Ohm Mobility- Privacy Policy

LAST UPDATED: [19 September 2022]

 

The website https://www.ohmmobility.com is owned and operated by Ohm Mobility Private Limited, a private limited company with its registered office located at B 104, Rohan Mihira, AECS Layout, Chinappanahalli, Bangalore- 560037 (“Ohm Mobility”, “we” or “us”). Ohm Mobility adheres strictly to information technology and data protection laws, rules and regulations. In order to ensure compliance with the same, Ohm Mobility has implemented this privacy policy (the “Privacy Policy”, “Policy”) to set out the manner in which Ohm Mobility handles the information relating to or collected from the users/ registrants (“User” or “You”) of the website and/ or any software application owned and operated by Ohm Mobility, collectively referred to as, the “Platform”. This Privacy Policy also specifies the manner in which sensitive personal data or information (if any) is collected, received, stored, processed, disclosed, transferred, dealt with and handled by Ohm Mobility in relation to your use of the Platform. This Privacy Policy does not apply to information that you provide to, or that is collected by, any third-party through the Platform, and any third-party site that you access or use in connection with using the services offered through the Platform.

 

Please read the privacy policy carefully before using or registering on the Platform or accessing any material, information or services on the Platform. Your visit or use of the Platform or services offered through the Platform shall signify your unconditional acceptance of this privacy policy, and your agreement to be legally bound by the same. We request you to carefully read our Privacy Policy and feel free to get back to our Grievance Officer in the event you require any clarification in respect of our Privacy Policy. We also request you to review our Privacy Policy from time to time because your use of our products and services implies your acceptance of our prevailing Privacy Policy.


BY ACCEPTING THE PRIVACY POLICY, YOU EXPRESSLY CONSENT TO OHM MOBILITY’S COLLECTION, RETENTION, ANALYSIS, USE AND DISCLOSURE OF YOUR PERSONAL INFORMATION IN ACCORDANCE WITH THIS PRIVACY POLICY.

 

(a) At Ohm Mobility, we are committed to protecting your personal data and respecting your privacy. Please read the following terms of the Privacy Policy carefully to understand our practices regarding your personal data and how we will treat it. This policy sets out the basis on which any personal data we collect from you or about you, or that you provide to us, will be processed by us.

(b) Capitalized words in the Policy shall have the same meaning ascribed to them in the Terms of Use (“Terms”), available at https://www.ohmmobility.com/termsofuse. Please read this Policy in consonance with the Terms.

(c) By using the Platform, you consent to the collection, storage, use, and disclosure of your personal data, in accordance with, and are agreeing to be bound by this Policy. We will not collect any information from you, except where it is knowingly and explicitly provided by you.

(d) This Policy together with any terms of the arrangement we have with you applies to your use of:

​- the Platform, once you have visited/ downloaded the same onto your mobile phone or handheld device; and

- any of the Services that are available on the Platform.

 

(e) This policy is provided in a layered format, so you can click through to the specific areas set out below.

  1. Collection of Information

  2. Usage and storage of Information

  3. Collection of Information by Third-Party Sites and Advertisers

  4. Disclosure to Third Parties

  5. Security

  6. User Discretion

  7. Data Retention

  8. Grievances

  9. Amendments

 

1. COLLECTION OF INFORMATION

 

This Privacy Policy applies to information that:

(a) You may provide to us while registering on our Platform and/ or using our services. This includes the information that Ohm Mobility: (i) collects from you when you register on the Platform, such as your name, electronic mail address, password, phone number, home address, Aadhaar number, User records, proof of identity, proof of address, feedback, orders, and other relevant details; (ii) collects regarding your content, received, uploaded or provided using the Platform; and (iii) collects via third parties such as payment service providers or online merchants relating to your payment transaction history and your previous purchases. All information disclosed by you shall be deemed to be disclosed willingly and without any coercion. No liability pertaining to the authenticity/ genuineness/ misrepresentation/ fraud/ negligence of the information disclosed shall lie on Ohm Mobility.

 

(b) Ohm Mobility may collect information via third parties, such as account information service providers (more specifically, please be advised that by connecting to your bank account, Ohm Mobility obtains certain information: your full name, address, email address, Aadhaar number, personal ID, phone and/ or any other identifying information available, together with information about the current balance and transactions for the last 12 months), credit information companies, or any other parties with whom Ohm Mobility has, from time to time, entered into agreements that include data collection and/or transfer; and

 

(c) Ohm Mobility may automatically receive and record on its server logs when you access or use our Platform, including but not limited to, your location, information about your internet connection and mobile device, Internet Protocol address, cookie information, web beacon information and details of the web pages you visit and your interactions on them. Further, Ohm Mobility may collect information about your preferences and settings such as time zone and language, your searches and the results you selected from the search and your transactional information.

 

(d) We will request you, subject to you agreeing to use the Platform, to provide for certain information such as credit related information that is collected from other sources like credit bureaus and other similar organization(s), including details of the loan (EMI, repayment schedules), transaction data including details of Services you have availed and details of payments you have made on the Platform. The Platform might also collect the following types of banking information from you – credit/debit card details such as the first six or the last four digits of your card number, payment wallet information (if you maintain a payment wallet with us), card details for quick purchase where you have selected the preference of letting us store the said information. However, for avoidance of doubt we would like to clarify that we do not store or process information necessary to make online payments such as all the digits of a credit card number/ bank account number, CVV numbers, one time PIN numbers and similar payment authentication information. However, do note that such information may be collected, stored and used by the payment gateway service provider you choose to complete your transaction with Ohm Mobility. All such information will be subject to and processed in accordance with the payment gateway service provider’s terms and conditions.

 

(e) The Platform or its affiliates’ website/ application are intended for users of the age of 18 and above only. Accordingly, we will not knowingly collect or use any personal information from individuals that we believe to be under the age of 18 years. In addition, we will delete any information in our database that we know originates from an individual under the age of 18.

 

(f) Aggregated data could be derived from your personal data but is not considered personal data under applicable laws. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific feature of the Services.

(g) We do not collect, use, store or transfer any personal data which form the contents of the documents accessed by the Platform to provide you with or in connection with the Services.

(h) We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data).

(i) We do not collect/ store any of your biometric data.

(j) Where we need to collect personal data by law, or under the terms of the arrangement we have with you, and if you fail to provide that data as and when requested by us, we may not be able to perform our obligations under the arrangement we have with you or are trying to enter with you (for example, to provide you with features of the Services). In this case, we may have to cancel or limit your access to the Services, but we will notify you if this is the case at the time.

 

2. USAGE AND STORAGE OF INFORMATION

 

The information gathered by Ohm Mobility as specified in Clause 1, may be used for the following purposes:

  • for your registration, login and management of the Platform;

  • to evaluate your creditworthiness and expected repayment performance and carrying out affordability tests in the context of determining your eligibility for a given consumer credit product;

  • to confirm your identity directly and/ or through third parties;

  • to prepare and conclude a credit/ loan agreement and other related documentation;

  • internal administrative processes directly related to the provision or management of a consumer credit product and your consumer credit account;

  • to monitor the quality of our financial services software and processes to detect errors or areas of improvement;

  • to understand your preferences and to enhance and customize your experience of using the Platform;

  • to communicate with you through mail, e-mail and telephone, in connection with negotiating, concluding or managing the contractual relationship with Ohm Mobility and the consumer credit account;

  • to respond to your comments, reviews and questions and provide better service;

  • to better identify and retain good customers, and to improve customer relations;

  • to carry out Ohm Mobility’s obligations and enforce Ohm Mobility’s rights arising from any contracts entered into between You and Ohm Mobility, including for billing and collection of amounts;

  • to make requests to and report any and all information regarding You to our NBFC partners/ other Regulated Entities by RBI from time to time;

  • to authenticate Your Aadhaar number and undertake related activities under the applicable laws;

  • to undertake Know Your Customer (KYC) compliance as required under applicable laws;

  • to communicate important notices or changes in the services provided by Ohm Mobility, use of the Platform and the terms/ policies which govern the relationship between You and Ohm Mobility;

  • for internal purposes such as auditing, data analysis, research and improvement relating to the Platform or the services provided through the Platform;

  • to create personalised statistical data for use in creditworthiness and affordability assessments of your future consumer credit applications;

  • to identify, prevent and combat fraud, money laundering and terrorism financing;

  • for promotion and marketing purposes;

  • to offer new products and services and new features in existing services you are using;

  • for sharing such information with any third-party, including any service providers and any group companies of Ohm Mobility, in the course of providing the services through the Platform;

  • for transferring such information to third parties for further processing, particularly accounting, audit and law firms;

  • for assignment or transfer, in whole or in part, of the rights deriving from a contract between you and Ohm Mobility;

  • to analyse risk and ensure security and legality of the services provided; and

  • to transfer data to the regulatory authorities or other appropriate authorities as required by law.

  • Ohm Mobility does not access and/ or store mobile phone resources like file and media, contact list, call logs, telephony functions etc. A one-time access may be taken for camera, microphone, location or any other facility necessary for the purpose of on-boarding/ KYC requirements only, with the explicit consent of the User.

The data gathered from you may also be used for any reason incidental to the reasons listed above; and for any other purpose with your consent.

3. COLLECTION OF INFORMATION BY THIRD-PARTY SITES AND ADVERTISERS

When you use the Platform, there may be certain links which may direct you to other websites or applications not operated/ maintained by Ohm Mobility (the “Third Party Site”). The manner in which your information is collected, received, stored, processed, disclosed, transferred, dealt with and handled by such third-party site(s) is governed by the terms and conditions and privacy policy of the respective third-party site(s). Ohm Mobility hereby expressly disclaims all liabilities with respect to the manner in which the third-party site collects and/ or uses your information. On our Platform, there may be third parties who advertise their products and/ or services. Such third parties may place or recognize a unique “cookie” on your browser and may use information about your visits to our Platform and other websites in order to provide advertisements about goods and services of interest to you. We shall, in no event, be liable for any unauthorized or unlawful disclosures of your personal information made by advertisers, who are not subject to our control.

4. DISCLOSURE TO THIRD PARTIES

(a) Ohm Mobility may need to disclose your information, if required to do so by law and if such action is necessary to: (a) comply with a legal obligation; (b) protect and defend the rights or property of Ohm Mobility, including to enforce our agreements, policies, and Terms of Use; (c) protect the personal safety of Ohm Mobility, the Users, or any person, in an emergency; (d) protect Ohm Mobility from incurring any legal liability; (e) firms representing Ohm Mobility in judicial proceedings and/ or accounting and auditing firms providing services to Ohm Mobility; and (f) for reasons incidental to the above. In such an event, Ohm Mobility shall be under no obligation to inform you or seek your approval or consent.

 

(b) You understand that when you consent to providing us with your personal data, you also consent to us sharing the same with third parties. You are aware and you agree that Ohm Mobility shall be at liberty to disclose your information to: (i) any third-party to facilitate the provision of Services through the Platform; and (iii) any third parties who provide services, such as auditing, data analysis, Platform improvement and assistance with delivery of relevant marketing messages and advertisements. If you provide a mobile phone number and/ or e-mail address, Ohm Mobility or the third-party service providers or the persons authorized by them, may send you text messages/ e-mails in relation to your use of the Platform. Ohm Mobility contractually requires these third parties to keep such information confidential and use it only for the purposes for which Ohm Mobility discloses it to them. These third parties may view, edit, or set their own cookies or may place beacons on your personal information.

 

(c) We may also share aggregated (and de-identified) information with third parties in our discretion. We may share personal information with third-party vendors, consultants, and other service providers who work for Ohm Mobility, who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.

 

(d) Ohm Mobility may disclose or transfer your information (personal or otherwise) to any subsidiary or affiliate, and to a third party if Ohm Mobility sells, transfers or divests all or a portion of Ohm Mobility’s business or assets to another company in connection with or during negotiation of any merger, financing, acquisition, bankruptcy, dissolution, transaction, or proceeding. Such third parties shall be contractually bound to not disclose further, any personal information disclosed to them.

 

(e) You are aware that any and all information pertaining to you, whether or not you directly provide it to us (via the Services or otherwise), including but not limited to personal correspondence such as emails, instructions from you, etc., may be collected, compiled and shared by us in order to render Services to you and you expressly authorize us to do so. This may include but not be limited to storage providers, data analytics providers, consultants, lawyers, and auditors. We may also share this information with our subsidiaries, affiliates or any of their holding companies.

 

(f) You agree and acknowledge that we may share data without your consent, when it is required by law or by any court or government agency or authority to disclose such information. Such disclosures are made in good faith and belief that it is reasonably necessary to do so for enforcing this Policy or the terms of the arrangement we have with you, or in order to comply with any applicable laws and regulations.

 

(g) In general, we will not disclose personal data except in accordance with the following purposes/ activities, undertaken without direct human supervision or control:

  • To install the Platform and register you as a user;

  • To deliver Services;

  • To manage our relationship with you including notifying you of changes to any Services;

  • To deliver content to you;

  • To monitor trends so we can improve the Services;

  • To perform our obligations that arise out of the arrangement we are about to enter or have entered with you;

  • To enforce the terms of the arrangement we have with you;

  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; and

 

(h) We will process personal data under direct human supervision or control only if:

  • Specific affirmative consent has been obtained to access certain messages;

  • It is necessary to administer and protect our business and the Services including troubleshooting, data analysis and system testing;

  • It is necessary to comply with a legal or regulatory obligation; or

  • Such use or processing otherwise is limited to internal operations.

 

(i) You authorize us to send you electronic alerts and messages for details pertaining to registration on the Platform and requirements arising out of the provision of Services.

 

5. SECURITY

 

Ohm Mobility shall take reasonable steps to help protect your rights of privacy and your information (personal or otherwise) in an effort to prevent loss, misuse, unauthorized access, disclosure, alteration, or destruction of such information, in compliance with the applicable laws. When payment card account information is being transmitted on or through the Platform, it will be protected by encryption technology. You expressly consent to the sharing of your information with third-party service providers, including payment gateways, to process payments and manage payment card information. Ohm Mobility does not itself store your payment card account information and does not have direct control over or responsibility for your payment card account information. Hence, Ohm Mobility cannot guarantee that transmissions of your payment card account information or personal information will always be secure or that unauthorized third parties will never be able to defeat the security measures taken by Ohm Mobility or Ohm Mobility’s third-party service providers. Ohm Mobility assumes no liability or responsibility for disclosure of your information due to errors in transmission, unauthorized third-party access, or other causes beyond its control. You play an important role in keeping your personal information secure. You should not share your username, password, or other security information for your account with anyone.

 

6. USER DISCRETION

 

(a) You may opt out of receiving promotional emails from Ohm Mobility by following the instructions in those emails. If you opt out, Ohm Mobility may still send you non-promotional emails, such as emails about the services availed through the Platform and emails about your account.

(b) We use cookies and/ or other tracking technologies to distinguish you from other users of the Services and to remember your preferences.  Cookies are small data files which are sent to your browser from the Platform and are stored on your computer or device (hard drive). The cookies shall not provide access to data in your computer or device such as email addresses or any other data that can be traced to you personally. The data collected by way of cookies will allow us to administer the Services and provide you with a tailored and user-friendly service. The cookies shall enable you to access certain features of the Services. Most browsers and devices can be set to notify when you receive a cookie or prevent cookies from being sent. If you do prevent cookies from being sent, it may limit the functionality that we can provide when you visit the Platform or try to access some of the Services.

(c) Cookie choices: Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject cookies. If you choose to remove or reject cookies, this could affect certain features or services on the Platform.

(d) Should you desire to opt out of disclosing your information to Ohm Mobility, Ohm Mobility requests that you close your user account and stop accessing the Platform and the services on the Platform. Thereafter, Ohm Mobility may delete your information (personal or otherwise) or de-identify it so that it is anonymous and not attributable to you.

 

7. DATA RETENTION

 

Ohm Mobility assures you that all data is stored only in servers located in India, while ensuring compliance with statutory obligations/ regulatory instructions. You are aware that your personal data will continue to be stored and retained by us for a reasonable period after termination of your use of our Services on the Platform.

 

8. GRIEVANCES

 

In the event you have any grievances relating to the Privacy Policy, please inform Ohm Mobility within 24 hours of occurrence of the instance from which the grievance has arisen, by writing an email to the Grievance Officer at contact@ohmmobility.com. Ohm Mobility shall respond to all grievances lodged with Ohm Mobility in accordance with Grievance Redressal Policy.

 

9. AMENDMENTS

 

Ohm Mobility retains an unconditional right to modify or amend this Privacy Policy without any requirement to notify you of the same. You can determine when this Privacy Policy was last modified by referring to the “Last Updated” legend above. It shall be your responsibility to check this Privacy Policy periodically for changes. Your continued use of the Platform following the posting of changes to this Privacy Policy on the Platform, will constitute your consent and acceptance of those changes.