1.BACKGROUND

Dhairya Management Services Private Limited (CIN: U74140MH2008PTC189107) (hereinafter referred to as we, our, us, “Abhi Rupee”) is a company incorporated under the Companies Act, 1956, having its registered office at 2nd floor, Plot no.36, Opp St. Joseph's High School, Pushpa Park, Daftary Road, Malad (East), Mumbai, Maharashtra, India, 400097. Abhi Rupee operates primarily in the financial products and services sector, utilizing technology platforms such as Websites, Apps, and Platforms and Partner Platforms, along with providing data processing services to customers and businesses. We collaborate with our Partner Lender Anupam Finserv Limited ( L74140MH1991PLC061715), a Non-Banking Financial Company (NBFC) registered with the Reserve Bank of India (RBI), to deliver financial products and services.

Abhi Rupee acts as a Lending Service Provider (LSP) facilitating loan products from our Partner NBFC, Anupam Finserv Limited, which remains the regulated entity (RE) and data controller for all financial and lending activities.

The purpose of this privacy policy (Privacy Policy) is to inform you about how Abhi Rupee collects, stores, uses, discloses, transfers, and processes your Personal Information, including Sensitive Personal Information (defined below). This occurs when: (a) you use our websites, software applications, mobile applications, or our partners platforms (Platforms), or (b) you access products or services directly through our Websites, Apps, or Platforms. This policy also outlines the measures we take to safeguard your Personal Information. The term Websites encompasses all pages, sub-domains, or associated content within each Website.

This Privacy Policy framed in light of the Digital Personal Data Protection Act, 2023, Sensitive Personal Data or Information (SPDI), and in compliance with the Reserve Bank of India’s Digital Lending Guidelines (2025).

Abhi Rupee or any person who on behalf of Abhi Rupee collects, receives, possesses, stores, deals or handles information of provider of information, should adhere to privacy policy for handling of or dealing in personal information including sensitive personal data or information and ensure that the same are available for view by such providers of information who have provided such information under a lawful contract. Such a policy should be published on site/app of Abhi Rupee.

Abhi Rupee facilitates loan transactions between borrowers and NBFCs/Banks. All loan applications are approved and sanctioned by RBI-registered NBFCs/Banks. Our Current Lending Partner is Anupam Finserv Limited, having CIN No. L74140MH1991PLC061715, a company incorporated under the Companies Act, 1956.

2.PURPOSE

Abhi Rupee intends to protect the privacy of its users and members on its site/app and maintain the privacy of the data provided by them to Abhi Rupee from time to time and strongly committed to protecting the personal information, including but not restricted to Sensitive, Personal and Financial Information that information provider/customer submits to us and we would endeavor to protect it from unauthorized use.

This Privacy Policy provides you with details about the way your data is collected, stored, and used by us and you are advised to read this privacy policy carefully.

This policy applies to all users of our website, mobile applications and services. By visiting the site/app, you consent to the use and disclosure of your personal information in accordance with the terms and conditions of this Privacy Policy. If you do not agree to the terms of this Privacy Policy, you may refrain from using our services.

Please contact us at care@abhirupee.com, if you have additional questions or require additional information about our privacy policy. This Privacy Policy is applicable for all our ongoing online activities and is also valid for visitors who come to our website/app and the information that they share and/or collect in Abhi Rupee. Information collected offline or through channels other than this website/app does not fall under the purview of this Privacy Policy

3.DEFINITIONS

1. “We,” “our” and “us” refer to “Abhi Rupee.”
2. “Site” refers to the website, mobile application that we provide and which includes a link to our Online Privacy Policy.
3. “User”, “You” or ““your” refers to anyone who visits, accesses, browses or uses the Abhi Rupee website/app at https://www.AbhiRupee.com/ or obtains our services through our website/app.
4. Personal Information: means any information that relates to a natural person which either directly or indirectly, in combination with other information available or likely to be available with a body corporate, is capable of identifying such person.
5. Personal and Financial Information: means personal information that is otherwise not available to anyone except the customer, such as password, financial information, sexual orientation, passwords, biometric data, medical records, physical, physiological, and mental health condition. Such information is generally not available in the public domain.
6. Consent: Means an explicit, freely given, specific, informed, and unambiguous indication of your agreement for processing data for a defined purpose.
7. Platform: Refers to the digital infrastructure provided by Abhi Rupee, including our mobile application, website/app (www.abhirupee.com), and any associated software or interface.

4.COLLECTION OF INFORMATION

While availing of service or products or using the site/app Abhi Rupee may collect and process information from the customers including sensitive information that is confidential in nature but not limited to the below mentioned.

1. Information that the users provide to Abhi Rupee by filling in forms on the website/app. This includes contact information such as name, email address, mailing address, phone number, financial details, family details, banking relationships, and transaction history etc.
2. We also collect information through supporting documents collected as per Know Your Customer (KYC) guidelines issued by the Reserve Bank of India, including KYC documents (PAN, Aadhaar, photograph), contact details (name, email, mobile, address), bank details (account number, IFSC), employment and income information, and financial SMS metadata necessary for loan risk assessment and other documents like statements of accounts, financial statements, etc. on behalf of our lending partner for the underwriting purpose.
3. Information that the users provide while registering for an account with us, such as name, address, email address, and telephone number. We may collect device metadata (IP address, device ID, OS version, installed application list), solely for fraud detection, service improvements, and security.
4. Other personal information provided by third parties such as credit bureaus and identity verification services.
5. Camera, Microphone and Location Permissions: Camera, Microphone and Location access is required only with your explicit consent. for completing your onboarding /eKYC. This allows you to scan or capture identification details and documents digitally, making the process faster and reducing manual errors. The captured data is used to complete your eKYC verification, validate your identity, and confirm loan eligibility as per regulatory standards.
6. Phone State Permissions: Our app may request Phone State permission only with your explicit consent. This is strictly for verifying that the device has an active SIM and valid network connection at the time of onboarding and disbursement, ensuring the transaction is carried out by the rightful customer and preventing spoofing/fraud. We do not use this permission for call logs, contacts, or any unrelated purposes. All access is carried out in line with RBI Digital Lending Framework and applicable Indian privacy laws.
7. We may read the headers of all SMS to check the type of sender. We only read the indicative SMS content from 6-digit alpha numerical number for verification purposes. Pertinent information such as sender names, SMS content, received timestamps are periodically collected for the purpose of provision of financial and allied services and the data is transmitted to third parties. It is important to note that we do not read or analyze personal or OTP messages, except OTP messages sent by us, which are linked to our purpose of use during lifetime of the app installed. This data may be used to verify financial statistics such as income, spending patterns which help us in the credit evaluation and may help us in facilitating higher limits, faster approval rates and for fraud detection & prevention.
8. We collect metadata about installed and system applications on your device—including application name, package name, install/update time, installer source, version name, and version code. This information may be collected even when the app is closed or not actively in use.
9. The data is securely uploaded to our trusted device intelligence partner, Credeau (via https://devicesync.credeau.com) to support identity verification, fraud detection (e.g., presence of VPNs, gaming or high-risk apps), underwriting, and offering tailored credit limits. These insights help us provide faster approvals and more relevant credit offers. Data collection is initiated only after your explicit consent and is handled in accordance with applicable privacy and data protection policies.
10. Abhi Rupee seeks one time permission to collect and monitor the information about the location of customer’s device to provide serviceability of loan application, to reduce risk associated with the loan application and to provide pre-approved customized loan offers. This also helps us to facilitate verification of the address, making a better credit risk decision and know your customer (KYC) process.
11. Abhi Rupee collects limited device-related information to enhance user safety, prevent fraud, and ensure secure digital lending operations. This may include details such as device model, operating system version, available RAM/storage. We do not collect permanently identifiable information such as IMEI or serial numbers, in compliance with Google Play policies and privacy regulations. Abhi Rupee requests Phone State permission strictly to verify the device’s active SIM and network status at the time of onboarding and disbursement, helping us ensure that the transaction corresponds to the rightful customer and is not spoofed. All such access is performed with your explicit, informed consent, and in accordance with RBI’s digital lending framework and applicable Indian privacy laws.
12. We do not collect or store biometric data.
13. Information that you provide to Abhi Rupee when interacting with our customer support team or other team members via phone, email, online form, or other correspondence.
14. Personal information stored with third parties that you choose to provide to Abhi Rupee, such as social media account information and your social media contacts. By linking your third-party accounts or using third party sign-in services, you authorize.
    Abhi Rupee to have access to this information, and you agree that Abhi Rupee may collect and use this information in accordance with this Privacy Policy.
15. Personal testimonial information or endorsements that you voluntarily provide to us and which we may display with your name on the Abhi Rupee Site/apps with your consent. To update or delete your testimonial, contact us at care@abhirupee.com.
16. Abhi Rupee App is hosted in India and We ensure that every data or information that we collect from you is stored in servers located in India and the same is compliance with all the statutory/regulatory obligations.
17. We display just-in-time consent screens for permissions like SMS, location, phone state, and app list in accordance with Google Play policy.

When the user uses the site/app, our servers automatically record certain information that the user’s web browser sends whenever the user visits any website/app. Such information is known as “LOG FILES.” 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. We use this information, which may or may not identify users, to analyze trends, administer the site/app, track user’s movements around the site/app, and gather demographic information about the user base as a whole. We do not access your contacts or call logs under any circumstance. Access to SMS, gallery, or location is strictly limited to specific, legitimate purposes such as fraud detection, credit risk assessment, or identity verification. Such data is collected only after obtaining your explicit and informed consent, in compliance with applicable laws and platform policies.

5.USE OF INFORMATION

The information collected by us is used in numerous ways to:

1. To facilitate assessment and provide credit underwriting support for sanctioning credit facility.
2. To provide information to our lending partner for checking eligibility criteria, credit assessment, credit underwriting, and other activities incidental thereto.
3. To inform you about the latest offers, products, and services from time to time.
4. To resolve disputes, troubleshoot concerns.
5. To help and promote safe services.
6. To Provide, operate, and maintain our website/app.
7. To Improve, personalize, and expand our website/app.
8. To Develop new products and services, features, and functionalities
9. Communicate either directly with you or through one of our partners to provide you with customer service, with updates and other website/app-related information, and for marketing and promotional purposes.
10. To Send you emails.
11. To protect and prevent fraud and other criminal activity.
12. To perform regulatory compliance

We do not use your data for purposes unrelated to the original consent, unless required by law or with your renewed consent. We do not sell, lease, or trade your personal data under any circumstances.

6.SHARING AND TRANSFER OF INFORMATION

Abhi Rupee may share information with individuals and body corporate in the course of normal business operations, and the customer has subscribed for, and any activity related to these services such as a collection of the fee. We share your information only with regulated partners and third parties under strict confidentiality agreements.

It may become necessary for Abhi Rupee to disclose the customer’s personal information to its Lending partner or agents in the course of normal business operations for the above referred purpose. Your personal data is shared only with: Regulated lending partners (Banks/NBFCs), Credit Information Companies (e.g., CIBIL, Experian), Third-party service providers (e.g., e-KYC, e-sign, payment gateways), and Government/regulatory bodies as mandated by law (e.g., RBI, tax authorities, law enforcement).

However, these parties would be required to use the information obtained from Abhi Rupee for such purposes exclusively and protect the personal information, including but not restricted to, Sensitive Personal and Financial Information under a strict code of confidentiality.

We will not voluntarily disclose your personal information to any non-connected third party but in certain circumstances, we may do so if we are required by court order, by Government Authorities, by law enforcement authorities, by statutory authorities or by other legal processes or where it becomes necessary to do so to protect the rights or property of the site/app and/or its group companies/affiliates, etc. We may also disclose your information to a third party as part of a merger, cooperation towards delivering services or transfer, or any restructuring.

We will only use your personal information data for the purposes for which we collect it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

The list of third parties collecting Information through the App is available on our website/app (www.AbhiRupee.com), which will be updated from time to time, for your reference.

7. COOKIES AND WEB BEACONS:

Like any other website/app, Abhi Rupee collects certain information from the user’s browser using small data files called “cookies.” These cookies enable us to store information including visitor preferences, IP addresses and allow visitors to secure move to different website/app pages having to re-enter information. This information is used to customize our web page content and optimize user experience based on the visitor’s browser type and/or other such information. Cookies help to enhance your experience on our platform, support security features, and analyse usage patterns for continual service improvement.

These tools enable us to: Recognize repeat users, maintain session integrity during login, Customize and personalize content and Analyse site/app performance and improve functionality.

Any information collected is stored in secured databases protected by a variety of access controls and is treated as confidential information by Abhi Rupee.

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

We do not track users across third-party website/apps, nor do we allow third-party behavioural advertising tools on our lending app or website/app

8. DATA SECURITY

We Abhi Rupee strongly committed to protecting the privacy of its customers and has taken all necessary and reasonable measures to protect the confidentiality of the customer information and its transmission through the world wide web and it shall not be held liable for disclosure of the confidential information when in accordance with this Privacy Commitment or in terms of the agreements, if any, with the customer. We regularly review and enhance our data protection practices to keep pace with evolving regulatory requirements and emerging threats in the digital lending ecosystem.

Access Controls: Access to personal data is role-based and restricted to authorized personnel on a need-to-know basis.

Network and Application Security: We implement regular vulnerability assessments, firewall protection, anti-malware controls, intrusion detection systems, and secure coding practices.

Data Minimization: We ensure data is collected and retained only to the extent necessary for the lawful purpose for which it was processed.

You are responsible for maintaining the security of your account credentials and other authentication involved in obtaining access to password-protected or secure areas. Abhi Rupee will not bear any liability in respect of such unauthorized use of your account.

9. DATA RETENTION CONSENT

Abhi Rupee shall not retain personal information longer than is necessary to fulfil the purposes for which it was collected and as permitted by applicable law. However, the Lending Partners will retain your personal information as needed during the tenure of loan and even after termination of account to comply with our legal and regulatory obligations, resolve disputes, conclude any activities related to the cancellation of an account, investigate, or prevent fraud and other inappropriate activity, enforce our agreements, and for other business reason.

Your data may also be retained temporarily in backup systems to ensure disaster recovery, system restoration, or legal hold purposes, although access will be restricted, and deletion will be scheduled in accordance with our internal retention protocols.

By continuing to use our services, you agree to this data retention policy. You may contact our Grievance Officer (Sheetal Dedhia Email: info@abhirupee.com, Phone: 7400430812 at any time to exercise your right to access, correct, or request deletion of your personal data.

10. LINK TO THIRD PARTY WEBSITE/APPS

Our platform may contain hyperlinks or redirections to third-party website/apps, mobile applications, or services that are not operated or controlled by Abhi Rupee. These links are provided for your convenience and informational purposes only. The inclusion of a link does not imply any endorsement by Abhi Rupee of the third-party website/app, the website/app’s provider, or the information on the third-party website/app. We do not endorse, monitor, or have any control over the privacy practices, security measures, content, or terms of use of such third-party platforms. If the users submit personal information to any of those website/apps, such information is governed by the privacy policies of such third-party website/apps and Abhi Rupee disclaims all responsibility or liability with respect to these policies or the website/apps.

We strongly advise you to review the privacy policies and security practices of any third-party website/app or service you choose to engage with, especially before submitting any personal, financial, or sensitive data. Abhi Rupee disclaims any responsibility or liability for any loss or damage that may arise from your use of such third-party site/apps, or your reliance on any information contained therein.

Use of third-party services (such as payment gateways, e-KYC vendors, or credit bureaus) via our platform is subject to additional privacy controls that will be explicitly communicated to you at the time of interaction, wherever applicable.

11. CHILDREN’S INFORMATION:

Another part of our priority is to ensure protection for children while using the internet. We encourage parents and guardians of children to observe and participate in monitoring and/or guiding their online activities. Abhi Rupee will never knowingly collect any Personal Identifiable Information from children below the age of eighteen. If you think that your child has divulged any such information on our website/app, we strongly urge you to contact us immediately. We assure you of prompt action in removing any such information available in our records.

As part of our loan eligibility checks and compliance with the Know Your Customer (KYC) norms prescribed by the Reserve Bank of India, we require documentary age verification at the time of onboarding. If we become aware that we have inadvertently collected personal data from a child, we will take immediate steps to delete or anonymize such data from our systems. By using our services, you affirm that you are at least 18 years of age and legally eligible to enter into a binding contract under Indian law.

12. CONSENT

By accessing, registering, or using the Abhi Rupee platform (including our website/app, mobile application, or digital services), you explicitly provide your free, informed, specific, and unambiguous consent to the collection, processing, storage, use, and disclosure of your personal data and sensitive personal data as outlined in this Privacy Policy. This consent is provided in accordance with the provisions of the Digital Personal Data Protection Act, 2023, and the applicable regulatory framework of the Reserve Bank of India (RBI).

If you do not agree with the Policy, you may refrain from using our services. You may withdraw your consent at any time by writing to our Grievance Officer. Upon receipt of such a request, we will cease processing your personal data for the purposes for which consent was originally

Granted, unless such processing is required: To comply with a legal obligation, for ongoing contractual obligations (e.g., servicing an active loan), or for the establishment, exercise, or defence of legal claims.

Please note that withdrawal of consent for essential data (e.g., KYC, repayment details) may affect your ability to access or continue using certain services. In certain limited cases, we may process your data without consent if it is: Necessary for the performance of a contract to which you are a party, required under a legal obligation, In the interest of credit risk assessment by regulated lending partners, or to detect or prevent fraud, cybercrime, or misuse of our services. Your continued use of our services following changes in privacy policy constitutes your reaffirmation of the consent provided, unless explicitly withdrawn.

13. GENERAL

Abhi Rupee reserves the right to amend or update this Privacy Policy periodically to reflect changes in legal or regulatory obligations, business practices, or service enhancements. Any changes will be effective prospectively and will be communicated through our website/app, app, or other appropriate means. We recommend reviewing this policy at regular intervals.

This Privacy Policy does not confer any rights or remedies upon any third party, nor does it create any contractual or legal obligations beyond those mandated by law or explicitly agreed to in our service agreements.

This Privacy Policy shall be governed by and interpreted in accordance with the laws of India, and any disputes arising from or related to this policy shall be subject to the exclusive jurisdiction of the courts located in Mumbai.

If any provision of this Privacy Policy is found to be invalid or unenforceable under applicable law, such provision shall be severed, and the remainder of the policy shall continue in full force and effect.

In case of any ambiguity or conflict in interpretation, the English version of this policy shall prevail. Headings are for reference purposes only and do not affect interpretation.

14. DISCLAIMER

The information, content, and materials provided on the Abhi Rupee website/app, mobile application, and related platforms are made available on an “as is” and “as available” basis, for general informational purposes only. All the information on our website/app is published in good faith and for general information purposes only. Abhi Rupee does not make any warranties about the completeness, reliability, and accuracy of this information. Any action you take upon the information you find on this website/app is strictly at your own risk. We will not be liable for any losses and/or damages in connection with the use of our site/app.

From our site/app, you can visit other site/apps by following hyperlinks to such external site/apps. While we strive to provide only quality links to useful and ethical website/apps, we have no control over the content and nature of these site/apps. These links to other website/apps do not imply a recommendation for all the content found on these site/apps. Site/app owners and content may change without notice and may occur before we have the opportunity to remove a link that may have gone ‘bad’.

Please be also aware that when you leave our website/app, other site/apps may have different privacy policies and terms that are beyond our control. Please be sure to check the Privacy Policies of these site/apps as well as their “Terms of Service” before engaging in any business or uploading any information.

Nothing on our platform constitutes financial, legal, or professional advice. You should independently verify any information before relying on it and consult appropriate advisors where necessary.

Abhi Rupee shall not be liable for any direct, indirect, incidental, consequential, or punitive damages, including but not limited to loss of profits, loss of data, or loss of business opportunities arising out of or in connection with your access or use of the platform or reliance on any material provided therein.

We do not guarantee that access to our platform will be uninterrupted, error-free, or free from viruses or other harmful components. You are responsible for implementing adequate safeguards before downloading any material from our platform.

15. REVIEW OF THE POLICY

The Policy should be subjected to an annual review by the management and modifications, if any warranted, to ensure that it remains accurate, complete, and aligned with applicable legal, regulatory, and operational requirements, should be taken up with the approval of the Board. If there are any amendments in the regulations, revision in the policy should be staged for the Board’s approval in the immediately ensuing Board Meeting, after the amendments are notified by the regulation. The most recent version of Privacy Policy will always be available on our website/app and mobile application. Users are encouraged to review this policy regularly to remain informed. Continued use of our services after such changes will constitute acceptance of the revised Policy.