Privacy Policy And Management Of User Data (“Privacy Policy”)

1. This Privacy Policy is governed by and is compliant with the Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules 2011, which is designed to protect personal information of the end-user(s) of the services; and other applicable rules and regulations related to privacy.
2. This Privacy Policy sets forth the modes of collection, utilisation and disclosure of your information gathered on the application. This Privacy Policy applies only to confidential information collected on the application. This Privacy Policy does not apply to information collected by Orocorp in other ways, including information collected through social networking platforms.
3. By clicking on "i accept" or "i agree", or continuing to use the services, or by installation or access to the application, you agree to the terms of this Privacy Policy. If you do not agree to this Privacy Policy, you may not avail the services.

1. APPLICATION/APP: "Application/App" shall refer to the Orocorp platform, i.e. the mobile application or the algorithm created, developed, designed and made available by Orocorp Technologies.
2. APPLICATION SERVICES: “Application Services” shall include the mobile application offered by Orocorp, services offered through the mobile application and emails sent by Orocorp.
3. BANK ACCOUNT: "Bank Account(s)" shall mean a bank account maintained by the User with a bank.
4. ELECTRONIC DEVICE: “Electronic Device” shall refer to any computing or electronically operated machine capable of accessing the platform, including but not limited to tablets, mobile phones, computers and their respective variants.
5. OROCORP TECHNOLOGIES/ORO: "Orocorp Technologies" or “Oro” shall mean Orocorp Technologies Private Limited, a private limited company incorporated under the Companies Act, 2013, an aggregator that provides a platform to connect borrowers with lenders for various loan products/facilities against gold owned by the borrower and facilitates application/processing/disbursal and closure of loans.
6. LOAN: "Loan" shall mean the loan of money a user may apply through the Application for the consideration of lenders or the grant of a Loan by lenders subject to the acceptance of the application terms and conditions of the Loan Agreement by the User.
7. LOAN AGREEMENT: “Loan Agreement” shall mean the loan agreement to be executed between Lender and the borrower for pertaining to or granting the Loan whether in physical or electronic form as may be applicable from time-to-time.
8. LENDER: “Lender” shall mean the provider of loan as gold term loans or as overdraft account facilities (doorstep and in-store) or as hypothecated overdraft account facilities (in-store).
9. MOBILE PHONE: "Mobile Phone" shall mean the handset and the SIM card along with all relevant accessories and necessary software for its operation which is owned by the user.
10. MOBILE PHONE NUMBER: "Mobile Phone Number" shall refer to the telephonic communication reference specified by the User during registration with Orocorp or during usage of the Application.
11. “Non-Personal Information” can be collected by Oro and doesn't directly identify an individual during their use of the Oro Platform. This sort of information primarily comprises details like IP address, device type, name of your internet service provider. It is clarified that Personal Information and Non-Personal Information are jointly referred to as the “aggregate information” for the purposes of this Privacy Policy.
12. ONLINE STORES: “Online Stores” shall refer to the Windows Store, Google Play Store, iOS App store or any other online store or portal in whatever nomenclature applicable to such store or portal where the Application will be made available by Orocorp to the Users, from time to time.
13. OUTSTANDING AMOUNTS: “Outstanding Amount(s)” shall mean any amount including the Loan, charges and other amounts due and payable by the User to lenders, on respective due date(s).
14. PERSONAL INFORMATION: "Personal information" encompasses any data directly or indirectly accessible to us that aids in the identification or authentication of an individual's identity. This might also encompass sensitive personal data, which notably consists of financial specifics such as bank details.
15. SERVICES: "Services" shall mean any service offered or rendered by Orocorp Technologies or its affiliates but not limited to facilitation of the collection of payments for the transaction/(s) between the Users.
16. USER ACCOUNT: "User Account" shall mean the registered Application account of the User/ Lender/Partner with Orocorp for use of the Application and services offered by Orocorp.
17. USER DATA: "User Data" shall include any data, information, pattern, behavior, documents, materials, transactions of the User.
18. WEBSITE: "Website" shall refer to www.orocorp.in, https://oromoney.in/ and https://orosafe.in/ or such other website Orocorp notifies for the purposes of these terms.
19. YOU/YOUR/USER: "You/Your/User" shall mean any person who accesses, downloads, installs, utilizes, operates or views the Application or Services offered by Orocorp.

1. The Personal Information shall be collected through the mobile application form ("Mobile Application Form") available on the Application.
2. We collect an "FCM registration token" from your mobile device which used only for the purpose of sending you notifications on you mobile device.
3. Deletion, uninstallation, and/or discontinuation of our Services, shall not release you from the responsibility, obligation and liability to repay the Outstanding Amount(s).

1. We shall use the User data in the following cases:
2. to provide you with the Services and to assist you in the event you need additional support;
3. to access your credit worthiness;
4. to maintain and manage your User Account;
5. to assist you with technical difficulties that may arise in relation to your use and access of the Application;
6. to manage our relationship with you;
7. for analytics;
8. to comply with our legal or statutory obligations;
9. to contact you about important announcements and other important information about your User Account, the Application and the Services;
10. in order to define your profile;
11. Additionally, you authorize us to share your Personal Information and User data with third parties for the purpose of facilitation of provision of Services and to ensure our compliance with the law.
12. You authorize Orocorp to share your Personal Information and User data to Lenders and Partners and other affiliates of Orocorp in order to enable smooth facilitation of the gold loan transaction.
13. User generated content is not confidential or proprietary. You grant, and warrant that you have the right to grant us a non-exclusive, non-revocable, worldwide, transferable, royalty-free, perpetual right to use your User generated content in any manner or media now or later developed, for any purpose, commercial, advertising, or otherwise, including the right to translate, display, reproduce, modify, create derivative works, sublicense, distribute, assign and commercialize without any payment due to you.

• Facilitating and providing financial services through Oro, including but not limited to lending facilities.
• Driving research, strategic planning, and statistical evaluations.
• Analytical purposes aiming at refining our offerings, bolstering security, elevating service quality, and fine-tuning marketing approaches.
• Evaluating and processing your applications, directives, or requests.
• Engaging in communication with you, including relaying modifications to our products or services.
• Steering our operational infrastructure and adhering to internal guidelines.
• Responding to your inquiries or feedback.
• Resolving any grievances, assertions, or conflicts.
• Validating your identity prior to availing our services.
• Undertaking obligatory credit assessments, screenings, and comprehensive checks.
• Crime prevention and detection, including countering financial offences.
• Handling financial, managerial, and risk assessment reports, audits, and documentation.
• Initiating contracts based on your solicitations.
• Employing data as mandated or authorised by law or with your explicit agreement.
• Using cookie-gathered data to enhance our service usability, refine our interface, and augment our functionalities.

1. Consistent with the principles outlined in this policy, Oro will retain your Personal and Non-Personal Information for the duration necessary to achieve the objectives for which it was collected. The duration for which Oro retains the combined information is guided by our obligations to meet legal, accounting, regulatory, and compliance reporting criteria. Retaining your combined information may also be pertinent following the deactivation, cancellation, or non-subscription of your account with us or our business associates. If you decide to close your User Account, you can notify us by reaching out to support@orocorp.in. While your account may no longer be active, we may continue to retain details about you in line with our legal obligations, to address disputes, and to enforce our contracts.
2. Notably, upon the completion of 5 years from the final closure of all your loans with the Lender(s), we will default to purging your data from our databases. Additionally, after your loans with the Lender(s) have been settled, you can instruct Oro at support@orocorp.in to have your data removed from our database. In such cases, Oro commits to expunging the specified data within a reasonable timeframe.
3. The period of data retention might persist even after the conclusion of our professional relationship, ensuring we have adequate records to address any future issues or for our own business records. We may also be compelled to disclose Personal Information when mandated by law or when we believe, in good faith, that such action is warranted in response to legal processes or court orders.
4. Should you opt to reactivate your account in the future, understand that Oro might still possess user information to ensure optimal service delivery. However, it's important to recognize that post-deletion, some latency might occur in erasing Personal Information from our servers, and backup versions could exist even after the main record is removed.

1. We value your Personal Information, and protect it on the Platform against loss, misuse or alteration by taking extensive security measures. In order to protect your Personal Information, we have implemented stringent security measures to protect the loss, misuse and alteration of the information under our control. Once your information is in our possession, we adhere to strict security guidelines, protecting it against unauthorized access.
2. All Personal Information is stored on a secure cloud setup and all communication happens via bank-grade secure SSL communication channels. The Personal Information is stored on Amazon Web Services. There is restricted access to any such information.
3. Although we provide appropriate firewalls and protections, we cannot warrant the security of any Personal Information transmitted as our systems are not hack proof. Data pilferage due to unauthorized hacking, virus attacks, technical issues is possible and we take no liabilities or responsibilities for it.
4. You are responsible for all actions that take place under your User Account. If you choose to share your User Account details and password or any Personal Information with third parties, you are solely responsible for the same. In the event of any misuse of your User Account by any third party, in any manner, you may lose substantial control over your Personal Information and may be subject to legally binding actions.

1. We will respond to your request about access to the information we collect about you within the time frame required by applicable law. The following persons may have access to the user data:
2. Administrators: We shall provide access to your Personal information to our authorized administrators for business purposes, who shall be under confidentiality obligations towards the same.
3. Affiliates: We may provide Personal Information we collect to our affiliates for the purpose of compliance with applicable law and to provide our service efficiently.
4. Financial institutes: We may provide Personal Information to the financial institutes who may be our financial partners for that particular transaction.
5. Lender: We may provide Personal Information we collect to Lenders such as banks, NBFCs or any other financial institutes we may partner with for providing better Services to You.
6. Business Partners: We may use certain trusted third-party companies and individuals to help us provide, analyze, and improve the Services including but not limited to data storage, maintenance services, database management, credit bureaus, rating agencies, web analytics, payment processing, and improvement of the Platform’s features. These third parties may have access to your information only for purposes of performing these tasks on our behalf and under obligations similar to those in this Privacy Policy.
7. Service Providers: We may share your Personal Information with the service providers, who are working with us in connection with the operation of the Services or the Platform, so long as such service providers are subject to confidentiality restrictions consistent with this Privacy Policy.
8. Joint Marketing Arrangements:  Where permitted by law, we may share your Personal Information with joint marketers with whom we have a marketing arrangement, we would require all such joint marketers to have written contracts with us that specify the appropriate use of your Personal Information, require them to safeguard your Personal Information, and prohibit them from making unauthorized or unlawful use of your Personal Information.
9. Persons who acquire our assets or business: If we choose to sell or transfer any of our business or assets, certain Personal Information may be a part of that sale or transfer.
10. Legal and Regulatory Authorities: We may be required to disclose your Personal Information due to legal or regulatory requirements. In such instances, we reserve the right to disclose your Personal Information as required in order to comply with our legal obligations, including but not limited to complying with court orders, warrants, or discovery requests. We may also disclose your Personal Information:
1. to law enforcement officers or others;
2. to credit information companies;
3. to comply with a judicial proceeding, court order, or legal process served on us or the Platform;
4. to enforce or apply this Privacy Policy or the terms of Service or our other policies or Agreements;
5. for an insolvency proceeding involving all or part of the business or asset to which the information pertains;
6. respond to claims that any Personal Information violates the rights of third-parties;
7. or to protect the rights, property, or personal safety of the Company, or the general public.

1. Notwithstanding anything mentioned hereinabove, the Company shall not be responsible for the actions or omissions of the service providers or parties with whom the Personal Information is shared, nor shall the Company be responsible and/or liable for any additional information you may choose to provide directly to any service provider or any third party.
2. We may share your information to other third parties, in which case we will protect your information by aggregation or de-identification of the information, so that it cannot reasonably be used to identify you.
3. In situations other than as set out above, you will receive prior written notice when information about you might be shared with third parties and you will have an opportunity to choose whether or not to grant them access to the information.

• Access to your information: You may request a record of your Personal Information that we process, upon verification of your identity and other particulars as per our internal policy.
• Review, Correct, and Rectify your information: You have the right to review, correct, or rectify any inaccurate Personal Information stored with us.
• Withdrawing your consent:
• You can retract a consent to processing that you've provided and stop further processing of your Personal Information in accordance with the terms of this Privacy Policy.
• You also have the option to refrain from granting consent before the collection and processing of your combined information.

• You do not have any ongoing credit facilities initiated through us.
• There are no unresolved or probable grievances regarding your prior engagements with us, our representatives, or our Lending Partners.
• Your account will undergo permanent deletion, eliminating the possibility of reactivation.
• You won't receive any further communications from us or our representatives.
• We maintain ISO 27001:2013 certification (“ISO”). Hence, rest assured that if we identify any breach concerning your data, we'll implement measures in alignment with the aforementioned protective standards.

1. We may provide you with certain ancillary services such as chat rooms, blogs and reviews for the Services. Subject to any applicable laws, any communication shared by you via the Application or through any other medium, reviews or otherwise to us (including without limitation contents, images, audio, financial information, feedback etc. collectively “Feedback”) is on a non-confidential basis, and we are under no obligation to refrain from reproducing, publishing or otherwise using it in any way or for any purpose.
2. You shall be responsible for the content and information contained in any Feedback shared by you through the Platform or otherwise to us, including without limitation for its truthfulness and accuracy. Sharing your Feedback with us, constitutes an assignment to us of all worldwide rights, titles and interests in all copyrights and other intellectual property rights in the Feedback and you authorize us to use the Feedback for any purpose, which we may deem fit.

1. You agree to indemnify us, our subsidiaries, affiliates, officers, agents, co-branders or other partners, and employees and hold us harmless from and against any claims and demand, including reasonable attorneys’ fees, made by any third party arising out of or relating to: (i) Personal Information and contents that you submit or share through the Platform; (ii) your violation of this Privacy Policy, (iii) or your violation of rights of another Customer(s).
2. You expressly understand and agree that Orocorp shall not be liable for any direct, indirect, incidental, special, consequential or exemplary damages, including but not limited to, damages for loss of profits, goodwill, use, data, information, details or other intangible losses (even if we have been advised of the possibility of such damages), resulting from: (i) the use or the inability to use the Services; (ii) unauthorized access to or alteration of your Personal Information.

1. We may make changes to this Privacy Policy. In the event that changes are made to this Privacy Policy, we will notify you through communications and will additionally revise the date at the top of the policy. If we make material changes, we will do so in accordance with applicable legal requirements, and we will post a notice on the application alerting you to the material changes prior to such changes becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

1. This Agreement shall be construed and governed by the laws of India and courts of law at Chennai shall have exclusive jurisdiction over such disputes without regard to principles of conflict of laws.
2. In case you need to access, review, and/or make changes to the Personal Information, you shall have to login to your User Account and change the requisite details. You shall keep your Personal Information updated to help us better serve you.
3. Our Application may include links to other websites or online services, whose privacy practices may differ from those of us. If you submit information to any of those websites or online services, your information is governed by their privacy policy. We encourage you to carefully read the privacy policy of any such website you visit.
4. When you use our application, we use action tags (also called pixel tags, clear GIF, or beacons) to identify the content that you visit and how you use such content. Action tags may collect and transmit this data in a manner that identifies you if you have registered with our application or are logged into our application. We also use action tags in our emails, to determine whether an email was opened or whether it was forwarded to someone else.
5. You are responsible for maintaining the secrecy and accuracy of your password, email address, and other account information at all times. We recommend a strong password that you do not use with other services. We are not responsible for personal data transmitted to a third party as a result of an incorrect email address.

1. Grievance Redressal Officer

If you are concerned about the handling of your Personal Information, or if you have any complaints or queries related to your Personal Information or our Privacy Policy, please contact:

• Mr Mohammed Kabir
• Grievance Officer
• Orocorp Technologies Private Limited
• 12/1, Varadappan Street, West Mambalam, Chennai 600-033
• Email: grievance@orocorp.in
• Ph: 080-46808068
• https://oromoney.in/

1. Grievance Redressal Mechanism

For every complaint/grievance registered by you in accordance with this Privacy Policy, a ticket number shall be provided to you. Using such ticket number, you may track and monitor the status of your complaint/grievance registered. Further, you may contact the Grievance Redressal Officer and/or the company in accordance with the details provided herein, to discuss your registered complaint/grievance further.

1. To keep your personal data accurate, current, and complete, please contact us regarding changes on support@orocorp.in. We will take reasonable steps to update or correct personal data in our possession that you have previously submitted using our services. You may also contact us on the above email address if you have any questions regarding our Privacy Policy.
2. If you prefer not to receive promotional emails from Orocorp, click on the unsubscribe link at the bottom of any promotional email that we send you to remove your email address from future promotional email campaigns. If you have difficulty with the unsubscribe process, contact us at support@orocorp.in.