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PRIVACY POLICY 

 

Terms of using the services of https://xtracapneo.com and/or mobile application XtracapNeo 

1.Introduction 

1.1 Your use of this website / mobile application (hereinafter referred to as the “Application”) and all services and products (hereinafter referred to as “Services”) is subject to these terms, which may be amended from time to time at the sole discretion of the Xtracap Fintech India Pvt. Ltd (hereinafter referred to as the “Company”) without a prior intimation to you. 

2.Accepting the Terms 

2.1 You shall interact with parties concerned through this Application. By clicking a button or check box, where this option is made available to you on the Application, you accept and agree to the terms set out herein to avail the Services. 

3.Provision of the Services through Application 

3.1 The Application is an online and digitally enabled financial technology service that helps you process your or your dealers working capital demand and online payments with the financial institutions registered with Reserve Bank of India . The Company is not a bank or a Non-Banking Financial institution, and does not represent or warrant that it seeks to or is capable of providing services for banking and allied activities by its self. Your usage of the Application is at the sole discretion of the Company. 

3.2 The provision of Services is entirely subject to you paying a non-refundable annual subscription fee to the Company at such rate as may be communicated to you by the Company for services provided through the mobile technology application by the Company. The company also has the option of charging an additional convenience fees for services which are opted by you. The company has the option to wavier the fees from time to time on its own account 

3.3 The Company shall not be responsible for any loss or damage caused due to your limited ability or inability to use the Application. The Application is merely a user interface between you, your bank/ NBFC, and all such sellers or buyers duly registered on the Application and the Company does not assume any responsibility arising due to any act or omission in performing obligations as may be decided between you and the concerned parties, including but not limiting to taxability of services, damages, compensations, claims and the like. 

4.Use of the Application by you 

4.1. In order to access Services, you may be required to provide information about yourself as part of the registration process for the Service, or for your continued use of the same, which you agree to provide and assure its accuracy and correctness. You are solely responsible, and the Company shall not in any way be liable for the information and data collected in order to process and authenticate a transaction performed. 

4.2. The Company can share the information provided to it with the Government or law enforcement agencies if requested under the law or by court order and with anyone else to up hold the law of the land without your consent but with information to you. 

4.3. You agree that you will not engage in any activity that interferes with or disrupts the Services. 

5.Your passwords and account security 

5.1. You shall be solely responsible for maintaining the confidentiality of passwords associated with any account you use to access the services. 

5.2. You will be solely responsible for all activities that occur under your account, including but not limiting to: 

5.2.1 Submitting information about your dealer not limited to mobile number 

5.2.2. Submitting any bill of purchase, bank account details of suppliers or transaction for processing that does not arise from your sale of goods or service to a customer. 

5.2.3. Acting as a payment intermediary or aggregator or otherwise resell the Services on behalf of any third party. 

5.2.4. Sending what you believe to be fraudulent authorizations or transaction. 

5.2.5. Using Service in a manner that any bank reasonably believes to be an abuse of the Banking guidelines by Reserve Bank of India. 

6.Intellectual Property rights 

You acknowledge and agree that the Company (or Company’s licensors) owns all legal right, title and interest in and to the Services, including any intellectual property rights which subsist in them (whether registered or not) and that you are merely a licensee of the Services. 

6.1. Unless the Company has given you specific written permission to do so, you may not assign (or grant a sub-license of) your rights to use the Service or otherwise transfer any part of your rights to use the Service. 

7.Exclusion of Warranties 

7.1. You expressly understand and agree that your use of the offering is at your sole risk and that the Services are provided as is and as available. 

7.2. No advice or information, whether oral or written, obtained by you from the Company or through or from the Services shall create any warranty not expressly stated in the terms. 

8.Limitation of Liability 

8.1. You expressly understand and agree that the Company shall not be liable to you for any direct, indirect, incidental, special, consequential or exemplary damages which may be incurred by you under the alleged cause of any loss of profit, goodwill, and the like arising out of the usage of Application. 

9.General legal Terms 

9.1. Sometimes when you use the Services, you may use a service or download a piece of software, or purchase goods, which are provided by another person or company, your use of which shall be at your discretion and the Company assumes no responsibility in this regard. 

9.2. If any court of law, having the jurisdiction to decide on this matter, rules that any provision of these terms is invalid, then that provision will be removed from the terms without affecting the rest of the terms. The remaining provisions of the terms will continue to be valid and enforceable. 

9.3. The terms, and your relationship with Company under the terms, shall be governed by the laws of India, and in particular the laws of the State of Delhi. You and Company agrees that any dispute will be referred to arbitration, with the arbitral panel as may be constituted by the High Court of Delhi upon an application in this regard being preferred by any of the parties. The seat and venue of arbitration shall be Delhi and the proceedings shall be governed by the Arbitration & Conciliation Act, 1993. 

Privacy Policy 

Xtracap Fintech India Pvt. Ltd (the “Owner”), the owner of the domain “www.bridge2capital.com” (the “Website”) values the users of our Website and application. Your privacy and trust are very important to us. We recognize that you may be concerned about our collection, use, and disclosure of the personally identifiable information (“Personal Information”) that we collect when you use the our Website and app and the services offered on the our Website and app. This Privacy Policy describes the information that we collect from you, how we collect this information, and what we do with it after we collect it. By using the Website and app you are accepting the practices described in this Privacy Policy. By using the Website and app you also give consent to use the Personal Information in accordance with the terms set out in this Privacy Policy. If you have any questions or comments regarding this Privacy Policy, please contact us at info@xtracapindia.com. You may mark the mail to the grievance officer at info@xtracapindia.com

You agree that we may also use Customer Information for the purpose of statistical analysis and for creation of data (“Statistical Information”). In addition to the information that is elicited from you, you are free to volunteer any other information that you feel that the Owner needs to know, but the security and confidentiality as per this Policy is guaranteed only to the information that the Owner directly asks from you. This Policy holds true for a non-customer who has provided information to the Owner, by any means, with the intention of establishing a relationship, of whatsoever nature, with the Owner. By divulging any information to us you agree to the terms and conditions of this Policy. 

 

CONSENT 

You hereby expressly consent to provide the information that may be required in relation to the services being rendered on the Platform by us. You acknowledge that we shall collect the information detailed under this Privacy Policy to facilitate the various financial and non-financial services by partnering with various lending partners, service providers, and third parties based on your requirement. To avail any Services being provided by XtracapNeo by itself or in partnership with the lenders or other third parties it is important that: 

YOU READ, UNDERSTAND, ACKNOWLEDGE AND UNCONDITIONALLY AGREE TO BE BOUND BY THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY. 
 
IF YOU DO NOT AGREE TO THIS POLICY OR ANY PART THEREOF, YOU CAN CHOOSE NOT TO USE THE PLATFORM OR, AT ANY TIME REVOKE THE CONSENT PROVIDED BY YOU. 

 For the users consenting to continue accessing the Platform and avail the Services, this Privacy Policy explains our policies and practices regarding the collection, use, and disclosure of Your information. 

 

USE OF CUSTOMER INFORMATION / STATISTICAL INFORMATION 

We may use the Customer Information for, among other things, customer verification, Know you customer, financial underwriting, provision of products and services, for personalization of products or services, marketing or promotion of our financial services or related products or that of our associates and affiliates; for creation of statistical information, statistical analysis or credit scoring, enforcement of your obligations, any other purpose that will help us in providing you with optimal and high quality services. For providing our users with more clarity, we have explained it in specific category of services below: 

Information for 360-degree Financial Health Check: Information that is required for the accurate calculation of the Financial Health Check. Your consent for fetching GSTIN & Credit bureau report and your bank data may be collected from you.  
 
How we use this information: We will collect your bank statement, consent to fetch Credit bureau report and GSTIN data to analyze these data to provide you a detailed analysis report of your financial wellness through our 360-degree FHC product. 
 

Information for Digital Lending: Information collected by Platform for facilitation of Loans being disbursed by the financial lending partners whose details are available on the Website and the Application and who are registered with the Reserve Bank of India (“Lending Partners”). We may collect the following information from you: 

User Personal Information: The data points we collect from You for both lending and non-lending services. If you create a Working Capital Limit Account, we may collect your name, image, shop video, mailing address, email address, pan number, ID Proof copy(redacted), income tax returns, bank account number, Bank statements, your supplier and vendor details like GSTN, Bank Account Detail and reasons for seeking finance, income sources and other documents and images that we request during the registration process, and any information that you provide on your own or for availing credit limit.  
 

KYC data: This includes identification documents issued by the government or other authorities, and includes details of or pertaining to your Aadhaar, PAN card etc. 
How we use this information: We use this information for your onboarding and Know Your Customer (KYC) purpose with your explicit consent. 
 

Login with Google account: You will be expressly asked in each case whether You want to connect Your email address with your account on our Platform to aid your registration. We do not read your emails or use any information from your account. 
 

Information for Working Capital Limit & Invoice Financing: We will collect the necessary business information, and related documents as per the instructions from the lender partner to be shared with them for availing working capital. We will also collect invoice images, e-way bills, invoice details, Buyer & Seller details including Name, GST, and contact details for invoice financing as per the instruction from the lender partner. 
 
How we use this information: We use this information to share the details and documents with the Lender as per their policy for onboarding and to facilitate invoice financing by sharing the invoice details as per Lender requirement. 
 

Contact Information: This includes your email addresses (including work email address), in code, office and residential address and contact list to provide seamless service to you with your consent. Sharing these details solely depends on user discretion. 
How we use this information: We will collect, and store the email id, name, and address associated with that account for the purpose of verification and to pre-populate relevant fields during the Platform interface. We will access contact list while you use our platform for referring other business owners and for invoice financing to provide buyer and seller information, but we do not store your contact data. 
 

Financial data: This includes your income details, details of loans issued or otherwise applied for through the Platform, payments, and repayments thereof, bank account details, and bank account statements. 
 
How we use this information: We may collect your financial data to facilitate your application to avail working capital loan and otherwise in connection with your obtaining of credit facilities from regulated entities including our lending partners 
 

Marketing and communications data: This includes your preferences in receiving marketing messages from us and our third parties and your communication preferences. 
 
How we use the information: To manage our relationship with you, including notifying you of changes to any Services. 
 

Device Information and Installed Apps data: We additionally collect certain device information provided herein for our lending and non-lending services. Information related to only UPI enabled apps is collected and its usage depends on how you manage your privacy controls on your device. 
 
How we use the information: We collect information about your device to provide automatic updates and additional security so that your account is not used in other people’s devices. In addition, the information provides us valuable feedback on your identity as a device holder as well as your device behavior, thereby allowing us to improve our products interaction, quality of services and provide an enhanced customized user experience to you. We further collect other identifiable information such as your transactions history on the Platform when you set up an account with us. 
 

Location, Camera, Microphone Access: We will collect your device location and request camera and microphone access for facilitating lending services like Video Personal Discussion as well as providing any non-lending services only in accordance with applicable laws. 
 
How we use this information: We shall collect your device location information for verifying your address, for the KYC and onboarding process for the Services. We may request camera access to scan and capture the required KYC documents as per the instructions of our Lending Partners in accordance with applicable laws. We require microphone permissions to enable a two-way communication between our authorized agents and you for the purpose of performing and completing your Video Personal Discussion for the Lending Services. Your audio shall be recorded for eKYC regulatory purposes. 
 

Information for Non-Lending Services: Information collected by Platform while registering a User on the Platform or while providing Value Added Services (i.e. all services other than calculation Financial Health Check & facilitation of loans). 
 
If you sign up to receive a newsletter, we will collect your email address and account number, reasons for seeking finance, income sources, and email address  
 
How we use this information: We shall collect your email address, name, and reasons for seeking finance to analyze your profile and interests to provide you services as per your requirement. 
 
We do not access your mobile phone resources such as file and media (except as disclosed above in order to enable you to upload documents), call logs and telephony functions. However, we may access your camera, microphone, location or any other facility solely for the purpose of onboarding or KYC checks, after obtaining your explicit consent. We do not collect your biometric data. 
 

Information for GST Analysis: Information that is required for the analysis of the GST data, i.e., Your consent for fetching GSTIN data will be collected from you. 
How we use this information: We will take your consent to fetch data from the GSTIN server to conduct the analysis and provide you with the accurate analysis report. 

Information for Invoice Financing: We will collect the necessary business information, bank details, invoice images, e-way bills, invoice details, Buyer & Seller details including Name, GST, and contact details for invoice financing with respect your selected buyer. Sharing these details solely depends on user discretion. 
How we use this information: We use this information to share the details and documents with the Lender as per their policy, for onboarding and to facilitate invoice financing by sharing the invoice details as per Lender requirement. 

Information for Neo Services: Information collected by Platform while registering a User on the Platform or while providing Value Added Services (i.e. all services other than Financial Health Check & facilitation of loans).  If you sign up to receive a newsletter, we will collect your email address and account number, reasons for seeking finance, income sources, and email address. 
How we use this information: We shall collect your email address, name, to analyze your profile and interests to provide you services as per your requirement. 
 

We do not access your mobile phone resources such as file and media (except as disclosed above in order to enable you to upload documents), call logs and telephony functions. However, we may access your camera, microphone, location, or any other facility solely for the purpose of invoice financing after obtaining your explicit consent. We do not collect your biometric data. 
 

 

INFORMATION ABOUT YOU WE COLLECT FROM THIRD PARTIES  

For making the Services available to you, we may collect information by obtaining specific authorizations from you (if required under applicable laws), from certain third parties such as credit bureaus or credit rating companies as your ‘authorized representative’ from time to time in accordance with applicable laws during the loan journey as may be requested by our Lending Partners. 
In order to facilitate credit products to you, we may receive certain information pertaining to GST verification, document verification etc. We may further collect your bank details if required for invoice financing.  

INFORMATION YOU GIVE US ABOUT YOU 

 
In the due course of using our Services, you are required to submit data to enable our Services. We use this data to create your profile and provide you with the best available services. Mentioned below is some of the data we collect from you:   

Data provided by you by filling in forms in the Application.   

Data provided by corresponding with us (for example, by e-mail or chat). 

Data and information, you provide when you register to download or register on our App, subscribe to any of our Services (such as applying for a loan), search for a Service, and when you report a problem with our App, our Services, or any of our Sites. 

Data including your name, address, gender, date of birth, e-mail address, phone number, username, and other registration information. 

Data generated by your usage of our Platform 

 

This data helps us create your profiles, complete and provide you with customized support in case of issues. Wherever possible, we indicate the mandatory and the optional fields. You always have the option to not provide any information by choosing not to use a particular service or feature on the Platform.    

We, under no circumstances and at no point, take any biometric data from you for any of our services or operations. In case any of our representatives ask for the same from you, we request you to kindly refrain from doing the same and address this concern to our Grievance Officer at info@xtracapindia.com

 PURPOSE OF COLLECTION 

We shall use the information collected from you for facilitating the various services for the following purposes as detailed below. We understand the importance of your information and ensure that it is used for the following intended purposes only. 
The intended purpose of collecting information provided by you is to: 
a) establish identity and verify the same; 
b) to facilitate your KYC, if required; 
c) troubleshoot problems, monitor, improve and administer our Platform; 
d) provide our service i.e. invoice financing for approved shopkeepers relevant to you. 
e) design and offer customized products and services offered by our third-party partners; 
f) analyze how the Platform is used, diagnose service or technical problems and maintain security; 
g) send communications notifications, information regarding the products or services requested by You or process queries and applications that You have made on the Platform; 
h) measure consumer interest and satisfaction in our products and services and manage Our relationship with You; 
i) marketing and promotional purposes including sending you promotional SMS, Email and WhatsApp and inform you about online and offline offers, products, services, and updates; 
j) conduct data analysis in order to improve the Services / Products provided to the User; 
k) use the User information in order to comply with country laws and regulations; 
l) use the User information in other ways permitted by law to enable You to take financial services from our lending partners. 
m) resolve disputes and detect and protect us against suspicious or illegal activity, fraud and other criminal activity; 
n) customize your experience and enforce our terms and conditions.   

We will use and retain only such basic personal information such as your name, contact information, address details and such other information which are necessary for the provision of Services and for such periods as necessary to provide You the Services on the Platform, to comply with our legal obligations, to resolve disputes, and enforce our agreements. 

SECURITY 

We have taken reasonable measures to protect security and confidentiality of the Customer Information and its transmission through the World Wide Web. You are required to follow the Terms and Conditions while using this Website including the instructions stated therein in respect of security and confidentiality of your Log-in and Password. 
The Owner will give access to Customer Information to only authorized employees. 

 

 

 

DATA RETENTION AND DELETION 

 

We retain information about you to provide a seamless experience, to contact you in case of support required and about your account, to detect, mitigate, prevent, and investigate fraudulent or illegal activities during the course of the Services. 

We retain your data for as long as necessary to provide you with our services. We may also retain and use your basic personal information inter alia as name, contact number, transactional details and address details as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements which shall always be in accordance with applicable laws. Subject to this section, we may delete your data upon reasonable written request for the same at info@xtracapindia.com at any stage. Additionally, you can request deletion through https://accountservice.bridge2capital.com/. However, you may not be able to use our services after deletion. 

 

DISCLOSURE 

We shall not be held liable for disclosure of the Customer Information or Statistical Information in accordance with this Privacy Commitment or in terms of any other agreements with you. 
We may disclose the Statistical Information to any person, without any limitation and you hereby give your irrevocable consent for the same. We may disclose Customer Information to any of our associates and affiliates, without any limitation and you hereby give your consent for the same. We may disclose the Customer Information, to third parties, without limitation, for the following reasons and you hereby give your irrevocable consent for the same:-To comply with legal requirements, legal process, legal or regulatory directive/ instruction. Or To enforce the Terms and Conditions of the products or services. or 
To protect or defend our rights, interests and property or that of our associates and affiliates, or that of our or our Affiliate’s employees, consultants etc. or For fraud prevention purposes or 
As permitted or required by law. We may disclose the Customer Information to third parties for following, among other purposes, and will make reasonable efforts to bind them to obligation to keep the same secure and confidential and an obligation to use the information for the purpose for which the same is disclosed, and you hereby give your irrevocable consent for the same: 
For participation in any telecommunication or electronic clearing network. or 
For credit rating by a credit rating agency. Or For advertising or For facilitating joint product promotion campaigns. Or For the purposes of credit reporting, verification and risk management to/ with clearing house centres or credit information bureau and the like. or 
For availing of the support services from third parties e.g. collecting subscription fees, and notifying or contacting you regarding any problem with, or the expiration of, any services availed by you. 

COOKIE POLICY 

To continually enhance your online experience, we use cookies that store your preferences and give us data about your browsing behaviour, such as the pages you visited on this Website, how much time you spent on our site, etc. This information helps us understand customer interests and helps us improve our Website. By visiting the Website, you acknowledge, accept and expressly authorize us for the placement of cookies on your computer or hand-held device. 
Please find below some more information regarding cookies and their application on our Website:  

 

What are Cookies? 

 
A cookie is a simple text file that is stored on your computer or mobile device by a website’s server and only that server will be able to retrieve or read the contents of that cookie. Every cookie is unique to your particular web browser. It will contain some anonymous information such as a unique identifier and the site name with some digits and numbers. It allows the website to remember your browsing behaviour & show you relevant ads based on the browsing pattern. The cookies also allow the Website to limit the number of advertisements shown. 

How does the owner use Cookies? 

 
The Owner uses cookies to capture following information : 
Source of visit to the Website, Time spent on the Website Pages viewed on the Website Advertisement clicks In addition to analysing anonymous user behaviour on the aforementioned data, the Cookies also allows us to pre-empt requirements of prospects and existing account holders & pitch relevant services through display advertising or tele-calling. Please note that the scope of this tracking is limited to the domain. User activity on other third-party websites is not tracked by our cookies. 

Does the owner ever make changes to its Privacy Policy? 

 
We may make changes to the Privacy Policy from time to time. We will notify you of any material changes by sending you an email, posting a notice on the home page of the Website, or posting a notice in your account when you first login after we have made changes. If you receive a notification or a change in our Privacy Policy, you must review the new Privacy Policy carefully to make sure you understand our practices and procedures. You may not be able to receive notices from us if your cookies are not set to accept and/or are disabled, and in such event the Owner shall have no liability towards you whatsoever. 

What types of information does the owner collect from me? 

 
Sensitive Personal Data / Information: We collect Sensitive Personal Data / Information that you provide to us, such as your name, mailing address, phone number, email address, bank account number, PAN number, Good & Service Tax number, income tax returns, passport details, driving license details, personal statements, reasons for seeking finance, income sources, details of your references, mobile billing information through your operator, social / digital foot prints, consumption pattern of various digital media’s, call history, address book on your phone and financial information. Non-Personal Information: We also collect non-personal information from you, such as your analytics on time spend app and website on specific areas, , your ISP, operating system, and your Internet protocol (IP) Address (“Non-Personal Information”). Non-Personal Information cannot be easily used to personally identify you. 

How and when does the owner collect this information? 

 
Providing Information to Us: We collect Sensitive / Personal Data / Information from you when you provide it to us. For example, if you purchase a product or services, or make an application for credit limit, loan or finance etc., we may collect your name, mailing address, telephone number, pan number, Goods & services Tax number, income tax returns, bank account number, passport details, driving license details, personal statements, reasons for seeking finance, income sources and email address. If you create Credit limit Account, we may collect your name, tax identification number, mailing address, email address, pan number, tan number, income tax returns, bank account number, passport details, driving license details, personal statements, Your supplier and vendor details like GSTN , Bank Account Detail and reasons for seeking finance, income sources and other information that we request during the registration process, and any information that you provide on your own or for availing credit limit. If you sign up to receive a newsletter, we will collect your email address. 

How and when does the owner collect this information? 

 
Providing Information to Us: We collect Sensitive / Personal Data / Information from you when you provide it to us. For example, if you purchase a product or services, or make an application for credit limit, loan or finance etc., we may collect your name, mailing address, telephone number, pan number, Goods & services Tax number, income tax returns, bank account number, passport details, driving license details, personal statements, reasons for seeking finance, income sources and email address. If you create Credit limit Account, we may collect your name, tax identification number, mailing address, email address, pan number, tan number, income tax returns, bank account number, passport details, driving license details, personal statements, Your supplier and vendor details like GSTN , Bank Account Detail and reasons for seeking finance, income sources and other information that we request during the registration process, and any information that you provide on your own or for availing credit limit. If you sign up to receive a newsletter, we will collect your email address. 

Communications With Us: 
If you communicate with us regarding the Website or the services, we will collect any information that you provide to us in any such communication. 

Analytic and Reporting Technologies: Like the operators of most websites, we use analytic and reporting technologies to record Non-Personal Information such as Internet domain and host names, Internet protocol (IP) addresses, browser software, operating system types, clickstream patterns, and the dates and times that the Website, app and the services are accessed. We also contract with several online partners or / and financial services partners to help manage, monitor and optimize our Website and the services and to help us measure the effectiveness of our advertising, communications and how visitors use the Website. To do this, we may use web beacons and cookies. 

How does the owner use my information? 

 
If you communicate with us regarding the Website or the services, we will collect any information that you provide to us in any such communication. 

Personal Information: We use Personal Information primarily for which may be useful to access your request for usage of our product or services or would for our own internal purpose such as providing, maintaining, evaluating, and improving the Website, fulfilling requests for information, and providing customer support. Upon acceptance of these terms and conditions, you hereby grant an unequivocal and absolute consent to share your personal information (but not your Sensitive Personal Data /Information) with third parties. The Owner is not required to seek your consent once again in respect of sharing your personal information with third parties. We would further share your information with marketing agencies and other businesses if we in our sole discretion understand that your information may be used to market a product or service. The term Personal Information shall include your name, address, e-mail id and mobile phone number but it shall not include any data in relation to your financial status except in case of sharing the data with a credit rating agency or a financial institution which would provide you with the product or service you seek through , income statements, earnings, source of earnings, personal identification numbers, passwords, bank account numbers, encryptions, cookies and other such electronic details. 

Non-Personal Information: We use Non-Personal Information to track the use of the Website and the services and for other internal purposes, such as providing, maintaining, evaluating, and improving the services and the Website. 

When will the owner disclose my information to third parties? 

 
Disclosure to Successors: We may disclose your Personal Information to any successor-in-interest of ours, such as a company that acquires us. In the event the Owner goes through a business transition, such as a merger or acquisition by or with another company, or sale of all or a portion of our assets, your Personal Information will likely be among the assets transferred. You will be notified via email or by a notice on our Website of any such change in ownership or control of your Personal Information. 

 
Disclosure to Unaffiliated Third Parties: We shall keep your personal information and Sensitive Personal Data / Information private and confidential. We may disclose your Personal Information and/or Sensitive Personal Data / Information to perform our service to you, to prevent an emergency, to respond to legal requirements, to protect or enforce our rights and policies, to protect or enforce the rights of a third party, or as required or permitted by law (including, without limitation, to comply with a summon or court order). 

 
Disclosure to Third Party Service Providers and Online Partners: We may contract with various third parties who help us provide, maintain and improve the Website and the services. For example, we use a third party to process payments made to us, and may subcontract out production, fulfilment, analytics, reporting or other operations. We also contract with several online partners to help manage, monitor and optimize our Website and the services and to help us measure the effectiveness of our advertising, communications and how visitors use the Website. We will use commercially reasonable efforts to prevent such third parties from disclosing your Personal Information, except for the purpose of providing the services in question. We cannot guarantee that such third parties will not disclose your Personal Information. Except as per this privacy policy we shall not disclose data in relation to your financial status, income statements, earnings, source of earnings, passwords, bank account numbers, encryptions, cookies and other such electronic details. 

 
Disclosure of Non-Personal Information: We will disclose Non-Personal Information, in aggregate form, to potential strategic partners, advertisers, investors, customers, and others. You may not opt-out of the sharing of this information. However, it cannot be easily used to identify you personally. 

 
Internet Advertising: We may use third party service providers to serve advertisements on our behalf across the Internet and sometimes on the Website. They may collect anonymous information about your visits to our Website, and your interaction with our products and services. They may also use information about your visits to this Website and other websites to target advertisements for goods and services. This anonymous information is collected through the use of a web beacon, which is industry standard technology used by most major websites. 

 
Disclosure to Credit Rating Agencies, Banks, NBFC & Reserve Bank of India: To make an improvement in its business the Owner/ lending partners may share the personal information and financial information of a user with a Credit Rating Agencies and the information shall be shared with Credit Rating Agencies in the event, Reserve Bank of India issues guidelines or direction in this regard. 

What about cookies and web beacons? 

 
A cookie is a small file placed on the hard drive of your computer. Most websites use cookies. We use cookies to track your use of the Website and the services, and provide you with a more personalized user experience, and to allow you to login and begin use of services automatically when you visit the Website. A web beacon is an often-transparent graphic image, usually no larger than a 1X1 pixel that is placed on a web page or in an e-mail that is used to monitor the behavior of the user visiting the Website or receiving the e-mail. Cookies and web beacons used by the Owner and our online partners are not linked to Personal Information. This Privacy Policy covers the use of cookies and web beacons by the Owner and does not cover the use of cookies or web beacons by any other third party, or advertiser. 

Does the owner protect my personal information? 

 
Personal Information: Whenever we obtain your Personal Information, we use commercially reasonable efforts to protect it from unauthorized access or disclosure. However, we are not insurers of the security of your Personal Information. Accordingly, we assume no liability for any disclosure of data due to errors in transmission, unauthorized third party access or other acts of third parties, or acts or omissions beyond our reasonable control. 

 
Website Content: The content that you store, post, or transmit on or through the Website, such as message board postings, storefront pages, and images on your Products, may be accessed by other users, including people that you do not know. We are not responsible for the actions of others. Therefore, you should use care in communicating with other users and only disclose your Personal Information to other users that you know to be trustworthy. You should not assume that your content will be kept private. 

How can I review and make changes to my personal information? 

 
You can do so by editing your personal & professional details by accessing your dedicated account / dashboard with supporting documents. For your protection, you will be required to access your account by your unique ID and password, backed with One Time Password (OTP) that’s sent to your Registered Mobile Number (RMN). If your personal information changes or if you no longer want to use the services, you may correct, update or deactivate your personal information and/or your account through the account management screen. If you would like to deactivate or terminate your account, you can also contact us at info@xtracapindia.com. 

The security of your Personal Information is important to us. When you enter sensitive information on our registration or order forms, we encrypt that information using secure socket layer technology (SSL). We follow generally accepted industry standards to protect the Personal Information submitted to us, both during transmission and once we receive it. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security. 

 
We use a combination of firewalls, encryption techniques and authentication procedures, among others, to maintain the security of your online session and to protect online accounts and systems from unauthorized access. 
Our servers are in secure facilities where access requires two factor authentication. 
Our databases are protected from general employee access both physically and logically. We encrypt your Service password so that your password cannot be recovered, even by us. 

 
However, it is important to understand that these precautions apply only to our Website and systems. All communications between your computer and our Website that contain any Personal Information are encrypted. This enables client and server applications to communicate in a way that is designed to prevent eavesdropping, tampering and message forgery. 

 
Internet-based Transfers Given that the Internet is a global environment, using the Internet to collect and process Personal Information necessarily involves the transmission of data on an international basis. By providing the Owner with your Personal Information you acknowledge and agree that we may store your Personal Information and transfer it to and from our servers located in India. We endeavor to protect all Personal Information collected through the Website in a safe, confidential and secure manner. 

Does this privacy policy apply when I access third party websites? 

 
You may be able to access third party websites directly from the Website. This Privacy Policy does not apply when you access third party websites. We cannot control how third parties may use Personal Information you disclose to them, so you should carefully review the privacy policy of any third-party website you visit before using it or disclosing your Personal Information to its provider. 

What about children’s privacy? 

 
The services are intended for users aged 18 and older only. Accordingly, we will not knowingly collect or use any Personal Information from individuals that we know to be under the age of 18. In addition, we will delete any information in our database that we know originates from an Individual under the age of 18. 

Can I opt-out from receiving communications from the owner? 

 
We provide you the opportunity to opt-out of having your Personal Information used for certain purposes. For example, if you purchase a product/service but do not wish to receive any additional marketing material from us, you can indicate your preference on our order form. If you no longer wish to receive our newsletters and promotional communications, you may opt-out of receiving them by following the instructions included in each newsletter or communication or by emailing us at info@xtracapindia.com. If you need assistance you may contact us at info@xtracapindia.com. If we disclose your Personal Information to a third party in a manner that is not set forth in this Privacy Policy you will be notified so that you can make an informed choice about sharing your Personal Information with that third party. 

You are responsible for maintaining the confidentiality of your login id and password 
You are responsible for maintaining the security of your Login ID and Password and may not provide these credentials to any third party. If you believe that they have been stolen or been made known to others, you must contact us immediately at info@xtracapindia.com. We are not responsible if someone else accesses your account through Registration Information they have obtained from you or through a violation by you of this Privacy and Security Policy or our Terms of Use. 
If you have any security related concern, please contact us at info@xtracapindia.com. We will work closely with you to ensure a rapid and personal response to your concerns. 

EXCLUSION 

 
This Policy does not apply to any information other than information collected by the Owners through the Website including such information collected in accordance with the clause on “Collection of Information” above. This Policy shall not apply to any unsolicited information provided by the Users through this Website or through any other means. This includes, but is not limited to, information posted to any public areas of the Website. All such unsolicited information shall be deemed to be non-confidential and Xtracap shall be free to use, disclose such unsolicited information without limitation. 

FOREIGN JURISDICTION 

The Owner makes no representation that the content contained on the Website is appropriate or to be used or accessed outside of the Republic of India. If the Users use or access the Website from outside the Republic of India, they do so at their own risk and are responsible for compliance with the laws of such jurisdiction. 

NOTICE 
The effective date of this Policy, as stated below, indicates the last time this Policy was revised or materially changed. 

Effective Date 
June 16, 2023 

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