We at Zwitch value your trust & respect your privacy.

This privacy policy (“Privacy Policy”) provides You with details about the manner in which Your data is collected, stored & used by Us. You are advised to read this Privacy Policy carefully. By registering on the App (as defined below), using any medium: mobileapp, website, web app, mobile site or otherwise, You permit Us to use & disclose yourPersonal Information (defined below) in accordance with this Privacy Policy by providing your consent to this Privacy Policy. If You do not agree to the terms of the policy, please do not use or access the App.

“Personal Information” of a person means any information that relates to a naturalperson, which, either directly or indirectly, in combination with other informationavailable or likely to be available with Us corporate, is capable of identifying such personand includes, (wherever appropriate and/or mandated under applicable laws) personalinformation categorized as sensitive personal data or information under the InformationTechnology (Reasonable Security Practices and Procedures and Sensitive Personal Dataor Information) Rules, 2011 as below:

• password;
• financial information such as Bank account or credit card or debit card or other payment instrument details;
• physical, physiological and mental health condition;
• sexual orientation;
• medical records and history;
• biometric information;
• any detail relating to the above clauses as provided to body corporate forproviding service; and
• any of the information received under above clauses by body corporate forprocessing, stored or processed under lawful contract or otherwise.

Sensitive personal data or information that is freely available, accessible in the publicdomain, or available under the Right to Information Act 2005, is excluded from the scope of this definition.

Note: Our Privacy Policy may change at any time without prior notification. To make surethat You are aware of any changes, kindly review this Privacy Policy periodically. This Privacy Policy shall apply uniformly to Open’s website, mobile site, web/desktop pluginsand mobile applications hosted at www.zwitch.io (“App”).

Throughout this Privacy Policy, the capitalized terms "Open " " We", " Us" and "Our" refers toOpen Financial Technologies Private Limited, its affiliates and assigns, and the terms“User”, "You", "Your", and " Yourself" refer to the users of the App whose PersonalInformation is being collected in accordance with the terms of this Privacy Policy. Open isproviding this Privacy Policy to familiarize you with:

Scope of this Privacy Policy and who it applies to :

This Privacy Policy applies to all forms of Personal Information, physical and digital,whether collected or stored electronically or in hardcopy.

We handle data in our own right and also for and on behalf of the Users.

If, at any time, a User provides data or other information about someone other thanhimself, herself or itself, the User warrants that it has that person’s consent to providesuch information for the purpose specified.

The App should not be used or accessed by minors (persons under the age of 18 years).

By registering on the App, You are accepting this Privacy Policy. This Privacy Policy is incorporated into and subject to the terms of use governing access and use of the App (hosted at www.zwitch.io/tnc) ( “Terms of Use”).

Device Permissions

We collect information from and about the web-connected devices you use (“Device”) that integrates with our App, By accessing and using the App, You hereby authorize theApp with:

• Permission to access the Device's camera:

The App allows You to scan and images/documents with optical characterrecognition instead of requiring you to manually enter the data or informationrequired to avail the App services, in order to enhance your user experience. Tofacilitate the provision of these services by Open to the User, the App requiresaccess to the Device's camera. The User consents to the access of the Devicecamera for the facilitation of products/services provided through the App.

• Permission to read/copy contacts from the Device:

The App, inter-alia, enables you to create invoices, purchase orders for your vendors and customers and as a means to improve your experience, the Appallows you to automatically add contacts from your Device’s phonebook withoutcompelling You to manually enter these details in every instance. To facilitate the provision of these services by Open to the User, the App may require accessto the contact-book on your Device. The User consents to the access of thecontact-book on the Device for facilitation of products/services through the App.

• Permission to store on the Device:

The App allows you to store sales and purchase orders, reports, images, invoice pdfs etc. that are generated from the App on your Device, for the purpose of offline viewing. To facilitate the provision of these services by Open to the User, the App may store information locally on the Device of the User. The User consents to the local storage of information on the Device of the User for the provision of the products/services through the App.

• Permission to access Device location::

As a security measure and means to tackle fraud, the App accesses your Devicelocation to validate banking transactions initiated using the App. To facilitate theprovision of these services by Open to the User, the App may access the Device’slocation. The User consents to the access of the Device location for thefacilitation of products/services by Open through the App.

Information Collected

When You use the App, We collect and store Your Personal Information which is providedby You from time to time. This allows us to provide services and features that most likelymeet your needs, and to customize the App to meet your requirements and make Your experience safer and easier. We collect Personal Information from You that we considernecessary for achieving this purpose.

Open respects the privacy of its Users and is committed to protect such privacy asdetailed herein. You may encounter "Cookies" or other similar device on a web page.These are data collection devices to help analyze Our web flow and measure promotionaleffectiveness. "Cookies" are small files placed on your hard drive that assist Open inproviding services to You and giving you information targeted to Your interests. Mostcookies are session cookies, meaning that they are automatically deleted from Your harddrive at the end of a session. You are always free to decline a cookie if Your browserpermits. Once you create an account (register) on the App and give us Your Personal Information,You are not anonymous to Us. Wherever possible, We indicate which fields are requiredand which fields are optional. If You are unable to provide the information We need, Wemay not be able to provide You with the product or service You have requested

Information that we collect from you would include:

In order to determine Your eligibility and enable the products/services offered on the Appfor You, We collect and process certain categories of Personal Information belonging toYou, including the following:

• Personal information like date of birth, age, marital status, birthplace, nationality, mother tongue.
• Contact information (e.g., name, address, telephone, and email address)
• Government-issued identifiers, including PAN and GST information.
• Financial information, including bank account details, credit/debit card details, billing information, tax information and payroll information (as applicable);
• Photographs and signature copies.
• Information which would help determine Your eligibility to avail the servicesoffered on the App.
• Any other information that Open is required to collect as per specific mandate from any bank, NBFC or as a requirement under applicable law, regulation, rule or statute in India.

In addition to above, for the mobile version of the App, We may collect any other authorization or information that enables Open to provide a smooth mobile experience, including but not limited to: SMS access for auto- OTP verification, camera/gallery/contacts access and any other permissions required to enable certain functionalities within the mobile application.

Information Sharing and disclosure to third parties

Open offers the App services as a technology aggregator. In view of this, disclosure ofYour information may be required by Us to provide You access to Our services, to complywith Our legal obligations, to prevent, detect, mitigate, and investigate fraudulent orillegal activities related to Our services.

We do not disclose Your Personal Information tothird parties except in accordance with the terms contained herein. We may disclose Personal Information if required to do so by law or in the good faithbelief that such disclosure is reasonably necessary to respond to subpoenas, court orders,or other legal process.

We may disclose Personal Information to law enforcement offices, third party rightsowners, or others in the good faith belief that such disclosure is reasonably necessary to:enforce the Terms of Use or this Privacy Policy; respond to claims that an advertisement,posting or other content violates the rights of a third party; or protect the rights, propertyor personal safety of Our users or the general public.

We may disclose Personal Information to third parties who work on Our behalf, providedthat such third parties adhere to the confidentiality obligations consistent with thisPrivacy Policy. These third parties are authorized to use Your Personal Information only asnecessary to provide the App services requested or availed by You. These services mayinclude providing cloud computing infrastructure, App crash reporting, App usagepattern so that we can serve You better and providing customer support or accountadministration.

Data Retention

We will retain your information for as long as Your account is active or as needed toprovide the App services. We shall retain and use the information collected by Us asnecessary to comply with our legal obligations, resolve disputes or for other businesspurposes. If You cancel/ deactivate/ unsubscribe Your account with Us, We are not underany obligation to retain Your information. Without prejudice, We may retain Yourinformation for twelve (12) months after You cancel/ deactivate/ unsubscribe Your accountwith Us to ensure compliance with applicable laws.

Information Security

You are aware of all security risks, including possible third-party interception of any of Your transactions and statements of account on the internet and the content of Your transactions or statements of account becoming known to third parties. You agree and undertake that you shall not hold Open liable therefore in any way. The use and storage of any information, including without limitation, the credit card number, PIN, password, account information, transaction activity, account balances and any other information available or stored on Your Device is at Your own risk and responsibility. You further more acknowledge and accept that Open may not encrypt all content or communications from and to your website(s).

Your rights in relation to sensitive personal data or informationcollected by Us

You have the right to withdraw your consent at any time in writing by sending an e-mail to us at [email protected] in accordance with the terms of this Privacy Policy. However,please note that withdrawal of consent will not be retrospective in nature and shall beapplicable prospectively.

You may write to us at [email protected] to access, review, modify or correct your sensitivepersonal data or information or withdraw your consent to provide sensitive personal dataor information. We are not responsible for the authenticity of the information provided by you.

You agree and acknowledge that Your right to access, modify and/or withdrawing Yourconsent to provide sensitive personal data or information as mentioned above may be denied or limited by Us, as may be required under any applicable law, law enforcementrequests or under any judicial proceedings.

Links to other sites

Links to third-party advertisements, third-party websites or any third party electroniccommunication service which are operated by third parties may be provided on the App.Such links may not be controlled by, or affiliated to, or associated with, Open unlessotherwise expressly specified on the App.

Open is not responsible for any form of transmission, whatsoever, received by You fromany third party website. Accordingly, Open does not make any representationsconcerning the privacy practices or policies of such third parties or terms of use of suchthird party websites, nor does Open control or guarantee the accuracy, integrity, or qualityof the information, data, text, software, music, sound, photographs, graphics, videos,messages or other materials available on such third party websites. The inclusion orexclusion does not imply any endorsement by Open of the third party websites, the website's provider, or the information on the third party website.

The information provided by You to such third party websites shall be governed in accordance with theprivacy policies of such third party websites, and it is recommended that You review theprivacy policy of such third party websites prior to using such websites.

Acknowledgements

You hereby agree that the application and copies of all documents submitted by You areand shall remain the sole and exclusive property of Open, and Open shall not be obligedto return the same to you upon Your request. Any unauthorized access to the App is abreach of these terms and a violation of the law. You agree not to access the App by anymeans other than through the interface that is provided by Open.

You hereby acknowledge and agree that this Privacy Policy:

• is clear and easily accessible and provide statements of policies and practices Open with respect to information security;
• provides for the various types of personal or sensitive personal data of information to be collected;
• provides for the purposes of collection and usage of the information
• provides for disclosure of information;
• provides for reasonable security practices and procedures.
• If you have any questions in respect of this Privacy Policy, you may write to the Grievance Officer appointed under the Act:

Mr.Rajkumar R.