Privacy policy

1. Introduction

Mindweave Transformers Private Limited (“we”, “us”, “our” or “OnFinance”) values your privacy and iscommitted to protecting personal information relating to you (“you”, “your” or “User”).Personal Data refers to information about you that can identify you, such as your name, email address, or phone number (“Personal Data”). This Privacy Policy explains what Personal Data we process, why we process it, how we use it, with whom we share your Personal Data, and your rights regarding your Personal Data. It describes how we handle your Personal Data when you interact with us via our website, the offerings of OnFinance such as NeoGPT, or when you otherwise interact, contact or transact with us.

This Privacy Policy should be read together with our Terms and Conditions, any product/service-specific agreements, and privacy notices provided when your Personal Data is collected. If there is a conflict between this Privacy Policy and a specific privacy notice, the terms of the specific privacy notice will prevail.

If you provide Personal Data or other information about someone other than yourself, or on behalf of an entity,organization, or body corporate, you confirm that you have the legal right, including consent where necessary, to provide the information for the specified purpose.

This Privacy Policy does not apply to our affiliates or partners, each of whom may have their own privacy policies. Insituations where you interact with such partners, we strongly encourage you to review the applicable privacy policy for that particular site, service, orinteraction.

2. What data do we process and why?

We process your data when you interact with us through our website, our offerings such as NeoGPT, or when you otherwise interact, contact or transact with us. The data that we process depends on the activity and the purpose for which the data is used. Here is an activity-wise description:

2.1.When you use the OnFinance website or OnFinance offerings  

When you use our website or our offerings suchas NeoGPT, for utilizing the services provided by us or our offerings, signing up for newsletter, or for contacting us, we may collect and process the following Personal Data:

●      Full name, email address, and phone number;

●      Office location oraddress;

●      IP address, device andbrowser information;

●      Information about you,such as pages visited, time spent, links clicked.

We process your Personal Data forthe following purposes:

●      To enable servicesthrough our website or offerings;

●      To verify your identityand maintain your account;

●      To provide customersupport;

●      To communicate serviceupdates;

●      To personalize userexperience and facilitate collaboration between teams;

●      To ensure technicalfunctionality and secure the platform;

●      To comply withapplicable laws and respond to legal requests.

When you visit our website or use our offerings, we may process certain technical and behavioural data via automated means, such as cookies,pixels, tags, web beacons, embedded scripts, and similar technologies. For more details on our use of cookies and tracking technologies, please see the ‘Cookies and Other Tracking Technologies’ section below. Typically, the information collected via automatedmeans, includes:

●      Your IP address, browsertype, device operating system, referring website, general geographic location(based on IP address), web-browsing behaviour, and interactions with our website and/or our offerings (e.g., pages or screens accessed, duration of visits,activity on a page or screen, access times, and length of access); and

●      To the extent you have consented, we may collect your precise location data.

We use this data for:

●      Administering our website and our offerings, including internal operations like updating,testing, securing, and troubleshooting;

●      Conducting data analysisand monitoring usage trends to improve and develop our services;

●      Customizing yourexperience on our websites and our offerings;

●      Verifying your identityand fulfilling your requests for services on our websites and our offerings;

●      Collecting statistics onyour usage and interactions with our websites and our offerings, as well asgathering feedback on our services;

●      Improving our servicesto provide you and others with a better user experience;

●      Maintaining and protecting the security of our offerings, services, and website, while preventing and detecting security threats, fraud, and other criminal ormalicious activities; and

●      Cooperating with public authorities, courts, regulatory bodies, and supervisory authorities as requiredby law, responding to legal requests, resolving disputes, managing risks,seeking legal advice, enforcing our policies and contractual terms, and protecting our business and platforms.

2.2. When you contact us to raise a grievance or complaint

When you contact our support team via email toraise issues or inquiries, we process:

●      Name, email address,phone number;

●      Details of the issue orcomplaint;

●      Communication logs.

We collect the above information for thefollowing purposes:

●      For verifying youridentity;

●      To address and resolveyour complaints or requests;

●      To contact you via email, SMS or text message andproviding you with the requested information, or resolution to your raised grievanceor complaint;

●      To improve our services;and

●      To comply with legalobligations, cooperating with public authorities, courts, tribunals, regulatory bodies and supervisory authorities as required by law, responding to legal requests, resolving disputes, managing risks, seeking legal advice, enforcing our policies and contractual terms, and protecting our business and platforms.  

2.3. When you interact with us through any marketing communication

You may consent to subscribe to or engage withour marketing communications (e.g., marketing newsletters, news or eventsrelating to our services) through various channels, including our website orour offerings, social media pages, advertisements on third-party platforms, orinteractions with our customer support. We process the following Personal Datato send you any marketing communications:

●      Information you provide while subscribing to our marketing communications, such as name, email,address, telephone number, company (if applicable), and location data, asnecessary to send marketing and commercial communications to you;

●      Information about your interactions with our website or our offerings, to see what services interestyou.

We collect your personal data for the followingpurposes:

●      To provide you with marketing communications, or if you are an enterprise customer, to sharerelevant commercial opportunities;

●      To contact you via email, SMS or text, and provide you such marketing communication;

●      To gather feedback and analyse the effectiveness of our marketing efforts, targeted advertisements, and surveys;

●      To improve our servicesand provide you and others with better user experience; and

●      To personalize ourcommunications with you.

2.4. When you engage with us on social media platforms

When you interact with us on social media (e.g.sharing comments on posts of our official page on any social media platform),we may process your Personal Data publicly available on these platforms. This includes:

●      Your full name or username (as displayed on the social media platform), your profile picture (ifpublicly available) and country (if indicated on your profile); and

●      Any comments or contentyou post publicly regarding us.

We process such data (which may include yourPersonal Data), for the following purposes:

●      responding to yourcomments and posts about our offerings and services;

●      gathering feedback onour offerings and services, and analysing the effectiveness of our social mediaposts;

●      improving our offerings and services to provide you and others with a better user experience;

●      analysing trendsrelating to our offerings and services, and developing new offerings or services accordingly; and

●      cooperating with publicauthorities, courts, tribunals, regulatory bodies and supervisory authoritiesas required by law, responding to legal requests, resolving disputes, managingrisks, seeking legal advice, enforcing our policies and contractual terms, andprotecting our business and platforms.

2.5. When you applyfor a job with us

When you interact with us about job openings at OnFinance, we collect the following Personal Data:

●      Contact details (such asfull name, email address, phone number, country of residence, home address, andother contact information);

●      Data about yourqualifications and other documentation (such as education history, workexperience); and

●      Data required to conductbackground or employment checks in accordance with the applicable law, and dataabout your job preferences.

We use this information for the followingpurposes:

●      Communicating with youregarding your interest with us or for your job application;

●      Verifying your data,including background checks for employment purpose, in accordance withapplicable law;

●      Cooperating with publicauthorities, courts, tribunals, regulatory bodies and supervisory authoritiesas required by law, responding to legal requests, resolving disputes, managingrisks, seeking legal advice, enforcing our policies and contractual terms, andprotecting our business and platforms.

3. Where we collect your Personal Data from?

We may collect your Personal Data from severalsources, including:

(i)        Personal Data you provide directly: This includes anyPersonal Data you share with us through our websites and/or our offerings, orother means, such as social media channel, or directly communicate with ourcustomer support.

(ii)       Personal Data we collect automatically: When you use ourwebsite or our offerings, we use automated means such as cookies and similartechnologies to automatically collect certain technical and behavioural dataabout you, including your Personal Data, that helps us in improving your userexperience.

(iii)     Personal Data we receivefrom third parties: We may also receivedata, including Personal Data, about you from external sources, such as ourbusiness partners or third-party platforms. This includes third-party analyticsservice providers, marketing and advertisement service providers, and social media channels like Facebook, as well as other public sources/platforms (suchas public database). We take steps to ensure that the information we receivefrom these third parties has been collected with your consent, or that these parties are otherwise legally permitted to disclose your Personal Data to us. We may also obtain information through our business partners or co-create datasets with them as part of our business operations. In some cases, wecombine your Personal Data that we receive from multiple sources, includingdirectly collected from you. This aggregated data is utilized for variouspurposes, including improving our services, improvement of user experience, anddeveloping new offerings and services.

4. Who we share your data with?

We share your Personal Data, with thirdparties, in accordance with this Privacy Policy or as required by law. Toclarify, we do not sell or otherwise disclose your Personal Data for unrelated purposes.

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(a) Service Providers
We engage third-party service providers to perform various functions for us and support us in facilitating our services to you. These include providers of hosting and management services, customer relationship management, database storage, order fulfilment, sending emails and text messages (including via WhatsApp), and marketing and advertising services. These service providers process your Personal Data only on our behalf and are contractually bound not to use it for any other purposes except as instructed by us or required by applicable law.

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(b) Business Partners
In certain cases, we collaborate with trusted business partners, to offer our offerings and services. These business partners process your Personal Data in accordance to this Privacy Policy and on our behalf, and are contractually bound not to use it for any other purposes except as instructed by us or required by applicable law.

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(c) Our affiliate companies
We may share your data, including your Personal Data, with companies within our corporate group, including affiliates, subsidiaries, or businesses under common ownership and control, to provide, maintain, or improve our products and services. All affiliated companies are required to process your Personal Data in accordance with this Privacy Policy or similar data protection standards.

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(d) Legal and regulatory processes
We may disclose your data with third parties (such as governmental authorities, law enforcement agencies, etc.) if:
(i) necessary to comply with applicable laws and regulations or directions of governmental authorities or law enforcement agencies, court judgments, decree or orders under any law in force;
(ii) required to respond to a valid subpoena, warrant, or court orders;
(iii) necessary to prevent, detect and prosecute any kind of fraudulent/illegal behaviour;
(iv) to enforce our Terms and Conditions or other policies;
(v) needed to investigate and defend ourselves against claims or allegations;
(vi) necessary to protect the rights and safety of OnFinance, our customers, personnel or others;
(vii) required by our auditors and legal advisors to assess our disclosure obligations and rights under this Privacy Policy; and
(viii) as permitted or required by applicable law.

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(e) Corporate transactions / Change in control
If we are involved in a merger, acquisition, restructuring, or sale of assets, your Personal Data may be transferred as part of that transaction. Any recipient of your data will be obligated to protect it according to this Privacy Policy.

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(f) With your consent
If you give explicit consent or make a specific request, we may share your data with other parties for purposes not covered in this Privacy Policy.

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5. How long do we keep your Personal Data?

We keep your Personal Data for as long asnecessary for the activity for which it was collected and to fulfil the purposes outlined in this Privacy Policy. Once the data is no longer needed forthese purposes or to meet legal, regulatory, or business requirements, we willsecurely delete it.

Youmay request deletion of your account information and Personal Data using bycontacting us at the email address provided below (How to contact us) in this Privacy Policy.

While we work to fulfil such deletion requests,we may need to retain certain Personal Data for a while longer for thefollowing reasons:

(a)       to perform our contractual obligations to which you are subject, or to respond toyour questions or provide necessary service or support;

(b)       to prevent fraud, resolve complaints, address inquiries, or exercise/defend legal claims, including providing evidence in legal proceedings;

(c)       to comply with legal obligations, exercise our rights, resolve disputes, or for security and safety reasons, as permitted under the law (such as adhering toapplicable statutes of limitations or regulatory investigations).

We may also retain anonymized data, aggregatedwith other anonymized information, for analytics, research, or other businesspurposes.

6. Your rights

You have certain rights over your Personal Data:

(a)       Right to access information about your Personal Data: You can ask us for a summary of your Personal Data, the processing activity, and the recipients with whom we have shared your Personal Data, along with a description of the Personal Data we shared.

(b)       Right to seek correction and erasure of Personal Data: If you believe that the Personal Data we hold isinaccurate, incomplete or outdated, you can write to us. You may also requestdeletion of your data; however, in certain cases, we may need to retain it forlegal or regulatory reasons (See Clause 5(How long we store your data) above).

(c)       Right to grievance redressal: If you wish tofile a grievance, you may contact our Data Protection Officer / GrievanceRedressal Officer in accordance with this Privacy Policy. If your grievanceremains unresolved, please be informed that you have the right to escalate itto the competent supervisory authority i.e., Data Protection Board.

(d)       Right to Nominate: You can designate anotherindividual to exercise your rights under this Privacy Policy on your behalf, inthe event of your death or incapacity.

(e)       Right to opt out: If we are processing your Personal Data based on your consent, you may withdraw your consent at any time.Should you do so, you may not be able to access some of our products orservices. You may choose to opt out of receiving marketing communication fromus.

To exercise any of these rights or seek furtherinformation, you can write to us at info@onfinance.in.We reserve the right to verify your identity before processing your request,and not to respond to complaints that we believe are manifestly false,unfounded, or frivolous. Additionally, these rights may be limited in certaincases, where we are legally required to process or retain your Personal Data.

7. How we protect your personal data?

We are committed to ensuring the security of the Personal Data weprocess, protecting it from unauthorized access, alteration, disclosure, ordestruction. Based on the type and sensitivity of the data, we implement avariety of technical and organizational measures to safeguard your PersonalData from such loss, misuse, unauthorized disclosure, and alteration. Werequire our employees, agents, contractors, and third parties with access toyour Personal Data to perform business functions, to process your Personal Datain accordance with this Privacy Policy. While we make every effort to protectyour Personal Data, we understand that no system can guarantee completesecurity. If you have any concerns, need assistance, or suspect that yourinteraction with us is no longer secure, please contact us immediately usingthe instructions under the How to ContactUs section below.

8. Third Parties and Links

Our website, our offerings and/or our services,may contain some links to external third-party websites and/or services. Suchexternal third-party websites and/or services are not under our control. If youchoose to use such linked third-party websites, services and/or products, thePersonal Data shared with them will be governed by their own terms and privacypolicies, and not this Privacy Policy. We are not responsible for such externalthird-party content, products, services and/or websites, including anysubcontractors they may use. Accessing such content, products, services and/orwebsites, is at your own risk, and we recommend reviewing their privacypolicies to understand how they manage your data.

9. Cookies and other tracking technologies

We use cookies and similar trackingtechnologies to enhance your experience on our website and other platforms,improve our services, and better understand how you interact with our content.Cookies are small data files stored on your device via your web browser basedon your consent, when you access any of our platforms. These files help inascertain your preferences, track trends, and enable faster logins, among otherpurposes. They collect data such as your IP address, browser type, and devicetype (e.g., PC, smartphone), and identify your subsequent visits to ourplatforms and tailor our offerings and services more precisely to yourinterests. We utilize cookies to accumulate information on your use of thedesignated portions of our platforms and facilitate the analysis of ourservices, user engagement, and measurement of effectiveness of our marketingand promotional communications. For example, these cookies help us see whichweb pages on our website are popular or to run user surveys.

We use both session cookies and persistentcookies. Session cookies are deleted when you close your browser, whilepersistent cookies remain on your device until they expire or you delete them.

You can control how cookies are used throughyour browser or device settings, where you can disable or delete all or somecookies. However, disabling or rejecting cookies may limit your access to allor certain features of our website or services, for which we require the use ofcookies.

10. Children’s Privacy

Our website, our offerings and/or our servicesare not intended for use by children under the age of 18 years. We do notknowingly collect, process or store Personal Data of children under the age of18 years. If you are a child under 18 years of age, please do not provide anyPersonal Data to us. Parents or legal guardians who become aware that theirchild may have provided us any Personal Data, may contact us using theinstructions under the How to Contact Us sectionbelow, for requesting deletion of their child’s Personal Data.

11. How to contact us?

You may contact us to exercise your rights orfor notifying discrepancies / raising grievances with respect to your PersonalData you provide to use or on any other aspect of this Privacy Policy, bycontacting our Grievance Redressal Officer/Data Protection Officer as set outbelow:

Name: Priyesh Srivastava

Email: priyesh@onfinance.in

Address: G904, Godrej Air, Bangalore MetroStation, Godrej Air Nxt, Junction, near Hoodi, Seetharampalya, Hoodi,Bengaluru, Karnataka 560048

Grievance redressal timeline: Asper the applicable laws, we aim to acknowledge your grievance or complaintwithin 24 hours and resolve it within 15 days, in compliance with applicablelaws.

12. Updates to this Privacy Policy

We reserve the right to modify, add, or remove portions of this PrivacyPolicy, at our sole discretion. We will make reasonable efforts to notify youof any material changes. Once the revised PrivacyPolicy is published on our website and/or other platforms, the changes willtake effect immediately unless stated otherwise. Your continued use of ourplatforms, products and services after such update constitutes consent to the updatednotice to the extent permitted by law. Please take the time to periodicallyreview this Privacy Policy for the latest information on our privacy practices.