Axio Site/Website:

During the use of the Website, axio may collect and process such information from the Users, including but not limited to the below mentioned:

• Information that the Users provide to axio by filling in forms on the Website. This includes contact information such as name, email address, mailing address, phone number, financial information, if any, unique identifiers such as user name, account number, password and preferences information such as favourites lists and transaction history and any Information provided by the User at the time of registration for the product/service offered by Axio.

• Information that the Users provide when the Users write directly to axio (including by way of e-mail) or other electronic communication.

• Information that the Users provide to axio over telephone. axio may make and keep a record of the information shared by the Users with axio;

• Information that the Users provide to axio by completing surveys;

• Information relating to logs is automatically reported by the User’s browser each time the User accesses a web page. When the User uses the Website, axio’s servers automatically record certain information that the User’s web browser sends whenever the User visits any website. These server logs may include information such as the User’s web request, Internet Protocol (IP) address, browser type, referring/ exit pages and URLs, number of clicks, domain names, landing pages, pages viewed, and other such information. axio uses this information, which does not identify Users, to analyse trends, to administer the Website, to track Users’ movements around the Website and to gather demographic information about the User base as a whole. axio does not link this automatically-collected data to personally identifiable information.

• Information which is in the nature of personal / sensitive personal information of the User provided to axio

• Information which may be collected from the authorized representatives, agents, group companies of axio from user’s browser, mobile application/devices

This policy is applicable to all information collected from the Users of axio including but not limited to the above mentioned information.

Axio App:

The information about the User as collected by the app falls under (a) information supplied by users and (b) information automatically tracked while using a mobile device having axio App Services enabled (collectively referred to as “information” or “Information”).

(a)Information supplied by Users:

To avail certain services on the axio App, users are required to provide some personally identifiable information for the registration process which may include a) your name, b) email address, c) phone number, d) access to your phone’s SMS inbox records d) debit card, credit card, bank details, e) KYC details f) PAN g) residential address etc. and any other such information as required. The Information as supplied by the users enables us to improve axio App Services and provide the most user-friendly experience. All required information is service dependent and the Company may use the above said user Information to maintain, protect, and improve the axio App Services and for developing new services.

Axio App takes limited access (usually one-time or as provided by the User) to services like Camera, and Microphone, for specific use cases in the app like uploading of bills, on-boarding or KYC requirements. Such access is only taken with the explicit consent of the User, and the specific use of the data is clearly communicated to the User. Location data taken for on-boarding or KYC is taken for limited period, however the User may explicitly provide Location data for longer periods for specific use cases like Expense Tracking and categorization, which is explicitly communicated to the User.

Any reviews, comments, messages, blogs posted/uploaded/conveyed/communicated by users on the public sections of the Site or an Application Store (like the App Store or Play Store) becomes published content and is not considered personally identifiable information subject to this Privacy Policy.

In case the User chooses to decline to submit personally identifiable information on the axio App/Site, Axio may not be able to provide certain services on the App/Site to the User. Axip will make reasonable efforts to notify the User of the same at the appropriate time. In any case, Axio will not be liable and or responsible for the denial of certain services to the User or lack of providing the necessary personal information.

(b)Information tracked with consent and information automatically tracked while using app:

SMS Inbox Information: The axio App also collects partial payment data and other information arising out of transactions made from cards, banks or while using other services through SMSes, after obtaining the User’s specific consent to allow the App to access the User’s SMS inbox. The axio App accesses business messages that originate from alphanumeric senders. No personal SMSes or OTPs are backed up. Any SMSes reported by users are also used to train our Spam filter algorithm. Users can automatically delete OTPs with a setting to delete OTPs older than 24 hrs in the app.

The collection of such information is only limited to the extent that such data is available in the relevant messages. axio may also record the identity of the product or service and the price or fee paid or payable in respect thereof.

Demographic and Related Information: We may reference other sources of demographic and other information in order to provide Users you with more targeted communications and promotions. We use Google Analytics, among others, to track user behaviour on our website.

Google Analytics specifically has been enabled to support display advertising to help us gain an understanding of our users’ Demographics and Interests. The reports are anonymous and cannot be associated with any individual personally identifiable information that you may have shared with us. You can opt-out of Google Analytics for Display Advertising and customize Google Display Network ads using the Ads Settings options provided by Google.

By using the platforms of the Company and/or by providing the above information to axio, the user consents to the collection, sharing, disclosure and usage of the information by the Company in accordance with this Privacy policy, other than for specific information that is collected and used based on user’s explicit consent as outlined in this privacy policy.

axio Stakeholders including Employees, Contractors and Suppliers may also provide personal information through various channels including but not limited to documentation, communication, electronic communication, contracts, agreements, and use of Axio products and Services. This policy is applicable to all such information collected by Axio.

Access to personal information is strictly restricted and shared in accordance with certain specific internal procedures and safeguards that govern access. Certain features of the Website or App may be available for use without any need to provide details. Other features of the Website may require Users to provide details including but not limited to the User’s name, address, mobile number, email address, PAN No., employment & income details.

axio never will sell or rent personal information of its Users and stakeholders to anyone, at any time, for any reason. axio may use the User’s personal information in the following ways, viz:

• Monitor, improve and administer the Website and improve the quality of services;

• Analyse how the Website or App is used, diagnose service or technical problems, maintain security;

• Remember information to help the User effectively access the Website or App;

• Monitor aggregate metrics such as total number of views, visitors, traffic and demographic patterns;

• To confirm the User’s identity in order to determine its eligibility to use the Website or App and avail of the services;

• To notify the User about changes to the Website or App;

• To enable axio to comply with its legal and regulatory obligations;

• To help the User apply for certain products and services.

• For the purpose of sending administrative notices, service related alerts and other similar communication with a view to optimising the efficiency of the Website or App.

• Doing market research, troubleshooting, protection against error, project planning, fraud and other criminal activity.

• To reinforce axio’s Terms of Use.

• For establishing Identification and to fulfill other KYC requirements before beginning the account based transaction

• To provide users with the right kind of products and services

• To fulfill our internal checks and other risk parameters of the Company.

• To safeguard the interest of the Business and to ensure compliance with laws including credit reporting.

• To maintain effective communication on the service availed by the Customer including but not limited to the transaction information, updates/changes to the product, assistance for the Customers etc.

• For marketing purpose, especially to promote the services of the Company and to notify about the new product/service offerings for the Customer. We may also use the user’s phone number, email address or other personally identifiable information to send commercial or marketing messages without the user’s consent [with an option to subscribe/unsubscribe (where feasible)]. We may, however, use the user’s email address and phone number without further consent for non-marketing or administrative purposes (such as notifying you of major changes, for customer service purposes, providing information about updates to axio App Services, billing, etc.).

• Wwe may contact the Users from time to time about updation of personal information to provide such features that we believe may benefit/interest the users.

• Axio also present information related to user spends, patterns and user data tracked by the company only in the form of aggregated statistics on data such as user spends by category, date, time, bank balances, etc. within our app/site or to our partners.

• No personally identifiable data of an individual user such as name, phone number, email address, spends data, card details etc. would be shared with any other User and/or third party – unless explicitly approved by the concerned individual user in order to avail of certain services unless as required to fulfil Axio’s legal and regulatory obligations.

axio pledges that it shall not sell or rent Users’ or stakeholders’ personal information to anyone. axio will protect every bit of the Users’ business or personal information and maintain the confidentiality of the same. With this seal of trust, axio makes its services available to the Users for assessment and analysis that include spend analysis, money management, credit and behaviour scoring, market and product analysis.

Axio may share your personal information with its group companies in relation to offering of products and services to the User, or for the purposes of the engagement with its stakeholders. Otherwise, axio guarantees that it is going to keep all information confidential except in the following cases:

• axio may disclose Users’ information to governmental and other statutory bodies who have appropriate authorisation to access the same for any specific legal purposes.

• axio may disclose Users’ information if it is under a duty to do so in order to comply with any legal obligation, or in order to enforce or apply the Terms of Use (displayed on the Website), or to protect the rights, property or safety of axio, its Users or others. This includes exchanging information with other companies / agencies that work for fraud prevention and credit reference.

• axio may disclose Users’ information to its agents under a strict code of confidentiality, where such sharing is required or permitted as per statutory or regulatory requirements.

• axio may disclose Users’ information to such third parties to whom it transfers its rights and duties under the customer agreement entered into with the Users, where such sharing is required or permitted as per statutory or regulatory requirements. In such an event, the said third parties’ use of the information will be subject to such confidentiality obligations as contained in this Policy.

• axio may disclose Users’ information to any member of its related or group companies including its subsidiaries, its ultimate holding company and its subsidiaries, as the case may be.

• In the event that axio sells or buys any business or assets, it may disclose the Users’ information to the prospective seller or buyer of such business or assets. User, email and visitor information is generally one of the transferred business assets in these types of transactions. axio may also transfer or assign such information in the course of corporate divestitures, mergers or dissolution.

axio shall ensure that in case of disclosure of whole or part of the User’s information to a service provider or agent, within or outside India, the same shall be bound by obligations of confidentiality at least as strict as axio’s obligations under this Privacy Policy and the information shall be accorded the same level of protection as provided by axio under the terms of this Privacy Policy. axio may store the User’s information in locations outside the direct control of axio (for instance, on servers or databases co-located with hosting providers).

The link to third parties can be found here

axio takes the security of its User’s and Stakeholders’ information very seriously. axio protects the User’s information at rest and in flight using bank-level data security: atleast 128 bit-encryption and Transport Layer Security (SSL where applicable) This creates an encrypted connection between the User’s browser or App and Axio’s servers. All information remains encrypted at all times. If the User allows axio to see its banking information online rather than in paper form, it is on a read-only basis. axio does not have access to change, edit, or modify bank account information in any manner whatsoever. axio employees cannot view the User’s banking username and passwords, and the same is securely stored in separate encrypted areas with its financial services providers. All information gathered and provided to Axio on the Website and axio App is encrypted and securely stored within the controlled databases on its secure servers within India. Access to the servers is password-protected and is strictly limited.

If enabled from the app, we take a backup of User’s data on the axio App on our Cloud database. This is done for the purpose of enabling users to get their data back in case their phone’s data becomes unusable, if the phone is lost, or the user moves to a new phone device.
We also use this backup to provide useful insights and information related to their spends such as weekly spends in a month, insights related to spend behaviour, etc., and to provide information related to user spends, patterns and user data in the form of aggregated and anonymised statistics on data such as user spends by category, date, time, bank balances, etc.

axio does not collect or store any biometric data in our systems or servers, and all limited and specific use of biometric data in any Axio product is as per regulations and extant statutory guidelines only.

axio uses commercially reasonable safeguards to preserve the integrity and security of the Users’ information against loss, theft, unauthorised access, disclosure, reproduction, use or amendment.

The information that is collected from the Users may be transferred to, and stored at, a destination inside India. By submitting information on the Website, the Users agree to this transfer, storing and/ or processing. axio will take such steps as it considers reasonably necessary to ensure that the Users’ information is treated securely and in accordance with the Policy.

In using the Website or App, the Users accept the inherent security implications of data transmission over the internet. Therefore, the use of the App or Website will be at the own risk of the users.

axio assumes no liability for any disclosure of information due to errors in transmission, unauthorised third party access or other acts of third parties, or acts or omissions beyond its reasonable control and the User agrees not to hold axio responsible for any breach of security unless such breach has been caused as a direct result of gross negligence or wilful default by axio.

In the event axio becomes aware of any breach of the security of the Users’ information, it will promptly notify the users and take appropriate action to the best of its ability to remedy such a breach.

axio collects certain information from the User’s browser using small data files called “cookies.” axio uses session ID cookies to confirm that customers are logged in. This type of cookie helps axio recognize a customer if he or she visits multiple pages on the Website during the same session, so that separate passwords are not required to access each page. These cookies terminate once the customer closes the browser. By default, axio uses a persistent cookie that stores customer login ID (but not password) to make it easier for the customer to login when returning to the Website. axio encodes its cookies so that only axio can interpret the information stored in them. The User may remove or block this cookie using the User’s browser settings to disable the feature.

axio also stores transaction history. axio may collect additional information in ways not specifically described herein. For example, axio may track information related to interactions with customer service or responses from surveys or other feedback tools. axio uses this information to continually improve the service provided to the customers.

axio’s Privacy Policy does not cover the use of cookies by its partners and affiliates. axio does not have access or control over these cookies. axio’s partners and affiliates may use session ID cookies to provide a custom user experience and to track the success of axio’s partnership with them.

The web pages of the Website contain electronic images known as “web beacons” (sometimes called single-pixel gifs) and are used along with cookies to compile aggregated statistics to analyse how the Website is used. Web beacons may also be used in some of axio’s emails to so as to know which emails and links recipients have opened, allowing it to gauge the effectiveness of its customer communications and marketing campaigns.

If the User wishes to introduce axio Website or axio App to any other person/entity, the User will be asked to provide such person/entity’s name and email address or any other contact details. axio will automatically send such person/entity an email or invite in any other form inviting the other entity to visit the Website or App or other axio Product offering as applicable. axio stores this information for the purpose of sending this invite and keeping a record of the number of persons/entities so referred by the Users. axio may send additional emails or information to the said person/entity in connection with services offered by axio. Such person/entity may contact axio at [email protected] to request that this information be removed from axio’s database.

The Website includes links to other websites whose privacy practices may differ from those of axio formerly Capital Float. The inclusion of a link does not imply any endorsement by axio of the third party website, the website’s provider, or the information on the third party website. If the Users submit personal information to any of those websites, such information is governed by the privacy policies of such third party websites and axio disclaims all responsibility or liability with respect to these policies or the websites. The Users are encouraged to carefully read the privacy policy of any website that they visit.

The Website includes Social Media Features, such as the Facebook “Like” button and Widgets, or interactive mini-programs that run on the Website. These features may collect the Users’ IP address, which page the Users are visiting on the Website, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on the Website. The Users’ interactions with these features are governed by the privacy policy of the company providing it.

When Users use the Website or axio App, we make efforts in good faith to provide Users, as and when requested by Users, with access to their respective personal information, and shall further ensure that any personal information or sensitive personal data or information found to be inaccurate or deficient shall be corrected or amended as feasible, subject to any requirement for such personal information or sensitive personal data or information to be retained by law or for legitimate business purposes.

We ask individual users to identify themselves and the information requested to be accessed, corrected or removed before processing such requests, and we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, or would be extremely impractical, or for which access is not otherwise required.

In any case, where we provide information access and correction, we perform this service free of charge, except if doing so would require a disproportionate effort. Because of the way we maintain certain services, after Users delete your information, residual copies may take a period of time before they are deleted from our active servers and may remain in our backup systems.

To opt out of email correspondence from axio (formerly known as Capital Float) or make a change to (or delete) the User information stored in axio’s records, Users may write to us and Axio will respond to the User’s request within 30 days.

All User information will be retained for as long as the User account is active or as needed to provide services to the User, and Axio may retain User information for a longer period unless specifically requested by the user to delete the information as detailed below. This also enables returning users to take advantage of backup of data and restore features where applicable.

If the User wishes to cancel its account or requests that axio formerly Capital Float no longer uses its information to provide services, the User may contact axio at [email protected] . Axio will retain and use User information as necessary to comply with its legal obligations, resolve disputes, and enforce its agreements or for other business purposes.

Specific requirements as per Prevention of Money Laundering Amendment Act, 2002 (Prevention of Money laundering Act, 2002 – Obligations of NBFCs in terms of Rules notified thereunder dated November 13, 2009, the NBFC should maintain for at least ten years the following:

• Transaction between the NBFC and the client, all necessary records of transactions, so as to provide, evidence for prosecution of persons involved in criminal activity.

• Records pertaining to the identification of the customers and their address obtained while opening the account and during the course of business relationship.

• All complex, unusual large transactions and all unusual patterns of transactions including STR, which have no apparent economic or visible lawful purpose. Such records and related documents should be made available to help auditors to scrutinize the transactions and also to Reserve Bank/other relevant authorities.

• Adherence to obligations under Rule 3 of the Prevention of Money Laundering (Maintenance of Records)Rules, 2005 – amended from time to time.

In the event Axio, the same will be updated on the Website. In case of any material changes to the Policy, the Users will be notified by email (sent to the email address specified in the User’s account) or by means of a notice on this Website prior to the change becoming effective. The Users are encouraged to periodically review this page for the latest information on its privacy practices.

Axio has made every effort to ensure that this Policy adheres with the applicable laws. The invalidity or unenforceability of any part of this Policy shall not prejudice or affect the validity or enforceability of the remainder of this Policy.

The rights and remedies available under this Policy may be exercised as often as necessary and are cumulative and not exclusive of rights or remedies provided by law. It may be waived only in writing. Delay in exercising or non-exercise of any such right or remedy does not constitute a waiver of that right or remedy, or any other right or remedy.

This Policy shall be governed by and construed in accordance with the laws of the Republic of India and subject to the provisions of arbitration set out herein, the courts at Bangalore shall have exclusive jurisdiction in relation to any disputes arising out of or in connection with this Policy.

If any dispute arises between axio formerly known as Capital Float and the User in connection with or arising out of the validity, interpretation, implementation or alleged breach of any provision of the Policy, such dispute shall be referred to and finally resolved by arbitration in accordance with the Indian Arbitration and Conciliation Act, 1996 for the time being in force, which rules are deemed to be incorporated by reference in this clause.

There shall be one (1) arbitrator and the seat of the arbitration shall be Bangalore, India. The language of the arbitration proceedings and of all written decisions and correspondence relating to the arbitration shall be English.

The Ministry of Electronics and Information Technology (MeitY) operates as the nodal agency for information technology in India.

axio formerly known as Capital Float makes no representation that the content contained on the Website is appropriate or to be used or accessed outside of the Republic of India. If the Users use or access the Website from outside the Republic of India, they do so at their own risk and are responsible for compliance with the laws of such jurisdiction.

In the event of User having any grievance relating to the Website or the App, the User may contact our Grievance Department at: [email protected].

User’s can also contact us by writing to any of the following addresses:

axio, Gokaldas Platinum, New No 3 (Old No 211), Upper Palace Orchards, Bellary Road, Sadashiva Nagar, Bengaluru – 560080.

Axio Digital Private Limited, 101, Plexus Commercial Complex, Aundh ITI Road, Aundh, Pune – 411007.