Synthronex Technologies Private Limited, and our various related group entities (collectively reffered to as “We/Our/Us/Pocket) provides various financial services to our customers (“Customer/You/Your/User”) through use of our website (https://getpocket.money), our application on the App Store any other websites or platforms that we may own and operate, or may operate in the future (the websites and other applications operated by Pocket shall hereinafter be collectively referred to as “Platform”).

This document (hereinafter referred to as “Privacy Policy”) describes how Pocket collects and handles certain information it may collect and/or receive from you via the use of this Platform. The statements & procedures mentioned under this Privacy Policy must be read in conjunction with our general term & conditions (“User Agreement”).

This Privacy Policy is published and shall be construed in accordance with the provisions of Information Technology Act, 2000 and rules made thereunder including the Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011 as amended thereof and other applicable law enacted from time to time.

You accept this Privacy Policy when you visit/use our Platform, sign up for, access, or use our products, services, content, features, technologies or functions offered on our Platform and all related sites, applications, and services (collectively referred to as “Pocket Services”).

This Privacy Policy applies to Personal Information (which includes any information/ documents/ details that relates to a natural or a legal person, which either directly or indirectly in combination with other information available with Pocket, can identify such person) and such other information as mentioned in 'Information Collected' section of this Privacy Policy.

This Privacy Policy is intended to govern the use of Pocket Services by our Customers (including, without limitation those who use the Pocket Services in the course of their trade or business) unless otherwise agreed through contract.

We may amend this Privacy Policy at any time by posting a revised version on our Platform. The revised version will be effective as of the published effective date. In addition, if the revised version includes a substantial change, we will provide you with prior notice. Upon completion of the aforesaid notice period, you a Customer will be deemed to have expressly consented to all amendments to this Privacy Policy.

We collect the following personal information in order to provide you with Pocket Services:

1. Device Information: We collect information sent to us by your computer, mobile phone or other access device. The information sent to us includes, the following: data about the pages you access, computer IP address, device ID or unique identifier, device type, geo-location information, computer and connection information, mobile network information, statistics on page views, traffic to and from sites which are part of the Platform, referral URL, and standard web log data and other information.


2. Cookies: We also collect anonymous information through our use of cookies and web beacons. We may collect and store any information you provide us when you use Pocket Services, including when you add information on a web form, add or update your account information, participate in community discussions, chats, or dispute resolutions, or when you otherwise correspond with us regarding Pocket Services.


3. Other general information including personal information: When you use Pocket Services, we also collect information about your transactions and your activities. In addition, we may collect the following types of information:
   
   
   1. Contact information, such as your name, address, phone, email and other similar information.
   
   
   2. Financial information, such as the full bank account number that you link to your Pocket account or give us when you use Pocket Services.
   
   
   3. Detailed personal information such as your date of birth.
   
   

We may also collect information from or about you from other sources, such as through your communication with us, including our customer support team, your results when you respond to a survey, your interactions with members of the Pocket team, and from other accounts we have reason to believe you control (whether in part or in whole).

Additionally, for quality and training purposes or for its own protection, Pocket may monitor or record its telephone conversations with you or anyone acting on your behalf. By communicating with Pocket, you acknowledge that your communication may be overheard, monitored, or recorded without further notice or warning.

In order to help protect you from fraud and misuse of your personal information, we may collect information about you and your interactions with Pocket Services. We may also evaluate your computer, mobile phone or other access device to identify any malicious software or activity.

When you download or use our mobile applications, or access one of our mobile optimized sites, we may receive information about your location and your mobile device, including a unique identifier for your device. We may use this information to provide you with location-based services, search results, and other personalized content.

You expressly consent to Pocket (including its marketing channels and business partners) to provide the details/documents/information mentioned hereinabove under 'Information Collected' for the purpose stated under this Privacy Policy.

You while providing your details/documents over the Platform, including but not limited to the personal information or other information as mentioned hereinabove expressly consent to Pocket (including its marketing channels and business partners) to contact you through SMS, call and/ or e-mail and to follow up calls in relation to the Pocket Services provided through the Platform, for imparting product knowledge, offering promotional offers running on Platform & various other offers offered by its business partner.

You authorize and expressly consent us to share your personal information (only to the extent required) with third parties for the purpose of providing you Pocket Services, such as your mobile number for OTP delivery, and to fetch bank accounts and other financial information as may be required to provide Pocket Services.

You hereby grant your unambiguous, free and express consent to authorize and appoint Pocket to request and obtain, collect, receive and/or fetch your credit score and/ or a copy of your credit information report from CIC, for and on your behalf, to the extent required to provide Pocket Services.

Our primary purpose in collecting personal information is to provide you with a secure, smooth, efficient, and customized experience. We may use your personal information to:

1. Provide Pocket Services and customer support; process transactions and send notices about your transactions; verify your identity, including during account creation and password reset processes;


2. Resolve disputes, collect fees, and troubleshoot problems; manage risk, or to detect, prevent, and/or remediate fraud or other potentially prohibited or illegal activities; detect, prevent or remediate violations of policies or applicable user agreements; improve Pocket Services by customizing your user experience; measure the performance of the Pocket Services and improve their content and layout;


3. Manage and protect our information technology infrastructure; provide targeted marketing and advertising, provide service update notices, and deliver promotional offers based on your communication preferences; contact you at any telephone number, by placing a voice call or through text (SMS) or email messaging, as authorized by our User Agreement; perform creditworthiness and solvency checks, and compare information for accuracy and verify it with third parties.

We will also use the User information to enable activities and transactions that need to occur during the process of lending, such as (a) generating and maintaining User profiles on the Platform; (b) provide personalized features; (c) aid financial services organizations to provide better services; (d) facilitate collection activities as needed; (e) maintain regular communications with the User concerning transactions the User initiates, such as requesting information or assistance, submitting a loan request, making payments, transferring funds, etc.; (e) modify the Platform from time to time to cater to the User's interests; (f) provide the Platform and the functions and features therein, efficiently; and (g) preserve social history as governed by existing law or policy.

We have used the term “personal information” to describe information that can be associated with a specific person and can be used to identify that person. Personal information does not include any information that has been anonymized and cannot be used to identify a specific user.

We store and process your personal information on our computers where our facilities are located. We protect your information using physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure and alteration. Some of the safeguards we use are firewalls and data encryption, physical access controls to our data centers, and information access authorization controls. We have fully ensured that the reasonable security practices adapted by Pocket are fully in compliant with the applicable laws and at par with the industry standards.

Pocket will not sell or rent your personal information to anyone, for any reason, at any time. However, we may share your Personal information with our affiliates and business partners wherein such data sharing may assist the User in utilizing Pocket Services. Additionally, Pocket may share your personal information with:

1. Members of the Pocket group companies, to provide joint content, products, and services (such as registration, transactions and customer support), to help detect and prevent potentially illegal acts and violations of our policies, and to guide decisions about their products, services, and communications. Members of our group companies will use this information to send you marketing communications only if you requested and consent to such services.


2. Partner Financial Institutions, we may share your personal information with our partner financial institutions, and they may only use this information to market Pocket-related products.


3. Credit bureaus and collection agencies to report account information, as may be permitted under law.


4. Banking partners as required by credit card association rules for inclusion on their list of terminated merchants (in the event that you meet their criteria which includes having Pocket close your Pocket account due to your breach of our User Agreement).


5. Any entities that we may propose to merge with or who may acquire us. In such a situation, the new entity which houses Pocket Services shall follow this Privacy Policy with respect to your personal information. If your personal information could be used contrary to this policy, you will receive prior notice.


6. Law enforcement, government officials, or other third parties pursuant to a subpoena/ summon, court order, or other legal process or requirement applicable to Pocket or its affiliates; or to comply with law or debit/ credit card rules; or wherein Pocket believes, that the disclosure of personal information is necessary to prevent physical harm or financial loss; or to report suspected illegal activity or to investigate violations of our User Agreement.


7. Other unaffiliated third parties, for the following purposes:




• Fraud Prevention and Risk Management: to help prevent fraud or assess and manage risk.


• As part of our fraud prevention and risk management efforts, we also may share necessary account information in cases where Pocket has placed a hold or other restriction on your account based on disputes, claims, chargebacks or other scenarios regarding the sale or purchase of goods. Also, as part of our fraud prevention and risk management efforts, we may share account information to enable them to operate their programs for evaluating buyers or sellers.


• Customer Service: for customer service purposes, including to help service your accounts or resolve disputes (e.g., billing or transactional).


• Shipping: in connection with shipping and related services for purchases made using Pocket.


• Legal Compliance: to help them comply with anti-money laundering and counter-terrorist financing verification requirements.


• Service Providers: to enable service providers under contract with us to support our business operations, such as fraud prevention, bill collection, KYC document collection, marketing, customer service and technology services.


• Other third parties with your consent or direction to do so.

We use data collection devices such as "cookies"/similar, etc on certain pages of the app to help analyse our app page flow, measure promotional effectiveness, and promote trust and safety. "Cookies" are small files placed on your device hard-drive/storage that assist us in providing our services. We offer certain features that are only available through the use of a "cookie".

We will retain your information for as long as it is necessary for providing you the Pocket Services available on the Platform and delete all personal identifiable information upon your request for deletion of your account with Pocket.

Pocket may be contractually or legally obligated to retain certain information and accordingly such information shall be retained as prescribed under the applicable law or part of Pocket's contractual obligation. We may keep your contact information along with your application details (if any) for fraud prevention purposes and for the exercise/ defense of a legal claim or for providing evidence in legal proceeding(s).

Post termination of your relationship, Pocket may use your anonymized data aggregated or in combination with anonymized data of other users. We may use this aggregated anonymized data for data analysis, profiling and research purposes, for example to gain insights about our users and their profiles.

Our Platform may contain links to other platform that may collect personally identifiable information about you. Pocket is not responsible for the privacy practices or the content of those linked platforms. Pocket is not responsible for the content or information practices of such third parties.

Pocket is committed to adequately protecting your personal information regardless of where the data resides and to providing appropriate protection for your personal information.

If you choose to use our referral service to tell a friend about the Platform or Pocket Services, we may ask you for your friend's name, phone number and email address. We will automatically send your friend a message inviting him or her to visit the Platform. We store this information for the sole purpose of sending this message and tracking the success of our referral program.

If you have grievance or complaint, questions, comments, concerns or feedback in relation to the processing of information or regarding this Privacy and Security Policy or any other privacy or security concern, send an e-mail to bishalsaha@getpocket.money

The name and contact details of the Grievance Officer is provided below: -

Name: Bishal Saha
Email: bishalsaha@getpocket.money
Mobile: 08415998761