We care about your privacy

When you log in to our Platform or sign in to your account on our Platform using a third party interface (your google account, facebook account etc.), we collect the information as allowed by such third party. For more information on how much data and information is shared by such third parties with us, please refer to their respective privacy policies or their terms on data sharing.

We also use 'cookies'. Cookies are small pieces of data that are stored in your computer and they help us in remembering/recalling some information about you while you access our Platform such as your preferences, your log in details etc. You may change the cookie settings on your browser if you are not agreeable to the use of cookies though that may impact your experience of the Platform and you may not be able to use some of our services.

We under no circumstances and at no point take any biometric data from you for any of our services or operations. In case, if 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 (the details of the same have been provided below).

We shall use the collected data and information for the following purposes-

In addition to the above, we also collect the data for the following reasons:

• To verify identity of the user that logs in to our Platform;
• To share information with our lending partners, third parties such as developers whose projects are advertised on our Platform, payment gateways, loyalty partners etc. in order to provide you with the relevant services on our Platform;
• To share information with governmental agencies pursuant to lawful requests for information as required under any law applicable in India and outside India;
• To improve user experience and quality of our services based upon your preferences etc. including improving the quality and content of the Platform;
• To send messages, alerts and any other promotional information to you regarding our services and related matters including any surveys, feedback forms etc.;
• To enforce the terms of this policy or to defend ourselves or our employees / agents in legal proceedings;
• To share information with our employees, third party service providers etc. on a need to know basis for purposes of customer support or to resolve your queries /feedback or to enhance the quality of user experience for you or to resolve disputes, detect fraud etc.;
• To review Platform insights and performance without identifying you, track certain information about you based upon your behaviour on our Platform;
• troubleshoot problems, resole disputes, detect fraud, monitor, improve and administer our Platform;
• use the user information in other ways permitted by law to enable You to take financial services from our lending partners;
• resolve disputes and detect and protect us against suspicious or illegal activity, fraud and other criminal activity;
• the contact details (i.e. the phone number) of the third party individuals (including your relatives and friends) that are voluntarily added by you at the time of loan application may be used for the purpose of establishing contact in case we are unable to contact you, including at the time of collection of instalments;
• to perform our obligations and to enforce our rights that arise out of any agreement between you and us.

We may share your information with third parties including our technology partners, for storage, processing and other related purposes, as necessary according to the purposes mentioned in this policy, which you hereby consent to. This will be done while adhering to the Indian laws.

We may disclose your information, in order to enforce or apply our terms of use or assign such information in the course of corporate divestitures, mergers, or to protect the rights, property, or safety of us, our users, or others.

We may share your information with another business entity should we (or our assets) merge with, or be acquired by that business entity, or re-organization, amalgamation, restructuring of business for continuity of business or in case any person intends to invest in our share capital.

We shall ensure that we share such data only with entities who provide for atleast equivalent data security measures as that provided by us.

We also share your information with government agencies, judicial forums if we are required by the law or by a judicial order, to do so. Additionally, we share your information with third parties for processing your transactions and serving you better in accordance with the purposes highlighted above.

We may also share your information with our affiliate entities solely in connection with the purposes highlighted above and to fulfil the transactions for which our services have been

Any disclosure to third parties is subject to the following:

• If we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request, we shall not seek your explicit consent however we shall reasonably endeavour to notify the same to you;
• In our capacity as a lending service provider, we shall take your express consent in the event we share your personal data with third parties;
• We shall share your information with third-party only on a need basis and only for the purpose stated hereunder, as per the applicable laws.
• Usage of your information by such third parties is subject to their privacy policies. We share limited information with them, strictly to the extent required.

We use robust and stringent security practices in managerial, technical, operational and physical security control measures when it comes to storage, use and processing of your data.

We will take reasonable measures to keep your information secure, but we shall not be liable for any loss or unauthorised access or any harm caused to you by any misuse of your personal information, unless it is a direct and foreseeable consequence of negligence and non-compliance on our part only.

You are responsible for maintaining your login credentials and other allied password recovery mechanisms like phone numbers, E-Mail accounts secure.

Modifying or rectifying your information: In the event that any personal information provided by you is inaccurate, incomplete or outdated then you shall have the right to provide us with the accurate, complete and up to date data and have us rectify such data at our end immediately. We urge you to ensure that you always provide us with accurate and correct information/data to ensure your use of our services is uninterrupted. In case of modification of personal information, users will be required to furnish supporting documents relating to change in personal information for the purpose of verification by us / lending partners.

Your Privacy Controls: You have certain choices regarding the information we collect and how it is used:

• Withdrawal/Denial of consent: You acknowledge that the Platform has duly collected the information with your consent and you have the option to not provide such information, or deny consent for use of specific information or revoke the consent already given. However, any withdrawal of such personal information will not be permitted in case any service availed by you is active. Where a consent has been withdrawn the Platform does not guarantee or be liable for providing such service. You shall have the following rights pertaining to your information collected by us.

Deny Consent: You shall have the right to deny consent for use of specific data, restrict disclosure to third parties, data retention, revoke consent already granted to collect personal data and if required, make the App delete/ forget the data. However, any such denial will not prejudice the right of the lending partners to retain any data in relation to the loans availed by you or by the non-lending service providers in relation to the non-lending services provided to you with your consent. Further, in case of a denial of a consent, the Platform does not provide a guarantee or will not be liable towards the continued facilitation of the services if any such controls are exercised.

If you need to revise or review any part of or all the data or information you have provided to us, or if you wish to withdraw your consent or require us to delete your data (to the extent possible), you may contact us at our grievance officer (details below). In the event you withdraw your consent to the terms of this policy, we shall not be responsible to provide any further services to you. Further, we may not be able to delete the transactions undertaken by you on the Platform for operational reasons and if required to be stored under applicable laws.

In the event of any disputes or grievances, you may write to Mr. Pramod Shet, our grievance officer at pramod.shet@floww.money. The grievance officer shall take cognisance of the matter and undertake steps to resolve the matter in accordance with provisions of applicable laws.

In the event of non-compliance with this privacy policy or Terms of Use or such applicable laws by us, you may terminate usage of our services.

If you visit any third party Platforms or links that may be available on the Platform, please note that the use and collection of your data will be governed by such third party's privacy policy and we shall not be liable in any manner whatsoever for use and processing of such data by third parties.

By agreeing to this policy, you also agree to not host, store, transmit, display, upload, modify, update, share or publish, on our Platform or any such platform (e-mail groups etc) which you are a part of, by virtue of accessing or using the Platform any information that :

Belongs to another person and to which the user does not have any right;

Is obscene, pornographic, paedophilic, invasive of another's privacy including bodily privacy, insulting or harassing on the basis of gender, racially or ethnically objectionable, relating or encouraging money laundering or gambling, or an online game that causes user harm or promoting enmity between different groups on the grounds of religion or caste with the intent to incite violence;

Is harmful to child;

Infringes any patent, trademark, copyright or other proprietary rights;

Violates any law for the time being in force;

Deceives or misleads the addressee about the origin of the message or knowingly and intentionally miscommunicates or information which is patently false and untrue or misleading in nature or, in respect of any business of the Central Government, is identified as fake or false or misleading by such fact check unit of the Central Government as the Ministry may, by notification published in the Official Gazette, specify;

Impersonates another person;

Threatens the unity, integrity, defence, security or sovereignty of India, friendly relations with foreign States, or public order, or causes incitement to the commission of any cognisable offence or prevents investigation of any offence or is insulting other nation;

Contains software virus or any other computer code, file or program designed to interrupt, destroy or limit the functionality of any computer resource;

Is in the nature of an online game that is not verified as a permissible online game;

Is in the nature of advertisement or surrogate advertisement or promotion of an online game that is not a permissible online game, or of any online gaming intermediary offering such an online game;

Is patently false and untrue, and is written or published in any form, with the intent to mislead or harass a person, entity or agency for financial gain or to cause any injury to any person.