Privacy Policy

The privacy policy (“Privacy Policy”) governs the use of the platform hosted by Mynd Fintech Private Limited hereinafter referred to as the”M2 platform” on its website www.myndfin.com (“Website”, “we”, “us”) and the services (“Services”) being provided on the M2 Platform. This Privacy Policy has been duly framed in accordance with the Information Technology Act, 2000 (“Act”) and the rules made thereunder to ensure maximum protection to the information provided by its users (“you”).

We recognize the importance our customers place on the privacy and security of their business and personal information. Our goal is to protect your information in every way that we interact with you, whether on the Internet or otherwise.

The security of your personal data is important to us. We have in place safeguards to protect the personal data stored with us. This policy describes how we may collect, use, disclose, process and manage your personal data.

This policy applies to any individual’s personal data which is in our possession or under our control.

By using the Website, you agree to abide by the terms and conditions pertaining to collection, retention and use of information set forth in this Privacy Policy. If you do not agree to the Privacy Policy, you may exit and cease to use the Website. In addition to the considerations stipulated under this Privacy Policy your activities undertaken on the Website shall also be governed by the Master Agreement signed by the respective parties with Mynd Fintech Private Limited (“Company”) and any other terms and conditions as published by the Company from time to time.

This Privacy Policy is incorporated in the Terms of Use of the Website and any other agreement, in which there is a specific clause incorporating the Privacy Policy in such agreement. In the event of conflict between the terms of such agreements and the Privacy Policy, the terms of such agreements will prevail and govern so long as they relate to matters specifically referenced herein and this Privacy Policy will apply with respect to all other matters.

1. What Data We Collect

1.1.  We may collect, retain and process the information provided by you through e-mail or filing of forms on the Website including but not limited to Information such as your personal particulars (e.g. name, contact details, residential address, date of birth, identity card/passport details, and/or education details);name, address, contact details, email id, details of the organisation on behalf of whom you are acting (if applicable); your specimen signature(s); and other information such as financial details (e.g. income, expenses, and/or credit history); employment details (e.g. occupation, directorships and other positions held, employment history, salary, and/or benefits); banking information (e.g. account numbers and banking transactions) (“Personal Information”).

1.2. Further, we collect, store and process such other information including but not limited to information about your Transaction undertaken on the Website; communication made by you; information generated electronically when you visit the Website or use our services and any modifications made to the information provided by you; information relating to your activities, preferences and interests arising from your use of our products and services; and/or other electronic data or information relating to you such as IP addresses, internet address of the referral site which brought you to visit our Website, date and time of visiting the Website, the name and version of your web browser, online activity, and duration of your online session. cookies, activity logs, online identifiers and location data through your usage of our products and services or as part of their delivery to you (“Other Information”).

1.3. Customer Information, Other Information and Automatically Generated Information shall together be referred to as “User Information”.

2. Usage of Collected Information

2.1. The User Information provided by you may be used by us and provided to third party websites, affiliates, consultants, employees in order to manage, collect, store, process the User Information in order to improve the quality, design, functionality and content of the Website and to any governmental authority under applicable law.

2.2. We may use User Information for business purposes for better user experience, such as developing and providing banking facilities, products or services (whether made available by us or through us), including but not limited to executing banking, commercial or other transactions and requests, including processing, settlement, clearing or reporting on these transactions; carrying out research, planning and statistical analysis; or analytics for the purposes of developing or improving our products, services, security, service quality, advertising or customization strategies; assessing and processing applications, instructions or requests from you; communicating with you, including providing you with updates on changes to products, services and banking facilities (whether made available by us or through us) including any additions, expansions, suspensions and replacements of or to such products, services and banking facilities and their terms and conditions; managing our infrastructure, business operations and complying with internal policies and procedures; responding to queries or feedback; addressing or investigating any complaints, claims or disputes; verifying your identity for the purposes of providing banking facilities, products or services; conducting credit checks, screenings or due diligence checks as may be required under applicable law, regulation or directive; complying with all applicable laws, regulations, rules, directives, orders, instructions, guidance and requests from any local or foreign authorities, including regulatory, governmental, tax and law enforcement authorities or other authorities; monitoring products and services provided by or made available through us; complying with obligations and requirements imposed by us from time to time by any credit bureau or credit information sharing services of which we are a member or subscriber; creating and maintaining credit and risk related models; financial reporting, regulatory reporting, management reporting, risk management (including monitoring credit exposures), audit and record keeping purposes; enforcing obligations owed to us; in connection with performance of our duties and obligations when seeking consultancy or professional advice, including legal advice; and/or administering benefits or entitlements in connection with our relationship with you or arising from your participation in events, campaigns, or marketing promotions by us or in conjunction with our partners; to recommend you products or services, including special offers, promotions, contests or entitlements that may be of interest to you or for which you may be eligible.

3. Third Party Service Providers

3.1. We may share User Information with “Service Providers” (third parties engaged by the Company who provide range of services like website hosting, digital signature verification.etc.) for provision of Services on the M2 Platform. We shall take your consent on the website / M2 Platform before sharing Personal Information with any third party, except for cases where such sharing is required as per statutory or regulatory requirement.

3.2. Any Personal Information provided by you shall be made available to only our Service Providers, employees, that are connected with or in relation to the Services of the Website. Such Service Providers shall not disclose the User Information disclosed to it further other than under such circumstances where disclosure is permissible by us under the terms and conditions of the Privacy policy.

3.3. We and/ or Service Providers may monitor and collect such information that will enable us to verify your credentials, maintain reasonable security practices, enable inclusion of better Services, fulfil your requests and enhance your user experience.
3.4. Other than as set out above, we shall not disclose the User Information to any third party without your written consent basis the Master Agreement signed with you, provided that such information may be disclosed to governmental agencies or bodies as required under applicable law or to exercise legal rights or defend legal claims or protect the safety of other users or public or our rights.

4. Cookies and Related Technologies

4.1. We and/ or our Service Providers may also collect “Cookies” (piece of software code that the Website automatically sends to your browser when you access the Website) in order to collect some of the above-mentioned information that enable us to provide you a better user experience. In some cases, you must accept the Cookies in order to view our Website. We do not link the information we store on the cookies to any personally identifiable information submitted by you. Advertisements may be displayed on our Website as well as on third party websites. When you click such advertisements, you may receive another Cookie, which you may or may not choose to accept. The use of cookies by them is subject to the privacy policy and other terms and conditions governing their website (“Automatically Generated Information”).

5. Consent for use of User Information

5.1. You shall provide us with all the information requested from you on the Website or through any other mode of communication. You are not legally obligated to provide us with all the information. You may give or deny consent for use of User Information or restrict disclosure to Service Providers. However, complete functionality of the Website shall not be rendered possible if you fail to provide us/our Service Providers consent to use the User Information with certain necessary information for the purpose of the Services of the Website. Without prejudice to the aforesaid, you shall have an option to, while availing the Services or otherwise, to withdraw your consent to allow us to use the Personal Information provided by you and if required, make the app delete/ forget the data and intimate us of the same in writing.

5.2. A one-time consent is taken from you at the time you register with us by opening account with us. Accordingly, we may access your camera, microphone, location or any other facility necessary for the purpose of on-boarding/ KYC requirements only. We desist from accessing your mobile phone resources like file and media, contact list, call logs, telephony functions. We do not store/collect your biometric data in our systems, unless allowed under extant statutory guidelines.

5.3. The User Information provided by you shall be used, with your consent, to communicate with you by us through newsletters, updates and notifications. The communication with you might be recorded but will be kept confidential otherwise than when asked to disclose to any governmental authority under applicable law.

5.4. The User Information shall be used for purposes only in relation to the Website and not for any other purposes. The User Information shall be retained till the termination of your Master Agreement or upto such other period as prescribed under Applicable Laws.

5.5. You shall have the right to view the information provided by you and also to update the information and keep us informed of any such change in case the information provided is deficient or inaccurate.

5.6. You undertake that the Personal Information and Other Information provided by you is true and accurate to the best of your knowledge. You agree and understand that we shall not be liable for the authenticity of the Personal Information and Other Information provided by you.

6. Links to third party websites

6.1. The Website contains links to third party websites. We are not responsible for any content on such third-party websites and we shall not be liable for any breach of privacy policy by such websites. You undertake to read and understand the privacy policy of such third-party websites. For the avoidance of doubt, our Privacy Policy only governs the User Information collected, received, possessed, stored, dealt with or handled for the purposes of Services on our Website.

7. Notification and Updates sent by the Website

7.1. We send an email notification to individuals once they sign up to avail services of Website as a Buyer/Supplier/Financier. We will send security related e-mail notifications once you sign up for “notify me” updates on your account(s). Further, we may send e-mail notifications whenever you change your passcode, security question or designated e-mail address.

8. Security Practices

8.1. The User Information shall be governed by and protected by us according to the security practices and procedures mandated under the Act and more particularly described under the Information Technology (Reasonable Security Practices & Procedures and Sensitive Personal Data or Information) Rules, 2011 and Information Technology (Intermediary Guidelines) Rules, 2011.

8.2. The Company and our Service Providers have developed stringent policies and procedure to safeguard the User Information.
8.3. The Website and our Service Providers maintain strong physical, electronic and procedural controls to protect against unauthorized access to customer information. Our computer systems are protected in the following ways:

8.3.1. Computer anti-virus protection detects and prevents viruses from entering our website, email, and computer network systems.

8.3.2. Firewalls and intrusion prevention systems block unauthorized access by individuals or networks.

8.3.3. We use encryption technology, such as Secure Socket Layer (SSL), to protect the transmission of your confidential information. Whenever you login to website or schedule an online transaction through our system, the communication is encrypted. Encryption scrambles the transferred data which ensures that it cannot be read by any unauthorized parties.

8.3.4. We use strong multi-level authentication and behaviour analysis to help prevent unauthorized access to your accounts. Multi-level authentication can help prevent access by someone who may have stolen your login credentials.

8.3.5. We continually monitor technological advances and upgrade our systems to ensure your information remains secure.

9. Beware of Phishing Attempts and Interest Scams

9.1. While email is convenient and has a good business use, it can also be misused by criminals for scams and various other fraudulent purposes. “Phishing emails” are frequently used by criminals to entice the recipient to visit a fraudulent website where they try to convince the recipient to provide personal & confidential information. Some of these fraudulent websites may also be virus laden and can be used to download mal-ware to your computer. Fraudulent websites often look identical to a legitimate site, so it’s important to look very closely at the website address. Below we have listed a few tips to help protect your personal information on the Internet:

9.1.1. Always be wary of links in emails, especially any links in emails purporting to be from this Exchange.

9.1.2. Bookmark financial websites and use these bookmarks every time you visit the website.

9.1.3. Whenever you enter personal information like your access ID or passcode, always look for the lock symbol, or https: in the address bar. Always click on the lock symbol and review the certificate details.

9.1.4. Update your Internet browser. Most browsers now offer free anti-phishing tool bars that can help alert you of fraudulent websites.

9.1.5. Make sure that your computer always has up-to-date versions of both anti-spyware and anti- virus software.

9.1.6. If you receive an e-mail that you think could be a scam, delete it immediately or contact the helpline numbers of the Website.

9.1.7. If you have any questions about the legitimacy of an email, especially an email from this Website, you can also contact us at the numbers or email id provided under “contact us” section of the website

10. Alteration of the Privacy Policy

10.1. The Privacy Policy may be amended, modified or refined from time to time at our sole discretion and the updated Privacy Policy shall be published on the Website and no separate communication shall be made in respect of the same. It shall be your responsibility to keep yourself updated with changes to the Privacy Policy by regularly checking the Website for updates. Usage of the Website’s Services pursuant to a change in its Privacy Policy shall be deemed to be acquiescence of the changed Privacy Policy on your behalf.

11. Grievance Redressal Mechanism

11.1. In order to address any of your requests/grievances w.r.t storage of your data or discrepancies of information displayed on the Website, we have designated a grievance redressal officer (“Grievance Officer”), who can be reached out at grievances@myndfin.com.

11.2. The Grievance Officer shall redress all the grievances expeditiously but within 1(one) month from the date of receipt of the grievance as provided under the Act.