Dear User,

Thank you for choosing to be part of our community at Brú Finance, doing business as Brú (“Brú”, “we”, “us”, or “our”). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about our policy or our practices regarding your personal information, please contact us at [email protected]. You trust us with your personal information when you visit our mobile application and use our services. We take your privacy very seriously. In this privacy policy, we seek to explain to you in the clearest way possible what information we collect, how we use it, and what rights you have about it. Please take some time to read through it carefully, as it is important. If there are any terms in this privacy policy that you disagree with, please discontinue the use of our Apps and our services. This privacy policy applies to all information collected through our mobile application ("Brú") and/or any related services or events (we refer to them collectively in this privacy policy as the "Services"). Please read this privacy policy carefully, as it will help you make informed decisions about sharing your personal information with us.

1. WHAT INFORMATION DO WE COLLECT?

In Short: We collect personal information that you provide to us. We collect the personal information you voluntarily provide us when registering at the Apps, expressing an interest in obtaining information about us or our products and services, participating in activities on the Apps, or otherwise contacting us. Social Media Login Data; We may allow you to register using social media account details, like your Facebook. If you choose to register this way, we will collect the Information described in the section "HOW DO WE HANDLE YOUR SOCIAL LOGINS" below. All personal information you provide must be true, complete, and accurate, and you must notify us of any changes to such personal information. Information automatically collected In Short: Some information — such as IP address and/or browser and device characteristics — is collected automatically when you visit our Brú App. We automatically collect certain information when you visit, use, or navigate the Apps. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Apps and other technical information. This information is primarily needed to maintain the security and operation of our Apps and for our internal analytics and reporting purposes. Like many businesses, we also collect information through cookies and similar technologies.

2. HOW DO WE USE YOUR INFORMATION?

We use personal information to provide you with services & products you explicitly requested, to resolve disputes, troubleshoot concerns, help promote safe services and updates, customize your experience, detect & protect us against error, fraud, and other criminal activity, enforce our terms and conditions, etc. We use the information we collect or receive: To facilitate account creation and the logon process. If you link your account with us to a third-party account (such as your Facebook account), we use the information you allow us to collect from those third parties to facilitate the account creation and the logon process for the performance of the contract. See the section below, "HOW DO WE HANDLE YOUR SOCIAL LOGINS," for further information. To send administrative information to you. We may use your personal information to send you product, service, and new feature information and/or information about changes to our terms, conditions, and policies.

3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?

We only share information with your consent to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations. We will not sell, share or rent your personal information to any 3rd party or use your email address/mobile number for unsolicited emails and/or SMS. Any emails and/or SMS sent by Brú will only be in connection with the provision of agreed services & products and this Privacy Policy. We may process or share data on the following legal basis: Consent: We may process your data if you have given us specific consent to use your personal information for a specific purpose. Legal Obligations: We may disclose your information where we are legally required to do so to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal processes, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements). Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

We may use cookies and other tracking technologies to collect and store your information automatically. A "cookie" is a small piece of information stored by a web server on a web browser so it can be later read back from that browser. Brú uses cookie and tracking technology depending on the features offered. No personal information will be collected automatically via cookies and other tracking technology; however, if you previously provided personally identifiable information, cookies may be tied to such information.

5. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

If you choose to register or log in to our services using a social media account, we may have access to certain information about you. Our App allows you to register and log in using your third-party social media account details (like your Facebook logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile Information we receive may vary depending on the social media provider concerned but will often include your name, e-mail address, friends list, profile picture, and other information you choose to make public. We will use the information we receive only for the purposes described in this privacy policy or otherwise made clear to you on the Apps. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their privacy policy to understand how they collect, use, and share your personal information and how you can set your privacy preferences on their sites and apps.

6. DO WE MAKE UPDATES TO THIS POLICY?

Yes, we will update this policy to comply with relevant laws or changes in our policies from time to time. We may update this privacy policy from time to time. The updated version will be indicated by an updated “Revised” date, and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy policy, we may notify you by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information.

OUR DATA INTEGRITY POLICY

Our all-encompassing Data Integrity Policy covers the following avenues:

  • 1.Data management has become a very important component with the volume growing exponentially.

  • 2. Data reliability, consistency as well as quality management will be taken up across the following processes that are a part of the data lifecycle:

    a)Collection of raw data (via web and app user interfaces; and APIs from third-party vendors)
    b)Processing of the raw data into structured format (using MongoDB and JSON objects retrieved from the API callbacks)
    c)Computation of the data (using backend business logic)
    d)Reporting of the data (via frontend admin panels, exports, database storage)
    e)Retention of the data (via database storage on the cloud, as well as updating of an immutable ledger in our underlying blockchain system)
    f)Archival and retrieval of the data (via database storage on the cloud and a blockchain explorer that we have built)
    g)Authorized destruction of the data (via Update operations on our database and appending new transactions to the blockchain system showing addition/updation to the historical data)

  • 3.Brú’s data management will follow the standard of being ‘Complete, Consistent, Enduring and Available.’

  • 4. Brú and its associated systems will be collecting data on the following fronts:
    a) Personal information to build the user’s profile.
    b)Deposit and Loan information is based on the data entered in our app.
    c) Deposit and Loan information is based on the data shared with us through our APIs by a third party.
    d) Clickstream data is aggregated and processed by reliable analytics platforms such as Google Analytics and Firebase.

  • 5. Brú will be following the below-mentioned data privacy policies:
    a) Personally Identifiable Information (PII) won’t be shared with Google via the Analytics codebase.
    b)The semi-public Blockchain Explorer will not display PIIs as a part of the transaction data shown on the explorer views.

  • 6.We understand that mismanagement of the data, or inclusion of suspicious data in our systems, will majorly bring a bad name to the reputation of the company, as well as hinder our efforts of helping farmers and other customers by making their lives significantly easier as we enable them to avail working capital and personal finance against their produce deposited at a nearby warehouse, with an all-encircling digital process.

HOW CAN YOU CONTACT US ABOUT THESE POLICIES?

If you have questions or comments about this policy, you may email us at [email protected].