PRIVACY POLICY

We are committed to protecting the privacy and security of your personal information. Your privacy is important to us and maintaining your trust is paramount to us.

This privacy policy ("Policy") explains how we Collect, Use, Process and Disclose information provided by you or collected by us on our mobile application ET Money and/or our website 'www.etmoney.com' (collectively referred as ET Money Platform or Platform) for the purpose of delivery of various services, products and content (collectively referred to as the "Services") via any mobile or internet connected device or otherwise.

BanayanTree Services Limited, (hereafter referred to as "Banayantree" or "BANAYANTREE" or "BTSL"), which provides comprehensive personal finance & wealth management products and services (hereinafter collectively referred to as the "Company") offer their respective Services on the ET Money Platform and respective entities develop, operate & manage its respective sections including collection and usage of the Information.

This Policy forms part and parcel of the Terms of Use and other terms on the ET Money Platform. The Privacy Policy should always be read in conjunction with the Terms of Use and specific products/services related terms and conditions, disclaimers, and undertakings.

The term "User" for the purposes of this Privacy Policy shall mean You, in the capacity of an individual, a guest user, browser and/ or representative of an entity, who visits, accesses, uses, downloads, deals with, avails Products & Services and/ or transacts through ET Money Platform. For the purpose of this Policy, wherever the context so requires "You" or "Your" shall mean User and the term "We", "Us", "Our" shall mean Company.

This Privacy Policy is applicable to You as a User of the BANAYANTREE Products and Services on the Platform. For the sake of clarity, the term "Company" shall be construed to mean either BANAYANTREE, as the context may so require i.e. based on the purpose for which the information is given (i.e. which product/services you intend to avail).

Based on the Products/Services You avail or intend to avail, it will be construed that the respective Company (which is offering such Products/Services) is collecting the data from You. Any Information, that You submit while availing BANAYANTREE's Products and Services, you hereby agree and acknowledge that You submit Your Information to BSTL.

Please note that in the event You do not agree to any or all the clauses of the Terms of Use, Privacy Policy and product specific Terms and Conditions or in case You do not wish to provide any information, including personal or personally identifiable information, then Company may not be in a position to offer You all or some of the product/Services, including without limitation, certain features of the ET Money Platform, and may even restrict You (partially or fully) from accessing the ET Money Platform. Further, if You do not agree to this Privacy Policy, Terms of Use, User Undertakings and/ or product specific Terms and Conditions, You may also not register on ET Money Platform, not avail Our Services and kindly deregister from ET Money Platform and stop using Our Products/Services. We shall not be held responsible and/ or liable for any denial of Service due to User not providing the required information.

You must be a natural person who is at least 18 (eighteen) years of age. You must not misrepresent Your identity. The right to use the ET Money Platform is personal to the User and is not transferable to any other person or entity. The Company presumes adequate and lawful parental consent in case the Personal Information is shared by a User under the age of 18 years.

As we update, improve, and expand the services, this policy may change. Hence, we urge you to refer to it periodically. By continuing to access the products/services and using the Sites, it is deemed that You understand and agree to this Privacy Policy and consent to collection, storage, and use of the personal information provided by You (including any changes thereto) for any of the Services that the Company provide.

The information about the User as collected by the Company is: (a) information provided by Users and (b) information automatically tracked while a user uses the Platform(c) information collected from any other source (d) information generated while availing Our Services including but not limited to transactional information (collectively referred to as "User Information" or "Information").

The Company respects the privacy of the Users, understands the sensitivity of the information and is committed to protect it in all respects.

1. Information We Collect

1.1 Information You Provide Us

When you start using the ET Money Platform, the Company asks you to provide Information about yourself on a voluntary basis. You are asked to provide such information at various points across the Platform. Some of the scenarios where you provide us your information includes, but not limited to

• While registering or setting up an account on ET Money platform
• While filling up forms to apply for certain services provided by the Company
• While transacting in any financial product that is available on the ET Money platform
• While providing feedback & opinion about the product and services that are currently available or maybe provided in the future

In some instances, you might have to provide certain information on a mandatory basis (such as KYC information or information which is required to comply with applicable laws, rules, guidelines, regulatory requirements). Any information disclosed by You shall be disclosed willingly on a voluntary basis and without any coercion.

• Investment Account: When you create a new investment account, we are required by regulation to collect the following information:
  - Mobile number, First name, Last name, PAN number (Tax Number), email, date of birth
  - Income slab, profession, address details, father's name, mother's name, tax residency, birth country, nationality, nominee details, gender, marital status
  - Bank account number, your name on bank passbook and IFSC code of the bank.
• KYC details: To comply with regulatory requirements, based on your explicit consent we fetch your KYC (Know Your Customer) details from regulated Central KYC Registry.
• Credit score & Liabilities information: You provide an explicit consent to the Company to collect this information from third party service providers that are expressly authorized by you to distribute such information (for example, Experian or CRIF High Mark which is a credit information company registered under the Credit Information Companies (Regulation) Act, 2005)
• Investments information: To enable you to have a clear, insightful & actionable view of your investments at one place, we provide the following options for you to update your investment information in a secure manner:
  - Upload your investment statements
  You can upload your investment statements that you receive from various entities such as depositories or your brokers or Registrar & Transfer Agents such as Computer Age Management Services, Karvy Fintech Private Limited, National Securities Depositories Limited, Central Depositories Services Limited, etc.
  - Connect your Google Mail/Gmail account
  We understand that it is very cumbersome for you to keep uploading your statements regularly & you may miss getting a clear view of your investments on the ET Money Platform. Hence you can choose to provide explicit consent to connect your Gmail account with the Company account (using Google's OAuth authentication method), so that the Platform can "read only" the attachment from a small set of senders specifically comprising:
  donotreply@camsonline.com, samfd@karvy.com, nsdl-cas@nsdl.co.in, eCAS@cdslstatement.com, NSE-direct@nse.co.in, samfd@kfintech.com, samfS@kfintech.com, CRA@NSDL.co.in, KCRA@kfintech.com
  If the sender email ids are changed then we will notify you and also update this Privacy Policy on a best effort basis.
  The attachments from these senders have the details of your investments such as Folio numbers, Transaction Dates, Dividends, Subscription and Redemption Amounts, etc. The Company organizes this information in your account to provide deep analytics.
  The benefit of opting to connect your Gmail account is that your investment information gets automatically updated every month. Given the updated information, the Platform can give you accurate analytics on your investments more seamlessly and in frictionless manner.
  You can choose to de-link your Gmail account at any time by writing to help@etmoneycare.com.
  Alternatively, you can also de-link your email by visiting Google Mail's permission settings located at: myaccount.google.com/permissions
  Please note we will never rent or sell your information or data to anyone.
  We never use or transfer the data collected via Gmail for serving ads, including retargeting, personalized, or interest-based advertising on the ET Money Platform.
  This act of connecting your Gmail accounts with the Company accounts comes under the "Restricted scopes" under Google API services user data policy. We urge you to also refer to the restricted scope as mentioned in the section 3.1 below.
• Your Expenses and Saving Account analytics via SMS (Short message service):
  You can choose to provide specific & explicit consent to allow ET Money App to access your text messages (SMS) inbox received on your mobile device. After obtaining such explicit consent from you, ET Money App may automatically read your SMS text messages pertaining to yours expenses and/or saving account balance data information arising out of transactions made from cards, banks, wallets through text messages (SMS) received by you from providers of services and/or banks (including but not limited to retail outlets, financial institutions, and utility companies). This will enable the application to organize your expenses and saving account balances across your transactions and banks in one view and also provide analytics on the same to you. This will also help you to get an accurate picture of your money at one single place.
  We would like to clarify that No personal SMSs or OTPs are accessed by the Company.
  You can choose to opt-out of the expense and saving account balance analytics services at any time by writing to help@etmoneycare.com.
  Alternatively, you can also opt-out of the expense and saving account balance analytics by visiting our Application's permission settings.
• Other Voluntary information:
  We may also collect additional information at other times, on a voluntary basis, including but not limited to, when You provide feedback, comments, change Your content or email preferences, respond to a survey, or any communications with Us. You shall ensure that the information provided by you is up to date. The Company/its affiliates and group companies/partners/vendors/ service providers etc. may also contact You from time to time, through any mode of communication, requesting You to update or confirm Your personal information, in order to keep the same up to date and also to provide you with such features that We believe may benefit / interest You.

1.2 Information that gets collected when you use the ET Money Platform

• To help us in providing you with a more seamless, faster, personalized experience or to improve our services, the Platform collects information as you use or visit pages/sections of the Platform and actions you perform such as transacting on the platform. We automatically collect such information through various technologies. Such information also gets logged from the browser & your device including IP address, device's name, device's serial number or unique identification number (e.g. UDiD on Your iOS device), device operating system, browser type and version, CPU speed, and connection speed etc.
• Cookies & other similar technologies
  To improve the responsiveness of the Platform, make the experience more seamless or analyze the effectiveness of our services, We may use "cookies", or similar electronic tools to collect Information. Please note that unless You voluntarily identify Yourself (through registration, for example), We will have no way of knowing who You are, even if We assign a cookie to Your computer or device. The only personal information a cookie can contain is the information You voluntarily supply. Similar to cookies, we may use "clear GIFs" (Web Beacons) to track the online usage patterns of Our Users in an anonymous manner, without personally identifying the User. We may also use clear GIFs in HTML-based emails sent to Our Users to track & analyze which emails are opened by its recipients.

1.3 Information from third parties

In order to render our service, comply with regulatory requirement or to provide a much easier online process on activities such as, but not limited to, opening an investment account or to verify the information given by you, you acknowledge and agree that we may receive information about You from other sources. Such sources include entities such as, but not limited to, KRA/CKYCR/Credit Bureaus etc. We may add such information to Your account information (already available with us) and treat it in accordance with this Policy.

All Information provided by you and/ or collected from other sources shall be considered confidential by Us. However, any personally identifiable information provided by You will not be considered as confidential/sensitive if it is freely available and / or accessible in the public domain like any comments, messages, blogs, scribbles available on social platforms like Facebook, Twitter etc. Further, any Information posted/uploaded/conveyed/communicated by you on the public sections of these Sites becomes published content and is not considered confidential and/ or personal or personally identifiable information.

2. How do we use the information we collect?

2.1 Providing, understanding, and improving our service

Any information provided by a User shall be used for creating and updating your Account and processing your transaction(s) or for any other purposes for which you have granted access to such information to us.

We may also use the information collected to perform internal operations necessary to provide our services, improve & customize user experience, troubleshoot software bugs and operational problems, to conduct data analysis, testing and research and to monitor and analyze usage and activity trends. Information collected may also be used to share communications to you about our products & services, provide additional features through cookies and to detect and/or prevent any fraudulent/criminal/prohibited activity as per applicable laws.

We may also use Your email address or other personally identifiable information to reach out to you or to send commercial or marketing messages about Our Services and/or such additional updates and features about third parties' products and services with an option to subscribe/unsubscribe.

2.2 Security & resolution of issues

We respect the privacy of our user and are committed to safeguard the same. Our hosting services and servers maintain its systems in accordance with industry standards and best practices to reasonably secure the information of its customers against unauthorized access, modification, disclosure, or destruction of data. We blend security at multiple steps within our products with state-of-the-art technology to ensure our systems maintain strong security measures. We conduct periodical internal and external reviews of Our data collection, storage and processing practices and security measures, including appropriate encryption and physical security measures to guard against unauthorized access to systems where We store personal data. All information gathered by the Company is securely stored within the Company controlled database. The database is stored on servers secured behind a firewall; access to the servers is password-protected and is strictly limited. We have an in-house network security team which uses industry leading products to conduct manual and automated VA/PT activities. Our safety and security processes are also audited by a third-party cyber security audit agency from time to time. If you have found a possible security vulnerability on our platform, we encourage you to report the issue to us responsibly at help@etmoneycare.com. We shall put best of our efforts to investigate and fix the legitimate issues in a reasonable time frame, meanwhile, requesting you not to publicly disclose it.

3. Sharing and disclosure of data with third parties

We neither rent nor sell your personal Information to anyone. However, we may share your Personal Information with third parties as described in this section:

• We only transfer the data to others if necessary, to provide or improve user-facing features that are prominent in the requesting application's user interface. We may also transfer data as necessary to comply with applicable law or as part of a merger, acquisition, or sale of assets with notice to users. All other transfers or sales of the user data are prohibited
• We don't use or transfer the data for serving ads, including retargeting, personalized, or interest-based advertising; and
• We don't allow humans to read the data, unless:
  - We first obtain your affirmative agreement for specific purposes;
  - It is necessary for security purposes (such as investigating a bug or abuse);
  - It is necessary to comply with applicable law; or
  - Our use is limited to internal operations and the data (including derivations) have been aggregated and anonymized.
  These prohibitions of user of data apply to all the information/data obtained from you with your explicit consent. Our employees, agents, contractors, and successors comply with this Policy.

3.1 Your personal information with respect to connecting your Gmail account with ET Money Application: Compliance w.r.t. Google OAuth API Scopes (Restricted scopes)

We will never rent or sell your information or data to anyone. Company ensures that it is always in compliance with the restricted scope defined under Google OAuth API policies.

• Company limits use of data to provide or improve your user experience. Connecting your Gmail account with the Company is completely optional and based on your explicit consent for only specific use cases as has been described in this Privacy Policy. The benefit of this option is that you do not need to keep updating your investment information every month. Given the updated information, the application can hence give you deep and accurate analytics on your investments. You can choose to de-link your Gmail account with the application at any time and/or you can request to delete your ET Money account by writing to us at help@etmoneycare.com (subject to regulatory compliance). Alternatively, you can remove access to Company from Google Mail's permission settings located at: myaccount.google.com/permissions.
• We only transfer the data to others if necessary, to provide or improve user-facing features that are prominent in the requesting application's user interface. We may also transfer data as necessary to comply with applicable law or as part of a merger, acquisition, or sale of assets with notice to users. All other transfers or sales of the user data are prohibited.
• We don't use or transfer the data for serving ads, including retargeting, personalized, or interest-based advertising and we do not allow, and we prohibit access to any of the third-party analytics providers.
• We don't allow humans to read the data, unless :
  - We first obtain your affirmative agreement for specific messages;
  - It is necessary for security purposes (such as investigating a bug or abuse);
  - It is necessary to comply with applicable law; or
  - Our use is limited to internal operations and the data (including derivations) have been aggregated and anonymized.
  These prohibitions of user of data apply to the raw data obtained from Restricted Scopes and data aggregated, anonymized, or derived from them. Our employees, agents, contractors, and successors comply with the "Google API Services: User Data Policy".
• We will also be undergoing annual security assessment from a Google-designated third party and keep the same updated from time to time or as per instructions from Google and will publish the "letter of assessment" on the Company website and mobile applications.

3.2 Your SMS information with respect to giving explicit permission to ET Money application with respect to your SMSs related to expenses & saving account balances (Personal & Sensitive information):

We will never rent or sell your information or data to anyone. ET Money ensures that it is always in compliance with the Google Play store policies and Google policies.

• Company limits use of data to provide or improve your user experience. Giving consent to access your SMS text messages to ET Money App is completely optional and based on your explicit consent for only specific use cases of organising your expenses and saving account balances and as described in this Privacy Policy. The benefit of giving explicit consent for this option is that our s enabled to organise all your fragmented expenses across your transactions and saving accounts across your banks on the ET Money App. Our application is also enabled to give you analytics across your expenses and saving account balances. This also helps you to get an accurate picture of your spending and overall financial picture in combination with your investments & liabilities. You can anytime choose to opt-out of this permission by visiting the App's permission settings or you opt out by writing to help@etmoneycare.com.
• We do not use or transfer the data for serving ads, including retargeting, personalized, or interest-based advertising and we do not allow, and we prohibit access to any of the third-party analytics providers.
• We don't allow humans to read the data, unless:
  - We first obtain your affirmative agreement for specific messages;
  - It is necessary for security purposes (such as investigating a bug or abuse);
  - It is necessary to comply with applicable law; or
  - Our use is limited to internal operations and the data (including derivations) have been aggregated and anonymized.
  These prohibitions of use of data apply to the raw data obtained from your SMS and data aggregated, anonymized, or derived from them. Our employees, agents, contractors, and successors comply with these policies.

4. Links to Third Party Sites

The ET Money Platform may include links to other websites or applications. Such websites or applications are governed by their respective privacy policies, which are beyond Our control. Once You leave Our servers ( which You can tell by checking the URL in the location bar on Your browser), use of any information You provide on such website/application is governed by the privacy policy of the operator of the application/site, You are visiting. That privacy policy may differ from Ours. If You can't find the privacy policy of any of these sites via a link from the application's homepage, you should contact the application owners directly for more information.

5. Accessing and Updating Personal Information

You may review, update, and correct your personal information through the Profile section on the ET Money application. In the event when your information is not accessible online and you wish to change your personal information or other information that you may have provided, please write to us at help@etmoneycare.com.

Your right to review, update, correct etc. Your information is subject to Our records retention policies and applicable law, including any statutory retention requirements.

You also have an option to request for account deactivation. This will temporarily block your access to ET Money Platform until a re-activation request on help@etmoneycare.com and is sent to reactivate the account.

Retention of Data

We shall retain the records as per Prevention of Money Laundering Act 2002 and SEBI (Investment Advisors) Regulations, 2013 for the period specified by SEBI from time to time. In the event any legal / regulatory proceeding is pending, we will retain records for a longer period till such proceedings come to a logical conclusion.

6. Changes to Privacy Policy

We may update and/ or modify this Policy from time to time to incorporate necessary changes in technology, applicable law, or any other variant. In any case, we reserve the right to change (at any point of time) the terms of this Policy or the Terms of Use. Any changes We make will be effective immediately, upon posting the new policy on Our ET Money Platform. While we will make reasonable efforts to keep you posted on any updates to this privacy policy, to make sure that you are aware of any changes, we advise you to review this policy periodically for the latest version, continued use of the Sites or Services, after such notice, will be deemed acceptance of such changes.

7. Compliance with Google OAuth API Scopes:

Please note that ET Money's use of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.

8. Questions / Grievance Redressal

Redressal Mechanism:

Any complaints, abuse or concerns with regards to the use, processing and disclosure of Information provided by You or breach of these terms should immediately be informed to the designated Grievance Officers as below in writing or through email to:

We request User to please provide the following information in User's complaint:

• Identification of the information provided by User.
• Clear statement as to whether the information is Personal Information or Sensitive Personal Information.
• User address, telephone number or e-mail address.