SALEMYOURS-PAY FINEZY MICRO FINANCE PRIVATE LIMITED

Privacy and Policy for Yourspay Co-Operative Society

How we use your personal information

Please read this privacy notice to understand how we use and protect the information you provide to us.Your information will be held by The Cooperative Society

Data protection law and how it protects you

Data protection law requires us to manage all personal information by the data protection principles. In particular,we are required to process your personal information fairly and lawfully. This means you are entitled to know how we intend to use any information you provide. You can then choose whether you want to give it to us so we can provide the product or service you require. All our employees are responsible for maintaining customer confidentiality. We provide training and education to all employees to remind them about their obligations. In addition, our policies and procedures are regularly audited and reviewed.

1. Where we obtain the information

The bank will securely hold your personal information so we can manage your relationship with us (either now or in the future). This will include information you provide whenyou apply to us, and any additional information provided by you or others in various ways, including:

Definitions

1.1. In applications, emails, and letters, during telephone calls and conversations in branches and online, when registering for services, in customer surveys, when you participate in competitions and promotions, through our website including our mobile app, and during financial reviews and interviews.

1.2. From analysis (for example, the amount, frequency, location, origin, and recipient) of your payments and other transactions,from your use of our services and what weknow from operating your account.

1.3. Information we receive from our business partners and from other organizations such as credit reference agencies and fraud prevention agencies.

1.4. Through your use of different technologies when accessing information about your accounts with us (such as IP addresses, web browsers, biometric data, and computer operating systems)

We will not retain your personal information forlonger than is necessary to maintain your account or legal or regulatory requirements. The Bank retains personal data relating to accounts for a maximum of seven years to meet our legal requirements, though certain productrelated documentation retention periods vary. If you have any questions relating to the retention periods applied to your data please get in touch with the Data Protection Officer at the following email address support@yourspay.in .The Bank may occasionally collect and hold highly sensitive personal information, under data protection law this is known as special categories of data.

If you give us personal information about someone else (such as a joint applicant) then you should not do so without their permissionand you must ensure they are made aware ofthe content of this notice.

Where information is provided by you about someone else, or someone else discloses information about you, it will be added to any personal information which is already held by us and it will be used in the ways described in this privacy notice.

2. The personal information we collect and process

The Bank will only gather and process the relevant type and amount of personal information required, allowing us to help you open and then manage your accounts with us. The categories of personal information that we collect (or create on your behalf) are:

 Category

 Some examples of the information in this category

 Name data

Title
Surname*

Forename*

Previous surname*

 Personal data

•Date of Birth*

National Insurance Number*

Gender

 Residence data

Residential address*
Tax residency*

Previous residential address

 Contact data

Home telephone number

Mobile telephone number

Correspondence addresses

 Employment data (only used at the account opening stage)

Employment status

Employer’s address

Salary details

 Account level data (created to allow an account to operate)

Account number

Card number

 Digital data

IP address

Internet banking username

Biometric Data

 Security data

  Internet passwords/codes

Mobile Banking passwords/ codes

*Certain data items we collect throughout the lifecycle of an account are mandatory to allow us to meet our regulatory requirements and will be shared with government bodies and for fraud prevention activities as described within this notice. While the list above is not exhaustive those marked with an asterisk are mandatory.

3. How we use your information

We will use the personal information we hold about you for the following administrative activities:

How we use your information

The basis on which we use your information

To develop our products and services

To manage our product delivery

To perform marketing and sales

To manage your applications

Assessing lending and insurance risks

Customer modeling and statistical trend analysis with the aimof developing and improving products and services

Fulfilling contracts

Our legitimate interests

Our legal obligation

Your consent

Managing your relationship with us

Updating, consolidating, and improving the accuracy of our records

Arrears and debt recovery activities

Undertaking transactional analysis

Process payments

Fulfilling contracts

Our legitimate interests

Our legal obligation

Crime detection,prevention and prosecutions

Fraud prevention and investigation

Anonymising and aggregating personal information for securityreasons

Our legitimate interests

Our legal obligation

Testing new systems and checking upgrades to existing systemsOur legitimate interests

Profiling for marketing purposes

Evaluating the effectiveness of marketing and market research andtraining

Administrating offers, competitions, and promotions

Your consent

Our legitimate interests

By processing this information it enables us tobetter understand your needs and operate youraccounts in the efficient way you expect.

Your information will also be used for other purposes for which you give your specific permission, or, in very limited circumstances,when required by law.

4. When we will share your information

We will treat your personal information asprivate and confidential but will disclose itoutside the Bank if:

4.1. Allowed by this agreement;

4.2. You consent;

4.3. Needed by our agents, advisers, or othersinvolved in running accounts and servicesfor you or collecting what you owe us;

4.4. Needed by sub-contractors to help usmanage your records;

4.5. HM Revenue & Customs or otherauthorities require it;

4.6. The law, regulatory bodies, or the publicinterest permits or requires it;

4.7. Required by us or others to investigate orprevent crime;

4.8. Needed by market research companies to assist us in providing better products and services to you;

4.9. Needed by any other parties connected with your account (including guarantors,power of attorney representatives);

4.10. Needed by organizations who provide us with a service, on the understanding they keep your information secure and confidential unless you tell us not to;

We will always ensure your information remains safe and secure. Please go to support@yourspay.in to see our supplier register.

5. Using your information to help prevent terrorism and crime

The government also requires us to screen applications that are made to us, to ensure we are complying with the international fight against terrorism and other criminal activities.As a result of this, we will need to disclose information to government bodies.

6. Sharing your information to assist with asset buying and selling

We may in the future wish to sell, transfer, or merge part or all of our business or assets, or any associated rights or interests, or to acquire a business or enter into a merger. If so, we will disclose your personal information to a potential buyer, transferee, merger partner, orseller and their advisers, so long as they agree to keep the information confidential and to use it only to consider the possible transaction. If the transaction goes ahead, the buyers, transferee, or merger partner will use or disclose your personal information in the same way asset out in this notice

7. How we use Fraud Prevention Agencies

We have systemsthat protect our customersand ourselves against fraud and other crimes.Customer information can be used to prevent crime and trace those responsible. We will share your personal information from your application with Fraud Prevention Agencies.

If false or inaccurate information is providedand fraud isidentified, details of this fraud will be passed to these agencies.

Law enforcement agencies may also access and use this information to prevent fraud andmoney laundering, for example, when:

7.1.Checking details on applications for credit and credit-related or other facilities;

7.2.Managing credit and credit-relatedaccounts or facilities;

7.3.Recovering debt;

7.4.Checking details on proposals and claims for all types of insurance.

We and other organisations will access and usethe information recorded by fraud prevention agencies from other countries.

Fraud prevention agencies can hold your personal data for different periods of time, and if you are considered to pose a fraud or money laundering risk, your data can be held for up to six years.

If we, or a fraud prevention agency, determinethat you pose a fraud or money laundering risk, we may refuse to provide the services and financing you have requested, or to employ you,or we may stop providing existing servicesto you.

A record of any fraud or money laundering risk will be retained by the fraud prevention agencies and may result in others refusing to provide services, financing, or employment to you.

8. How we manage the information collected on your bank account, mortgage account, and credit card statements Transactions that you or a joint account or cardholder make will create personal information that will appear on your statement.

By making such transactions you give us your consent to process this information.

9. Individual Rights

Right to be informed – you have the right tobe informed about what we do with the data we have about you.

Right to access – you have the right to access personal data and supplementary informationthat is held about you by the Bank.

Right to rectification – you are entitled to have your data rectified if it isinaccurate or incomplete.

Right to erasure – you have the right to request the removal or deletion of your data (also known as the “right to be forgotten”), where there is no compelling reason for the Bank to continue processingthis data. The Bank can refuse your request where there is a legal obligation to hold the information. This will be further explained toyou upon making a request.

Right to restrict processing – you have the right to restrict the processing of your data in the following circumstances

(i) where you contest the accuracy of the personal data. The Bank will restrict the processing until you have verified the accuracy of the personal data

(ii) where you have objected to the processing, and until the Bank has considered the legitimate grounds to override the processing.

(iii) when processing is unlawful

(iv) where the Bank no longer needsthe personal data but yourequire the data to establish, exercise or defend a legal claim.

Right to data portability – this right allows you to move copy or transfer your dataeasily from one IT environment to another safely and securely, without hindrance to usability.

Right to object – you have the right to object to processing for direct marketing (including profiling) purposes. The Bank can refuse this right where there is a legitimate interest in processing your data. This will be further explained to you upon making a request.

Rights related to automated decision making including profiling – you have the right to object to automated decision-making without any human involvement, and to the profiling of your personal data. The Bank only carries out this type of processing where it is necessary to enter into a contract with us or where you have provided us with your consent,for example when applying for a loan or mortgage.

10. Legitimate Interest Tests

As an essential part of our business, the Bank collects, holds, and manages (“processes”) datarelating to our customers. The data protection regulation recognizesin certain circumstances,processing may be deemed “necessary for the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection”.

To validate that a specific purpose for data processing is indeed legitimate; the Bank will conduct a legitimate intereststest. This willserve to balanceour rights to process the data against the data protection rights of the affected individuals.

In deciding whether or not legitimate interests may apply in each circumstance, we will ensure the balance of rights always favors the individual customer, and the processing will not cause the individual unwarranted harm using discrimination, damage to reputation,financial loss, loss of confidentiality, or othersignificant economic orsocial disadvantage.

11. How we may contact you

Using your personal information to contact you about products and services

If you have permitted us, we may contactyou for marketing purposes, by mail, telephone, email, or text message about products and services available from us. In addition, we may also contact you about products and services from other selected companies, which we believe will be of interest to you or benefit youfinancially. You have the right to withdraw, object to, or change your marketing preferences at any time, online via your account, by calling us at +91-9585535569, or by visiting your nearest branch.

We promise not to contact you about everything – only if we think it could be appropriate and relevant to you, such as preferential savings opportunities, account upgrades, or special offers. This contact may continue after your relationship with us ends.

Passing your information to other companies for their direct marketing

Unless you have given us your permission, we will not contact you on behalf of third parties,or pass your details on to them directly.

Using your contact information for service contact

Making sure we deliver excellent customer service is very important to us, and to do this various methods of communication will be used when sending you information about youraccount. Most of the time you will be contacted by letter or telephone, but you will also be sent updates by text message or email when it is deemed to be appropriate.

12. When you apply for and use our products and services

Using credit scoring

When you apply for credit, an automated system known as credit scoring will be used when considering whether to agree the borrowing.

It is a method of assessing your likely conductof an account based on a range of data, including the conduct of previous similar accounts.

It is a system widely used by credit providers to help make fair and informed decisions on lending.

Credit scoring takes account of information from three sources; the information you provide on your application, information provided by CRAs, and information that may already be held about you by us e.g. existing account information.

A credit scoring system will considerinformation from these sources, to make an overall assessment of your application. The credit scoring methods used are regularly tested to ensure they remain fair, effective, and unbiased. Using a credit scoring system helps us to lend responsibly. If you submit an application and it is declined through this automated process, you can contact us within 21 days to have the decision reconsidered. You also have the right toask that the decision is not made based solelyon using an automated creditscoring system.

How we check your identity

We will ask you to provide physical forms of identity verification when you open your account. Additionally, we will search CRA files to assess your application. The CRA also gives us other details and information from the Electoral Register to verify your identity.

The CRA keeps a record of our search, whether or not your application proceeds. Our search inthisinstance is notseen or used by the Bank toassess your ability to obtain credit.

Undertaking anti-money laundering andfraud checks

To comply with money laundering requirements,there are times when we will need to confirm (or reconfirm) the name and address of our customers.

As part of the processing of your data, decisions may be made by automated means.This means we may automatically decide thatyou pose a fraud or money laundering risk if:

•Our processing reveals your behaviorto be consistent with that of known fraudsters money launderers; or is inconsistent with your previoussubmissions; or

•You appear to have deliberately hiddenyour true identity.

Obtaining information about you and other personal details

When you apply for a mortgage or further borrowing it will be necessary to obtain references, details of your existing financialcommitments, and any other information required to assess or review lending risks, to recover debts, and to prevent or detect fraud. Where applicable, your current and previous employers, accountant, landlord, lender, bank, insurance, or pension company will be contacted to obtain this information. In limitedcircumstances, these references may need to be obtained after you open your account. This may be for regulatory purposes, or if thelending decision needs to be reviewed.

Your permission to obtain these references will therefore continue to apply after your accounthas been opened. It will also be necessary to obtain information or documentation from your solicitor relating to any work they carry out either on your or our behalf

Using information on social networking sites As part of our ongoing commitment to understanding our customers better and to improve our services, we will research public comments and opinions on social networking sites such as Twitter and Facebook.

13. Your right to rectify and erase data we hold about you

The information we hold about you must be accurate and up-to-date at all times, as holding incorrect information can have an impact on what the Bank shares with third parties such as the CRAs, taxation authorities,and fraud prevention authorities.

If you believe we are holding any information relating to you which is incorrect please contact us to let us know what is wrong, and we will work with you to put it right.

15. How we protect your information

We are committed to taking appropriate technical, physical, and organizational measures to protect customer and colleague personal information against unauthorized access, unlawful processing, accidental loss ordamage, and unauthorized destruction.

We use secure servers to enable you to makeinquiries or access your account information, which encrypts your information before it is sent to us. We also take appropriate measuresto ensure the information disclosed to us is kept secure, accurate, and up-to-date and keptonly for as long as necessary for the purposes for which it is used.

We limit access to our internal systems which hold personal information to a selected groupof authorized users who are given access to such systems through the use of a unique identifier and password. Access to personal information is limited to and provided to individuals to perform theirwork duties.

16. Changes to privacy notice

We will update this notice to reflect changesto our information practices. If we make anymaterial changes we will notify you by meansof a notice on our website prior to the changebecoming effective.

We encourage you to periodically review support@yourspay.in for the latest information on our privacy practices.

17. Complaints about how we process your personal information

We know sometimes things go wrong, and here at the Bank we value your feedback.Letting us know when you are not happy with our products and services provides us with the opportunity to put it right as quickly as possibleand helps usto improve ourservice for all our customers.

Our promise is to:

  • Treat your complaint fairly and promptly;
  • Try to resolve complaintsstraight away,when you first contact us; and
  • Keep you informed of our progress.

Customer Response

You can contact us via email at support@yourspay.in Alternatively, you can call us at +91-9585535569 call into your nearest branch or write to us at 21, Yercaud main road, Hasthampatti, Salem636008. Send to us, or emails you request from us, may not be protected in transit;

  • The Bank may choose not to reply withcertain types of information via email,therefore please include alternative contact details; and
  • Please be aware, we cannot accept file attachments that are larger than 5MB

Customer Response

You can contact us via email at support@yourspay.in Alternatively, you can call us at +91-9585535569 call into your nearest branch or write to us at 21, Yercaud main road, Hasthampatti, Salem636008. Send to us, or emails you request from us, may not be protected in transit;
  1. The Bank may choose not to reply withcertain types of information via email,therefore please include alternative contact details; and
  2. Please be aware, we cannot accept file attachments that are larger than 5MB