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Privacy Policy

With effect from [•] This Privacy Policy [the “Privacy Policy”] is created and published in accordance with Rule 3 (1) of the Information Technology (Intermediaries Guidelines) Rules, 2011, which requires the publishing of Privacy Policies and Terms of Use for website access or usage. This Privacy Policy regulates your use of the Website https://minko.app/, Mobile Application https://play.google.com/store/apps/details?id=com.app.minko&hl=en_IN&gl=US as well as email communications received from [.], and text messages received from [.] [collectively, referred to as the “Platform/MINKO”]. Minko Application is developed by Minko Platforms Private Limited, a company incorporated under the Companies Act, 2013 with its registered office at 263/1, Karapur Tisk, Vithalapur, Karapur, Sanquelim, North Goa- 403505, Goa, India (“the Company/We”). We value the users of our website or application (“Minko/Platform”) and the information provided by them. We understand that the Users might be concerned about the collection, use and disclosure of the Personal Information, viz. personally identifiable information, that we collect when you access Minko. For the aforementioned purpose, the Privacy Policy describes the collection, processing and storage of information we receive from you. It is pertinent to note that by using Minko you are accepting the practices described in this Privacy Policy. Also, by using Minko you are giving consent to the use of your Personal Information by us in accordance with the terms set out in this Privacy Policy.

DEFINITIONS

  1. “Account(s)” refers to your profile(s) (created after undergoing the Registration Process) by which you are able to create and share information, personal messages, communications and other content.
  2. “Cookies” are small files stored on your device (computer or mobile device) while browsing through the Platform or Application.
  3. “Fee(s)” means the charges as prescribed in the Platform and as payable by you through the payment gateways available on the Platform for availing the Services available on the Platform.
  4. “End-User(s)” refers to person or his/her representative(s) or affiliate(s), who has/ have an Account (after undergoing the Registration Process) with the Platform want to make an Account through the Platform to avail the Services provided therein.
  5. “Personal Information” as defined under the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 [the “SPI Rules”] means any information that relates to a natural person, which, either directly or indirectly, in combination with other information available or likely to be available to a body corporate, is capable of identifying such person.
  6. “Sensitive Personal Data or Information” as defined under Rule 3 of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 [the “SPI Rules”].
  7. “Registration Process” means the process which a User undergoes while registering himself/ herself/ themselves on the Platform thereby creating an Account in accordance with the process mentioned in the Terms of Use available at https://minko.app/terms- conditions.html.
  8. “Service(s)” means and includes enabling short term credit for retailers and buyers against their invoice issued by the distributor/seller/anchor via NBFC partners.
  9. “Usage Data” is data collected automatically either generated by the use of Service or from Service infrastructure itself (for example, the duration of a page visit).
  10. “You”, “Your”, “User” or “Users” refers to any individual, organisation, association or to his/her/ their representatives or affiliates, who utilises or visits the Platform and includes “End-User(s)”.

WHAT INFORMATION DOES MINKO COLLECTS FROM YOU?

  1. Personal Information- Generally, you can visit and browse the Platform without disclosing the personal information. However, to fully use the Services provided by the Company, via the Platform, you are required to undergo the Registration Process as provided in the Terms of Use available at https://minko.app/terms-conditions.html. Minko collects sensitive and personal information which you provide to us during the registration process, which includes but is not limited to your name, date of birth, gender, resident status, mailing address, phone number (primary and alternate), email address, credit card number, Aadhar verification, pan number, business name, business address, GST number, tan number, business registration certificate, bank account details.
  2. Non-Personal Information- Minko also collects non-personal information from you, which includes but not limited to your browser type, URL of the previous website you visited, ISP, operating system and you IP Address. It is to clarify that non-personal information cannot be readily used to personally identify you.
  3. Location Data-Minko may use and store information about your location if you provide us permission for the same. Minko uses this data to provide features of our service, to improve and customize our services, and provide efficient service to you. Kindly note that you have an option to enable or disable location services while using MINKO, at any time by way of your device settings.
  4. Tracking Cookies Data- We use data collection devices such as Cookies and similar technologies to track the activity on Minko and we hold certain information. Please note that Cookies are files with a small amount of data which may include an anonymous unique identifier. You can decline the use of Cookies in your browser. Since each browser is different therefore you have to check with the browser to learn how to manage Cookies. However, if you opt to not accept Cookies, you may not be able to avail some portions of the Services offered by MINKO.

PURPOSE OF COLLECTION OF INFORMATION

  1. We may use the Personal Information provided by you for the following purposes:
    1. for the purpose of providing you the Services;
    2. for the purpose of improving the quality of the Services;
    3. for marketing and promotional purposes;
    4. for the purpose of transactional communications;
    5. for the purpose of financial transactions;
    6. for the purpose of debugging customer support related issues;
    7. for the purpose of receiving feedbacks from the User(s);
    8. for the purpose of responding to summons, court orders or other legal obligations;
    9. for the purpose of research and generating statistical analysis;
    10. for the purpose as mentioned under the Information Technology Act, 2000 and the rules thereunder.
  2. Minko or any person/organisation acting on behalf of Minko shall not be responsible for the authenticity and accuracy of the Personal Information and/or the Sensitive Personal Data or Information provided by you.

STORAGE AND RETENTION OF DATA

  1. Minko stores Personal Information and/or Sensitive Personal Data or Information within India and retains it only for as long as it is necessary to provide our Services and to comply with our legal obligations, resolve disputes, and enforce our policies.
  2. Retention period will be determined taking into account the type of data that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused data at the earliest reasonable time.

OBLIGATIONS OF THE USER(S) FOR THE PERSONAL INFORMATION AND/OR THE SENSITIVE PERSONAL DATA OR INFORMATION

  1. By using Minko app/web, user gives their consent that Minko could collect, disclose, share, and use user's information in accordance with the terms of this privacy policy, also user consented to be bound by the terms and conditions of this Privacy Policy.
  2. If case where user does not wish/wants Minko to collect, disclose, share and use users’ information, including but not limited to any personal information (as defined below), user may choose not to register for an account or terminate their account with Minko in accordance with the applicable Terms and Conditions available at the App/web.
  3. You hereby consent to the collection and use of the Personal Information and/or the Sensitive Personal Data or Information, provided by you to Minko, for any of the purposes stated herein.
  4. You agree and understand that all the information provided to Minko by you, including Personal Information and/or the Sensitive Personal Data or Information, is voluntary.
  5. For creating the Account, you are required to provide Personal Information and/or the Sensitive Personal Data or Information such as the Username, User ID, email address, country, ZIP/postal code, age, phone number, and valid financial account information.
  6. You agree and understand that Minko is not liable for the authenticity of the Personal Information and/or the Sensitive Personal Data or Information provided/ supplied by you.
  7. You are responsible for the accuracy and correctness of the information that you submit to Minko.
  8. If you intend to deregister your Account or request that your information no longer be used, you can contact Minko by sending an email addressed to [email protected] Upon receiving such request, Minko shall not keep such information in its databases beyond the required time.
  9. After the withdrawal of consent, or cancellation of Account, Minko may discontinue or may not be able in a position to provide the Services to such User(s).

DISCLOSURE OF PERSONAL INFORMATION AND/OR THE SENSITIVE PERSONAL DATA OR INFORMATION

  1. The following is applicable to all the User(s):
    1. You confirm and agree that Minko does not sell or share any Personal Information about you with other people/ organisation except to provide the Services under the Terms of Use or this Privacy Policy.
    2. Minko shall only disclose the Personal Information and/or the Sensitive Personal Data or Information only to the extent as will be necessary to provide its Services as under:
      1. Minko may require you to pay a certain amount of Fee via a credit card, debit card or through other online payment gateways, viz. Decentro, Castler, Cashfree, for the Services rendered by Minko. You may opt for Minko to collect and store such your credit card number and/or other financial information such as bank account numbers, in a digitally encrypted format, for ease of payment processes and future references.
      2. When you visit the Platform, Minko will automatically receive the IP address of your computer, operating system and type of web browser that is being used. This will help Minko to analyse the overall trends which will help the Platform in improving its Services.
      3. Minko, via the Platform, uses temporary cookies to store certain data and for the purpose of research and development, and for administration purposes. These cookies do not store any of your Personal Information and/or the Sensitive personal data or information.
      4. Minko has no control over the third-party websites that may be displayed as search results or links from within the Services. These third-party websites may place their own cookies or other files on your computer, collect data or solicit personal information from you, for which Minko shall not be liable.
      5. Other parties if so required by any law at the time being in force and in compliance of Minko's legal obligation.
      6. Minko shall disclose the Personal Information and/or the Sensitive personal data or information to Government agency if so mandated under the law in force at the relevant time.
    3. The following information collected will not be shared with any third parties or disclosed to any person other than as required by law; Sensitive Personal Data or Information of any person being the password, financial information such as Bank account or credit card or debit card or other payment instrument details, sexual orientation or any other sensitive personal information not essential for the continued use of the Website.
    4. We may share Personal Information with our other corporate and /or associate entities and affiliates to help detect and prevent identity theft, fraud and other potentially illegal acts and cyber security incidents; correlate related or multiple accounts to prevent abuse of our services; and to facilitate joint or co-branded services that you request where such services are provided by more than one associate entity. Those entities and affiliates may not market to you as a result of such sharing unless you explicitly opt-in.
    5. We may disclose Personal Information if required to do so by law or in the good faith belief that such disclosure is reasonably necessary to respond to summons, court orders, or other legal process. We may disclose Personal Information to law enforcement offices, third party rights owners, or others in the good faith and belief that such disclosure is reasonably necessary to: enforce our Terms of Use or Privacy Policy; respond to claims that an advertisement, posting or other content violates the rights of a third party; or protect the rights, property or personal safety of our users or the general public.
    6. We give access of your Personal Information only to those personnel's/officials who are authorised in this behalf and the third-parties who are hired by them to perform administrative services. We do not guarantee that your information will be kept confidential by these parties and we will not liable in any manner for the loss of confidentiality by them.
    7. Minko has implemented best market practices and security policies, rules and technical measures to protect the Personal Data/ Information of the User(s) from unauthorised access, improper use, disclosure of data, unauthorised modification and damage or accidental loss.

TRANSFER AND SECURITY OF PERSONAL INFORMATION AND/OR SENSITIVE PERSONAL DATA OR INFORMATION

  1. Your Personal Information and/or the Sensitive Personal Data or Information is maintained by Minko in its secured/ encrypted database. Minko may also keep the records of electronic communications with you through the Platform for the limited purpose as stated herein the Privacy Policy and for customer support, research and development, for administrative purpose.
  2. Your Personal Information and/or the Sensitive Personal Data or Information may be transferred to and maintained on a secured/ encrypted database outside your State and the laws might differ accordingly.
  3. You agree and understand that the Personal Information and/or the Sensitive Personal Data or Information provided by you are shared with the employees of the Company who are authorised in this behalf and on need-to-know basis for the purpose of rendering Services to you.
  4. You understand that all the employees of the Company who have access to such Personal Information and/or the Sensitive Personal Data or Information are obligated to keep the same confidential. Minko is committed towards maintaining your Personal Information and/or the Sensitive Personal Data or Information secret and confidential.
  5. Minko may transfer the Personal Information and/or the Sensitive Personal Data or Information to any third party for providing better Services on behalf of Minko. The third party shall also maintain and ensure protection and confidentiality of the Personal Information and/or the Sensitive personal data or information of such User(s).
  6. If Minko or its subsidiaries, if any, are involved in a merger, acquisition or asset sale, your Personal Information and/or the Sensitive Personal Data or Information may be transferred in accordance with law and also in accordance the agreements executed for such merger(s)/ acquisition(s)/ asset sale(s).
  7. Minko takes all reasonable precautions to protect your data (whether online or offline) and your Personal Information and/or the Sensitive Personal Data or Information. You understand that no one, except the End-User(s) will have access to End-Users' passwords for its Account.
  8. Minko shall not be liable to indemnify you for any loss suffered by it due to such unauthorized use of your Account and the password thereof.

AMENDMENRS IN PRIVACY POLICY

  1. The Company may update the Privacy Policy from time to time. Minko will notify you of any changes by posting the new Privacy Policy on the website available at https://minko.app/Minko retains the right to change, modify or terminate the terms of this Privacy Policy, or any portion of this Privacy Policy, at any time by publishing such changes on the Website. The amended Privacy Policy would be effective as on the date of change, which Minko would post on the Website, and it shall be binding upon you from such date. If you do not agree to any of the terms and conditions in the amended Policy, you may discontinue from using the service available on Minko immediately.
  2. You are advised to review this Privacy Policy periodically for any changes. Use of information Minko collects, is subject to the Privacy Policy in effect at the time such information is used. Your continued use of the Services following the posting of changes to this Privacy Policy will constitute your consent and acceptance of those changes.

RESTRICTIONS ON USAGE

  1. You are not permitted to host, display, upload, modify, publish, transmit, update, share or distribute any information that:
    1. belongs to another person and over which you have no right upon;
    2. is defamatory, obscene, pornographic, grossly harmful, harassing, blasphemous, defamatory, obscene, paedophilic, libellous, invading another's privacy, including bodily privacy, insulting or harassing on the basis of gender, hateful, libellous, racially or ethnically objectionable, disparaging, relating to or encouraging money laundering or gambling, or otherwise unlawful in any way;
    3. harms minors in any way; infringes on the rights of minor;
    4. infringes on any patent, trademark, copyright, or other proprietary rights; violates any current law;
    5. includes software viruses or any other computer code, files, or programmes designed to disrupt, damage, or limit the functioning of any computer resource;
    6. is patently false and untrue, and is written or published in any form, with the intent to mislead or harass a person, entity or agency for financial gain or to cause any injury to any person.
  2. The Company reserves the right to delete any content and/or remove any non- compliant information from the Platform that violates any of the foregoing criteria.
  3. The Company also reserves its right to terminate the access to any User(s) immediately in case of non-compliance with the Terms of Use and Privacy Policy.

PERMISSIONS

Certain permissions are being sought by Minko /digital platform/APP, from the consumer at the event of downloading the application, registration or requesting for loan.

  • Camera Access - to capture the individual image, check the liveliness and authentication of the applicant. The incident may be termed as “Selfie”
  • Location - This area specific permission helps understand and filter location which are marked as negative/ sensitive for lending.
  • Microphone- to complete the process of onboarding

CONSENT TO THIS POLICY

  1. You voluntarily acknowledge that this Privacy Policy is a part of the Terms of Use of the Platform. You agree that visiting the Platform or utilising the Services of the Platform you signify your consent to this Privacy Policy. Your visit to the Website and use of the Services is subject to this Privacy Policy and the Terms of Use.

JURISDICTION

  1. This Agreement is governed by Indian law, which includes, but is not limited to, the following:
    1. The Indian Contract Act, 1872;
    2. The (Indian) Information Technology Act, 2000;
    3. The (Indian) Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information) Rules, 2011;
    4. The (Indian) Information Technology (Intermediaries Guidelines) Rules, 2011;and
    5. The Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021.
  2. Minko was created in the Indian state of Goa, India. The laws of the State of Goa will apply to this Agreement. You consent to the jurisdiction and venue of the courts in Goa, India in connection with any action, suit, process, or claim arising under or by reason of this Privacy Policy by using Minko.

GRIEVANCE CELL

If you have any question regarding this Privacy Policy, access or usage of computer resource, and/or to register any complaint, you can approach the Grievance Officer appointed by Minko. You may reach out the Grievance Officer vide an email addressed to [email protected], the official email-id of the Grievance Officer. The Grievance Officer and Minko shall make reasonable and prompt efforts to resolve your issue. The details of the Grievance Officer are mentioned herein below:
Name : Rishu Mathur
Address: 263/1, Karapur Tisk, Vithalpur, Sanquelim, North Goa-403505
Phone: 91-9699700762
Email: [email protected]
Availability:
In case your complaint remains unaddressed for a period of one month, you may appeal to the Customer Education and Protection Department of Reserve Bank of India.


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