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Privacy Policy

This privacy policy (“Privacy Policy”) sets out the manner in which Fintech Blue Solutions Private Limited (“Company”, “we”, “us”, “our”, “ours”) collects, uses, processes, stores, handles and discloses our users’ (“User”, “you”, “your”, “yours”) information (“Personal Information”) gathered on the ‘Turtlefin’ website https://www.turtlefin.com/ and mobile phone application, and the application programming interfaces deployed by the company for the provision of its services (“Platform”, together “Platforms”). The Company provides technology services to its customers, including services for hosting and distributing their products and services to their end-customers (“Services”). 

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Please read this Privacy Policy carefully and note that by continuing to use the Services or accessing the Platform(s) you agree to this Privacy Policy. By accepting this Privacy Policy, you represent that you are eighteen years of age or above and that you expressly agree to the collection, storage, processing, disclosure and/or transfer, and use of your Personal Information according to terms set out hereunder.

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1.    Collection of Personal Information and other information
When you use our Platform(s), we collect and store your Personal Information as provided by you from time to time. Our primary goal in doing so is to provide you a safe, efficient, smooth and customized experience. We may collect Personal Information from you in a variety of ways, including, but not limited to, when Users visit our Platform(s), register on the Platform(s), avail our Services and in connection with other activities, services, features or resources we make available on our Platform(s). 


This may include the collection of Personal Information, including but not limited to your (a) contact details like name, email address, mailing address, phone number, IP address, (b) copies of government issued identity cards like PAN, Aadhaar, drivers’ license, voter ID card, etc. which you may provide voluntarily as proof of address and/or identity for our third party customers, as may be required under applicable laws; and (c) and non-personally identifiable information such as browser name, operating system, name of internet service provider, etc., with the goal of improving our Service.
Please note that we may further collect certain Personal Information on behalf of our third-party customers. Consent may be provided for such collection and use of your Personal Information will be subject to such third parties’ privacy policies and terms and conditions.


You undertake that you shall be solely responsible for the accuracy and truthfulness of the Personal Information you share with us, and that the Company will not be responsible for ensuring the authenticity of your Personal Information. You may choose to request access for reviewing your Personal Information and request any modification or amendment of Personal Information by writing to the Company grievance officer (“Grievance Officer”) at the contact details mentioned in this Privacy Policy.


You further understand and acknowledge that provision of your Personal Information is voluntary, and you may choose to provide and/or withhold provision of any such information. You may further choose to withdraw your consent for use/collection of your Personal Information at any point by writing to the Grievance Officer. However, in case of non-provision of any Personal Information or withdrawal of consent from the Company to collect and use your Personal Information, you may not be eligible for certain services for which such Personal Information needs to be collected.
 

2.    Cookies
A “cookie” is a small piece of information stored by a web server on a web browser so it can be later read back from that browser. Cookies are useful for enabling the browser to remember information specific to a given user. We place both permanent and temporary cookies in your computer’s hard drive. You may choose to set their web browser to refuse cookies, or to alert you when cookies are being sent.

 

3.    Use of your information
We may use your Personal Information for the following purposes:

  • To personalize User experience;

  • To improve our Platform(s), products and Services we offer;

  • To facilitate the identity verification and know-your-customer procedures by our customers with respect to their end customer (for instance, legally mandated checks to be implemented by insurers for issuance of policies to their customers under specific sectoral laws);

  • To improve customer service;

  • To send you information and updates pertaining to our Services;

  • To send periodic communication in the form of a newsletter, updates about our products or other promotions. Email unsubscribe instructions may be included at the bottom of each email or User may contact the relevant support team from where they have received the email;

  • To contact you via email or phone on your contact details provided to offer you information and services pertaining to the product you have opted for; 

  • To carry out our obligations under agreements with third parties including our business partners, group companies, affiliates, etc. and to comply with our legal obligations under applicable laws in India (“Applicable Laws”); 

  • To investigate and resolve any claims, complaints, disputes or user grievances.  
     

You agree and acknowledge that collection of your Personal Information is necessary for the purposes above and the collection of the same is in furtherance of a lawful purpose.
 

4.    Retention of Personal Information
We will retain your Personal Information for as long as necessary for the purposed described above and for providing our Services. We may also retain and use your Personal Information for such period as is necessary to comply with Applicable Laws, fulfill our legal obligations, resolve disputes, and enforce our agreements. 


5.    Protection of your Personal Information
We have adopted reasonable security practices, including physical, managerial, operation and technical security measures to protect against unauthorised access, alteration, disclosure or destruction of your Personal Information and data stored by the Company, as required under Applicable Laws (as defined hereunder). We further endeavor to keep such security practices and procedures updated as and when new technology becomes available, and as may be appropriate.
 

6.    Sharing your Personal Information
The Company does not sell your personal information with any third party for any purpose whatsoever. Keeping this in mind, we may disclose, transfer and/or share your Personal Information with certain persons, including persons outside India, for the following cases: 

  • To our partners, affiliate entities, employees, consultants, contractors, independent service providers and other third-parties and persons who are bound by contractual obligations to keep User Personal Information confidential and use it only for the purposes for which we disclose it to them, namely for providing our Services or to assist us with our operating the Platform(s).

  • To our affiliates, subsidiaries, group companies, related parties and other assigns to allow them to provide support services and technical services to us and to receive some of these services from them and to provide support services and technical services to them and to offer their products and services to you including offering combined products and services. 

  • For administering activities such as detection of identity theft, fraud and other potentially illegal acts, to facilitate joint or co-branded Services that you request where such services are provided by more than one corporate entity. We may share your information with these third parties for those limited purposes provided that you have given us your permission.

  • 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 fulfil our obligations under any Applicable Law or enforce our legal rights, pursue our legal remedies, respond to subpoenas, court orders, or any other legal process.

  • For any other purpose in connection with the purposes above.

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Other than as prescribed under this Privacy Policy, we will not disclose any User Personal Information to any external organisation unless (i) we have obtained the consent of the User; or (ii) we are required by law to provide such information.

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Notwithstanding anything mentioned hereinabove, the Company shall not be responsible for the actions or omissions of the service providers or parties with whom the Personal Information is shared, nor shall the Company be responsible and/or liable for any additional information you may choose to provide directly to any service provider or any third party.

 

7.    Links to third party websites
Users may find advertising or other content on our Platform(s) that link to the sites and services of our partners and other third parties. We do not control the content or links that appear on these sites and are not responsible for the practices employed by websites linked to or from our Platform(s). Browsing and interaction on any other website, including websites which have a link to our Platform(s), is subject to that website’s own terms and policies. We encourage you to read the privacy policies of any third party before proceeding to use their websites, products, or services.


As noted in Section 1 above, you understand and acknowledge that we may further collect certain Personal Information on behalf of our third-party customers. The collection and use of your Personal Information will be subject to such third parties’ privacy policies and terms and conditions. 
 

8.    Updates to this Privacy Policy
We reserve the right to update, modify and change this Privacy Policy, from time to time, and we will post those changes on our Platform(s) so that you are always aware of how we collect and use your Personal Information. We encourage you to frequently check our Platform(s) for any change in this Privacy Policy. If you do not agree with any revisions to this Privacy Policy, please consider refraining from further use of our Services and write to our Grievance Officer.

 

9.    Complaints & Grievances

  • If you have any questions, concerns or grievances regarding this Privacy Policy, you can reach out to our Grievance Officer Mr. Manoj Pandey at our grievance email-address: grievance@turtlefin.com. 

  • The grievance will be acknowledged within 7-10 working days of its receipt.

  • We will further resolve your concerns as expeditiously as possible, and no later than within 1 month of receipt.

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Last Updated: 02-March 2023

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