and/or the Partners on the registered mobile number and e-mails on your registered e-mail address. You have the option to 'opt-out' of all newsletters and other general email or marketing communications from ZET by way of links provided at the bottom of each mailer. ZET respects your privacy and in the event that you choose to not receive such mailers, ZET shall take all adequate steps to remove you from such lists. Notwithstanding the foregoing, you understand that you will not be able to opt-out of receiving administrative messages, customer service responses or other transactional communications. ZET also cannot guarantee availability of such opt-out options from the mailers of the Partners. You shall be required to contact the relevant Partner directly in relation to the same.

18.

CHANGES TO THIS POLICY

ZET reserves the right to update, change or modify this Policy at any time. The Policy shall come to effect from the date of such update, change or modification.

19.

GOVERNING LAW AND DISPUTE RESOLUTION

This Policy shall be governed by and interpreted and construed in accordance with the laws of India. The place of jurisdiction shall exclusively be in Bangalore, Karnataka. In the event of any dispute arising out of this Policy the same shall be settled by a binding arbitration conducted by a sole arbitrator, appointed jointly by both parties and governed by the Arbitration and Conciliation Act, 1996, as amended from time to time. The venue and seat of arbitration shall be Bangalore, Karnataka..

20.

GRIEVANCE REDRESSAL MECHANISM

For registering your concerns, complaints or grievances, please reach out to the below mentioned designated officer of ZET at the below-mentioned contact details in relation to any violation of this Policy or the applicable laws. The designated officer shall redress the concerns, complaints or grievances in accordance with the provisions of the applicable laws

Name: Mohan

Email: care@zetapp.in

Phone No: 9910992875

21.

CONTACT DETAILS

If you have questions or concerns about this Policy, please contact ZET at the following email address: care@zetapp.in.

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