We MAVY FINTECH PVT LTD., a Company, incorporated under the Companies Act, 2013, having its registered office at “2nd Floor, Office No. 203, 1 Aerocity Premises Co-Op Society Ltd, Andheri Kurla Road, Safed Pool Sakinaka Andheri (E) Mumbai - 400072” represented by its members, hereinafter referred to as the “Company” (where such expression shall unless repugnant to the context thereof, be deemed to include its respective legal heirs, representatives, administrators, permitted successors and assigns.) The creator of this Privacy Policy ensures steady commitment to Your privacy with regard to the protection of your invaluable information.

This privacy policy contains information about its Mobile application Mavy Fintech and the web application – https://mavyfintech.com (hereinafter collectively referred to as the “Platform”).

In order to provide You with Our uninterrupted use of services, We may collect and, in some circumstances, disclose information about you with your permission. To ensure better protection of Your privacy, We provide this notice explaining Our information collection and disclosure policies, and the choices You make about the way Your information is collected and used.

By visiting https://mavyfintech.com or accessing the mobile application, you acknowledge and accept the practices outlined in this Privacy Policy. All users of the mobile application (the "Application") or website (the "Website") are encouraged to read and fully understand our Privacy Policy. By accessing the Application, you agree to be bound by its terms and conditions, and consent to the collection, storage, and usage of your information as detailed herein. Your use of the Smart Bazaar Business mobile application signifies your explicit consent to the use and disclosure of your personal information in accordance with this Privacy Policy. This Privacy Policy is incorporated into and forms part of the Terms of Use. If you have any questions or concerns, please contact our Customer Support Desk at info@mavyfintech.com.

ANY CAPITALISED WORDS USED HENCEFORTH SHALL HAVE THE MEANING ACCORDED TO THEM UNDER THIS AGREEMENT. FURTHER, ALL HEADING USED HEREIN ARE ONLY FOR THE PURPOSE OF ARRANGING THE VARIOUS PROVISIONS OF THE AGREEMENT IN ANY MANNER. NEITHER THE USER NOR THE CREATERS OF THIS PRIVACY POLICY MAY USE THE HEADING TO INTERPRET THE PROVISIONS CONTAINED WITHIN IT IN ANY MANNER.

1. DEFINITIONS
"We", "Our", and "Us" refer to the Platform and/or the Company, depending on the context.
"You", "Your", "Yourself", "User", "Buyer", and "Customer" refer to natural and legal individuals who use the Website and are legally competent to enter into binding contracts under Indian law.
"Buyers/Customers" refers to any person who avails the services or products of the Merchant and makes the corresponding payment or remittance.
"User" refers to both "Customers/Buyers".
"Services" refers to the Platform that develops custom Unified Payments Interfaces (UPI) for retailers and businesses to accept online payments.
"Third Parties" refers to any application, company, or individual other than the User and the creator of this Application.
"Merchant Services" refers to the products or services provided by the Merchant to its Customers, for which payments or remittances are made through the Customer's valid accounts, cards, or bank accounts using Smart Bazaar Services.
"Platform" refers to the application for accepting payments via any UPI app.
"Personal Information" refers to any personally identifiable information we may collect from you, such as your name, date of birth, gender, location, and credit/debit card details. For further clarification, please refer to Clause 2.

2. INFORMATION WE COLLECT

We are committed to protecting your online privacy and recognize the importance of safeguarding your Personal Information. We collect the following types of information: - **Personal Data**: This includes, but is not limited to, your name and mobile number. - **Store Details**: This includes your store's name, location, and category. - **Bank Account Information**: This includes details such as your IFSC code, bank account number, and PAN number. - **Tracking Information**: This includes data such as your device's IP address, device ID, browsing history, URLs accessed, and other interactions with the application. - **Application Usage Data**: We collect analytics on how you use the application. This Privacy Policy also applies to data collected from non-registered users, such as browsing behavior and pages viewed. We collect and store personal information provided by you on the site as necessary to provide a seamless, efficient, and secure experience customized to your needs. This information is used for: - Providing the services you have opted for - Communicating account and service-related information - Offering customer care and data collection services - Complying with applicable laws, rules, and regulations If a service request involves a third party, we may share the necessary information with that third party to fulfill your request. We may also use your contact details to send personalized offers based on your interests and activities. You can opt out of these communications by unsubscribing through the button or by emailing us at info@mavyfintech.com. You may occasionally provide financial information, such as credit card details or bank account information, through the platform. We ensure that all sensitive data is securely handled via approved payment gateways that are digitally encrypted. This data is stored in our internal servers for a limited time, and deleted upon the expiry of your user membership or upon withdrawal of your consent. We will only use your financial information to complete transactions and will not use it for any other purposes. You have the option to withhold certain information or choose not to use specific features on the site. You can also opt out of non-essential communications. Please be aware that online transactions have inherent risks. To mitigate these risks, you should follow security best practices, such as safeguarding your account/login information and notifying customer care of any suspicious activity. You have the right to access, modify, or delete your personally identifiable information at any time, as well as restrict its retention or use, according to your preferences.

3. OUR USE OF YOUR INFORMATION

The information you provide will be used to deliver and enhance our services for you and all users.
- **Internal Records**: We use your information to maintain accurate internal records. - **Service Provision**: We use your data to provide and improve our services. - **Service Enhancement**: Your information helps us refine and enhance the services we offer.
For more details about the nature of communications, please refer to our Terms of Service. Additionally, your personal and sensitive personal data may be collected and stored by us for internal record-keeping.
We may share certain details such as name, location, and phone number of customers with sellers, and vice versa, for the purpose of providing services.
Your tracking information, such as IP address and device ID, helps us identify you and gather demographic data to improve our services.
r We do not sell, license, or trade your personal information. We will only share your personal data with third parties if they are acting on our behalf, or if we are legally required to do so.
Information collected through our server logs, including IP addresses and pages visited, helps us manage and troubleshoot the platform. We also use third-party analytics, tracking, optimization, and targeting tools to understand user engagement, enabling us to improve the platform and provide personalized content or ads based on user preferences.

4. HOW INFORMATION IS COLLECTED

We will clearly identify the purposes for which personal information is being collected, either before or at the time of collection. If the purpose is not communicated to you, you have the right to request clarification from the Company. Until this is provided, you are not obligated to disclose any personal information.
We will collect and use your personal information exclusively to fulfill the specified purposes, within the scope of your consent or as required by law. Personal data will be retained only as long as necessary to achieve those purposes. We will collect personal information through lawful, fair means, with the knowledge and consent of the individual concerned.
The personal data collected should be relevant to the intended purposes, and, when necessary, should be accurate, complete, and up-to-date.

5. COOKIES

We use data collection devices such as “cookies” on certain pages of our applications. “Cookies” are small files sited on your hard drive that assist us in providing customised services. We also offer certain features that are only available through the use of a “cookie”. Cookies can also help us provide information which is targeted to your interests. Cookies may be used to identify logged in or registered users. Our Application uses session cookies to ensure that you have a good experience. These cookies contain a unique number, your 'session ID', which allows our server to recognize your computer and 'remember' what you've done on the Platform. The benefits of this are:

You only need to log in once if you're navigating secure areas of the site
Our server can distinguish between your computer and other users, so you can see the information that you have requested.
You can choose to accept or decline cookies by modifying your browser settings if you prefer. This may prevent you from taking full advantage of the Platform. We also use various third-party cookies for usage, behavioural, analytics and preferences data. The following are the different types of Cookies used on the Platform:

Authentication cookies:To identify the user and share the content that he or she requested for.
Functionality cookies:For customised user experience and resuming past course progress.
Tracking, optimization and targeting cookies:To capture usage metric on device, operating system, browser etc. to capture behavioural metrics for better content delivery. To cater and suggest the most suited products and services.

6. 3rd PARTY ANALYTICS

We use 3rd Party Analytics tools to help us to understand how you make use of our content and work out how we can make things better. These cookies follow your progress through our, collecting anonymous data on where you have come from, which pages you visit, and how long you spend on the site. This data is then stored by Google in order to create reports. These cookies do not store your personal data.

The information generated by the cookie about your use of the Application, including your IP address, may be transmitted to and stored by the 3rd Party on their servers. The 3rd Party may use this information for the purpose of evaluating your use of the Application, compiling reports on Application activity for us and providing other services relating to Application activity and internet usage. The 3rd Party may also transfer this information to third parties where required to do so by law, or where such third parties process the information on the 3rd Party’s behalf. By using this Application, you consent to the processing of data about you by the 3rd Party in the manner and for the purposes set out above.

7. EXTERNAL LINKS ON THE APPLICATION

The Application may include advertisements, hyperlinks to other Applications, applications, content or resources. We have no control over any Applications or resources, which are provided by companies or persons other than Us. You acknowledge and agree that we are not responsible for the availability of any such external sites or resources, and do not endorse any advertising, services/products or other materials on or available from such platforms or resources. You acknowledge and agree that We are not liable for any loss or damage which may be incurred by you as a result of the availability of those external sites or resources, or as a result of any reliance placed by you on the completeness, accuracy or existence of any advertising, products or other materials on, or available from such Application s or resources. These external Application s and resource providers may have their own privacy policies governing the collection, storage, retention and disclosure of Your Personal Information that You may be subject to. We recommend that you enter the external Application and review their privacy policy.

8. YOUR RIGHTS

Unless subject to an exemption, you have the following rights with respect to your personal data:

The right to request a copy of your personal data which we hold about you
The right to request for any corrections to any personal data if it is found to be inaccurate or out of date
The right to withdraw Your consent to the processing at any time
The right to object to the processing of personal data
The right to obtain information as to whether personal data are transferred to a third country or to an international organisation.
Where you hold an account with any of our services, you are entitled to a copy of all personal data which we hold in relation to you.

9. CONFIDENTIALITY

You further acknowledge that the Platform may contain information which is designated confidential by us and that you shall not disclose such information without our prior written consent. Your information is regarded as confidential and therefore will not be divulged to any third party, unless legally required to do so to the appropriate authorities. We will not sell, share, or rent your personal information to any third party or use your email address for unsolicited mail. Any emails sent by us will only be in connection with the provision of agreed services, and you retain sole discretion to seek discontinuation of such communications at any point of time.

10. OTHER INFORMATION COLLECTORS

Except as otherwise expressly included in this Privacy Policy, this document only addresses the use and disclosure of information we collect from you. To the extent that you disclose your information to other parties, whether they are on our Platform or on other sites throughout the Internet, different rules may apply to their use or disclosure of the information you disclose to them. To the extent that we use third party advertisers, they adhere to their own privacy policies. Since we do not control the privacy policies of third parties, you are subject to ask questions before you disclose your personal information to others.

11. OUR DISCLOSURE OF YOUR INFORMATION

We shall disclose details including but not limited to Name, Location, Phone number, etc. of the Customers to the Sellers and Name, Phone number, etc. of the Sellers to the Customers for the purpose of provision of Services to the aforementioned. Information collected will not be considered as sensitive if it is freely available and accessible in the public domain or is furnished under the Right to Information Act, 2005, any rules made there under or any other law for the time being in force.

Due to the existing regulatory environment, we cannot ensure that all of your private communications and other personally identifiable information will never be disclosed in ways not otherwise described in this Privacy Policy. By way of example (without limiting and foregoing), we may be forced to disclose information to the government, law enforcement agencies or third parties. Therefore, although we use industry standard practices to protect your privacy, we do not promise, and you should not expect, that your personally identifiable information or private communications would always remain private. We do, however, assure you that any and all disclosure of your personally identifiable information shall be personally intimated to you through an email sent to your provided email address.

As a matter of policy, we do not sell or rent any personally identifiable information about you to any third party. However, the following describes some of the ways that your personally identifiable information may be disclosed:

External Service Providers:There may be a number of services offered by external service providers that help you use our Platform. If you choose to use these optional services, and in the course of doing so, disclose information to the external service providers, and/or grant them permission to collect information about you, then their use of your information is governed by their privacy policy.

Law and Order:We cooperate with law enforcement inquiries, as well as other third parties to enforce laws, such as: intellectual property rights, fraud and other rights. We can (and you authorise us to) disclose any information about you to law enforcement and other government officials as we, in our sole discretion, believe necessary or appropriate, in connection with an investigation of fraud, intellectual property infringements, or other activity that is illegal or may expose us or you to legal liability.

12. ACCESSING, REVIEWING AND CHANGING YOUR PROFILE

Following registration, you can review and change the information you submitted at the stage of registration, except mobile number and other fields such as Bank account details, PAN number that are deemed unique to the user by us. An option for facilitating such change shall be present on the Platform and such change shall be facilitated by the User. If you change any information we may or may not keep track of your old information. We will not retain in our files information you have requested to remove for certain circumstances, such as to resolve disputes, troubleshoot problems and enforce our terms and conditions. Such prior information shall be completely removed from our databases, including stored ‘back up’ systems. If you believe that any information we are holding on you is incorrect or incomplete, or to remove your profile so that others cannot view it, the User needs to remediate, and promptly correct any such incorrect information.

13. CONTROL OF YOUR PASSWORD

When you sign up to become a Member, you might be asked to choose a password. You are entirely responsible for maintaining the confidentiality of your password. It is important that you protect it against unauthorised access of your account and information by choosing your password carefully and keeping your password and computer secure by signing out after using our services.

You agree not to use the account, username, email address or password of another Member at any time or to disclose your password to any third party. You are responsible for all actions taken with your login information and password, including fees. If you lose control of your password, you may lose substantial control over your personally identifiable information and may be subject to legally binding actions taken on your behalf. Therefore, if your password has been compromised for any reason, you should immediately change your password. You agree to notify us immediately if you suspect any consistent unauthorised use of your account or access to your password even after changing it.

14. SECURITY

We treat data as an asset that must be protected against loss and unauthorised access. We employ many different security techniques to protect such data from unauthorised access by members inside and outside the Company. We follow generally accepted industry standards to protect the Personal Information submitted to us and information that we have accessed.

However, as effective as encryption technology is, no security system is impenetrable. Our Company cannot guarantee the security of our database, nor can we guarantee that the information you provide will not be intercepted while being transmitted to the Company over the Internet.

15. SEVERABILITY

Each paragraph of this privacy policy shall be and remain separate from and independent of and severable from all and any other paragraphs herein except where otherwise expressly indicated or indicated by the context of the agreement. The decision or declaration that one or more of the paragraphs are null and void shall have no effect on the remaining paragraphs of this privacy policy.

16. AMENDMENT

Our Privacy Policy may change from time to time. The most current version of the policy will govern our use of your information and will always be at the Platform.

17. CONTACT US

If you have any questions or concerns about this privacy policy, please reach out to us via email at info@mavyfintech.in.

Please note that the information provided in the application may not be fully accurate and is intended for promotional purposes related to the business.

Data Retention Policy:-

Data retention period is 6 months. We collect and generate various data points about you.
Data by which you are identified is termed as “Personal Data”. Personal Data does not mean information that is freely available or accessible in public domain
Your Privacy is of utmost importance to us and protection of your Personal Data is a key commitment for us.
We are governed by the provisions of applicable law in India including the Information Technology Act 2000 and the Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011 to maintain the privacy of your Personal Data