PRIVACY POLICY

ZEPHYR SOLUTIONS (PRIVATE) LIMITED is a high-tech financial service consulting business that cares about customers’ privacy, and for that reason, we always treat your information as carefully as possible.

Personal information defined in this Privacy Policy is information that can be used to identify you.

“Information” is defined in this Privacy Policy as all information that can be used to identify you that is collected through any methods and by any means.

How your information is exploited and protected is explained in the Privacy Policy and Agreements. Please note this Privacy Policy may be updated by us at any time at our discretion, to accommodate possible legal and/or market changes, while ensuring the confidentiality of your information.

Please carefully refer to this Privacy Policy before using the services we provide and accessing our websites or mobile app, because through the above actions, you understand and agree to the terms set forth in this Privacy Policy and we do not need any further permission from you to do the things we have specified in this Policy.

• 1. Scope of information collection:

Through any lawful means (including but not limited to: our website, portal, mobile app ), we may collect and process the information about customers as following:

• 1.1. Information that Customers provide to us:

Information provided to us may include, but is not limited to:  Full name, gender, date of birth, place of birth, address (permanent residence, temporary residence, contact address), marital status;  Profession, source of income, income level;  Phone number, phone model, phone serial number, email address (email);  Financial status, information about credit/debit cards, bank accounts;  Identity characteristics and self-image, social network profiles;  Personal or workplace references that we may ask you to provide if necessary when customers apply for a loan;  Other relevant information. The above information is provided by the Customer through:  Information to be filled out in registration forms and sent to us from Customers; Customer’s interaction on our web platform: lotus.loan ;  Customer’s interaction through phone channels, messages, emails or any other means of communication.  Other related means.

• 1.2. Information collected during the use of the service:

 Service information: including information about the service that the Customer is using such as product type, registration date and time, the amount corresponding to the product type, service period and other relevant information related to the service.  Device information: electronic devices that customers use to access and use services on mobile applications, including but not limited to hardware model, operating system and version, software, device identifier and other relevant information.  Location information: information about the location of the Customer when the Customer accesses the phone application or through other means that the Customer allows determining the Customer’s location.  Contact Information: You authorize us to access your device’s contacts in order to collect names and contact information from your contacts in support of the services we provide.  History, app, camera, picture, audio and other information: When Customers use our services, we collect device information such as application and history information (device’s IP address, access date and time, application features and other system activity, browser and website type, etc.), images and audio (accessing and using the camera and images stored on the Customer’s electronic media for the process of using the service), other relevant information to serve the process of using the service.

• 1.3. Information collected from other sources:

 Information has been made public on any medium by any means.  Information collected from other sources by our business partners/associates, banks associated with us, credit reporting agencies, other credit information providers, and third-party information sources as permitted by law.  Other relevant sources.

• 2. Purpose of collecting Customer information:

The information we collect from you may be used for any of the following purposes:

 Register and activate services for customers to use our services, including: processing your application, communicating with you through voice calls, video calls, e-mails, texts or other means, to ensure the quality of service arising from the contract between you and us/partner. Remember the information so that the Customer does not have to re-enter it during the visit or the next time the Customer uses the service.  Support customers in the process of using the service: we may interact with the Customer to answer questions, support requests from the Customer, follow and update services for the Customer, notify the Customer of changes or other products that may be of interest and/or need to the Customer;  Improve the service we provide to customers: We collect information to ensure that the services we/partners provide to customers are stable, improve the quality of our services as well as the confidentiality and security of the information collected.  Promotion and communication: We collect information to promote to Customers about products, services, promotions, surveys, news, updates, events, advertisements and related content about our/partner’s services. We may use the information we collect to communicate and advertise our brands, services, products or other information of us/partners for business purposes within the framework of applicable law.  Legal procedures: We use the information we collect to enter into Contracts with Customers, support the verification process, resolve complaints, disputes (if any) that arise during the use of the Customer’s services or other activities permitted by applicable law.

• 3. Disclosure of Customer’s information:

Any Customer information that we hold as covered by this Privacy Policy may be disclosed to:

 Any of our associates/business partners/suppliers;  Other lenders/credit service providers to evaluate your loan application;  Any relevant agent/contracted party/service provider/third party who is a legal entity providing administration, telecommunications, billing, management, auditing or other services other for us;  Any relevant credit reporting agency/collection and/or credit collection agencies;  Our associates/supervisors/inspectors/staff/professional consultants including auditors, legal and/or other types of consultants;  Competent state agencies.

• 4. Information security:

 Information collected in accordance with this Privacy Policy will be kept confidential by us in accordance with the law. The use of information other than the purposes in this Privacy Policy is made only when:

•  ○ With the consent of the Customer.
•  ○ With the consent of the Customer.
•  ○ Providing it to a third party if we find this information will help prevent possible damage to the Customer.
•  ○ Other cases as prescribed by law.

 We take all reasonable steps and make every effort to ensure that all information is secure and safe, whether online or offline. We secure information with a variety of technical and administrative security measures to reduce the risk of loss, misuse, unauthorized access, disclosure or modification. We may use or adapt as appropriate new technology and security measures become available.  All third parties authorized to access, access and use the information set forth in this Privacy Policy are required to comply with our privacy obligations.  Notwithstanding the foregoing, you must also contribute to the security of your Personal Data, including, but not limited to, the use of secure passwords; do not share passwords and other information sent to you with any third parties,…  Our website or application may contain links to other websites not operated by us. If you click on those links, you will be redirected to a third party website. We would like to advise users to carefully review the privacy policy of each website Customers visit. We have no control over, and are not responsible for, the content, privacy policy or operation of any third-party websites or services.

• 5. Correction of incorrect information:

If at any time you believe that the personal information we hold is incomplete, inaccurate or not up to date, you are obliged to contact us. We will take corrective steps if both parties agree that the information is incomplete, inaccurate or not updated.

• 6. Restrict access:

Customers have the right to accept or refuse to let us access Customer information such as location information, contact information,… By this refusal, the Customer accepts that the features and services of the application may not be fully implemented.

• 7. Information storage time:

Customer agrees that We may store Customer’s collected information during and after using the Service and/or another time limit prescribed by law or requested by the Customer. We may store Information Collected for the purposes of regulatory compliance, fraud prevention, dispute resolution and other matters.

In accordance with our data privacy policy, We will safely destroy the Collected Information and in accordance with the law, after the Information collected is no longer needed and no longer relevant to Our Services, unless otherwise required by law or Customer.

• 8. Receiving notifications

We will send notifications in the form of SMS messages, online messages via social networks, automated voice messages, call centers for customer care, appraisal department, debt collection department or other forms to customers about advertising information about products, the company’s policies from time to time related to the use of services.

• 9. Disclaimer Notice:

All information provided on this website is “existing” information and is for reference only and makes no warranties, express or implied, as to the completeness or accuracy of this information. In addition, the content and images provided on this website will be changed, updated and improved regularly without prior notice.

ZEPHYR SOLUTIONS (PRIVATE) LIMITED is not responsible for errors, typographical errors caused by data entry, and other objective incidents such as: virus infection, hacker, vandalism, malicious behavior occurring on this website.

ZEPHYR SOLUTIONS (PRIVATE) LIMITED will not be liable for any cost, loss or damage, whether directly or indirectly, related to either as a result of the use or inability to use this Website by any party, or in connection with inactivity, errors, omissions, interruptions, defects or delays in operation or transmission, due to computer viruses or transmission lines or system interruptions.

• 10. Copyrights and trademarks:

All information and images on this website are owned by ZEPHYR SOLUTIONS (PRIVATE) LIMITED., except for information and images about partners and associates. Any form of copying, use or distribution of this information is not allowed, unless approved in advance in writing by ZEPHYR SOLUTIONS (PRIVATE) LIMITED.

• 11. Changes to the Privacy Policy:

We reserve the right to amend, supplement and update the Privacy Policy at any time and ensure that the amendments and supplements are consistent with the relevant provisions of the law.

To the extent permitted by applicable law, Customer’s continued use of our services constitutes Customer’s agreement to the updated contents of this Privacy Policy