PRIVACY POLICY

This Privacy Policy sets forth the reasonable security practices and procedures adopted by Innovage Fintech Private Limited ("Innovage") and shall apply to the use and disclosure and sharing of sensitive personal data or information ("Personal Information") provided by the registered users/investors of the Website/Web Application www.5nance.com ("Website/Web Application/Mobile Apps"), which is owned, maintained and operated by Innovage. This policy is equally applicable to the visitors/users/investors on the Website/Web Application/Mobile Apps.

We value the trust you have placed with us. To provide you with a convenient and safe online experience, we have implemented measures to protect the confidentiality, integrity, and security of your Personal Information, during storage and transmission through the World Wide Web. This Privacy Policy explains how we protect personal Information provided by you through the Website/Web Application /Mobile Apps and how we store and use that information, to deliver the services on the Website/Web Application/Mobile Apps.

By entering this Website/Web Application/Mobile Apps and providing personal information when subscribing and sending enquiries to us, you expressly agree to this privacy policy. By entering this Website/Web Application/Mobile Apps, you shall be treated as having given your consent to process your personal information as set out in the Privacy Policy.

This Privacy Policy is in conformity with the Industry Standards and Practice, however is subject to change at any time. It is advised that you review this Privacy Policy periodically. This Privacy Policy is also incorporated into and subject to the Terms of Use of the Website/Web Application/Mobile Apps.

Personal Information

Personal information means any information that relates to a natural person, which directly or indirectly is capable of identifying that person.

The personal information collected from you and covered within this Private Policy may include your full name, address, telephone/mobile number, email address, pan number, Bank account number other information as defined in Rule 3 of the Information Technology (Reasonable security practices and procedures and sensitive data or information) Rules, 2011, as may be required by us from time to time in order to provide services to you. However, you have the right to modify or update your personal Information/details with us.

Collection of Personal Information

Most features of the Website/Web Application/Mobile Apps would require registration, which may require you to provide your details such as an email address, a password, pan number and other information.

In case, you avail the online services through www.5nance.com/Mobile Apps, you will be required to provide personal Information like your name, address, pan, and other information required as per applicable regulations ["KYC information"] at the time of registration/activation of such facility. The collection of these KYC Information is obligatory pursuant to regulatory requirements in order to activate and enable the online services. Such KYC information shall be used/shared/maintained/accessed/stored with/by third party technology provider/authorised service providers in order to enable/facilitate/complete/process of online services. Any personal information/KYC information/policy collected from the User/Investor shall be encrypted for data security. The encryption protection is verified by Entrust.

From time to time, the Website/Web Application/Mobile Apps may also request other personal information to provide you with additional benefits of the services as selected by you. On all such occasions, you will have the option to provide or decline to provide that personal information.

The section "Your data is secure" shall describe the various security mechanism followed for securing your data.

You agree and understand that your personal information shall be collected, processed, stored and used by us, and passed to other data processors for the services identified under this Privacy Policy.

Use of Personal Information

The Website/Web Application//Mobile Apps uses and discloses your Personal Information only as follows:

• To the AMC’s/product providers/Insurers/broker’s or their authorised agents for availing the product/schemes/investment required by you.
• To fulfill / complete your requests for products and services offered, or subscribed or availed by you on the Website/Web Application/Mobile Apps.
• To deliver to you any administrative notices, alerts and communications relevant to your use of the services.
• To any Governmental Authority including but not limited to the Reserve Bank of India, SEBI or IRDAI.
• To Third Party Service Providers (including payment gateways) that provide services to Insurers.
• To any regulator for identifying the registered user/investor for complying with Anti Money Laundering Act.
• To comply with orders of the Court, any applicable law or any statutory or legal requirements or process.
• To analyze the Website/Web Application/Mobile Apps usage improve features, tailor the Website/Web Application/Mobile Apps to cater to your interest's and improve the services offered.

For market research, troubleshooting problems, detecting and protecting against error, fraud, hacking or cyber-crimes.

For any of these purposes, we may use group companies / affiliates, third party vendors, agents, contractors, consultants or service providers (individually a 'Third Party Service Provider' and collectively, the "Third Party Service Providers"). Such Third Party Service Providers are bound by privacy restrictions which are similar to the restrictions mentioned in this Privacy Policy.

Sharing and disclosure of Personal Information

We will not disclose your Personal Information with any affiliated or unaffiliated third parties, except as stated under:-

• To provide you the product and services.
• To enforce the terms and conditions of the products or services for transaction processing and report generation.
• To protect the interests of Innovage, its affiliates, directors, officers and employees, representative and authorised agents.

Innovage may disclose or use such data or personal information only in a non-personally identifiable manner (anonymously) for purposes of research, advertising, comparison to organizations approved by Innovage.

Notwithstanding anything above, portions of your data, derived from your Account Credentials/Information, may remain on servers indefinitely. Your data may also remain on our backup server. These backups are required to ensure our continued ability to provide the services and comply with regulations.

If you choose the option of deactivating your account with us from the Website/Web Application/Mobile Apps, your data will be deactivated on our servers and no one except an Authorised person shall have access to your account. However, you always have the option of reactivating your account with www.5nance.com. An Authorised Person shall have the access to comply with orders of the Court, any applicable law or any statutory or legal requirements or for re-activating your account with your consent.

Non-personal identification information

We may collect non-personal identification information about Users/Investors whenever they interact with our Website/Mobile Apps. Non-personal identification information may include IP address, the browser name, the type of computer and technical information about Users means of connection to our Website/Mobile Apps, such as the operating system and the Internet service providers utilized and other similar information.

Promotional Communication from the Website/Web Application/Mobile Apps

The Website/Web Application/Mobile Apps will provide you with periodic summaries of your Account Information and send email / SMS alerts. The Website/Web Application/Mobile Apps also allows you to subscribe to email newsletters, research information and from time to time may transmit emails / SMS promoting the Website/Web Application/Mobile Apps or third-party products or services. You have the ability to opt-out of receiving our promotional emails / SMS and to terminate your newsletter subscriptions by following the instructions on the Website/Web Application/Mobile Apps. Opting out in this manner will not end transmission of service-related emails / SMS or transactional alerts.

Third Party Services and Website/Web Applications/Mobile Apps

You should be aware that Innovage shall permit third parties to offer subscription and/or registration-based services through the Website/Web Application/Mobile Apps. Innovage shall not be responsible for any actions or policies of such third parties, and you should check the applicable privacy policy of such third parties while providing personally identifiable information. Further, Innovage will not be responsible for any services/ benefits announced, if any, by the third parties permitting to offer subscription and registration based services on its Website/Web Application/Mobile Apps.

Personal information will not be sent/transferred to these third parties by Innovage unless reasonable steps have been taken to maintain the required level of data protection.

Blog on financial investment and other Forums on the Website/Web Application/Mobile Apps

While using a bulletin board, blog or chat room on the Website/Web Application/Mobile Apps, you should be aware that any information you submit there can be read, collected or used by other users/visitors and could be used to send you unsolicited messages. The Website/Web Application/Mobile Apps and Innovage are not responsible for any personal information you choose to submit in these forums. These forums shall be hosted by the Website/Web Application/Mobile Apps or by our Third Party Service Providers on behalf of Innovage.

Use of Cookies and Online session information

The Website/Web Application/Mobile Apps will automatically receive and collect certain anonymous information in standard usage logs through our web server, including computer-identification information obtained from "cookies" sent to your browser from a web server or by other means.

The Website/Web Application/Mobile Apps uses cookies for a number of purposes. For instance, to enable us to simplify the logging on process for registered users including helping to ensure the security and authenticity of registered users. Please note that most Internet browsers will allow you to stop cookies from being stored on your computer and to delete cookies stored on your computer. If you choose to eliminate cookies, the full functionality of the services may be impaired for you.

Your Data is Secure

When you register for the services, the Website/Web Application/Mobile Apps requires a Login ID and a password from you for your privacy and security. For further security, OTP (One Time Password) will be generated and will be sent on your registered mobile number for enabling your online transactions. You are responsible for maintaining the confidentiality of your Login ID, password and OTP. You should not provide these credentials/information to any third party. It is recommended that to protect yourself and your online information you should change your password periodically.

Your password must conform to standards and as a security feature the Website/Web Application/Mobile Apps will automatically reject weak passwords. It is recommended that you should pick a strong password for online security. We shall not be responsible if someone else accesses your account through Login ID and password they have obtained from you or through a violation by you of this Privacy Policy or the Website/Web Application's/Mobile Apps Terms of Use.

While accessing your accounts online, the Website/Web Application/Mobile Apps uses a combination of firewall barriers, encryption techniques and authentication procedures, among others, to maintain the security of your online session, and to protect Website/Web Application/Mobile Apps accounts and systems from unauthorized access. From the time you submit your Login ID and password, these communications between your computer and the Website/Web Application/Mobile Apps are encrypted using at least 256-bit encryption socket layer technology (SSL), Bank Level Security. This enables client and server applications to communicate in a way that is designed to prevent eavesdropping, tampering and message forgery. The Website/Web Application/Mobile Apps also encrypts your Website/Web Application/Mobile Apps password so that your password cannot be recovered, even by us.

For enhanced security, all Account Credentials/Information of your bank account and other personal information provided by you, for your use / consolidated view are encrypted and stored by us in a highly secured data center with bio-metric access 24/7 surveillance and electronic locking system along with full-fledged disaster recovery system.

Breach of Internal Security

Despite our best efforts as stated above, if any unauthorised person breaches our security control measures beyond our control resulting in the website/Mobile Apps being hacked, Innovage shall not be held responsible for the same.

Feedback

If you have questions, comments, concerns or feedback regarding this Privacy Policy or any other privacy or security concern, you can contact us at customercare@5nance.com.

Last updated: 28^th October, 2020