Privacy Policy

INTRODUCTION This privacy policy (the “Policy”) sets out Nikunj Health Technologies Private Limited’s approach to data privacy in furtherance of its obligations under the applicable data privacy laws. Reference to “We”, Us”, “our”, “ours” and “AyushPay” refers to Nikunj Health Technologies Private Ltd (including its affiliates). Further, the terms “You”, “Your”, “Yours” refer to You as a user of the services as elaborated in the Terms and Conditions available on the Portal (“Services”). This Policy is aimed at providing individuals notice of the basic practices and principles by which We process the personal data of individuals (“Personal Data”) who visit, use, interact with and/or transact through the android app, (“Portal”) including guest users and browser. By visiting/ accessing the Portal, and voluntarily providing us with data, both personal and / or sensitive personal, You are consenting to our use of it in accordance with this Policy. Any capitalised used but not defined in this Policy shall have the meaning assigned to them under our Terms and Conditions.

TYPES OF DATA COLLECTED We may collect the following types of Personal Data: Any personal or personally identifiable information that You may submit or may be required to submit for registration and continued use of the services offered by Us including Your name, title, gender, date of birth, email address, telephone number (home/work/mobile telephonic number), profile/display picture, login name, screen name, nickname, or handle, country/state/postcode or city of residence, postal or other physical address, name(s) of the workplace, job position/designation (including salary), IP addresses and other information collected passively may be collected; Your picture/selfie; Any other personal information You may choose to further provide us, without limitation, any information to update Your Account (as defined in the Terms and Conditions) and profile, if required, to fill out any forms, provide Your feedback to surveys, or to use any features offered by us.

We may collect the following types of sensitive personal information (“Sensitive Personal Data”): any such personal information about a natural person, which consists of information relating to: password, financial information such as bank account or credit card or debit card or other payment instrument details, physical, physiological and mental health condition, sexual orientation, medical records and history, biometric information, any detail relating to the above clauses as provided to Us for providing services and any of the information received under any of the above clauses by Us for processing, storing or processing under lawful contract or otherwise;

Credit reports, credit data bureau data collected from financial organizations (including, inter-alia, TransUnion, CIBIL Limited and other credit bureaus) on Your behalf or on behalf of our Financing Partner (as defined in the MITP) in the event You have applied for a loan / facility to the said Financing Partner; Any information that is freely available or accessible in public domain or furnished under the Right to Information Act, 2005 or any other law for the time being in force shall not be regarded as Sensitive Personal Data for the purposes of this Policy; PAN, Aadhar number and other KYC documents on behalf of the Financing Partners, at Your sole discretion. The Personal Data and the Sensitive Personal Data shall collectively be referred to as the “Collected Data”.

TYPES OF DATA STORED AyushPay stores only Personal Data that may be required to carry out our operations and provide You with our Services and does not store any Sensitive Personal Data.

EXPRESS CONSENT With regard to the Collected Data, You: explicitly provide us with consent for collecting on a one time basis: Sensitive Personal Data, including but not limited to Your picture/selfie (through camera and microphone permissions), location (through GPS), Kindly also provide us your explicit consent for collecting on a periodic basis and basis our discretion until such time such time You communicate to us in writing for Us to discontinue such requests (a) Your sensitive personal data and documents including but not limited to your Aadhar, PAN, Bank Details, Credit Score / Report from credit information companies. fully understand that the purpose of collecting the Collected Data is to enable Us to make informed lending decisions effectively and enable faster processing of credit applications to help provide speedier access to credit through our Portal; also understand that AyushPay may apply for the credit score / report either ourselves directly or through any of their partner tie ups who are members of credit information companies, and fully authorize Us to share my details with such partner.

SOURCES OF OBTAINING PERSONAL DATA The Collected Data that is processed by Us can broadly be categorised as follows: (i) data shared by you; and (ii) data shared by third parties. The Collected Data provided by You in most cases is direct when you: (i) register to use our Portal and/or Services. PURPOSE OF OBTAINING PERSONAL DATA In addition to verifying Your identity, We collect and process Your Collected Data for a variety of reasons including the following: verify the Collected Data; monitor, improve and administer our Portal; deliver our Services; design and offer customized products and services offered by our third-party partners (whether Financing Partners or otherwise); provide You with the websites and services, together with any support You may request; send communications notifications, information regarding the products or services requested by You or process queries and applications that You have made on the Portal; to respond to Your inquiries or fulfil Your requests; use the Collected Data in other ways permitted by law to enable You to take financial services from our Financing Partners; diagnose technical problems; relay announcements, newsletters; enhance and improve our Services; prevent, detect and mitigate any fraudulent activities; contact/reach out to You via email, phone, WhatsApp messages, SMS or any other similar channels to offer You our Services and offers, as applicable; and comply with our legal obligations, resolving disputes with users, enforcing our agreements. LEGAL BASIS OF PROCESSING YOUR COLLECTED DATA Our basis for collecting Your Collected Data is based on the fact that You have consented to Us processing Your Collected Data for a specific reason. This includes, without limitation, any information that You have made public through Your social media account, information that the social media service shares with Us or information that is disclosed during the sign-up and sign-in processes of our Portal and/or using our Services. Further, the processing is necessary for the performance of the contract We have with You or to take steps to enter into a contract with You and is necessary for compliance with a legal obligation We have towards You and under applicable law.

SHARING OF YOUR COLLECTED DATA WITH THIRD PARTIES We reserve the right to share Your Collected Data with third parties, including our regulated Financing Partners for provision of Services on the Portal and/or for facilitation of a loan / facility to You as permitted under applicable law. We may also share the Collected Data with third parties under a confidentiality agreement for provision of services which inter alia restricts such third parties from further disclosing the information unless such disclosure is for the purpose as detailed under that confidentiality agreement. We will share Your information with third parties in such manner as described below: We may disclose Your Collected Data with the regulated entities such as, banks or NBFCs and our third-party partners for providing the Services as detailed under the Terms and Conditions We may share Your Collected Data with our third-party partners in order to conduct data analysis in order to serve You better and provide Services on our Portal; We may disclose Your Collected Data, without prior notice, if We are under applicable law obligated to do so in order to comply with any legal obligation or an order from the government and/or a statutory authority, or 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 also share the Collected Data with our technology service providers to perform credit and KYC checks to facilitate a loan for You through a regulated Financing Partner; and We and our affiliates may share Your Collected Data 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. COOKIES When You visit our websites, We may collect information from You automatically through cookies or similar technology. Cookies are essentially small text files that are placed on Your computer by websites that You visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information about Your actions to the owners of the website. We essentially use cookies for a variety of reasons such as: (i) improve the way our website works; (ii) to create greater content for You and remember Your likes and dislikes and other preferences; and (iii) to formulate information relevant to the user’s area of interests. Most browsers allow You to refuse to accept cookies and to delete cookies. Disabling some cookies from the website may have a negative impact and may result in some features be unavailable. If You want to remove previously stored Cookies, You can manually delete the Cookies at any time. However, this will not prevent the Sites from placing further Cookies on Your device unless You adjust Your Internet browser settings. DO NOT TRACK Some web browsers have a “Do Not Track” feature. This feature lets You tell websites You visit that You do not want to have Your online activity tracked. These features are not yet uniform across browsers. Our sites are not currently set up to respond to those signals. RETENTION OF YOUR PERSONAL DATA We keep the Personal Data (and not the Sensitive Personal Data) We collect about You for as long as it is required for the purposes set out in this Policy and for legal or regulatory reasons, or as otherwise communicated to you. We may take reasonable steps to delete or permanently de￾identify Your Personal Data that is no longer needed. Please note that We may, from time to time, engage an overseas recipient to provide services to us, such as cloud￾based storage solutions. While the use of overseas service providers to store Personal Data will not always involve a disclosure of Personal Data to that overseas provider, We will store such information only in servers that are localized in India Please note that We do not retain Your Sensitive Personal Data at any point of time. EXTERNAL LINKS Our Portal may contain links to websites of other organizations. This Policy does not cover how those organizations process Your Collected Data. Further, We do not endorse and are not responsible for the privacy practices of these third-party sites. Therefore, We encourage You to read the privacy policies available on the other websites You visit. During, and as part of the services being offered by AyushPay, the users might be required to access, visit, browse and make use of third-party websites and content, the use of which is governed by terms and conditions of such third parties. The information the third-party site or platform collects is subject to the third-party site or platform’s privacy practices. Privacy choices You have made on the third-party site or platform will not apply to our use of the information that We have collected directly through our applications. We encourage You to be aware when You leave our sites or applications and to read the privacy policies of other sites that may collect Your data. SAFEGUARDING AND SECURING THE COLLECTED DATA AyushPay uses administrative, technical, and physical safeguards to protect Your Collected Data, taking into account the nature of the Collected Data and the threats posed. AyushPay has implemented a variety of safety and security features to consistently protect Your Collected Data. AyushPay has done all in its power to prevent data theft, unauthorized access, and disclosure by implementing the latest technologies and software, which help Us safeguard all the information We collect. The Collected Data We collect is securely stored within our databases, and We use standard, industry-wide, commercially reasonable security practices such as encryption, firewalls, SSL (“Secure Socket Layers”) for protecting Your information. Further, AyushPay is dedicated towards Your safety and hence We have an ever-evolving structure including but not limited to hardware and software.

NO SALE OF YOUR PERSONAL DATA We do not intend to use your personal data in any ways except those specified in this Privacy Agreement; the Terms and Conditions and the Most Important Terms and Conditions

YOUR RIGHTS Depending on the jurisdiction in which You are resident, You may enjoy certain rights regarding Collected Data that We process about you. Such rights may include: Access: You have a right to know what Collected Data We hold about You.

Correction: If You believe that any Collected Data We are holding about You is incorrect or incomplete, You can request that We correct or supplement such Collected Data. You can also correct some of this information directly through Your Account settings after logging onto our Portal.

Objection: You can contact Us to let Us know that You object to the collection or use of Your Collected Data for certain purposes.

Restrictions: You can always request Us to deactivate Your Account to restrict further processing of Your Collected Data.

Erasure: You can request that we delete some or all of your Personal Data from our systems. While this will be done immediately, residual data may be saved in certain logs and this will be purged within a year after deleting your data. Once your data is deleted, you will no longer have an account with us.

ELECTRONIC COMMUNICATIONS You agree that AyushPay (either directly or through its affiliates, subsidiaries or other permitted assigns) may provide You communications about Your Account and the Service electronically or through phone calls, Whatsapp messages, or in writing. Standard mobile, message, or data rates may apply, and You are responsible for any such fees. AyushPay reserves the right to close Your Account and immediately collect all due amounts if You withdraw Your consent to receive electronic or other communications or if You revoke access to any third party site on which the Service relies (e.g., Facebook, Twitter, etc.) or if any such Service should revoke or cancel Your account on that site. Any electronic communications will be considered to be received by You within 24 (twenty four) hours of the time We email it to You or otherwise send it to Your attention (such as via SMS or other online notification, through Whatsapp messenger application). We may assume You have received any communications sent to You by postal mail 3 (three) business days after We send it. If We need to contact You to service Your Account, You give direct consent to Us and Our permitted assigns to communicate with You in any way, such as calling, texting, or e-mail via any method of communicated provided by You to us, or at any means which We believe We can reach You (even if it is not yours) including (a) any email address You provide to Us or one of Our merchants or Financing Partners; (b) automated dialer systems and automatic telephone dialing systems; (c) pre-recorded or artificial voice messages and other forms of communications. You also agree that these communications are not unsolicited for purposes of any applicable law, and You understand that this may result in additional mobile, text message, or data charges.

HOW DO I WITHDRAW MY CONSENT? If You change Your mind after opting-in, You may withdraw Your consent to contact You, for the continued collection, use or disclosure of Your information, at any time, or request for deletion of Your Account maintained at AyushPay portal by raising a request through Portal or by mailing Us at care@ayushPay.com.

However, if You have availed any loan facilities from Our Financing Partner, the Financing Partner shall have the right to continue processing Your information till such credit facility has been repaid in full, along with any interest and dues payable and/or for such period as may be allowed under applicable law. However, AyushPay will not retain Your data and information if it is no longer required by Us and there is no legal requirement to retain the same. Do note that multiple legal bases may exist in parallel, and We may still have to retain certain data and information at any time.

BREACH NOTIFICATION Where a Personal Data breach is likely to result in a risk to the rights and freedoms of individuals, it will be reported to the relevant supervisory authority in a timely manner in compliance with applicable laws. Individuals will be informed directly where required by law.

PHISHING "Phishing" usually occurs when users of a website are induced by an individual/entity into divulging sensitive Personal Data by using fraudulent websites and/ or e-mail addresses. In the event You provide information to a website or respond to an e-mail which does not belong to Us or is not connected with Us in any manner, You will be a victim to Phishing. We do not send e-mails requesting a user for payment information, username or passwords. However, AyushPay may verify the user name, password etc. provided by You from time to time.

SEVERABILITY AND EXCLUSION We have taken every effort to ensure that this Policy adheres with the applicable laws. The invalidity or unenforceability of any part of this Policy shall not prejudice or affect the validity or enforceability of the remainder of this Policy. This Policy does not apply to any information other than the information collected by AyushPay through the Portal. This Policy shall be inapplicable to any unsolicited information You provide Us through the Portal or through any other means. This includes, but is not limited to, information posted in any public areas of the website / app. All unsolicited information shall be deemed to be non-confidential and AyushPay shall be free to use and/ or disclose such unsolicited information without any limitations.

NO WAIVER The rights and remedies of available under this Policy may be exercised as often as necessary and are cumulative and not exclusive of rights or remedies provided by law. It may be waived only in writing. Delay in exercising or non-exercise of any such right or remedy does not constitute a waiver of that right or remedy, or any other right or remedy.

NOTIFICATION OF CHANGE We regularly review and update our Policy to ensure it is up-to-date and accurate. Any changes We may make to this Policy will be in effect immediately after being posted on this page. We reserve the right to update or change our Policy at any time and You should check this Policy, periodically. Your continued use of the service after We post any modifications to the Policy on this page will constitute Your acknowledgment of the modifications and Your consent to abide and be bound by the modified Policy.

CONTACT If You have any questions about our policy or related dealings with Us or would like further information about our services and practices, You can contact Us at care@ayushPay.com. This Policy must be read in conjunction with the other agreements You may enter into with Us and the terms of services as published by Us on our Portal. Any grievance, with respect to the Collected Data, Your privacy or this Policy shall be addressed to care@ayushPay.com.

GRIEVANCE OFFICER In the event You have any queries regarding the policy, including but not limited to reporting any violation of this Policy, kindly contact Us at: Name: Veena Karevhan Email: care@ayushPay.com

You may address any grievances You may have in respect of this Policy or usage of Your Collected Data or other data to him/her. COPYRIGHT, TRADEMARK, AND OTHER INTELLECTUAL PROPERTY PROTECTION ‘AyushPay’ is a registered trademark of QB Health Technolgy Private Limited, all materials on this Portal are protected by copyright, trademark, and other intellectual property rights. Any unauthorized use of any such information or materials may violate copyright laws, trademarks laws, intellectual property laws, and other laws and regulations.

TERMINATION Subject to Our Terms and Conditions, We may suspend or terminate Your Account or Your use of this Portal at any time, for any reason or for no reason, provided that there are no outstanding credit provided by any of Our Financing Partners. You are personally liable for any charges incurred through Your Account prior to termination. We reserve the right to change, suspend, or discontinue all or any aspects of this Portal at any time without notice. Please note that if You revoke any mandatory permissions or revoke the consent to process and store information such as Your Account data, financial and KYC Information and/or any other information needed to facilitate Your access to the loan facilities offered by Our Financing Partners, then We may have to cease the provision of Services to You. You cannot withdraw Your consent once You have availed a credit facility using the Portal till You have repaid the entire outstanding amount and all related charges in its entirety to such Financing Partner.

INDEMNIFICATION AyushPay shall not be liable in case You breach any terms or conditions provided under this Policy and will not be obligated to indemnify You for any direct or indirect losses accruing to You. You agree to indemnify, defend and hold harmless AyushPay, its affiliates, group companies and their directors, officers, employees, agents, third party service providers, and any other third party providing any service to AyushPay in relation to the Services whether directly or indirectly, from and against any and all losses, liabilities, claims, damages, costs and expenses (including legal fees and disbursements in connection therewith and interest chargeable thereon) asserted against or incurred by AyushPay that arise out of, result from, or may be payable by virtue of, any breach or non-performance of any terms of this Policy including any representation, warranty, covenant or agreement made or obligation to be performed by You pursuant to the Policy.

CONSENT TO THIS POLICY By accessing Our Portal, You agree to this Policy or any updated version of this Policy. This document supersedes any prior communication on this topic and reflects the entire and exclusive Policy for the Portal.

AyushPay is changing the way Indians pay for their healthcare and bridging the gap of their actual healthcare expense and what their insurance pays for. Simplifying, Indian Healthcare.