Privacy Policy

We are committed to ensuring that your privacy is protected in accordance with applicable laws and regulations. We urge you to acquaint yourself with this Policy to familiarize yourself with the manner in which your data is being handled by us. IMBU SHANKAR CHITS PRIVATE LIMITED may change this policy periodically, and we urge you to check this page for the latest version of the policy in order to keep yourself updated.

---

1. Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

• Account means a unique account created for You to access our Service or parts of our Service.
• Affiliate means an entity that controls, is controlled by or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
• Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to Imbu Shankar Chits Pvt. Ltd., 48/Y, 14th Main Road, 3rd Block, Rajajinagar, Bangalore - 560 010, Karnataka, India.
• Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.
• Country refers to: Karnataka, India.
• Device means any device that can access the Service, such as a computer, a cellphone, or a digital tablet.
• Personal Data is any information that relates to an identified or identifiable individual under relevant Indian laws (including the Digital Personal Data Protection Act, 2023).
• Service refers to the Website.
• Service Provider means any natural or legal person who processes the data on behalf of the company. It refers to third-party companies or individuals employed by the company to facilitate the service, to provide the service on behalf of the company, to perform services related to the service, or to assist the company in analyzing how the service is used.
• Usage Data refers to data collected automatically, either generated by the use of the service or from the service infrastructure itself (for example, the duration of a page visit).
• Website refers to Imbu Shankar Chits Pvt. Ltd., accessible from https://www.imbushankarchitspvtltd.com/.
• You means the individual accessing or using the service, or the company or other legal entity on behalf of which such individual is accessing or using the service, as applicable.

---

2. Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using our services, we may request you to provide certain personally identifiable information that can be used to contact or identify you. This may include, but is not limited to, the following:

• Name
• Contact information, including physical address and email address
• Phone number
• Demographic information, preferences, or financial interests relevant to chit funds
• Personal data or other information relevant/required for providing chit fund products or services to you

What We Do with the Data We Collect

• Internal record keeping and chit subscriber management
• Improving our products and services
• Providing updates about our chit schemes, including special offers
• Communicating important statutory and administrative information to you
• Internal training and quality assurance purposes

Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers, and other diagnostic data.

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device's unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers, and other diagnostic data.

---

3. Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service. The technologies We use may include:

• Cookies or Browser Cookies: A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our service.
• Web Beacons: Certain sections of our Service and our emails may contain small electronic files known as web beacons that permit the Company to count users who have visited those pages or opened an email and for other related website statistics.

We use both Session and Persistent Cookies for the purposes set out below:

---

4. Use of Your Personal Data

The Company may use Personal Data for the following purposes:

• To provide and maintain our Service: Including to monitor the usage of our Service.
• To manage Your Account: To manage Your registration as a user of the service.
• For the performance of a contract: The development, compliance, and undertaking of chit fund subscriber contracts or any other contract with Us through the Service.
• To contact You: To contact You by email, telephone calls, SMS, WhatsApp, or other equivalent forms of electronic communication regarding updates or informative communications related to chit plans.
• To provide You: With news, special offers, and general information about other goods, services, and events that we offer unless You have opted not to receive such information.
• To manage Your requests: To attend to and manage Your inquiries or Data Principal statutory requests to Us.
• For business transfers: We may use Your information to evaluate or conduct a merger, restructuring, reorganization, or transfer of assets.
• For other purposes: For data analysis, identifying usage trends, and evaluating and improving our Service.

Sharing Your Personal Information

We may share Your personal information in the following situations:

• With Service Providers: To monitor and analyze the use of our Service, or to contact You.
• For business transfers: In connection with, or during negotiations of, any merger or sale of Company assets.
• With Affiliates: Requiring those affiliates to honor this Privacy Policy.
• With business partners: To offer You certain products, services, or promotions.
• With Your consent: We may disclose Your personal information for any other purpose with Your consent.

---

5. Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, statutory financial retention required under the Chit Funds Act, 1982 and Prevention of Money Laundering Act - PMLA for 5 years post chit group closure), resolve disputes, and enforce our legal agreements.

The Company will also retain Usage Data for internal analysis purposes for shorter periods, except when used to strengthen security or functionality.

---

6. Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company's operating offices in Bangalore, Karnataka. Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer. We ensure adequate controls are in place to secure Your data.

---

7. Rights to Delete / Correct Your Personal Data

You have the right to delete or request that We assist in updating or deleting the Personal Data that We have collected about You. You may also visit our dedicated Data Principal Rights Portal to submit statutory requests for access, correction, erasure, or withdrawal of consent.

Please note, however, that We may need to retain certain information when we have a statutory legal obligation or lawful basis to do so under the Chit Funds Act 1982 or PMLA regulations.

---

8. Disclosure & Security of Your Personal Data

Business Transactions: If the Company is involved in a merger or asset sale, Your Personal Data may be transferred with prior notice.

Law Enforcement: Under valid legal process, We may disclose Personal Data if required by public authorities or court orders.

Security: We employ commercially reasonable electronic safeguards to protect Your data, though no transmission over the Internet is 100% secure.

---

9. Children's Privacy

Our Service does not address anyone under the age of 18 (or 13 for digital services). We do not knowingly collect personally identifiable information from children without verified parental/guardian consent.

---

10. Grievance / DPO Contact Information

If you have any questions, concerns, or grievances regarding this Privacy Policy or data processing practices, you may contact our Grievance Officer / Data Protection Officer (DPO):