Hap2py asks for and uses your personal information and is committed to keeping this information secure and protected. This Privacy Policy explains why we require personal information and how we collect, use, disclose and secure your personal information. This Privacy Policy applies to personal information we collect from you and from third parties both, online and offline but does not apply to any personal information collected by third parties from you.

By accessing or using the Website and Mobile Application, you signify that you have read, understood and agreed to be bound by this Privacy Policy. We reserve the right to update or modify this Privacy Policy at any time without prior notice. Therefore, we encourage you to review this Policy each time you access our Services on our Website and Mobile Application. We may also choose to notify you of material changes to the Privacy Policy by email or by means of a notice on our home page.

The following terms and definitions have been set out in this privacy policy:

• “Hap2py”, “We”, “Us”, and “Our” means PEER 2 PEER FINANCE LIMITED. which owns and operates the website, www.hap2py.com (“Website and Mobile Application”)
• “You” and “Your” means a user of the website and the products and services provided via the website and Mobile Application.
• “Services” includes lending and any other related services by us via our Website and Mobile Application.

To create an account on Hap2py, you must provide us with the basic details and information required as part of our Customer Identification process and you agree to this Privacy Policy, which governs how we treat your information. During the use of our Services, Website and Mobile Application and App, we may collect information about you from you and from third parties. While some information must be mandatorily provided, others are optional and certain portions of the information will remain private and some will be shared with associated third parties. All information you provide to us is voluntary. This information is including but not limited to the following:

• Information about you when you register or when you use our Website and Mobile Application.
• Personal and financial information like your name, email address, contact number, gender, date of birth, contact information, address, etc.
• Information about your transaction history like spend data, through our app etc.
• We may also collect other personal information such as SMS, contacts, location data, mobile device data etc.
• Your unique identifiers such as username and password, preferences information and transaction history.
• Information collected through your Facebook, Twitter, LinkedIn or other social media accounts which have been linked to the account on the Website and Mobile Application.
• Information that you provide when you write directly to us (including by email) or provide us over telephone
• Any other information that Hap2py is required to collect as per specific mandate from any bank or as a requirement under applicable law.
• Aggregate information and electronic data - like the pages viewed, how you navigate through the website and interact with web pages, etc

By registering for a Hap2py account or beginning an application on the Hap2py website or mobile application for any product or service, you are consenting to be contacted by us by written notices, email messages, text messages, WhatsApp, or telephone, and, in connection with any such telephone calls, you consent to the use pre-recorded/artificial voice messages and/or automatic dialling devices, at any telephone number associated with your Hap2py account, including mobile telephone numbers or at any email address or mailing address we have for you in our records or from other public and nonpublic databases we may lawfully access. You agree that Hap2py may contact you using the information you provided with information and offers of services available through Hap2py website and mobile application.

The information we collect about you will depend on the products and services we offer, on an ongoing basis. If you do not allow us to collect all the information we request, we may not be able to deliver all these services effectively.

You understand that, by creating an account or by registering through third party sites, we and others will be able to identify you by your Hap2py profile. However, we will not be liable under any circumstance for the generation of your profile or the information you provide therein. Hap2py will also not be liable for any information collected in the form of SMS, contact, media or any other sources that the users might upload, the data collection process may extract, the use and misuse thereof.

All the information that you shall provide us is voluntary, including sensitive personal information. You understand that Hap2py may use certain information of yours, which has been designated as ‘sensitive personal data or information’ under the IT Rules for the purpose of providing you with the Services and for sharing the information only with affiliates who are subject to this Privacy Policy, as will be explained further below.

We will take utmost care to ensure that your personal information is not shared with the public and that your transactions on the Website and Mobile Application are confidential. If we use any third parties for any of these transactions, we will also make sure that confidentiality is maintained with these authorised third parties. We only share your personal information with affiliated third parties as permitted or required by law. When we share your personal information with vendors and service providers who perform functions on our behalf, we require that they keep your information confidential and secure and that they use it only as is reasonably necessary to carry out their work or comply with applicable law. We may share your personal information with affiliates and as part of joint marketing campaigns with other financial companies. In addition, personal information may be disclosed or transferred to our affiliates and as part of, or during negotiations of, a merger, consolidation, sale of company assets or equity, financing, acquisition, strategic alliance or in any other situation where personal information may be transferred as one of the business assets of Hap2py.

We maintain administrative, technical and physical safeguards designed to protect the security, confidentiality and integrity of your personal information. We store all the customer data on AWS cloud servers to reduce the risks of loss, misuse, unauthorised access, disclosure and alteration. Some of the safeguards we use are firewalls, SSL data encryption and access authorisation controls. In addition, your personal information resides on servers or in areas of facilities that only selected Hap2py personnel and contractors have access to.

However, you understand and accept that there’s no guarantee that data transmission over the Internet will be completely secure and that any information that you transmit to us is at your own risk. We assume no liability for any disclosure of information due to errors in transmission, unauthorised third party access to our Website and Mobile Application and databases or other acts of third parties, or acts or omissions beyond our reasonable control and you shall not be entitled to hold Hap2py responsible for any breach of security.

Personal information that is not collected on the Website and Mobile Application or in connection with the Service is not generally subject to this Privacy Policy. The Website and Mobile Application may contain links to other websites which may collect personal information. For example, Hap2py may have relationships with various service providers whose services you might find useful and are available to you from the Website and Mobile Application, from websites that are linked to the Website and Mobile Application, or in connection with the Service. Those providers may require you to provide personal information to use their services. Unless expressly provided to the contrary, the privacy policy applicable to that website, and not this Privacy Policy will govern the collection, use, disclosure and security of your personal information.

You can access all your personal and personally identifiable information that we maintain by logging in to your account and going to “My Profile”. This section of the site is password-protected to better safeguard your information. To protect the confidentiality of such personal information, you should not divulge your password to anyone. You are responsible for all uses of the Website and Mobile Application by any person using your customer ID and password. As a registered user, you can update physical address, phone numbers, education and employment information at any time on the website.

Cookies are small data files that a website stores on your computer. Hap2py uses cookies for security and to personalise your web browsing experience. We may use cookies for some situations, such as

• To allocate an identification number to your Internet browser (you cannot be identified from this number).
• Personal and financial information like your name, email address, contact number, gender, date of birth, contact information, address, etc.
• To make our Website and Mobile Application more user-friendly.
• To determine if you have previously visited the website.
• To track and report on website and online campaign performance.
• To identify other pages or third party websites you have accessed.
• To detect fraud and for security purposes.

It is possible for you to configure your browser so that it does not receive cookies. However, this means you will be unable to use secure services that require cookies in order to participate. Some of those services include (but are not limited to) our online application and some member features.

We place and track advertisements on third party websites. Like many advertisers, we advertise our products and services, and we contract with third parties to place advertisements on websites not affiliated with us where we think the advertisements are likely to be most relevant. These advertisements may contain cookies or other mechanisms that allow tracking of your response to our ads. We and our contracted third parties track and report performance of our advertising and marketing campaigns by using cookies, web beacons, and other similar technology, which may be used to collect and store information about user visits, page visits and duration, and the specific ad or link that the user clicked on to visit the site. No personally identifiable information is stored during this process.

If you have questions regarding our Privacy Policy or if you believe that Hap2py has not complied with this Privacy Policy with respect to your personal information, please contact us at [email protected]. If you are reporting noncompliance with this Privacy Policy, in your email or letter, please describe in as much detail as possible (but without disclosing any sensitive information about you or third parties) the ways in which you believe that the Privacy Policy has not been complied with.