Business Model and Policies

Disclaimer

Fair Vinimay Services Private Limited (IndiaMoneyMart, “IMM”) is an NBFC-P2P lending platform registered withthe Reserve Bank. However, Reserve Bank does not accept any responsibility for the correctness of any of thestatements or representations made or opinions expressed by the Fair Vinimay Services Private Limited (IndiaMoneyMart, “IMM”)and does not provide any assurance for repayment of the loans lent on it.

The lending transaction is strictly between the lenders and borrowers, carried out at their sole discretion.Fair Vinimay Services Private Limited (IndiaMoneyMart, “IMM”) does not guarantee the completion of the loantransaction or the accrual of simple interest. The information available on the platform is verified on a best-effort basis,without any assurance of its absolute accuracy. Any decision to lend, based on this information, is entirely up to the lender.Fair Vinimay Services Private Limited (IndiaMoneyMart, “IMM”) makes no promise regarding full or partial recovery of the lendingamount from the borrower. The entire risk lies with the lender. IMM shall not be held liable for any loss, entire principal orinterest or both, if any, in respect of funds lent by lenders.

The purpose of Credit Assessment is to ascertain repayment capacity of the borrower before making the borrower live on "Fair Vinimay Services Private Limited" (IndiaMoneyMart ("IMM") platform). The Borrower is assessed on wide range of parameters using our own proprietary credit algorithm and based on the credit assessment and verification, an IMM score is given to the borrower while making them live on our platform.

The process of Borrower Assessment comprises of the following steps and methodology

1. Validation of KYC Details

• Address Proof validation
• Identity proof validation

2. Validation of Personal and Financial Data

• Income documents like Salary slip, Income Tax Return (if applicable)
• Credit History and payment track record of the borrower as per credit information bureau
• Bank Statements
• Additional information provided by the borrower

3. On Ground Verification

• Residence, Shop / Office Verification, Telephone Verification, Personal Discussion at place of work to understand the business (if applicable)

4. IMM Credit Assessment Score

IMM credit assessment score arrives based on various parameters considered from personal and financial data of the borrower as per

• Income and employment details
• Analysis of Income, Expenditure and Investment details
• Analysis of existing and past loans
• Past payment track record
• Analysis of additional income, expenditure, additional earning members in the family
• Physical Verification

Fair Vinimay Services Private Limited operating under the trade name IndiaMoneyMart (IMM) is one of the existing Peer to Peer (P2P) Lending platforms in India. IMM platform connects lenders looking for returns with borrowers looking for loans at competitive rates. These loan are unsecured loans requirements of the borrowers for various needs. IMM is a tech-enabled platform that provides:

• Lenders an opportunity to lend directly to the borrowers.
• A platform which is essentially a peer-to-peer platform utilizing and validating multiple data-points to establish the credibility of both parties.

Lenders on IMM platform get access to profiled creditworthy borrowers with complete details and lend funds to borrowers of their choice, which provides an attractive return on the funds lent.IMM follows a rigorous credit underwriting process to determine the intention and ability of a loan seeker to repay debt and enable lenders to deploy their funds profitably.

The business activities comprise of the following processes

A. Process of Participant Authentication

The participants on IMM platform are borrowers and lenders. The process of authentication for both the borrowers and lenders are automated and starts with a simple registration process.

• The process of borrower authentication is done at the first step itself through authentication of mobile and email data.
• The registration of borrower at IMM comprises of various steps starting from submitting basic Know Your Customer (KYC) details, Personal/ Professional details, Financial Information and finally uploading details required for credit assessment.
• The KYC details uploaded by the borrowers are then verified by the IMM team.
• Credit assessment of the borrower is done based on information submitted and credit information reports obtained with consent of borrowers and other documents uploaded by the borrowers.
• Finally, the last step is to do a Home/Office/Tele verification of the borrower, if considered necessary.

ii.Lender’s authentication process

• The registration of lender also starts with submission of basic KYC details and uploading of various KYC documents.
• The process of lender authentication is done at the first step itself through authentication of mobile and email data.
• The KYC details uploaded by the borrowers are then verified by the IMM team.

B. The procedure of documentation of loan agreements (Agreement Generation and Loan Disbursal Process)

• Based on the credit assessment, if the borrower registered on the platform is found creditworthy, his/ her profile is made live on the IMM platform and the Lenders registered with IMM can view the credit profile of the proposed borrowers along with IMM Score.
• Lenders can view the proposed mapped borrowers and giveconsent to lend to them.
• Disbursement of loan is done once documentation formalities are completed.
• Collection of EMI and transfer to Lender's account is based on re-landing period selected if any.
• All payments from Lenders to Borrowers is done through Escrow Accounts.
• All borrower payments are received in Escrow Account.
• Providing Legal support services to Lenders for collection, if required on best efforts basis.
• Providing updates to Lenders on the portfolio performance for loans disbursed.

The business activities of the company do not include the following

• The company does not provide any secured loans
• The company does not carry any lending from its own book.
• It does not provide any credit guarantee for the loans on its platform nor does it provide any return assurance.

Business Model

The Business Model of IMM is enabling transactions between Lenders and Borrowers through P2P lending on a tech enabled platform and earning Registration fees, Transaction fees and Service charges from both borrowers and Lenders

1. Introduction

Welcome to IndiaMoneyMart. Your privacy is important to us. www.indiamoneymart.com is a Platform run by Fair Vinimay Services Private Limited (“Company”). This Privacy Policy governs the use of the website www.indiamoneymart.com (“Website”) and Platform. IndiaMoneyMart urges you to review the information provided in this Privacy Policy.

2. Scope

2.1. This Privacy Policy covers the manner and purpose of collection, use, disclosure, transfer and storage of your Personal Information (defined below) by IndiaMoneyMart, which is more particularly described below. By using this Platform, you hereby accept the practices described in this Privacy Policy. By using this Platform, you also grant explicit consent to the use of your Personal Information by IndiaMoneyMart in accordance with the terms set out in this Privacy Policy.

2.2 You may be able to access third party websites directly from this Website. This Privacy Policy does not apply when you access third party websites. We cannot control how third parties may use Personal Information you disclose to them, hence we recommend that you carefully review the privacy policy of any third party website you visit before using it or disclosing your Personal Information to its provider.

2.3. We may modify or amend the Privacy Policy from time to time. We shall notify you of any material changes by sending you an email, posting a notice on the home page of the website, or posting a notice in your account when you first login after we have made changes. Subsequent to the modifications in the Privacy Policy, your continued use of this Platformand our services shall mean that you have accepted the modified Privacy Policy and you shall be bound by the practices in the updated Privacy Policy as and when you use this Platform. If you have any questions or comments regarding this Privacy Policy, Please contact us at support.imm@ekosh.in.

3. Collection of Personal Information

3.1. For the purpose of this Privacy Policy, the term “Personal Information” shall mean your name, address, mailing address, mobile number, email ID, PAN Number, Aadhar Number, passport details, driving license details, income tax returns details, bank account number, personal statement of your credit card or debit card or other payment instruments, reasons for seeking finance, salary slip, credit information report, income sources and such other financial information that the Company deems necessary for the purpose of providing its services to you including but not limited to KYC (Know your Customer) verification and authentication of identity, location & income documents and assessing the credit worthiness of the borrowers.

3.2 We collect Personal Information from you when you create an account on the Platform, either as a lender or borrower. The information on the website is accessible to some extent, but to take part in the services offered, registration is mandatory, which enables you to participate. During registration, the Personal Information collected will be used for the purpose stated therein.

4. Use of Personal Information

4.1. The Personal Information collected shall be used for the following:

• primarily for providing the requested services;

• for carrying on day-to-day operations, i.e. for processing the transactions, maintaining the accounts, responding to legal investigation, providing customer support and services;

• sharing with the other members of the Platform on a need to know basis and only for the purpose of entering into the contemplated transactions facilitated through our Platform;

• sharing with third-party contractors which have dealings with IndiaMoneyMart;

4.2. IndiaMoneyMart may use and analyse the Personal Information for trends and statistics to improve the services offered on the Website. Such trends and statistics may be shared with marketing agencies to plan and introduce new product offerings and services to improve user experience on the Platform. The information shared to marketing agencies cannot be used to identify the customers of IndiaMoneyMart but will be generic in nature such that the confidentiality of the Personal Information is maintained.

4.3. We shall protect your Personal Information from unauthorized access and use. We use security measures in its implementation by adopting advanced practices prevailing from time to time. We may use third party service providers for carrying out the transaction, which includes verification services, credit score verification from Credit Information Companies, payment services, legal due diligence services or legal processes involved who shall also maintain confidentiality of the Personal Information as per the prescribed measures. In addition, we may disclose information to the extent necessary to Government agencies, Reserve Bank of India, Credit Information Companies, as may be required to comply with guidelines applicable to us from time to time. We have adequate safeguards to ensure that the Personal Information shall not be subject to unauthorized use and we have an Outsourcing Policy in place, wherein the measures of securing confidentiality of customers are enlisted and adhered to.

4.4. Upon acceptance of these terms and conditions, you hereby grant an unequivocal and explicit consent to share your Personal Information with third parties subject to the terms mentioned in this section.

5. Sharing of Personal Information

5.1 Disclosure to Successors: We may disclose and/or transfer your Personal Information to an acquirer, assignee or other successor entity in connection with a sale, merger, acquisition or reorganization of all or substantially all of the business or assets of IndiaMoneyMart. You will be notified via email or by a notice on our website of any such change in ownership or control of your Personal Information.

5.2.Disclosure to Third Party Service Providers and Online Partners: We may contract with various third parties who help us provide, maintain and improve the Website and the IndiaMoneyMart services. IndiaMoneyMart may engage third party service providers for verification of KYC data, physical verification, collection of documents, Payments, Collection and recovery services. IndiaMoneyMart shall ensure that the third parties and online partners refrain from disclosing your Personal Information (by following the safeguards already mentioned in this Privacy Policy and the Outsourcing Policy), except for the purpose of providing the services in question. In no circumstances, IndiaMoneyMart shall disclose data in relation to your financial status, income statements, earnings, source of earnings, personal identification numbers, passwords, code numbers, bank account numbers, expiry dates relationship numbers, encryptions, cookies and other such electronic details. IndiaMoneyMart shall be responsible to keep your Personal Information confidential and secure. IndiaMoneyMart will not share the Personal Information with any third party without your explicit consent. In cases, where any such third party service provider must have access to your personal information for performance of its services, IndiaMoneymart will require such service providers to maintain confidentiality restrictions as outlined in this Privacy Policy and the Outsourcing Policy.

5.3. Disclosure to lenders: We will disclose your data to lendersregistered with us. We may access your financial and credit information for credit assessment and risk profiling and disclose the same to any lendersfor taking an informed decision to lend on our platform. Any such disclosure of data requires the lendersto follow confidentiality & protection measures and not use data in any manner other than as provided in this Privacy Policy and terms and conditions.

5.4. Disclosures to facilitate payments: IndiaMoneyMart may direct you to a payment gateway service or any other payment service provider to facilitate payments to process your transactions. Such Payment gateway may have access to the personal information provided by you in order to effect the payments. IndiaMoneyMart will have no access to such information.

5.5. Internet Advertising: We may use third party service providers to serve ads on our behalf across the internet and sometimes on the Website. They may collect information on a ‘no name’ basis about your visits to our Website, and record customer experiences with our products and services. They may also use such information to target advertisements for goods and services. This anonymous information is collected through the use of a web beacon, which is an industry standard technology used by major websites.

5.6. Disclosure to Credit Information Bureaus & Reserve Bank of India: To comply with the regulatory requirements, IndiaMoneyMart may share the Personal Information and/or other data of a user with the Credit Information Bureaus, Reserve Bank of India and/or any other regulatory authority in accordance with applicable laws.

6. Data Usage of Cookies & Others

Cookies: This is information stored by your browser on your computer when allowed. The use of cookies on our Website is similar to other online marketplaces. These are used to enhance your experience with our Website. We use cookies to help us identify who you are, so your login experience is smooth each time. Cookies also allow us to collect Non-personally identifiable information from you, like the pages you visited and what links you clicked on. Use of this information helps us to create a more user-friendly experience for all visitors. In addition, we may use Third Party Advertising Companies to display advertisements on our Website. Most browsers automatically accept cookies, but you may be able to modify your browser settings to decline cookies. Please note that if you decline or delete these cookies, some parts of the Website may not work properly.

7. Changes to Personal Information

You can obtain a copy of and request that we correct errors in your Personal Information by emailing us at support.imm@ekosh.in.For your protection, you will be required to provide proof of your identity to obtain a copy of your Personal Information. If any of your Personal Information changes or if you no longer want to use the IndiaMoneyMart services, you may correct, update or deactivate your account through the account management screen. If you would like to deactivate or terminate your account you can also contact support.imm@ekosh.in. If you choose to deactivate your account with IndiaMoneyMart, we will ensure that your Personal Information is no longer retained by us. Should you wish to reactivate your account, you will be required to re-enter all the Personal Information sought by us to provide our services to you and such collection of information will be subject to our Privacy Policy, which may be amended from time to time as set out therein.

8. Security of information

8.1. We take appropriate precautions to protect the security of personal identity details. You can access your personal identity details on our website through your login and password, once your registration process and our verification processes complete. We recommend that you do not share your password with anyone. In addition, your personal details are stored on a secure server that only selected personnel and contractors have access to. We encrypt certain sensitive information using Secure Socket Layer (SSL) technology to ensure that your personal details are safe as it is transmitted to us.

8.2. However, you hereby accept that no data transmission over the Internet can be guaranteed to be completely secure.

8.3. At www.indiamoneymart.com, we keep adequate safeguards in our IT systems to ensure that it is protected against unauthorised access, alteration, destruction, disclosure or dissemination of records and data. We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.

9. Opt-Out

9.1. We provide you the opportunity to opt-out of having your Personal Information used for certain purposes. If you no longer wish to receive our newsletters and promotional communications, you may opt-out of receiving them by following the instructions included in each newsletter or communication or by emailing us at support.imm@ekosh.in. We also offer you an opportunity to opt-out of certain communications through the account management screen. If you need assistance you may contact us at support.imm@ekosh.in.

9.2. If we disclose your Personal Information to a third party in a manner that is not set forth in this Privacy Policy, you will be notified so that you can make an informed choice about sharing your Personal Information with that third party.

10. Grievance Officer

In accordance with the Information Technology Act, 2000 and Rules made thereunder, the name and contact details of the Grievance Officer are provided below:

Name of GrievanceOfficer: Mr. Ashish Chavan

1014. The Summit Business Bay,

Andheri East, Mumbai - 400093. India

Email : support.imm@ekosh.in

Telephone No: 022-40021106

11. Data Protection Officer

In accordance with the Information Technology Act, 2000 and Rules made thereunder, the name and contact details of the Data Protection Officer are provided below:

Name of Data Protection Officer: Mr. Sudarshan Suman

1014. The Summit Business Bay,

Andheri East, Mumbai - 400093. India

1.Introduction

Fair Vinimay Services Private Limited (IndiaMoneyMart "IMM") hereinafter (referred as “the company” or “IMM”), is a NBFC – Peer to Peer Lending platform. This Fair Practice Code (FPC) is aimed to provide to all the stake holders, especially customers effective overview of practices followed by the company in respect of the financial facilities and services offered by the company to its customers.

The FPC is aimed to provide to the customers effective overview of practices, which will be followed by the Company in respect of the financial facilities and services offered by the company on its P2P platform IMM to its customers. The Code will facilitate the customers/ participants to take informed decisions in respect of the financial facilities and services to be availed by them and will apply to any loan that is sanctioned and disbursed on the company’s platform. It is, and shall be, the policy of IMM to make available to all eligible qualified applicants, without discrimination.

Our Company’s policy is to treat all the clients consistently and fairly. The employees of the Company will offer assistance, encouragement and services in a fair, equitable and consistent manner. The Company will also communicate its FPC to the customers by uploading the same on its website.

2.Key Objectives

The key objectives of putting in place the FPC are as under:

(i) To act fairly and reasonably in all the dealings with the borrowers and Lenders (collectively known as “The Participants” or “The Customers”) by ensuring that

• The Company’s products and services meet relevant laws and regulations as applicable;

• The products and services of the Company meet the commitments and standards in this Code.The Company's dealings with customers will rest on ethical principles of integrity and transparency.

(ii) Adhering by the Prudential Norms specified by the RBI Guidelines with respect to maintenance of leverage ratio, period of maturity of loans (i.e. not to exceed 36 months) and ceiling applicable on the amount that can be borrowed and lent.
(iii) Provide a true and fair disclosure to the lender with respect to the details of the borrower (including personal identity, required amount, interest rate sought and credit score arrived at by the Company, terms and conditions of the loan including likely return, fees and taxes); to the borrower details of the lender (excluding personal identity and contact details)
(iv) Ensuring that the all dealings between the participants and the Company are backed by appropriate agreements that categorically specify the terms and conditions agreed between the participants (i.e. borrower, lender) and the Company
(v) The Company shall maintain confidentiality of information received from the participants.
(vi) The Company shall not resort to undue recourse in matters of recovery of loans of the lenders.
(vii) For the purpose of transparency, the Company shall publicly disclose on its website overview of credit assessment/ score methodology and factors considered, broad business model, grievance redressal mechanism, disclosure on usage/ protection of data.

(viii) Help customers understand how company's product and services work by:

• Informing about the company’s products, services and process in simple English or simple Hindi or local Language as per customers preference.

• Explaining the financial implications on on-boarding borrower/lender.

(ix) The Company will make every attempt to ensure that its customers would have trouble-free experience in dealing with it. However, in case of error of commission and/or omissions, it shall:

• deal with the issues promptly and professionally

• handle customer's complaints quickly

• deal with the customer grievances in a quick and efficient manner to the satisfaction of the customers

• take steps for reversal of any charges / interest levied erroneously or through oversight on a customer’s account

3.Sales Origination

The Company will guide its customers in choosing products and services which meet his/her requirements.

a) When dealing with potential customers, the Company will:

• Give the customer clear information explaining the key features of the services and/or products the customer has evinced an interest in and how they meet his requirements.

• Inform the customer about the information requirement to fulfill its ‘Know Your Customer’ (KYC) norms, establish the customer’s identity and any other documents required to comply with legal and regulatory requirements in force from time to time

• Seek additional information from the customer regarding his family or any other data, with his consent, to build a database.

(b) The Company will provide information on the various channels that can be used to access its products & services.
(c) Once the customer has posted his/her requirement, the Company will inform the customer how it works and explain the rights and responsibilities specific to the mode of operation.

4.Applications for loans and their processing

The Company shall act only as an intermediary providing an online marketplace or platform to participants involved in P2P lending and will not lend on its own or provide any credit enhancement or credit guarantee.

The participants will have themselves listed on the web-portal of the Company and have access the information available. The loans shall be processed based on the instructions of the borrower, lender and trustee.

The fund transfer between the participants on the P2P platform shall be through escrow account which will be operated by the trustee. At least two escrow accounts, one for funds received from lenders and pending disbursal, and the other for collections from borrowers, shall be maintained. All fund transfers shall be through and from bank accounts and cash transaction is strictly prohibited. The Company shall only have a ‘view access’ to the information available on its portal for reporting purposes.

In addition to the above, the participants may also take a note of the below:

i. All communications with the borrower shall be in English language/ explained in Hindi/ local language for proper understanding by the borrower. No application will be processed unless the applicant completes the entire process of registration with Company. The registration of borrower on the Company's platform does not guarantee that the loan will be sanctioned to the applicant.
ii. The application for loan would require the applicant to submit/ upload the documents including those required under KYC guidelines of RBI and as required for credit and financial assessment for sanction of loan.
iii. The Company has devised a system of giving acknowledgement for registration of the borrower and receipt of information for all loan requirements.

iv. All applications for loan will be disposed within a reasonable period of time subject to submission of required information.

The platform shall not provide any assurance for the recovery of loans. Further, there is no guarantee of return and that there exists a likelihood of loss of entire principal in case of default by a borrower.

5.Approval - Loan appraisal and terms/conditions

i. Being a digital P2P Lending platform, the loans will be made live on the platform once the underwriting team of Company assesses credit risk/ profile of the borrower and finds it creditworthy.
ii. The Company shall consider all the loan applications keeping in mind the risk based assessment procedures adopted by it.
iii. The Company, before making the borrower live on the platform, would assess the ability of the borrowers to repay the loan.
iv. Once approved by the Company's underwriting team, the borrowers are made live on the platform indicative interest rates (annualized), based on which Lenders may select and indicate their interest on funding the borrowers.Only post lender’s agreement disbursals are done. Borrowers are also shown their mapped lenders.

v. Sanction Letter signed with agreement also mention about the penal interest and other charges applicable for late payment.

6.Disbursement of loans, including changes in terms and conditions (communicated in preferred language)

i. Disbursement of amount of loans sanctioned may be made available to the borrowers as per Company’s platform internal rules subject to completion of all formalities including execution of loan documents.
ii. Any change in the terms and conditions will be in mutual consent of the borrowers and Lenders and with complete information to Company.
iii. The platform allows prepayment of loan. Change in the interest rates and service charges shall be made applicable prospectively in case there is delay in repayment. The loan agreement shall contain a specific clause in this regard.
iv. All disbursement of loans and collection of repayment will be through escrow accounts opened specifically for this purpose, the details of which will be available

7.Post disbursement supervision/monitoring

i. The decision, if any, of the Company to recall/accelerate payment or performance of loan shall be in accordance with the terms and conditions of the Loan Agreement.
ii. The Company shall give reasonable time to the borrowers before recalling the loan or asking for accelerating the payment or performance subject to the terms and conditions contained in the Loan Agreement and other related documents

8.Recovery Process

In the matter of recovery of loans, the company shall resort only to remedies which are legally and legitimately available to it and will not resort to undue harassment viz. persistently bothering the borrowers at odd hours, use of muscle power for recovery of loans, etc.

9.General Clause

i. The company will refrain from interfering in the affairs of the borrower except for the purposes provided in the terms and conditions of the loan documents, unless new information not earlier disclosed deliberately or otherwise by the borrower has come to its notice.
ii. The Company shall not discriminate on the grounds of gender, caste or religion in its lending policy and activities.
iii. On request from borrower for closure of his loan account, the request will be executed within one month of receipt of request subject to clearance of pending dues and completion of all the formalities as prescribed by the Company. In case the request cannot be executed in the time frame stated above due to any reason, the same may be communicated to the borrower.

iv.The Company shall not assume any credit risk, either directly or indirectly, arising out of transactions carried out on its platform. In other words, entire loss of principal or interest or both, if any, in respect of funds lent by lenders to borrowers on the platform shall be borne by the lenders.

10.Empanelment of Lenders/ Borrowers

i. The process of authentication for both the borrowers and Lenders are completely automated and starts with a simple registration process.
ii. The registration of borrower at platform is a step by step process starting from submitting basic KYC details (Adhaar number, PAN, etc) to uploading of various data (salary slip, bank statements, etc.) as required for credit assessment.
iii. On receipt of the KYC information of the borrower, the authentication is done by getting information from credit information companies and matching with the details provided in the KYC details followed by a physical verification of the borrower.
iv. The process of lenders/ borrower authentication is done at the first step itself through authentication of mobile and email data by sending OTP to the lender/ borrower for verification and also filling information as required for security check.
v. The registration of lender also starts with submission of basic KYC details to uploading of various data related to financial information.

11.Matching of borrowers/ lender

i. Based on the credit assessment by the Company’s team, if the borrower registered on the platform is found creditworthy, his/ her profile is made live on the platform and the lenders registered with companycan view the credit profile of the borrowers.
ii. Lenders can approve the mapped borrower. Borrowers are also shown their mapped lenders.
iii. As per Company’s platform rules, no lender can fund more than50% of the requirement to a borrower with a maximum cap of Rs. 50,000 per borrower.

12.Credit Information Companies

The company would give information about customers to Credit Information Companies(CIC) as per RBI Guidelines on:-

(a) Opening of a loan account
(b) Details of the customer failing to meet his/her repayments on time and the performance of loan account which includes how much loan has been sanctioned and the subsequent performance
(c) Legal proceedings have been initiated against the customer to recover the dues.
(d) Debts settled through legal recourses against the customer
(e) The company give CICs other information about the customer's account if law requires it or the customer has given them his/her permission to do so. A clause to this effect has been included in the Loan Agreement seeking the customers consent to share information on his loan with Credit Bureaus.

13.Confidentiality

Unless authorized by the borrower, the Company will treat all his personal information as private and confidential except to the extent of disclosure of information related to the borrowers of the Companyto the Lenders for taking Lending decisions as permitted under RBI Guidelines for NBFC – Peer to Peer Lending Platform (Reserve Bank) Directions, 2017 dated 4th October 2017 and subsequent amendments.

IMM will not reveal information or data relating to customer accounts, whether provided by the customers or otherwise, to anyone, other than in the following exceptional cases:

• If the information is to be given by law.

• If there is a duty towards the public to reveal the information.

• If the Company’s interests require them to give the information (for example, to prevent fraud) but it should not be used as a reason for giving information about customer or customer accounts [including customer name and address] to anyone else, including other companies in the group, for marketing purposes.

• If the customer gives consent to the Company to reveal the information.

• If Company is asked to give a reference about customers, they shall obtain his / her/ it’s written permission before giving it.

• Company shall not use customer’s personal information for marketing purposes by anyone unless the customer specifically authorizes them to do so.

• Company shall be entitled to share the loan and other information of the customer with the Credit Information Companies as per RBI guidelines.