PRIVACY POLICY

1. GENERAL

a) This document is an electronic record in terms of the Information Technology Act, 2000 and rules made thereunder as applicable, and the amended provisions pertaining to electronic records in various statutes as amended by the Information Technology Act, 2000. This electronic record is generated by a computer system and does not require any physical or digital signatures.

b) This document is published in accordance with Rule 3(1) of the Information Technology (Intermediaries Guidelines & Digital Media Ethics Code) Rules, 2021, which requires publishing the rules and regulations, privacy policy, and Terms of Use for access or usage of https://www.urbanmoney.com

c) The domain name https://www.urbanmoney.com ("Website"), is owned and operated by Urban Money Private Limited ("Company"), formerly known as Square Capital Advisory Services Private Limited, a private company limited by shares, incorporated under the provisions of the Companies Act, 2013, and having its registered office at 1st Floor, Tower A, M3M Urbana Business Park, Sector 67, near M3M Urbana, Gurugram, Haryana – 122001.

d) For the purpose of this Privacy Policy ("Policy"), wherever the context so requires:

i) The term 'You' &'User' shall mean any legal person or entity accessing or using the services provided on this Website, who is competent to enter into binding contracts, as per the provisions of the Indian Contract Act, 1872;

ii) The terms 'We' , 'Us' & 'Our' shall mean the Website and/or the Company, as applicable;

iii) The terms 'Party' & 'Parties' shall respectively refer to the User and the Company individually and collectively, as applicable.

e)Headings in this Policy are for reference purposes only and shall not affect the meaning or interpretation of any part of this Policy.

f) The use of the Website by the User is governed by this Policy and the Terms of Use available at https://www.urbanmoney.com, and any modifications or amendments made by the Company from time to time. Continued use of the Website shall be deemed to signify the User’s acceptance of this Policy and Terms of Use.

g) The User agrees that this Policy constitutes a legally binding agreement between the User and the Company and shall be read in conjunction with the Terms of Use and any other policies governing the use of the Website.

h) The Company reserves the exclusive right to amend or modify this Policy at any time and upload the revised Policy on the Website. The User is advised to review this Policy periodically. Continued use of the Website post any such changes shall constitute User’s acceptance of the revised Policy.

2. COLLECTION OF PERSONAL AND OTHER INFORMATION

a) The Company collects basic personal information from the User such as name, address, email, phone number, date of birth, gender, PAN, Aadhaar, employment details, and income as voluntarily submitted by the User on the Website.

b) The Company also collects and stores minimal data that is necessary to provide its services, such as name, address, and contact details. No biometric data is collected or stored unless specifically permitted under statutory guidelines.

c) The purpose of collecting the User’s information is explicitly disclosed at each stage of interaction, and consent is sought before collection, use, or disclosure.

d) Explicit consent of the borrower is always obtained before sharing personal information with any third party

e) If you wish to deny consent for the use of specific personal data, please write to us at connect@urbanmoney.com

f) The Company does not store sensitive personal data beyond what is required for business or regulatory purposes.

g) Any information collected, whether directly or indirectly, is stored in compliance with industrystandard data protection practices and used for service optimization, analytics, and user experience enhancement.

3. STORAGE, PROCESSING, AND RETENTION OF DATA

a) The Company stores customer data only in secure servers located in India.

b) In cases where data is temporarily processed outside India, such data is deleted from foreign Privacy Policy_Urban Money servers and brought back to India within 24 hours, in compliance with Paragraph 11 of the Digital Lending Guidelines (DLG).

c) The Company has a well-defined data governance framework that includes:

i) Type and duration of data stored

ii) Restrictions on use of data

iii) Data destruction protocols

iv) Security breach response and incident handling procedures

d) The Company ensures data minimization by limiting collection and storage to only what is necessary for lawful purposes.

4. COOKIES

a) The User is aware that a ‘Cookie’ is a small piece of information stored by a web server on a web browser so it can later be traced back from that particular browser, and that cookies are useful for enabling the browser to remember information specific to a given user, including but not limited to a User's login identification, password, etc. The User is aware that the Website places both permanent and temporary cookies in the User&apso;s computer's hard drive and web browser, and does hereby expressly consent to the same.

b) The User is further aware that the Website uses data collection devices such as cookies on certain pages of the Website to help analyze web page flow, measure promotional effectiveness, and promote trust and safety, and that certain features of the Website are only available through the use of such cookies. While the User is free to decline the Website's cookies if the User's browser permits, the User may consequently be unable to use certain features on the Website.

5. DIVULGING/SHARING OF PERSONAL INFORMATION

a) Any sharing of personal data with third parties occurs only after obtaining explicit consent from the User, and only for purposes communicated clearly in advance.

b) The Company complies with applicable laws when responding to requests from regulatory authorities, and ensures that data disclosures are lawful, necessary, and proportionate.

6. SECURITY

Transactions on the Website are secure and protected. Any information entered by the User when transacting on the Website is encrypted to protect the User against unintentional disclosure to third parties. The User's credit and debit card information is not received, stored by or retained by the Company / Website in any manner. This information is supplied by the User directly to the relevant payment aggregator/gateway which is authorized to handle the information provided, and is compliant with the regulations and requirements of various banks and institutions and payment franchisees that it is associated with.

All personal data is encrypted and securely stored. The Company does not retain or store User’s card or biometric information. All such sensitive data is managed by authorized payment gateways or processors in compliance with applicable regulations. Data access is restricted to authorized personnel only.

7. THIRD PARTY ADVERTISEMENTS / PROMOTIONS

The User is aware that the Company/Website uses third-party advertising companies to serve ads to the users of the Website. The User is aware that these companies may use information relating to the User’s visits to the Website and other websites in order to provide customized advertisements to the User. Furthermore, the Website may contain links to other websites that may collect personally identifiable information about the User. The Company/Website is not responsible for the privacy practices or the content of any of the aforementioned linked websites, and the User expressly acknowledges the same and agrees that any and all risks associated will be borne entirely by the User.

8. USER'S CONSENT

User expressly consents to the collection, use, sharing, processing, and storage of their data as outlined in this Policy. User also acknowledges that explicit consent is required and obtained before sharing data with any third party or using it beyond the stated purpose.

9. GRIEVANCE OFFICER

In accordance with Information Technology Act 2000 and rules made thereunder, the name and contact details of the Grievance Officer are provided below:

Mr. Piyush Bothra, email address: piyush.bothra@squareyards.com

10. DISPUTE RESOLUTION AND JURISDICTION

It is expressly agreed to by the Parties hereto that the formation, interpretation and performance of this Policy and any disputes arising here from will be resolved through a two-step Alternate Dispute Resolution ("ADR") mechanism. It is further agreed to by the Parties that the contents of this Section shall survive even after the termination or expiry of the Policy and/or Terms.

a) Mediation: In case of any dispute between the parties, the Parties will attempt to resolve the same amicably amongst themselves, to the mutual satisfaction of both Parties. In the event that the Parties are unable to reach such an amicable solution within thirty (30) days of one Party communicating the existence of a dispute to the other Party, the dispute will be resolved by arbitration, as detailed herein below;

b) Arbitration. In the event that the Parties are unable to amicably resolve a dispute by mediation, said dispute will be referred to arbitration by a sole arbitrator to be appointed by the Company, and the award passed by such sole arbitrator will be valid and binding on both Parties. The Parties shall bear their own costs for the proceedings, although the sole arbitrator may, in his/her sole discretion, direct the other party to bear the entire cost of the proceedings. The arbitration shall be conducted in English, and the seat of Arbitration shall be Delhi India

The Parties expressly agree that the Terms, Policy and any other agreements entered into between the Parties are governed by the laws, rules and regulations of India, and that the Courts at Delhi shall have exclusive jurisdiction over any disputes arising between the Parties.