1. Introduction

Freed India Private Limited ("FREED", "we", "us", "our") is committed to protecting the privacy and security of your personal data. This Privacy Policy explains how we collect, use, store, disclose and otherwise process personal data of users ("you", "your", "User(s)") in connection with our mobile application (the "App") and any associated website/portal (together, the "Platform") which enables you to view, monitor and analyse your credit information (including credit bureau score, credit report) obtained from authorised credit information companies ("CICs") in India.

By using the Platform, registering an account, or otherwise providing your personal data to us, you consent to the processing of your personal data in accordance with this Privacy Policy. If you do not accept this Privacy Policy, please do not use the Platform.

2. Definitions & Scope

You represent, warrant and covenant that:

Personal Data / Personal Information: means any information/ documents/ details that relates to a natural person, which either directly or indirectly in combination with other information available with FREED, can identify such a person.

Processing: collection, storage, use, disclosure, transfer, deletion, or any other operation performed on Personal Data.

This Privacy Policy applies to all Users of the Platform in India and to personal data collected by us whether via App, Website, other online or offline means.

3. Data We Collect

We may collect the following categories of personal data, as required for providing our services:

3.1 Data you provide us directly

• Identity information: name, date of birth, gender, photograph, unique identifiers (PAN, Aadhaar number if required for KYC or verification)
• Contact information: address, email, mobile number
• Financial / credit information: credit bureau score, credit report data (from CICs), account numbers, loan/credit history, payment history
• KYC / verification information: documents you upload (identity proof, address proof), bank account or payment instrument details if required
• Usage data: details of how you interact with the Platform (features used, date/time of access)
• Device information: IMEI, device ID, operating system, IP address, browser type
• Other information: any other information you choose to provide (for example feedback, support requests)

3.2 Data collected automatically

• Log information: IP address, device identifiers, crash data, date/time stamps, usage analytics
• Cookies, pixels, other tracking technologies used on the Website or App (for improving our service, analytics, security)
• Location data (if you grant permission and if required for certain features, though for a credit-score app this may be limited)

4. Purposes of Processing

We process your personal data for the following purposes:

• To register and manage your account on the Platform
• To verify your identity, to comply with KYC/AML/credit-reporting compliance obligations (including those under CICRA)
• To obtain your credit information from authorised CICs (with your consent) and display it to you
• To provide credit-score monitoring, alerts, dashboard, analytics and improvement tools
• To personalise your experience, provide recommendations, push-notifications, in-app messages
• To send you service-related communications (e.g., account status, changes to features) and, if you consent, marketing communications
• To comply with legal obligations, respond to lawful requests by regulators/authorities or courts
• To detect and prevent fraud, unauthorized access or misuse of the Platform
• To improve, maintain and optimise our services, for analytics, research and business intelligence

5. Legal Basis & Consent

You hereby provide FREED with your consent for the processing of your personal data as per this Privacy Policy as may be necessary for the legitimate purposes of providing the Platform to you and complying with applicable legal obligations (such as credit information regulation under CICRA). You may withdraw your consent at any time (subject to certain limitations, e.g., if we are required to retain data for compliance or dispute resolution) by writing an email to karishma.arora@freed.care

6. Disclosure of Your Data

We will treat your personal data as confidential, and will not disclose it to third parties except under the following circumstances:

• To authorised CICs (credit information companies) for the purpose of obtaining your credit information (with your explicit consent);
• To our service providers, vendors or partners (including hosting providers, analytics, KYC/verification agencies) who require access to your data to provide services to us; we impose contractual obligations to maintain confidentiality and security;
• To group companies or affiliates of FREED to the extent necessary for providing you the Services or if you indicate a preference to avail any other services provided by FREED or its group companies or affiliates;
• To regulators, courts, law enforcement or other government authorities when required by law or to protect rights, property or safety of FREED, its users or others;
• If FREED is acquired or merges with another entity, or sells/develops new business lines: your data may be transferred in accordance with this Privacy Policy, and we will notify you where required;
• For aggregated or anonymised data (which does not identify you personally) for research, business intelligence or analytics.

7. Data Retention

We will retain your personal data only for as long as necessary for the purposes stated in this Privacy Policy, unless a longer retention period is required or permitted by law. After the retention period ends, we will securely delete or anonymise the data such that it can no longer identify you.

8. Data Security & Transfers

We implement reasonable and appropriate technical and organisational measures to protect your personal data from unauthorised access, misuse, alteration or destruction (e.g., encryption, access control, auditing).

All servers and data storage employed by us are located in India.

Although we endeavour to protect your data, no security system is entirely fail-safe. We cannot guarantee absolute security, and you accept that there is some risk inherent in transmitting data over the internet.

9. Your Rights

We acknowledge that you have following rights in relation to your personal data, including:

• Right to access your personal data that we hold
• Right to request correction or update of your personal data if inaccurate or incomplete;
• Right to request deletion or erasure of your personal data (subject to exceptions for compliance or legitimate business necessity)
• Right to withdraw your consent for processing (if applicable)
• Right to object to certain processing (if applicable)
• Right to complain to a supervisory/regulatory authority

To exercise your rights or if you have queries about your data, please contact our Grievance/Privacy Officer at the contact details below (see section 12).

10. Cookies and Tracking Technologies

We may use cookies, web beacons, SDKs, analytics tools and other tracking technologies in connection with the Platform to collect data about your device, usage patterns, browser interactions to help us understand how the Platform is used, improve performance, personalise content and for security/fraud-detection purposes. You can manage cookies through your browser or device settings, however disabling cookies may affect your use of certain features of the Platform.

11. Children / Minors

The Platform is intended for use by persons aged 18 years or older. We do not knowingly collect personal data from anyone under 18. If you believe we have inadvertently collected data from a minor, please contact us and we will take appropriate steps to delete such data.

12. Grievance Officer & Contact Details

If you have any questions or concerns about these Terms, please contact us at:

13. Changes to this Privacy Policy

We may update this Privacy Policy from time to time (for example to reflect changes in our data practices, legal/regulatory requirements, or the features of the Platform). We will notify you of any material changes by posting the updated version on the Platform and revising the "Last updated" date. Your continued use of the Platform after such changes constitutes your acceptance of the updated policy.

14. Miscellaneous

• If any provision of this Privacy Policy is found to be invalid or unenforceable, the remaining provisions will remain in full force and effect.
• This Privacy Policy is subject to the governing law and dispute resolution provisions set forth in our Terms & Conditions.
• This Privacy Policy is not intended to and does not create any contractual rights enforceable by third parties.

15. Account Deletion & Data Removal Requests

If you wish to delete your account and have all associated personal data removed from our systems, you may submit a request at any time by contacting us at help@freed.care.

Upon receiving your request, we will verify your identity and process the deletion in accordance with applicable data protection laws.

Please note that certain information may be retained where required for legal, regulatory, or legitimate business purposes.