# AMICA FINANCIAL TECHNOLOGIES PRIVATE LIMITED
        ## PRIVACY POLICY 2020
        
        This document is published in accordance with the provisions of Rule 4(1) of the Information Technology (Reasonable
        Security Practices and Procedures and Sensitive Personal Data or information) Rules, 2011 which requires the publishing
        of a privacy policy for handling of or dealing in personal information including sensitive personal data or information.
        
        1. GENERAL
        Amica Financial Technologies Private Limited (“Amica”, “we”, “our” or “us”) recognizes the importance of protecting
        personal details and information and provides this Privacy Policy with respect to the access and use of www.bullet.money
        and mobile application (“Sites”) as owned and operated by us and/ or our affiliates and services provided thereon by us
        and/ or our affiliates (“Services”). The term Sites will also include all pages that are sub-domains or are associated
        or within each Site and all devices, applications, features, technologies, functionalities and other services that Amica
        operates or offers through such Sites.
        For the purpose of this Privacy Policy, the user of Services may be customers, or any other persons using Services or
        accessing Sites (“User”, “you” or “your”). This Privacy Policy will help you understand our policies and procedures
        regarding the collection, handling and use of your information.
        By using our Services through the Sites, you signify your assent to this Privacy Policy and consent to the processing of
        your Information (personal information and/or sensitive personal data or information). If at any time, an individual
        provides Information about someone other than himself or herself, the individual warrants that they have that person’s
        consent to provide such information for the purpose specified. The Services are not available to persons below the age
        of 18 years.
        If you do not agree with this Privacy Policy do not, in any manner, use our Services or download, install and/ or use
        the mobile application.
        2. INFORMATION COLLECTION
        We collect such information about you which is essential to operate our business and to enable us to deliver and improve
        our Services and offer you our new products. We may obtain the following information about you and your device from
        which you avail Services:
        i. Profiling Information: For providing Services we require certain information for registration such as your name,
        physical addresses, postal addresses, PAN details, Aadhar details, telephone and fax numbers; and certain information
        about your personal identity such as gender, age, etc. Further, we also collect and store your usernames, passwords,
        email addresses and other security-related information that you use for our Sites in relation to our Services. We may
        also collect details about how you use our Sites.
        
        ii. Service Usage and Transactional Information: For enabling you to make payments using our Services, we may, upon your
        consent, store your financial information such as your bank account or details mentioned on your credit cards or debit
        cards, or other payment instrument details etc. that are required for a successful transaction. We also store
        transaction details such as amount spent, counterpart details, transaction ID, date and time of transaction. Further, we
        may also store information relating to your income, lifestyle levels and usage pattern.
        We clarify that all information stored by us is in accordance with applicable laws.
        iii. Correspondence Information: We collect the content, information about your correspondence, the destination/ origin
        of communications between you and any other person using our Services, which include email communications, blog, chat
        room and discussion board communications, instant message communications, experts forum communications, facsimile mail
        communications, membership of mailing lists etc.
        iv. Cookies: A cookie is an insignificant portion of data that is sent to the web browser of your device from which Site
        is accessed. If your web browser settings permit, cookies can be sent to your web browser for recording information
        about your online preferences and allowing us to cater to your interests in a better manner. You can set your browser to
        notify you when you are sent a cookie, giving you the chance to decide whether or not to accept it. If you do accept a
        cookie, you thereby agree to our use of information collected by us using that cookie.
        v. Stored Information: We may collect any data or information either created by you or by a third party and which you
        wish to store on our servers such as usernames, image files, documents, etc. or which may be required to display
        information to you through our Service.
        vi. One Time Password (“OTP”): OTP is a one-time password which is provided by your issuing bank in order to carry out
        the second factor authentication of your debit/credit/payment card. If you opt for our ‘one tap’ feature, you understand
        that we will be able to retrieve your OTP from the message received on your mobile and populate and submit the OTP on
        the issuer’s page for second factor authentication of your debit/credit card.
        vii. Information from other sources: We collect information about your navigation using our Services, for example the
        URLs of websites from which you reach our Site, websites or pages of merchants you visit using our Services. We may also
        collect details of your browser, operating system, domain name, IP address, mobile application version and such other
        information that Amica is required to collect in order to provide a smooth mobile experience, including but not limited
        to sms access, camera/ gallery/ contacts/ location access, for various functionalities within the application. If any of
        your information is publically available on social networking sites, we may also collect the same.
        viii. Information from external sources: When you sign up, we search your record at credit reference agencies to check
        if we can offer you an overdraft and manage business risk, and at fraud prevention agencies and KYC (Know Your Customer)
        and AML (Anti Money Laundering) service providers to fulfil our legal duties.
        ix. Other information: We collect information that is required to be collected as per specific mandate from any
        bank/nbfc or as a requirement applicable as per the legal rules in India.
        x. We may collect information with your consent from your mobile device like transactional and promotional (non-personal) 
        SMSes. Other SMS data is not accessed.
        
        3. PURPOSE & USE OF INFORMATION
        We understand the importance of your Information and ensure that it is used for the intended purpose. By accepting the
        terms of use you agree that we may collect and store your Information, in accordance with the applicable law and
        applicable data privacy standards, as long as you subscribe to or use our Services subject to the limitations set out in
        this Privacy Policy:
        i. We require the profiling information which includes details such as identity details, contact details, usernames and
        passwords in order to manage our relationship with you and provide Services to you.
        ii. We collect and store your service usage and transactional information in order to enable you to view certain details
        of all your transactions which have been made using our Services, to provide you uninterrupted and satisfactory
        Services, to administer our relationship with you, to comply with any statutory or regulatory requirement, to monitor
        your use of our Services for the purposes of ensuring compliance with our user rules.
        iii. To improve our Services, we need to constantly update and alter our business and marketing strategies for which we
        require the navigational and log information to determine and analyse the merchants, markets, technology, operating
        systems, browsers, devices, locations from which our Services are used most or used least. For example, such information
        and its analysis will help us focus more on your needs by providing you a wider range of Services, or developing updates
        for particular operating systems and mobile application versions, etc. Further, the information collected helps us offer
        you other products, programs, or services that we believe may be of interest to you. In addition, such information
        collected will help us alert you in case of software compatibility issues.
        iv. We want to serve you better and therefore we require your correspondence information in order to enable us to learn
        about the information and content of communications by you such that we can deduce your feedback from such
        communications, analyse, endeavour to improve, ask you for further feedbacks, reply.
        v. The data collected by cookies helps us track, analyse and understand User trends so as to enable us to understand
        lacunas (such as slow response time on our website page or application) and improve your interactive experience of using
        our Services, our web design, features and functionalities.
        vi. We access data or information stored by third party in case required for providing you uninterrupted and
        satisfactory Services or in case consented by you.
        vii. Combinations of the information collected as mentioned in this Privacy Policy such as physical address, device
        information, email address when coupled with information which is not Information such as speed of typing, the maximum
        screen area usage, other patterns and data help us detect and protect Users and ourselves against errors, fraud, or
        other criminal activity.
        viii. We use your Information to check your record at credit reference agencies when you sign up to see if we can offer
        you an overdraft or a loan. Further we share Information with credit bureaus so we can benefit from up to date
        information when we make lending decisions.
        
        ix. We use your Information to tell you about products and services through the Sites or other channels, like social
        media companies, based on how you use our products and services and other Information we hold about you. We do this so
        we can make sure our marketing is useful. That includes instructing platforms to show or not show Amica advertisements
        to existing customers. We don’t share any identifying information with social media companies other than your mobile
        advertising ID. You can disable or reset your mobile advertising ID in your device’s operating system.
        Further, we may use the data and Information collected/ stored as mentioned above for improving our services, improving
        user experience, risk checks, strengthening our security checks, for analysis and for offering you new features in the
        existing services you are availing or offering altogether new product/ service which may be relevant for you. We collect
        and use some of your Information in an aggregated form to compile statistical and demographical profiles for our
        business and marketing activities and to customise our Services to you.
        x. SMS data will be used only to monitor financial transactional SMS for description of the transactions and the 
        corresponding amounts for credit risk assessment. 
        4. DISCLOSURE OF INFORMATION
        We do not disclose or share your Information with any third party until essential for providing you Services; or for the
        below purposes in accordance with this Privacy Policy:
        i. Information security is critical to us and we will not share your Information with any other third parties except,
        and only to the extent necessary, with parties such as our merchants, acquiring banks, credit card processors, etc. for
        us to deliver payment processing services to you and such third parties with which Amica has entered into an applicable
        data processing agreement or adhere to confidentiality obligations consistent with this Privacy Policy.
        ii. You acknowledge and agree that in the interests of improving personalisation, offering new features in the existing
        services you are availing, offering new products/ services which may be relevant for you and Service efficiency, we may,
        under controlled and secure circumstances, share your Information with our affiliates or associates.
        iii. We do not share, disclose or distribute any of your Information to any third party unless required under an
        arrangement between Amica and the third party for product enhancement, analysis, risk and security purposes,
        communication purpose, etc. For example, Amica may, itself or through third parties, send you e-mails, SMS, such other
        means to communicate, send reminders for payment, advertise its services, promote new products and activities or for
        your invaluable feedback.
        iv. We do not use your Information for marketing purposes unless we receive the express consent of the User.
        v. If, by usage of some functionalities of our Service, you receive Information about other user(s), you agree to keep
        the same confidential and only use it in connection with the Services, without disclosing the same to another user or
        third party.
        vi. In order to ensure that all our users comply with the user rules, we may monitor your Information to the extent that
        this may be required to determine compliance and/or to identify instances of non-compliance.
        
        vii. We may disclose the Information if required to do so by applicable law or in the good faith that such disclosure is
        reasonably necessary to comply with any directive or order of a government entity or statutory authority or any judicial
        or regulatory authority or any law enforcement agencies in any official investigation including but not limited to cyber
        incidents, prosecution and punishment of offences. You agree that Amica has the right to monitor and to disclose
        Information as may be necessary to satisfy any law, regulation or other governmental request. We may transfer your
        Information or other information collected, stored, processed by Amica to any other entity or organization located in
        India or outside India only in case it is necessary for providing Services to you in connection with Application. We
        will cooperate with the appropriate law enforcement authorities in investigating claims of illegal activity.
        viii. We will only disclose your Information in accordance with this Privacy Policy. If we want to use it for any other
        purpose, we will obtain your consent.
        ix. If you decline to submit Information to us, then we will unfortunately not be in a position to provide the Services
        to you.
        x. If all or some of the business, stock or assets of Amica are acquired or merged with another business entity, we will
        share all or some of your Information with such entity to continue to provide the Service to you.
        xi. Amica does not control the acts of its Users. All Users should be aware that, when they disclose Information such as
        their name, e-mail address, etc. to third parties, the Information may be collected and used by others to send
        unsolicited e-mail from other parties, who may or may not be Users. In the event that you encounter any person
        improperly collecting or using information about Users, please contact us by emailing at support@bullet.money.
        5. SECURITY OF INFORMATION
        i. We work to protect the security of your information during transmission by using appropriate software, which encrypts
        information you input. This encrypted information is stored on secure systems/ computers. Further, we ensure that the
        number of employees involved in the management of the data centre who have physical access to these computers is
        limited. Also, we use advanced security technology to prevent our computers from being accessed by unauthorized persons.
        ii. We have also implemented information security practices and standards and have in place information security
        programmes and policies containing managerial, technical, operational and physical security measures that are in
        compliance with the Indian laws including, so as to protect the Information provided to us from unauthorized access,
        use, modification, damage, disclosure or impairment. Further, we may from time to time use reasonable additional or
        alternative procedures to ensure the security and confidentiality of your Information through our Sites.
        iii. No data transmission over the internet is fully secure, so we cannot ensure or warrant the security of any
        information you submit to us. Further, we do not guarantee in any way, the security of any Information that you transmit
        or share on the Site; and you do so at your own risk.
        
        iv. If any security breach comes to our knowledge, then we may take all steps required to protect misuse of such
        Information and may attempt to notify you electronically so that you can take appropriate protective steps.
        Any of your information which you provide when you use our Services to an open, public environment or forum including
        (without limitation) any blog, chat room, community, classifieds or discussion board, (a) will not be considered
        confidential, (b) will not be considered as Information, and (c) is not subject to protection under this Privacy Policy.
        Since such public environments are accessible by third parties, it is possible that third parties may collect or use
        such information for their own purposes. You should accordingly be careful when deciding to share any of your
        Information in such public environments. Please note that we are not liable to you or any third party for any damages
        that you or any third party may suffer on account of your disclosure of Information in any public environment.
        
        6. DATA RETENTION
        We will retain your Information for as long as your account is active or as needed to provide our Services. We shall
        retain and use the Information collected by us as necessary to comply with our legal obligations, resolve disputes or
        for other business purposes. If you cancel/ deactivate/ unsubscribe your account with us, we are not under any
        obligation to retain your Information. However, we may retain your Information for a period of twelve (12) months or
        more, after you cancel/ deactivate/ unsubscribe your account with us, as our business practice.
        
        7. CHANGES TO THE PRIVACY POLICY
        Amica reserves the right to change, modify, add, or remove portions of this Privacy Policy at any time for any reason.
        In case, any changes are made in the Privacy Policy, Amica shall update the same on the [website/application]. Users
        should periodically review this page for the latest information on our privacy practices. Once posted, those changes are
        effective immediately, unless stated otherwise. Continued access or use of the Services constitutes your acceptance of
        the changes and the amended Privacy Policy. However, if you do not agree with the changes, please do not continue to use
        the Services or submit Information to us.
        
        8. LINKS TO OTHER SITES
        i. Links to third-party advertisements, third-party websites or any third party electronic communication service may be
        provided on the Sites which are operated by third parties and are not controlled by, or affiliated to, or associated
        with Amica unless expressly specified on the Sites.
        ii. Amica is not responsible for any form of transmission, whatsoever, received by you from any third party website.
        Accordingly, Amica does not make any representations concerning the privacy practices or policies of such third parties
        or terms of use of such third party websites, nor does Amica control or guarantee the accuracy, integrity, or quality of
        the information, data, text, software, music, sound, photographs, graphics, videos, messages or other materials
        available on such third party websites. The inclusion or exclusion does not imply any endorsement by Amica 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 the privacy policies of such third party websites, and
        it is recommended that you review the privacy policy of such third party websites prior to using such websites.
        
        9. ACKNOWLEDGEMENTS
        It is clarified that the consolidated Information of all Users which has been collected by us or provided to us, is the
        property of Amica and we may use it, in whole or in part, in our sole discretion and without any compensation to you,
        for any legitimate purpose and you hereby confirm that you have no objection to the aforesaid use of your Information.
        Any unauthorised access to our Sites is a breach of these terms and a violation of the law. You agree not to access the
        Sites by any means other than through the interface that is provided by Amica.
        
        10. YOUR RIGHTS
        You have a right to:
        i. Access the Information we hold about you, or to get a copy of it in a portable (machine readable) format or make us
        send it to someone else.
        If you require a copy of the Information we have collected from you or you want us to share your Information with a
        third party, please send us your request by email on the support@bullet.money.
        ii. Make us correct inaccurate data.
        If you are a User, and would like to view the information we have collected from you or you want to correct your
        information or details, please send us your request by email on the support@bullet.money.
        iii. Withdraw any consent you have given to us.
        The User can at any time while availing the services or otherwise, withdraw his/her consent given previously to Amica
        for collecting, receiving, possessing, storing, dealing or handling Information of the User, by sending us your request
        by email on support@bullet.money. In such case, Amica will unfortunately not be in a position to provide the Services to
        you.
        
        11. CONTACTING AMICA
        If you have any questions, queries, concerns or feedbacks about this privacy policy or our privacy related practices,
        please feel free to contact us at on the ‘contact us’ page on www.bullet.money
        In case you have any grievance relating to the collecting, receiving, possessing, storing, dealing or handling of
        Personal Information provided by you, you may contact our Grievance Officer at the following address:
        
        Name: Designation: Address:
        Vishwanath Sharma
        Company Secretary and Manager (Legal)
        32, 3rd floor, Viraj Buildings, SV Road, Above HDFC Bank Mumbai- 400052, Maharashtra, India.
        Phone no: 022-68619000