Nikki Global Finance Limited

POLICY ON PRIVACY

This policy shall be called the Fox DigiTech Finance Limited Policy on Privacy of users engaged with the services or products whose ownership is under Fox Digitech Finance Limited.

PREAMBLE

i. This Policy has been framed keeping in mind the requirements of the Right to Privacy as has been enshrined in the basic structure doctrine of the Constitution of India and various Indian Laws including the Personal Data Protection Bill, 2019

ii. The matters covered in this code are of outmost importance to the Company, shareholders, and other stakeholders of the Company and thus expedient for the company to incorporate the values that the company strives by this code of conduct for board of directors and senior management.

iii. As a Corporate governed company, we are strongly committed to protect the personal and financial information that you submitted to us and would endeavor to protect it from unauthorized use in every possible manner whatsoever.

iv. The Company will also communicate its policy to its clients by uploading it on its website.

APPLICABILITY AND PRIVACY COMMITMENT

The company is strongly committed to shield the personal, economic, social, demographic, and financial information that our clients submit to us and would endeavor to protect it from unauthorized use in every possible manner. Keeping ourselves in line with the commitment we assure that the company is committed to provide for protection of the privacy of individuals relating to their personal data, specify the flow and usage of personal data, create a relationship of trust between persons and entities processing the personal data, protect the rights of individuals whose personal data are processed, to create a framework for organizational and technical measures in processing of data, laying down norms for social media intermediary, cross-border transfer, accountability of entities processing personal data, remedies for unauthorized and harmful processing and purposes incidental thereto.

DEFINITIONS

“company” shall mean Fox DigiTech Finance Limited,or the products and services owned by Fox Digitech Finance Limited that includes but not limited to (Mobile App “KREDITLO”, Website https://kreditlo.com. Website https://foxdigitech.com )

"data" includes a representation of information, facts, concepts, opinions, or instructions in a manner suitable for communication, interpretation, or processing by humans or by automated means.

"Financial data" means any number or other personal data used to identify an account opened by, or card or payment instrument issued by a financial institution to a data principal or any personal data regarding the relationship between a financial institution and a data principal including financial status and credit history.

"Personal data" means data about or relating to a natural person who is directly or indirectly identifiable, having regard to any characteristic, trait, attribute, or any other feature of the identity of such natural person, whether online or offline, or any combination of such features with any other information, and shall include any inference drawn from such data for the purpose of profiling.

COLLECTION OF INFORMATION POLICY

i. The company in course of providing the products and services vide the online application forms and questionnaires or otherwise including services through its affiliates/ Subsidiaries may become privy to the personal information of its clients, including information that is of a confidential & sensitive nature and thus endeavor to protect the same.

ii. The company endeavors and is committed in protecting the privacy of its clients and has taken all necessary and reasonable measures to protect the confidentiality of the client information and its transmission through the internet or any other medium and it shall not be held liable for disclosure of the confidential information when in accordance with this Privacy Commitment or in terms of the agreements, if any, with the clients.

iii. The company endeavors that any information collected is stored in secure databases protected or cookies via a variety of access controls and be treated as confidential information by us, however, the clients are advised to be careful with usage of the username and password by maintaining confidentiality and ensure that you do not knowingly or accidentally share, provide, and facilitate unauthorized use of it as changing technology is beyond the control of the company.

USE AND DISCLOSURE OF PERSONAL & FINANCIAL INFORMATION

i. The company is committed to protect its clients’ personal information against unauthorized use, dissemination, or publication in the same way we would protect our confidential information of like nature. However, under certain conditions we may share this information which may include:

ii. Information required to improve our services

iii. Information required to keep clients updated about our new products

iv. Sharing of information in normal course of business including activities related to collection of fees and services.

v. The company endeavors to take all reasonable steps to ensure that the confidentiality of your information is maintained by imposing strict confidentiality standards on all the third parties to whom it discloses such information.

vi. The company does not guarantee personal data protection in cases where required to disclose clients’ personal and financial information to the statutory authorities in connection with any legal process that may be initiated by such authorities in accordance with applicable laws of the law as amended from time to time.

vii. The Company saves itself from liability in situation where the client’s information is to be provided to superior services and a range of offers.

viii. The Company may use such information collected to advise client of products, services, and other marketing materials, which we think, may be of interest to our client and may also invite visitors to this site to participate in market research and surveys and other similar activities.

ix. If the client so desires the Companyto limit such sharing whereby client would not like to be informed of offers available client has an optionto contactthe company at info@foxdigitech.com(email) or otherwise the company shall be using the client information to improve the client experience on the site and make subsequent offers to the visitor on products which may be of interest to them.

AUTHORISATION

The Clientauthorizesthe Companyto exchange, share, part with all information related to the details and transaction history of the Clients to its Affiliates / Subsidiaries / banks / financial institutions / credit bureaus / agencies/participation in any telecommunication or electronic clearing network as may be required by law, customary practice, credit reporting, statistical analysis and credit scoring, verification or risk management and shall not hold the Companyliable for use or disclosure of this information.

EXCLUSIONS

Other websites that client may access via website may have different privacy policies and access to such web sites will not be subject to this privacy policy. We recommend that our clients read the privacy statement of each such website to find out how they protect your personal information.

NON-BINDING

Please note that this privacy policy does not create any contractual or other legal rights in or on behalf of any party, nor is it intended to do so.

PROHIBITED ACTIONS

While using our services, clients hereby agree not to, by any means (including hacking, cracking, or defacing any portion of the Site) indulge in illegal or unauthorized activities including the following:

DISCLOSURES

The Policy shall be disclosed in the Company’s website.

DISCLAMAIR

i. That it shall be obligatory on the part of every Director and Senior Management team Member to make an annual disclosure under this Code affirming their adherence to the Code on annual basis in the format appended.

ii. That the company reserves to change this policy due to change in legislation or enhancements to functionality and content on the website, we may make changes to privacy policy (without being obliged to do so) and would reflect those changes in this privacy policy statement. Hence you are requested to go through the privacy policy statement on a regular basis.

iii. That this policy is in addition to and not in derogation with any Act, Law, rules, and regulations that governs the conduct of Board Directors.