Privacy Policy

1. INTRODUCTION.

This privacy policy (the “Privacy Policy”) sets out the types of Personal Data (defined below) collected by Opptra and / or its affiliates (“Opptra”) to offer you the Services (defined below) in collaboration with its partners (hereinafter individually referred to as “Partner” and collectively as “Partners”, or “us”, “we”, or “our”, depending on the context), through our website (hereinafter referred to as the “Platform”). 

This Privacy Policy also sets out the manner in which we use, exchange, disclose, and transfer your Personal Data (defined below) amongst us, as well as third parties, to the extent necessary to provide you (as well as your nominees, co-applicants, etc. if any) with our Services (defined below) through the Platform.

This Privacy Policy also identifies the rights and options available to you with respect to your Personal Data under Applicable Law, as well as the manner in which you may reach out to us should you have any concerns, grievances or other queries regarding how we process your Personal Data under this Privacy Policy.

Should you choose not to provide us with the requested Personal Data, we may be unable to offer you such Services for which we require such Personal Data.

You are advised to carefully read the Privacy Policy before using our Platform or any other channels for communicating with us or sharing information or data (including any Personal Data) with us or our Representatives (defined below), or prior to using the Services. We shall not be liable / responsible for any breach of privacy owing to your negligence. Please note that our Platform contains links to third party applications / digital platforms and Partner Modules which are provided for your convenience. This Privacy Policy governs the collection and processing of Personal Data for the purpose of offering the Platform. 

All capitalised terms not defined in this document shall have the meanings ascribed to them in the terms and conditions (“Terms”) of the Platform.

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2. DEFINITIONS

1. “Applicable Laws” means and includes the Digital Personal Data Protection Act 2023 (“DPDP Act”) and rules thereunder (as and when applicable), the Information Technology Act, 2000 (“IT Act”) and rules, including the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, each as amended from time to time, and any other applicable law for the time being in force relating to the processing of data.

2. “Body Corporate” means any company and includes a firm, sole proprietorship or other association of individuals engaged in commercial or professional activities.

3. “Cookies” means a small file placed on your device by our Platform when you either visit or use certain features of our Platform, which allows a website or application to remember your actions or preference for a certain period of time.

4. “Data” means and includes a representation of information, knowledge, facts, concepts or instructions which are being prepared or have been prepared in a formalised manner, and is intended to be processed, is being processed or has been processed in a computer system or computer network, and may be in any form (including computer printouts magnetic or optical storage media, punched cards, punched tapes) or stored internally in the memory of the computer. 

5. “Partner Module” means such third-party links, interfaces, modules, or such other technological platform(s) of the Partners hosted on the Platform which are not controlled, operated, or maintained by Opptra.

6. “Personal Data” shall have the same meaning as under the IT Act and rules, or under the Digital Personal Data Protection Act 2023 (“DPDP Act”), whichever applicable.

7. “Reasonable Security Practices and Procedures” means security practices and procedures designed to protect information from unauthorised access, damage, use, modification, disclosure or impairment, as may be specified in any law for the time being in force.

8. “Representatives” means the personnel employed or otherwise engaged by Opptra or its Partners for the purpose of their business.

Capitalised terms used in this Privacy Policy, but not defined herein, shall have the meaning given to them in the Terms.

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3. WHAT DATA DO WE COLLECT FROM YOU?

1. We collect, transmit, and store personal data based on your consent to this Privacy Policy, to provide you with the Services. On the basis of your consent, we collect the following Personal Data: 
   • Identity and profile-related information. This comprises of information such as your first and last name, username or similar identifiers, gender, title, photos, educational qualifications, location, and employment details. Your identity and profile-related information helps us create your profile, facilitate providing you with the Services and providing you with customised support as may be required from time to time. We do not collect your biometric data.
   • Contact information. This includes your email addresses, phone numbers, and residential address. 
   • Transaction information. This comprises details of transactions that occur through the Platform or are related to the Services. For instance, it may include services you've requested or confirmed through the Platform.
   • Data from SMSes. This comprises of SMS data from your phone to provide you the Services.
   • Marketing and communications data. This includes the use of Cookies, pixels and similar technologies for marketing and / or other purposes such as identifying your preferences regarding marketing messages from us and third parties, as well as your communication preferences. 
   • Device data. This involves IP addresses, browser types, time zone settings, operating systems, and device information. We securely collect, transmit, and store this data on our servers. 
   • Usage data. This consists of information about how you use the Platform. We collect information about your device to provide automatic updates and additional security so that your account is not used in other people’s devices. In addition, the information provides us valuable feedback on your identity as a device holder as well as your device behavior, thereby allowing us to improve our products interaction, quality of services and provide a personalised user experience to you.

2. We may supplement the Data that you provide with other information that we obtain from our dealings with you or which we retrieve from other organisations, for example, our affiliates, Partners and other group companies, in accordance with Applicable Law. 

3. You are requested to provide Opptra with complete, accurate and complete Personal Data to avail the Services. We request that any change to your Personal Data be communicated to us, for us to service you better.

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4. HOW AND WHEN DO YOU CONSENT TO USAGE AND SHARING OF YOUR DATA?

1. You understand and acknowledge that all Data provided by you (including Personal Data) is purely voluntary, and that your consent for the provision of such Data is free, specific, informed, unconditional and unambiguous, and provided by you through an affirmative act signifying your agreement to the terms of this Privacy Policy. 

2. Opptra collects consent from you, prior to collecting your Personal Data under this Privacy Policy. Towards compliance with Applicable Laws, Opptra maintains an auditable record of such consents granted, modified, or withdrawn, based on requests received from you from time to time. 

3. You may also withdraw or modify your consent to collect / provide / share / process the Data (including your Personal Data) by communicating to nodalofficer@opptra.com given below in writing. However, in such instance, to the extent that such Personal Data is necessary for us to provide you with our Services, (i) you may not be able to access some or all of the features or pages of the Platform; (ii) you may not be able to avail some or all of our Services; or (iii) if you have already availed our Services, such Services may be withdrawn, curtailed or cancelled as per the terms thereof upon such withdrawal or modification of consent. When you withdraw your consent, Opptra promptly communicates such withdrawal of consent to its Partners, so we can delete such data held by us based on your consent, within a reasonable time period.

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5. HOW AND WHERE DO WE COLLECT AND STORE YOUR DATA?

1. Opptra may also collect your Personal Data through your conversations (telephonic or otherwise) with any of Opptra’s customer service agents and / or any other mode of communication or submitted by you vide documents, images or in any other form and whether in the physical or digital / online mode. You agree that any such communication whether written or oral may be recorded to comply with Opptra’s internal processes, training and monitoring purposes, or for compliance with any Applicable Laws. 

2. We use Cookies, pixels and similar technologies to receive and store certain types of Data. Such Data helps us to make improvements to our content and helps us provide you with a better navigation experience on our respective Platform. Our backend servers and / or Partners and / or affiliates who provide analytic services, collect inter alia IP addresses, operating system details, browsing details, device details and language settings. Such Data is processed to inter alia estimate the number of visits, average time spent on the Platform, and nature of pages viewed. 

3. When you access third-party websites / applications or Partner Modules that use our technology or with whom we have specific arrangements to that effect, the applicable website / application operators’ or Partner Module’s privacy policies would apply and is not covered by our Privacy Policy. In such an event, we may also receive such Personal Data used by the relevant third-party websites / application to identify your account with such website / application.

4. Our Platform may contain advertisements and banners for third-party offerings and Partner Modules. Such advertisements and banners may operate as links to the advertiser’s website / platform or Partner Module and as such any information they collect by virtue of your clicking on that link will be collected and used by the relevant advertiser / Partner in accordance with Applicable Laws and the privacy policy of that advertiser / Partner.

5. The Personal Data collected from you is stored at our backend servers situated in India. In transferring your Personal Data, we comply with any applicable restrictions on data transfer under the DPDP Act, and sectoral regulations.

6. You also understand and acknowledge, that we may collect your Personal Data from other sources, such as our affiliates, business partners and other related third parties, in accordance with Applicable Law, for the purpose of better understanding your preferences and interests, so we can better tailor the Services provided to you through the Platform.

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6. WHAT DO WE USE YOUR DATA FOR?

In broad terms, we use your Personal Data for the following purposes:

1. Establishing and verifying your identity for onboarding purposes including but not limited for ourselves and our Partners.

2. Administer, provide, or facilitate Services you request or have expressed an interest in through us or our Partner Modules.

3. To notify you of any transaction or activities occurred within the Platform or Partner Modules or other system linked to our Platform.

4. Communicate with you in the event that any Services you have requested are unavailable. 

5. Internal risk assessments and analysis.

6. For record keeping purposes, to comply with laws and regulations as may be applicable from time to time, and to comply with other legal processes and law enforcement requirements.

7. The contact details (i.e., the phone number) of the third-party individuals (including your relatives and friends) that are voluntarily added by you at the time of availing any Service may be used for the purpose of establishing contact in case we are unable to contact you in furtherance of such Service. You confirm that the Personal Data of such third-party individuals is shared with us voluntarily for the purpose of availing such Service, that such person has not objected to sharing such data with us, and that such data is complete, accurate and consistent.

8. To carry out profiling, market research, surveys, and similar activities so that we can improve the Services we offer.

9. To track your activities and engagement on our Platform to personalise and improve your experience on our Platform and allow you to utilise our Platform’s features by granting Opptra and its Partners access to Data from your device, in accordance with Applicable Laws.

10. To perform activities such as data analytics, audits, usage trends to determine the effectiveness of Opptra’s or its Partners’ campaigns and as input into improving Services and facilitate customised Products based on your requirements.

11. To assess your eligibility for our Services and provide you with such Services which you may have shown interest in or requested for.

12. To inform you about important details like Opptra’s digital platforms, change in the Terms and policies and / or other administrative information important to meet your interests. 

13. To address your requests, feedback and queries and manage your relationship with Opptra and its Partners.

14. For security, business continuity and risk management. 

15. To notify you of any updates to the Platform or changes to the Services available.

16. For system or product development and planning, audit, and administrative purposes.

17. To carry out our obligations arising from any contract executed between you and us or our Partners.

18. To inform you about loyalty programs or other offers owned and operated by us or our Partners.

19. To ensure continued relationship with our customers or suppliers.

20. To meet our requirements to perform functions in the capacity of a DLA. 

21. Recover any payments you owe to Opptra and / or its Partners.

22. To use / modify / display, distribute and create new material from the Data you provide.

23. To help investigate violations of our or our Partners’ terms of use or to defend against legal claims.

24. To disclose the Data under special circumstances such as compliance with the Applicable Law, court summons, court orders, requests / orders from legal authorities or law enforcement agencies requiring such disclosure.

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7. WHO DO WE SHARE YOUR PERSONAL DATA WITH?

1. Opptra may share your Data (including the Personal Data) with third parties including but not limited to its Partners, group entities, vendors, service providers, data processors, banks, investigating authorities, law enforcement agencies, telecommunication companies, and statutory bodies; for customer verification, personalisation of Services, data enrichment, complying with statutory requirements, marketing or promotion of the Services of Opptra, its Partners or of any other service provider. 

2. Opptra and / or its affiliates may share such Data during normal business operations, such as providing services you have subscribed to, and any activity related to these services such as collection of fees, enrolling you for additional services and benefits.  

3. It may become necessary for Opptra to disclose your Personal Data to its agents and contractors during normal business operations for the above referred purpose. However, these parties would be required to use the Data obtained from Opptra strictly in accordance with the purposes specified in this Privacy Policy. 

4. The third parties with whom your Personal Data is shared shall be required to only process such Personal Data in accordance with express instructions and as necessary to perform services for purposes set forth in this Privacy Policy. Such third parties shall also be required to safeguard the security and confidentiality of the Personal Data they access and process by implementing appropriate technical and security measures and confidentiality obligations. 

5. Opptra shall undertake all Reasonable Security Practices and Procedures and implement appropriate technical and organisational measures in accordance with Applicable Laws to secure the confidentiality, integrity, and availability of your Personal Data maintained by us, as well as third parties to whom it discloses such information pursuant to our express instructions towards providing you with the Services.

6. Opptra may be required to disclose your Personal Data to the statutory authorities or other persons in connection with any legal process that may be initiated by such authorities in accordance with Applicable Laws, or for any risk mitigations purposes undertaken by us. However, this does not include selling or otherwise disclosing your Personal Data for commercial purposes in violation of this Privacy Policy and Applicable Laws.

7. It should be noted that our affiliates and / or Partners may have privacy practices and policies that differ from those of Opptra. The use of your Personal Data will be governed by their respective privacy statements when you provide your Data and other information on their websites and / or applications.

8. Opptra reserves the right to communicate your Personal Data to any third party that makes a legally compliant request for disclosure.

9. In the event we buy or acquire other businesses from third parties, or we undertake any corporate debt restructuring or sell our business (or any verticals thereunder, by whatever name called) to a third party, or otherwise take actions to develop and grow our business, the Personal Data collected by us may be shared with third parties and / or statutory authorities in such instances, for the purposes specified in this Privacy Policy.

10. From time to time, we may make available on the Platform some campaigns / programmes / promotional events, that are sponsored or offered by third parties. You agree to receiving such sponsored content from time to time on the Platform. If you sign up for the same on the Platform, your Personal Data may also be collected by such third parties independently. We recommend that you read their privacy policies to understand how such third parties may handle your Personal Data.

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8. HOW LONG DO WE RETAIN YOUR PERSONAL DATA?

1. Opptra shall not retain any Personal Data longer than permissible under Applicable Laws. 

2. Your Personal Data may however be retained for a longer period where we need such information for legal or regulatory purposes which may include but not be limited to filing / addressing complaints, responding to any queries raised by any of our regulators / customers / governmental bodies and defending any legal claims. 

3. You must note that different data types and purposes necessitate varying retention periods and therefore the length of retention of their Personal Data (depending on the nature thereof) may vary significantly.

4. In some circumstances, Opptra may anonymise your Personal Data so that it is no longer capable of identifying you, either directly or indirectly, through such information. Opptra may retain, use and process such irreversibly anonymised Data for such period as it deems necessary. 

5. Upon your written request sent at the email IDs set out below, to the effect of requesting us to delete all your Personal Data, we will undertake all reasonable actions, legally mandated to us as per Applicable Laws, to delete and no longer store your Personal Data with us. However, such request may not be possible to fulfill in case such Personal Data is required to be retained by Applicable Law, or if necessary for a purpose specified in our contract with you, including the Terms and Conditions, as well as this Privacy Policy. 

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9. HOW DO WE SAFEGUARD YOUR PERSONAL DATA?

1. We implement appropriate technical and organisational measures as well as Reasonable Security Safeguards and Practices to safeguard your Personal Data and protect it against a personal data breach. If you suspect any misuse or loss or unauthorised access to your Personal Data, please let us know immediately by contacting us by e-mail on the IDs set out below.

2. We require the recipients of Personal Data shared under this Privacy Policy such as entities processing Personal Data on our behalf to safeguard the security and confidentiality of such Personal Data to which they receive access, by implementing appropriate technical and organisational security measures, as well as Reasonable Security Practices and Procedures in accordance with Applicable Laws. 

3. In addition, access to your Personal Data is limited to only those Representatives, agents, contractors and other third parties on a need-to-know basis, who may only process your Personal Data on Opptra’s instructions subject to a duty of confidentiality.

4. Opptra will protect your Personal Data against unauthorised use, dissemination, or publication in the same manner in which Opptra would protect its confidential information of like nature, all in compliance with Applicable Laws.

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10. WHAT ARE YOUR PRIVACY RIGHTS AND HOW CAN YOU EXERCISE THEM?

1. We provide you with the right to access and review your Personal Data, request for the correction, updation or completion of your Personal Data, or the erasure of your Personal Data, in accordance with Applicable Laws. Any correction or deletion of Personal Data will be duly reflected in each of the in-app third-party services and Partners Modules within our Platform. However, please note that any correction or deletion of your Personal Data may affect the Services provided to you by us or our Partners on the Platform. In order to protect your privacy, we will take reasonable steps to verify your identity before granting access to your Personal Data. 

2. You can choose not to receive marketing emails from us by clicking on the unsubscribe link in any marketing email.

3. You can make choices about our collection and use of your Personal Data including by requesting to access, correct, complete or erase your Personal Data on our Platform. You also have the right to seek the following information:

• a summary of personal data which is being processed by us and the processing activities undertaken by us with respect to such Personal Data; 

• the identities of all other entities with whom the Personal Data has been shared by us, along with a description of the Personal Data so shared; and

•  any other information as prescribed under Applicable Laws. 

4. You may also nominate, any other individual, who shall, in the event of your death or incapacity, exercise your rights in accordance with Applicable Laws. This right may be exercised by contacting us at nodalofficer@opptra.com.

5. If you have any concerns or grievances, you may write to our grievance redressal officer, identified at the end of this Privacy Policy.

6. You also have the right to file complaints to the relevant regulatory authorities in connection with the protection of your Personal Data as notified on our platform from time to time.

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11. YOUR REPRESENTATIONS TO US.

1. You represent to us that you are 18 years of age or above and are in contracting capacity to access our platform and share your Personal Data with us.

2. In circumstances where you provide us with Personal Data relating to other individuals on their behalf (such as Personal Data relating to your family members, spouse, friends, or other parties), you represent and warrant that you have obtained such individual’s consent for, and hereby consent on behalf of such individual to, the collection, use, disclosure and processing of their Personal Data by us. You confirm that the Personal Data that you provide to us of other individuals mentioned in this clause are complete, accurate and consistent.

3. You also represent that any Personal Data that you share with us, relating to your nominees or co-applicants towards availing our Services, would be provided to us voluntarily by such persons, for the purposes specified in this Privacy Policy. You confirm that you have obtained the requisite consent of such person(s) for sharing their Personal Data with us. You also confirm that the Personal Data that you provide to us of other individuals mentioned in this clause are complete, accurate and consistent.

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12. CHANGES TO OUR PRIVACY POLICY.

1. We may change our Privacy Policy from time to time and post the updated version of the same on our Platform. We will notify you and obtain your explicit consent for any material changes made to this Privacy Policy. We may e-mail periodic reminders of our terms, unless you have instructed us not to. 

2. We encourage you to visit these terms frequently to stay informed about how we use your Personal Data.

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13. INCORPORATION OF PRIVACY POLICY TO THE TERMS AND CONDITIONS

This Privacy Policy is also incorporated into the Terms and other specific terms of this Platform.

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14. ASSIGNMENT / NOVATION

You understand and acknowledge that Opptra may assign / novate its rights and responsibilities under this Privacy Policy to any third party (including pursuant to any corporate restructuring or similar exercises). You confirm that you have no objection to such assignment / novation by Opptra, and you agree that your obligations under this Privacy Policy would be binding on such third party. We assure you that irrespective of any change in the contracting party, your rights and our obligations under this Privacy Policy will remain unaffected/unchanged. In case of such an assignment, the assignee will maintain the same or better level of protection as is required under this Privacy Policy. You accordingly confirm that you have no objection to such assignment / novation by Opptra. You also understand and agree that in case of an assignment / novation, your obligations under this Privacy Policy may be owed/transferred to such assignee / third party.

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15. GOVERNING LAW AND JURISDICTION

This Privacy Policy shall be governed by the laws of India and the courts of Bangalore (India) shall have the exclusive jurisdiction to try any dispute arising thereof.

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16. SEVERABILITY

If any court or competent authority finds that any provision of this Privacy Policy (or part of any provision hereof) is invalid, illegal or unenforceable, such provision or part thereof (as the case may be) shall, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this Privacy Policy shall not be affected and shall continue to apply.

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17. HANDLING PRIVACY CONCERNS

If you have any questions about this Privacy Policy or if you believe that your Personal Data or Information is not handled in accordance with the Applicable Laws or this document, then you may contact us as at nodalofficer@opptra.com.

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Details of our Nodal Grievance Redressal Officers are as under:

Name: Suresh Saini

Email: nodalofficer@opptra.com