HT DIGITAL STREAMS LIMITED - PRIVACY POLICY

Effective Date: Nov 1st, 2024

1. INTRODUCTION

HT Digital Streams Limited (hereinafter referred to as "HTDSL", "We", "Us", "Our"), a company incorporated under the laws of India, recognizes the critical importance of protecting the privacy and personal data of every user and visitor who accesses or avails our services ("You, Your"). We are licensed to operate and manage the websites of HT Media Ltd. and its subsidiaries.

Your privacy is paramount to us, and we deeply value the trust you place in us. We are committed to being fully transparent about the personal data we collect, how we use it, and the measures we take to protect it.

This Privacy Policy ("Policy") is provided in accordance with the requirements of the Digital Personal Data Protection Act, 2023 ("DPDP Act, 2023") and other applicable Indian laws concerning data protection and privacy. This Policy explains how we collect, receive, store, disclose, share, and use your personal data when you use our website and associated services (collectively, the "Platform") or interact with us. It also outlines your rights regarding your personal data and how you can exercise them.

Please read this Policy carefully before using our Platform or availing any of our Services. By accessing, browsing, using, or registering on our Platform, or by providing us with your personal data, you signify that you have read, understood, and agree to be bound by the terms of this Policy and consent to the processing of your personal data as described herein. If you do not agree with the terms of this Policy, please do not access or use our Platform or Services.

2. WHO WE ARE

HTDSL is an Indian company licensed to operate and manage the websites of HT Media Ltd. and its subsidiaries. We act as an online intermediary facilitating your access to various financial products and services offered by third-party financial institutions, service providers, and intermediaries ("Financial Institutions"). Our role is to connect users with these Financial Institutions and facilitate processes such as applying for loans, credit cards, insurance, investment products, and accessing credit information reports.

3. DEFINITIONS

For the purpose of this Policy, the following terms shall have the meanings assigned to them under the applicable data privacy laws:

Data Principal: The individual to whom the personal data relates and who is identified or identifiable by such data. In the context of this Policy, "You" or "Your" refers to the Data Principal.

Data Fiduciary: A person who alone or in conjunction with other persons determines the purpose and means of processing of personal data. HTDSL acts as a Data Fiduciary when processing Your personal data for the purposes outlined in this Policy.

Data Processor: Any person who processes personal data on behalf of a Data Fiduciary. Our service providers may act as Data Processors.

Personal Data: Any data about an individual who is identifiable by or in relation to such data.

Processing: In relation to Personal Data, means a wholly or partly automated operation or set of operations performed on digital personal data, and includes operations such as collection, recording, organisation, structuring, storage, adaptation, alteration, retrieval, use, alignment or combination, indexing, disclosure by transmission, dissemination or otherwise making available, restriction, erasure or destruction.

4. WHAT INFORMATION DO WE COLLECT AND HOW IT IS COLLECTED?

In order to enable and facilitate the provision of Services and to provide You with relevant financial product offers, HTDSL collects and receives various types of information from and about You. This information is collected directly from You when You interact with our Platform, use our Services, or communicate with us.

The types of personal data we may collect include, but are not limited to:

Identity and Contact Data:

Gender
Name
Mobile Number
Email Address
Date of Birth
Location Details / Pincode

Financial and Transaction Data:

Permanent Account Number (PAN)
Know Your Customer (KYC) related information
Employment Details
Income Range (where provided for loan/credit card eligibility checks)
Details related to loan applications, credit card applications, insurance applications, investment applications submitted through the Platform.
Transaction information related to your use of the Platform (e.g., products viewed, applications submitted).

Location Data:

Your current location (which may be derived from your IP address or device GPS data if You grant permission).

Technical and Usage Data:

Device Details (e.g., device type, operating system, browser type, unique device identifiers).
IP address.
Information about how You use our Platform and Services (e.g., pages visited, time spent on pages, clickstream data, search queries).
Information collected through cookies and similar technologies (see Clause 9).

Communication Data:

Information You provide when You contact us with inquiries, feedback, or support requests.

Biometric Data:

We do not collect, store, process or retain any biometric data (including but not limited to fingerprints, facial recognition data, iris scans or voiceprints) from You.
Not withstanding the foregoing, we may process Your biometric data only where expressly permitted or required under applicable law, regulatory directions or statutory guidelines, and in such cases, such processing shall be carried out strictly in accordance with such applicable requirements.

How is this information collected?

We collect personal data through various means:

Directly from You: When You register for an account on the Platform, apply for a financial product, fill out forms, participate in surveys, or communicate with us.
Through Your Use of the Platform: We automatically collect technical and usage data as You navigate and interact with our Platform.
From Financial Institutions and Service Providers: With Your explicit consent, we may receive information from Financial Institutions or service providers (such as Credit Information Companies) to facilitate the Services (e.g., receiving Your credit information report).
From Affiliates and Business Partners: We may receive information from our affiliates or business partners in accordance with their privacy policies and applicable law, to enhance our Services and provide relevant offers to You.

5. PURPOSE OF PROCESSING YOUR PERSONAL DATA

We collect and process Your personal data for specific, explicit, and lawful purposes, as permissible under applicable data privacy laws. The primary purposes for which we process Your personal data include:

To Provide and Facilitate Services:

This is the core purpose. We use Your personal data to:

Create and manage Your User Profile on the Platform.
Enable You to access and use the features and functionalities of the Platform and Services.
Process and facilitate Your applications for financial products (loans, credit cards, insurance, investments) with Financial Institutions.
Retrieve and provide You with Your credit information report and credit score from CICs as Your authorized representative (as detailed in Clause 22 of the Terms and Conditions).
Provide you with analysis, insights, or educational content based on Your credit information.
Verify Your identity and eligibility for certain Services.

To Identify and Present Relevant Financial Product Offers:

We use Your personal data, including Your credit score and information You provide about Your financial needs and profile, to analyze and identify financial products (such as loans, credit cards etc.) that may be suitable for You and present these offers on the Platform. This helps You discover potentially relevant options.

To Communicate with You:

To send You service-related communications, including confirmations, updates on Your applications, and important notices regarding the Platform or Services.
To respond to Your inquiries, requests, and support needs.

For Marketing and Promotional Purposes:

With Your consent (where required by law), or based on legitimate interests, we may use Your contact information to send You marketing communications, promotional offers, newsletters, and information about products and services that may be of interest to You, offered by HTDSL, our affiliates, or third parties. You can opt-out of receiving marketing communications at any time (see Clause 8).

For Analytics and Service Improvement:

To understand how You and other users interact with our Platform and Services.
To analyze trends, track usage patterns, and gather demographic information.
To monitor and analyze the effectiveness of our marketing and advertising campaigns.
To improve and optimize the performance, functionality, and user experience of our Platform and Services.
To develop new features and services.

For Security and Fraud Prevention:

To detect, prevent, and investigate fraudulent, unauthorized, or illegal activity.
To protect the security and integrity of our Platform and systems.
To enforce our Terms and Conditions and other policies.

To Comply with Legal and Regulatory Obligations:

To comply with applicable laws, regulations, legal processes, and governmental requests, including those under the the Information Technology Act, 2000, and rules framed thereunder or any other data privacy laws.
To cooperate with law enforcement and regulatory authorities.
To establish, exercise, or defend our legal rights.

For Business Operations:

To manage our business operations, including internal administration, accounting, and record-keeping.
In connection with a corporate transaction (see Clause 7).

We will not process Your personal data for purposes other than those specified in this Policy, unless we obtain Your fresh consent or are permitted to do so under the applicable data privacy laws.

6. LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA

We process Your personal data based on the following legal bases, as permissible under the applicable data privacy laws:

upon your consent; We rely on Your consent as the legal basis for processing your Personal Data. You may at any time revoke or withdraw your consent to provide your information to us by using the applicable contact details set out in the Policy.
for fulfilling any obligation under any law for the time being in force in India
on any person to disclose any information to the State or any of its instrumentalities.
for compliance with any judgment or decree or order issued under any law for the time being in force in India, or any judgment or order relating to claims of a contractual or civil nature under any law for the time being in force outside India;
for responding to a medical emergency involving a threat to the life or immediate threat to the health of the Data Principal or any other individual;
for taking measures to ensure safety of, or provide assistance or services to, any individual during any disaster, or any breakdown of public order.

7. SHARING AND DISCLOSURE OF YOUR PERSONAL DATA

We may share or disclose Your personal data with the following categories of recipients for the purposes outlined in this Policy, in compliance with applicable laws:

Financial Institutions:

We share Your personal data with the Financial Institutions whose products or services You choose to apply for or express interest in through our Platform. This sharing is essential to facilitate Your application and enable the Financial Institution to assess Your eligibility and process Your request.

Credit Information Companies (CICs):

When You consent to access Your credit information report through our Platform, we will share Your necessary identity and contact details with the designated CIC to retrieve Your report as Your authorized representative.

Service Providers:

We engage third-party service providers to perform various functions on our behalf to operate our business and the Platform. These service providers may process Your personal data only in accordance with our instructions and this Policy.

Affiliates and Business Associates:

We may share Your information within our group of affiliated companies and with our business associates who offer value-added services, for business purposes and to offer You relevant products and services, in accordance with their privacy policies and applicable law.

Third Parties Providing Content, Advertising, or Functionality:

With Your consent (where required) or as permitted by law, third parties may collect or receive certain information about Your use of the Services (e.g., through cookies) to provide content, advertising, or functionality, or to measure and analyze ad performance. These third parties will process Your data according to their own privacy policies.

Law Enforcement and Regulatory Authorities:

We may disclose Your personal data if required to do so by law or in response to valid requests by public authorities, including to meet national security or law enforcement requirements, or in response to court orders, subpoenas, or other legal processes.

In Connection with a Corporate Transaction:

We may share or transfer Your personal data in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.

To Protect Our Rights and Users:

We may disclose Your Personal Data when we believe it is necessary to investigate, prevent, or take action regarding potential violations of this Policy, our Terms and Conditions, suspected fraud, situations involving potential threats to the safety of any person, or as evidence in litigation in which we are involved.

With Your Consent or at Your Direction:

We may share Your information with other third parties when You provide Your explicit consent or direct us to do so.

We ensure that when we share Your personal data with third parties, appropriate contractual safeguards and security measures are in place to protect Your data in compliance with applicable data privacy laws.

8. YOUR RIGHTS AS A DATA PRINCIPAL

Under the Digital Personal Data Protection Act, 2023, You have certain rights regarding Your personal data. HTDSL is committed to facilitating the exercise of these rights:

Right to Access Information about Processing:

You have the right to obtain from us confirmation as to whether or not Your personal data is being processed, and where that is the case, access to the personal data and other information, including the categories of personal data concerned, the purposes of the processing, and the recipients or categories of recipients to whom the personal data have been or will be disclosed.

Right to Correction and Erasure:

You have the right to request the correction of inaccurate or incomplete personal data concerning You. You also have the right to request the erasure of Your personal data if the processing is no longer necessary for the purposes for which it was collected, if you withdraw consent. We will take reasonable steps to verify Your identity before processing such requests.

Right to Grievance Redressal:

You have the right to a readily available and effective mechanism for the redressal of Your grievances. You can contact our Grievance Officer (details in Clause 16) to raise any concerns or grievances regarding the processing of Your personal data.

Right to Nominate:

You have the right to nominate another individual who shall, in the event of your death or incapacity, exercise your rights under this Policy.

Right to Withdraw Consent:

Where we rely on Your consent as the legal basis for processing Your personal data, You have the right to withdraw Your consent at any time. Withdrawing consent will not affect the lawfulness of processing based on consent before its withdrawal. Please note that withdrawing consent may affect Your ability to access or use certain features or Services that rely on the processing of the data for which consent was given. The process for withdrawing consent is outlined in Clause 17.

How to Exercise Your Rights:

You can exercise Your rights (except for the right to lodge a complaint with the Data Protection Board) by contacting us through the contact details provided in Clause 17 (Withdrawal of Consent) or Clause 16 (Grievance Redressal). We will respond to Your requests in accordance with the requirements of the applicable data privacy laws.

9. COOKIES AND SIMILAR TECHNOLOGIES

We use cookies and similar tracking technologies (like web beacons, pixels, and tags) to collect information about Your browsing behavior on our Platform. Cookies are small text files stored on Your device.

We use cookies for various purposes:

Necessary Cookies: Essential for the operation of our Platform and to provide You with basic functionalities.
Analytical/Performance Cookies: Help us understand how visitors use our Platform, track usage patterns, and improve the performance of our website.
Functionality Cookies: Allow us to remember Your preferences (such as language or region) and personalize Your experience.
Advertising/Targeting Cookies: Used to deliver advertisements that are more relevant to You and Your interests. They may also be used to limit the number of times You see an advertisement and measure the effectiveness of advertising campaigns. These cookies may be placed by us or by third-party advertising networks.

You can control and manage cookie preferences through Your browser settings. Most browsers allow You to block or delete cookies. However, please note that disabling cookies may affect the functionality of the Platform and Your ability to access certain features.

By using our Platform, You consent to the use of cookies and similar technologies as described in this Policy.

10. DATA SECURITY

We are committed to protecting the security of Your personal data. We implement reasonable security safeguards and measures, including technical, administrative, and physical safeguards, designed to protect Your personal data from unauthorized access, use, disclosure, alteration, and destruction.

While we strive to protect Your personal data, please note that no method of transmission over the internet or method of electronic storage is 100% secure. We cannot guarantee the absolute security of Your data and that any data, during transmission or while stored on our systems, will be safe and secure from intrusion by others. You are also responsible for maintaining the confidentiality of Your account credentials and for the security of Your own devices.

11. DATA RETENTION

We will retain Your personal data only for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements, or for the period agreed upon for specific services.

Upon the expiry of the retention period or when the data is no longer necessary for the purposes for which it was collected, we will securely delete, destroy, or anonymize Your personal data in accordance with applicable laws and our internal policies.

For Credit Information Services, we will retain Your Credit Information for the Permitted Time Period (as defined in our Terms and Conditions) or until You withdraw consent, whichever is earlier. Upon expiry or withdrawal, we will promptly destroy, purge, and erase the Credit Information.

12. DATA TRANSFER

Your personal data will be stored on servers located in India. We do not transfer Your personal data outside India unless it is strictly necessary for the provision of services and permitted under applicable laws. In such exceptional cases, we will ensure that appropriate safeguards are in place to provide a level of protection for Your data that is comparable to the standards under Indian data privacy laws. Further, in case Your data is processed outside India, the same shall be deleted from servers outside India and brought back to India within 24 hours of processing.

13. LINKS TO THIRD-PARTY WEBSITES

Our Platform may contain links to third-party websites, financial institutions, and services that are not operated by us. We are not responsible for the privacy practices or the content of these third-party websites. This Policy applies only to information collected by HTDSL through our Platform and Services. We encourage You to review the privacy policies of any third-party websites You visit before providing any personal data.

When you access Third-Party Services through our Platform, your interaction with those services is governed by their respective terms and conditions and privacy policies.

14. CHILDREN'S PRIVACY

Our Platform and Services are not intended for use by individuals under the age of 18 (or the age of legal majority in Your jurisdiction). We do not knowingly collect personal data from children without verifiable parental consent. If we become aware that we have collected personal data from a child without appropriate legal basis, we will take steps to delete such information promptly. If You believe that we may have collected information from a child, please contact us using the details provided in Clause 16.

15. CHANGES TO THIS PRIVACY POLICY

We reserve the right to change or update this Privacy Policy at our sole discretion or in line with the DPDP Act, 2023, the rules framed thereunder and other regulatory changes from time to time to reflect changes in our practices, technologies, legal requirements, and other factors. The "Effective Date" at the top of this Policy indicates when it was last revised. If we make material changes to this Policy, we will notify You by posting the updated Policy on our Platform and, where appropriate, by other means such as email. We encourage you to review this Policy regularly for such changes. The updated Privacy Policy will take effect as soon as it has been updated. Your continued use of the Platform or Services after the updated Policy is posted constitutes Your acceptance of the changes.

16. GRIEVANCE REDRESSAL MECHANISM

In accordance with applicable laws, HTDSL has established a Grievance Redressal Mechanism.

If You have any questions, concerns, complaints, or grievances regarding this Privacy Policy, the processing of Your personal data, or the exercise of Your rights under the DPDP Act, 2023, You may contact our Grievance Officer:

Grievance Officer: Mr. Neelabh Vikram Mall
Designation: Business Head - Financial Services
Address: HT Digital Streams Limited, 5th Floor, Lotus Tower, A Block, Community Centre, New Friends Colony, New Delhi- 110025
Email: grievance.fs@htdigital.in
Contact Timings: to be used during office hours i.e. 9am to 5pm on all working days i.e. Monday to Friday) except on public holidays

We will acknowledge Your grievance within twenty-four hours and endeavor to resolve it within a period of fifteen days from the date of receipt.

17. WITHDRAWAL OF CONSENT

You may withdraw the consent You have previously provided for the processing of Your personal data by communicating Your withdrawal in writing to us using the following contact details:

Upon receiving Your written request to withdraw consent, we will cease processing the personal data for which consent was withdrawn, subject to any legal or contractual obligations that require continued processing.

Please note that withdrawing consent may result in our inability to provide You with certain Services or features of the Platform that rely on the processing of the data for which consent was given. We will inform You of the potential consequences of withdrawing Your consent.

We will update Your preferences as soon as reasonably practical after receiving Your request.

18. CONTACT US

If You have any questions or concerns about this Privacy Policy or our data practices, please contact us:

Contact Person: Mr. Neelabh Vikram Mall
Address: HT Digital Streams Limited, 5th Floor, Lotus Tower, A Block, Community Centre, New Friends Colony, New Delhi- 110025
Contact Number: 0124-4118763 (during office hours: 9am to 5pm, Monday to Friday, except public holidays)
Email: info.fs@htdigital.in

19. LODGING A COMPLAINT WITH THE DATA PROTECTION BOARD

You have the right to lodge a complaint with the Data Protection Board of India if You believe that the processing of Your personal data by HTDSL is not in compliance with applicable laws.