INDIAN TRADE CREDIT INFORMATION BUSINESS (ITCIB – a trademark of LEGAL EMPOWERMENT INDIA LLP) PRIVACY POLICY

The contents of this privacy policy (“Privacy Policy”) along with the general terms and conditions (“General TNC”) available at http://www.itcib.com/terms-and-conditions are applicable to all hyperlinks under http://www.itcib.com(this “Website”) and http://www.itcib.com. You hereby acknowledge of having read and accepted the same by use or access of this Website. We reserve the right to modify this privacy policy at any time, so please review it frequently. If we make material changes to this privacy policy, we will notify the by means of a notice on our home page. By continuing to use our service after notice of changes have been published on the Website, you are consenting to the changes. The capitalized terms used herein and not defined shall have the meaning set out in the General Terms and Conditions.

ITCIB’s Privacy Statement

This privacy statement covers the website. By accessing, using or registering with website, you accept and agree to ITCIB’s Privacy Policy.

Our Privacy Policy explains:

• What information we collect and why we collect it.
• How we use that information.
• Safety measures and procedures.

We respect your privacy and recognize the need to protect the personally identifiable information (any information by which you can be identified, such as name, physical and email address, citizenship, and phone number) which and if you share with us. We would like to assure you that we follow appropriate and necessary standards when it comes to protecting your privacy on this Website. If you have any queries, kindly contact us at info@itcib.com.

INFORMATION WE COLLECT

By using or accessing this Website, you agree to the collection and use of your data such as, inter alia, your name, email address, gender, age, PIN code, telephone or mobile number, the credit card or debit card details (as maybe applicable), etc., and / or your occupation, interests, and the like (hereinafter referred as “personal information” or “information” or “data”), by us in the manner provided in this Privacy Policy.

In general, you can visit this Website without telling us who you are or revealing any personal information about yourself. We track the Internet Protocol address from which people visit us/ our Websites and analyze this data for trends and statistics independently or as per our agreement with our third party service providers, but the individual user remains anonymous. We use the information we automatically receive from your web browser to see which pages you visit within our Website, which Website you visited before coming to ours, and where you go after you leave. We develop statistics that are helpful to understand how our visitors can use this Website. We use this information in the aggregate to measure the use of our Website and to administer and improve our Website. This statistical data is interpreted by us in its continuing effort to present the Website content that visitors are seeking in a format they find most helpful.

ITCIB collects the following general types of information about you when you visit the Websites: personal information, demographic information, behavioural information and indirect information. Personal information is information that can be used to identify you, or any other individual to whom the information may relate, personally. ITCIB a part of (Legal Empowerment India LLP) does not collect personal information unless you choose to provide it to ITCIB a part of (Legal Empowerment India LLP). Some examples of personal information that ITCIB a part of (Legal Empowerment India LLP) collects in some areas of the Website, depending on the Products and Services you use and local law, are: name, address, identity and address proof, email address, number, payment details, contact information, billing information, loan account numbers, information about third parties, such as references, mentors or contacts etc., that the you provide to ITCIB a part of (Legal Empowerment India LLP) if it pertains to you or if you has their express written consent to do so. Demographic information is information that is not unique to you in the sense that it refers to selected population characteristics, such as ZIP code or postal code, age, preferences, gender, occupation, career history, interests and favourites etc. ITCIB a part of (Legal Empowerment India LLP) also collects behavioral information regarding how you use the Website and mobile applications, the areas of Website that you visit, what services you accesses, and information about your computer hardware and software including your IP address, device information (such as your hardware model, operating system version, unique device identifiers, and mobile network information including phone number), geolocation, log information (device event information such as crashes, system activity, hardware settings, browser type, browser language, the date and time of your request and referral URL), browser and operating system type, domain names, access times and referring website addresses etc. This information is necessary for analyzing the use of resources, troubleshooting problems, preventing fraud, and improving our Products and Services and providing additional services. In addition, ITCIB a part of (Legal Empowerment India LLP) may collect indirect information about you when you use certain third party services on our web site. For example, if you provide a title of ‘Mrs.’ we will assume you are female.

PURPOSE OF COLLECTION

The information we collect and analyze is used to improve our service to you. You agree that we or our third party service providers collect your IP address or other unique identifier. At times, we also use these identifiers to collect information regarding the frequency with which our guests visit various parts of our sites. We, either through ourselves or our partners, affiliates, group companies, advisors, agents etc. (collectively referred to as the “Affiliates”) may combine your IP address with other personally identifiable information for marketing and for market research purposes, including internal demographic studies, so we can optimize our products and services and customize this Website for you.

Personalization. We may combine your credit information or other information collected through cookies, web beacons and other technical methods with personally identifiable information in order to understand and improve your online experiences and to determine what products, promotions and services you prefer or are likely to be of interest to you. There are times when we may collect personal information from you such as name, physical and email address, phone number etc. for the purpose of enabling you to avail the services offered by ITCIB a part of (Legal Empowerment India LLP) and its Affiliates and to enable ITCIB a part of (Legal Empowerment India LLP) and its Affiliates to conduct its activities in accordance with the applicable laws. We will also strive to use any and all information provided by you to enhance the utility of the Website in the future for you. If you choose not to provide the information we request, you can still visit this Website, but you may be unable to access certain options, offers and services.

Provision of Services and other Purposes. ITCIB a part of (Legal Empowerment India LLP) may share your information with third parties (including not limited to its Affiliates) who help ITCIB a part of (Legal Empowerment India LLP) in the delivery of its products and services to you. ITCIB a part of (Legal Empowerment India LLP) discloses information to companies and individuals it employs to perform functions on its behalf. Examples include hosting our web servers, analysing data, providing marketing assistance, processing card payments, providing customer service etc. ITCIB a part of (Legal Empowerment India LLP) may disclose such information to third parties if you consent to such disclosures. If you expressly indicate that you would like to receive information about the opportunities, products or services of third parties, ITCIB a part of (Legal Empowerment India LLP) would supply your contact information to select third parties (including not limited to its Affiliates), Members, or others for the purpose of sending you e-mail or otherwise communicating with you. Such aggregated data does not identify users of the Website or the Consumers individually, and may be made available to various market intermediaries. ITCIB a part of (Legal Empowerment India LLP) may use the information it collects for the Products and Services, to provide, maintain, protect and improve the Products and Services, to develop new ones, and to protect ITCIB a part of (Legal Empowerment India LLP) and our other Consumers. ITCIB a part of (Legal Empowerment India LLP) also uses this information to offer you tailored content – like giving you more relevant search results and advertisements. ITCIB a part of (Legal Empowerment India LLP) may use the email address and other details to inform you about ITCIB’s Products and Services, such as letting you know about upcoming changes or improvements etc.

You agree that we or any of our Affiliates may contact you from time to time to provide the offers/ information of such products/ services that we believe may benefit you.

ITCIB a part of (Legal Empowerment India LLP) may disclose and transfer such information to a third party who acquires any or all of ITCIB’s business units, whether such acquisition is by way of merger, consolidation or purchase of all or a substantial portion of our assets or by any other permitted way.

DISCLOSURE OF INFORMATION

We may use personal information shared by you or Consumer during the process of registration or otherwise for verification purposes and the customer agrees and allows ITCIB a part of (Legal Empowerment India LLP) to share such information with third parties solely for verification purposes. We may also use the information you provide to update our consumer credit database. We may provide information so collected from you to government authorities or any court of law as per the applicable laws of India or as per our agreement with our third party service providers or any third party. However, such third party receiving your personal information shall not disclose it further, save and except if required under the any law. It is possible that we may need to disclose personal information when required by law, such as responses to civil or criminal subpoenas, or other requests by law enforcement personnel. We will disclose such information wherein we have a good faith belief that it is necessary to comply with a court order, ongoing judicial proceeding, subpoena, or other legal process or request to ITCIB a part of (Legal Empowerment India LLP) brought in any country throughout the world, or to exercise our legal rights or defend against legal claims.

LINK TO THIRD PARTY SITES

We may link to the websites of other third parties. These third-party websites may collect personal information about you on those Websites, and our Privacy Policy does not extend to these external websites and third parties. Please refer directly to these third parties and web sites regarding their privacy policies. Links to third party sites do not imply endorsement or approval of the sites by ITCIB a part of (Legal Empowerment India LLP).

HOW WE COLLECT INFORMATION

Some of our web pages including our third party service providers store and use "cookies" so that we can better serve you with customized information when you return to our site. Cookies are identifiers which a web site can send to your browser to keep on your computer to facilitate your next visit to our site. You can set your browser to notify you when you are sent a cookie, giving you the option to decide whether or not to accept it.

Cookies, web beacons and other technical methods may involve the transmission of information either directly to us or to another party authorised by us to collect information on our behalf. The information from use of these technical methods may be collected in a form that identifies you personally. You may get cookies from our advertisers. We do not control these cookies, and once you have clicked on the advertisement and left our Website, our Privacy Policy no longer applies. We also use these technical methods in HTML e-mails that we send you for a number of purposes including: to determine whether you have opened or forwarded those e-mails and/or clicked on links in those e-mails; to customize the display of the banner advertisements and other messages after you have closed an email; and to determine whether you have made an enquiry or purchase in response to a particular email.

APPLICATION

This privacy policy does not apply to services offered by other companies or individuals, including products or sites that may be displayed to you in search results, sites that may include ITCIB a part of (Legal Empowerment India LLP) services, or other sites linked from our services. This privacy policy does not cover the information practices of other companies and organizations who advertise our services, and who may use cookies, pixel tags and other technologies to serve and offer relevant ads.

SAFETY MEASURES AND PROCEDURES

We will not sell, trade or disclose to third parties any information derived from the registration for, or use of, any online service (including names and addresses) without your consent unless required under applicable law save and except to any of our Members and/or Affiliates for helping you in receiving loans or other purposes in relation to the businesses of our Members and Affiliates and as may be required by legal process or in the case of imminent physical harm to any person. Further, ITCIB a part of (Legal Empowerment India LLP) will allow its Members, Affiliates to access the information for purposes of confirming your registration and providing you with benefits you are entitled to.

Upon withdrawal of consent by you, personal information shared by you or any Consumer will not be used/retained by ITCIB a part of (Legal Empowerment India LLP) for any purposes. You may withdraw the consent by way of unsubscribing from the services offered by ITCIB a part of (Legal Empowerment India LLP) or by sending a written notice of withdrawal to ITCIB a part of (Legal Empowerment India LLP). We will take appropriate steps to protect the information you share with us. We have implemented technology and security features and strict policy guidelines to safeguard the privacy of your personally identifiable information from unauthorized access and improper use or disclosure. We will continue to enhance our security procedures as new technology becomes available. Because of the nature of the Internet, we may transmit the information collected from you to another country, but among our Affiliates and Members in the course of provision of our Products and Services.

ITCIB a part of (Legal Empowerment India LLP) or its Affiliates shall not publish the personal information provided by you without your consent save and except as stated in this Privacy Policy and/or in the General TNC CHANGES If our privacy policy changes in the future, it will be posted here and a new effective date will be shown. You should access our privacy policy regularly to ensure you understand our current policies. ITCIB a part of (Legal Empowerment India LLP) will attempt to respond to all reasonable concerns or inquiries on a best efforts basis within a reasonable period of time. ITCIB a part of (Legal Empowerment India LLP) may provide notifications, whether such notifications are required by law or are for marketing or other business related purposes, to you via email notice, written or hard copy notice (including via fax), or through posting of such notice on the Website. ITCIB a part of (Legal Empowerment India LLP) reserves the right to determine the form and means of providing notifications to you, provided that you may opt out of certain means of notification as described herein. ITCIB a part of (Legal Empowerment India LLP) is not responsible for any automatic filtering that you or your network provider may apply to email notifications we send to the email address you provide us. We may choose to use testimonials/ feedback provided by you via email or on the Website for marketing purposes. By making any suggestions, feedback or comments on our Website, for our people and services, you have agreed to allow us to publish the same for marketing purposes by ITCIB a part of (Legal Empowerment India LLP).

GOOGLE ADWORDS REMARKETING

Explanation:

This website (www.itcib.com) uses Google Adwords Remarketing services to help analyze consumer behavior. Whenever consumer visits our website, google system (Adwords Remarketing) would drop cookies (a packet of small data text files with id tags) on consumer’s system. Once consumer leaves our website and goes to some other website which have content or website relevant to our website (like Banks), Google would display our ads on those websites based on cookies which were dropped earlier by Google (while consumer was on ITCIB’s website). It could mean that we advertise to previous visitors who haven’t completed a task on our site, for example using the contact form to make an enquiry. Any data collected will be used in accordance with our own privacy policy and Google’s privacy policy. Privacy of Collected Data:

We will never use the statistical analytics tool to track or to collect any Personally Identifiable Information (PII) of visitors to our site. ITCIB a part of (Legal Empowerment India LLP) will not link, or seek to link, an IP address with the identity of a computer user. We will not associate any data gathered from this site with any Personally Identifiable Information from any source. Information to Google Adwords privacy policy can be found at the following link- https://support.google.com/adwordspolicy/answer/143465?hl=en Information About Google Remarketing: This website uses Google Remarketing to advertise online using text or image ads on the Google Display Network. Remarketing is a feature that lets us reach people who have previously visited our site, and show them relevant ads when they visit other sites on the Google Display Network.

Web site Terms And Conditions:

In order to undertake Remarketing, Google has instructed to include certain terms in our website terms and conditions such as - We utilize Google Analytics features which are implemented based on Display Advertising (e.g., Remarketing, Google Display Network Impression Reporting, the DoubleClick Campaign Manager Integration, or Google Analytics Demographics and Interest Reporting). ITCIB a part of (Legal Empowerment India LLP) uses Remarketing with Google Analytics to advertise online. Third-party vendors, including Google may show ITCIB a part of (Legal Empowerment India LLP) ads on sites across the Internet. ITCIB a part of (Legal Empowerment India LLP) and third-party vendors, including Google, use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimize, and serve ads based on website visitors past visits to our website.

ITCIB a part of (Legal Empowerment India LLP) and third-party vendors, including Google, use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) together to report how your ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to visits to ITCIB a part of (Legal Empowerment India LLP) site.

ITCIB a part of (Legal Empowerment India LLP) would use data from Google's Interest-based advertising or 3rd-party audience data (such as age, gender, and interests) with Google Analytics. In order to opt out of Google Analytics for Display Advertising / Remarketing consumer can access Google Analytics' Google Analytics Opt-out Browser Add-on at following link https://tools.google.com/dlpage/gaoptout/. Consumers can customize Google Display Network ads by using the Ads settings for their respective google accounts By accessing the Website, providing personal information for inclusion in ITCIB’s database, or by using the Solution, Products and Services, you hereby expressly and unconditionally consent to your information being stored, used, altered, modified, compiled, dis-assembled, shared and disseminated as described here, by ITCIB a part of (Legal Empowerment India LLP) and its Affiliates.