Thank you for visiting www.atmoonpe.com, an online platform which is independently owned and managed by At Moon Ventures Private Limited, for providing the services in India. In this Privacy Notice “we”, “our” and “us” refers to the Company and “you” and/or “your” refers to the User(s) of the Website. Your visit to this Website is subject to this privacy, security and cookies policy (“Privacy Notice”) and other terms and conditions available here in this Website.

Please read this Privacy Notice carefully to make sure you understand how any personal information you provide to us will be handled.

If you use any of our services, you will be regarded as having read and accepted this Privacy Notice.

By mere use of this Website, you expressly consent to our use and disclosure of your personal information in accordance with this Privacy Notice. This document is published and shall be construed in accordance with the provisions of the Information Technology Act, 2000 read with Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data of Information) Rules, 2011 under the Information Technology Act, 2000 and other applicable laws; that require publishing of the Privacy Notice for collection, use, storage and transfer of sensitive personal data or information. The Company is committed to ensuring that your privacy is protected. This Privacy Notice is provided to explain our policies and practices regarding the collection, use, and disclosure of information about you. That’s why we insist upon the highest standards for secure transactions and user information privacy. Please read the following statement to learn about our information gathering and dissemination practices.

In the course of using this Website or availing the services offered on the Website vide the online application forms, communication services etc., the Company and its affiliates may become privy to the personal information of the users, including information that is of a confidential nature.

We know that you care how information about you is used and shared, and we appreciate your trust that we will do so carefully and sensibly. We are strongly committed to protecting your privacy and have taken all necessary and reasonable measures to protect the confidentiality of your information and its transmission through the world wide web and the Company shall not be held liable for disclosure of the confidential information when in accordance with this Privacy Notice. This Privacy Notice describes how we handle your personal information for our services on this Website.

INFORMATION WE COLLECT

We collect and process information which:

• you give to us when you register with us, such as your name and contact details.

• we collect about you based on your use of our website or from your mobile device if you are using our app.

• we receive from other sources, such as third parties who give us information about you • is collected from cookies.

We may collect and process the following data about you:

Information you give us. You may give us information about you when you register for our service or by communicating with us. This includes information you provide when you participate in discussion boards, answer specific questions on our website, provide us with feedback, participate in surveys, and when you report a problem.

The information you give us may include:

• Title

• Name

• Income

• Email address

• Date of birth

• Phone number

• Monthly expenditure

• Residential status

• Employment status

• Address history

• Bank

• Property value

• Deposit • Monthly rental income

• Mortgage term

• Mortgage amount • Years left on mortgage

• Current monthly repayments

• Current mortgage balance

Information we collect about you based on your use of our website or apps. Each time you visit our website or use our app we may automatically collect the following information:

• technical information, including the Internet protocol (IP) address, your login information, browser type and version, time zone setting, operating system and platform.

• information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our website (including date and time); services you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number Information we receive from other sources. We may receive information about you if you use any of the websites we operate or the other services we provide. We are also working closely with third parties (including, for example, business partners, service providers, advertising networks, analytics providers, search information providers, social media) and may receive information from them, whether or not you have availed a service with them, what other services you may have used, and other such details. Information collected from cookies. We and our service providers collect information about your use of our website from cookies. For more on how we use cookies and how to decline them or turn them off please read our Cookies Policy.

Other mobile information for mobile users. If you are using our app on a mobile device and you have consented for us to do so (where necessary), we may collect the following information from your device:

• your precise location – longitude and latitude details with the time that the details are captured.

• call log details – we will access your phone call history (this includes the phone numbers used for calls or SMS messages sent or received, duration of calls and the time of the communication). We do not access the content of the text messages.

• the amount of mobile and Wi-Fi data which other applications on your phone use (this is the upload and download usage per applications, total upload and download usage for the device and the time spent in the applications)

• device information or operating system version for your mobile device.

• battery charging behavior – we receive notification of changes to your battery as they occur Recording telephone calls and other communications. We may monitor or record telephone conversations or other communications between you and us. If you choose to provide us with personal information, you consent to the transfer and storage of that information on our servers and use of your personal information as mentioned in the Privacy Notice. You hereby authorise and permit the Company to disclose, from time to time, any information on or relating to you, to any of its subsidiaries or affiliates or to any governmental authority, statutory authority, judicial authority, associated partners, whether in India or any other jurisdiction, or any other third party or the Company’s consultants, advisors or service providers or commercial partners, and also to use and analyses such information for generating management reports as provided in the Company’s Privacy Notice, without requirement for any further consent from you at any point of time.

HOW WE USE THE INFORMATION

We use information we hold about you to provide our services to you and improve those services, administer your account and communicate with you and to use information on an anonymous basis for research, profiling and analytical purposes.

Information you give to us or we collect from third parties on your behalf as part of our services. We will use this information to:

• administer your account and relationship with us and to, communicate with you by telephone, mail, email, text (SMS) message or other electronic means.

• verify your identity as part of our identity authentication process.

• provide you with information and services.

• where you have provided your consent for us to market to you, provide you with information about other services we feel may interest you or be best for you.

• notify you about changes to our services.

• ensure that content from our website is presented in the most effective manner for you and your device.

• aggregate it on an anonymous basis with other data for data analytical and reporting purposes.

• undertake analysis and profiling of your information in order to identify and inform you of services that we consider are likely to interest you or be suited to your circumstances or to enhance our services.

Information we collect about you based on your use of our website. We will use this information:

• to administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.

• to improve the service we offer you such as understanding the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you • as part of our efforts to keep our website safe and secure and to prevent fraud.

• to make recommendations about the services that may be of interest.

Information we receive from other sources. We may combine this information with information you give to us and use this information and the combined information for the purposes set out above.

Recording telephone calls and other communications. We will use telephone recordings or transcripts of communications to check your instructions to us, analyze, assess and improve our services, for training and quality purposes and for the purposes of investigating any complaint you may make, or as evidence in any dispute between you and us.

Use of other information for mobile users on our app.

• We use location data because it helps us to better understand issues relating to people who haven’t used much of our services before and to better offer services to those people. We will not share location data with any third parties.

• We collect log details and other app usage data because this assists us in categorizing certain patterns or behaviour.

• We also use the call log details, data usage for external applications, device information and battery charging information to improve the performance of our apps and to refine the user experience. For example, we use the device information to check whether updates we are making to our apps will work on your phone, and to check how our apps are affecting your battery life.

• This data collection will be used for the purposes of modelling and analysis to ascertain if this data can be used to assist those individuals with difficulty in accessing their financial well-being and to protect you from fraud. If we determine that the information collected does not prove to be useful for these purposes, we will cease to collect it and it will be deleted. We will keep you informed of any significant changes to this type of data collection.

What we will never do. Rest assured, we will never sell your information to third parties.

WHO WE MAY SHARE DATA WITH:

We may share your data with other members of our group and with other third parties, such as our service providers, advertisers and fraud prevention agencies.

We may need to disclose your data to others to ensure the smooth provision to you of the services and information you request. Your data may be disclosed to the other entities as described below.

These third parties act on our instructions and are processors of your information.

We may share your data with other members of our group and with other third parties, such as our service providers, advertisers and fraud prevention agencies.

Group company. We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries.

Selected third parties. We may also share your information with selected third parties including:

• Fraud prevention agencies, to prevent crime and trace those responsible.

• Service providers, such as our business partners who offer you services.

• assess if you are an existing customer and for fraud prevention purposes.

• conduct analysis to provide you with better services in the future, and for segmentation purposes.

• pre-fill an application form with the service provider.

• assess your probability of being accepted for a service.

Fraud Prevention Agencies. We will share your personal information with fraud prevention agencies. If false or inaccurate information is provided and fraud is identified, details of this fraud will be passed to these agencies. Law enforcement agencies may access and use this information. We and other organizations may access and use from other countries the information recorded by fraud prevention agencies.

We shall also share personal data with other organizations outside of the Company in the following circumstances:

i. Satisfy any applicable law, regulation, legal process or enforceable governmental request.

ii. Enforce applicable terms of use, including investigation of potential violations thereof.

iii. Protect against imminent harm to the rights, property or safety of the Company, its users or the public as required or permitted by law.

WHAT IS THE LEGAL BASIS FOR US USING THE INFORMATION:

We make we have appropriate legal bases on which to collect, use and share data about you. If you have any questions about the lawful bases upon which we collect and use your personal data, you can contact us.

Our lawful bases may include consent (where you have given consent), contract (where processing is necessary for the performance of a contract with you (such as delivering our core services to you) and our own legitimate interests.

Performance of a contract. We need you to give us the information you provide, and to collect information about you from third parties in order for us to provide you with our services as agreed in our contract with you. We cannot provide our services to you without collecting the information you give us because we need certain information from you to be able to give you services.

For other types of information (such as the information we collect based on your use of the website and information we receive from our sources about you), we process this information for the purposes of providing our services to you as agreed in our contract and for the purpose of to enable us to:

• provide a secure website to our customers.

• analyze our users’ behaviour and preferences, and information collected from users’ devices in order to have information required to be able to improve the services we provide to our customers and the user experience on our website. Consent. We will always seek your consent to process certain types of information where we are legally required to do so. You have the right to withdraw or decline your consent at any time.

Legitimate interests. We may process your personal data for the purposes of our legitimate interests or for the legitimate interests of our service providers or other suppliers provided that such processing does not outweigh your rights and freedoms. As an example, we may process your personal data to:

• display tailored service offers to you.

• comply with laws that apply to us.

• provide you with our service, including for the purpose of quality control and analysis.

• protect you and us from fraud or other threats.

• conduct analysis, segmentation and profiling of your data in order to provide you with direct marketing communications.

• improve our service and manage our customer relationships. Where we rely on legitimate interests, you have the right to object at any time.

DIRECT MARKETING AND HOW YOU CAN CHANGE YOUR PREFERENCE:

We offer you the opportunity to receive marketing information from us. You can opt out easily of receiving marketing from us at any time.

We will normally send direct marketing by email if we have your email address but may choose to contact you via other methods.

You may receive the following types of communications from us:

• Service recommendations – we’ll get in touch with personalised, timely service recommendations that can help you improve your financial situation. We will only ever send these if you explicitly consent to receiving them and you can unsubscribe whenever you like.

• Content communications – we’ll send you content such as tips, research, features and news, coaching programs on how to keep on top of your money and other related content. You can unsubscribe from these at any time and we will never spam your inbox.

If you would like us to stop sending direct marketing to you, we offer simple ways to do this. Whenever you receive direct marketing you will be given an option to unsubscribe. You may also update your preferences [here].

You can also tell us that you do not wish to receive any more marketing communications at any time by writing, with your full name, address and other contact details (to enable us to find your records), to [email protected]

HOW LONG WE KEEP YOUR INFORMATION FOR?

We take the security of your data very seriously and use strict procedures to protect it. Whenever we transfer personal data, we ensure that appropriate safeguards are in place to protect the data.

All information you provide to us is stored on our secure servers.

We do our best to protect your personal data, but we cannot guarantee the security of your data transmitted to our website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access, loss or damage.

Where possible, we try to only process your information within the UK and European Economic Area (EEA). If we or our service providers transfer personal data outside of the UK or EEA, we always require that appropriate safeguards are in place to protect the information when it is processed. Part of our customer services function is based in India. We have put in place safeguards to protect personal data processed in or accessed from India.

LINK TO AND FROM THIRD PARTY WEBSITES:

If you follow a link to or from our website to a third party website, please be aware that these websites have their own privacy policies.

Our website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies.

AUTOMATED DECISION MAKING:

We use an automated decision making system to make automated decisions based on personal information we have about you. This helps us to make sure our decisions are quick and fair, based on what we know.

Identity verification. We use an automated decision making system to verify the details you provide against those held by third party providers. If you do not pass the check using the automated system, we cannot provide our services to you without being able to verify your identity.

Tailored services. We may use your information to predict the probability that you may be accepted for a services or to determine the best order or manner in which to display services to you.

Tailored communications. We want to make sure we’re only sending you emails that are relevant to you, and so we will use your personal information to determine which content you may be more interested in receiving.

You’ve the right not to be subject to a decision based solely on automated processing, including profiling. We understand that not everyone is comfortable with decisions being left entirely up to machines. If you have any questions about automated decision making, please contact us via [email protected]

YOUR RIGHTS:

You can exercise specific rights with regards to the data that we hold about you.

We will provide you with the necessary tools and contact details to be able to exercise your statutory rights regarding the information that we hold about you. You will be able to:

• Correct your data: you will usually be able to amend any information that we hold about you that is inaccurate or incomplete through the settings in your account.

• Request access to your data: you can ask for access to the personal data that we hold about you so that you can check that we are using your information in accordance with data protection law.

• Erase your data: you can ask us to fully or partially delete your personal data where there is no compelling reason for us to keep using it, although we may not be able to continue to provide our services. We may keep your email address to make sure the restriction is respected in future. We also have the right to continue using your information if such usage is necessary for compliance with our legal obligations.

• Download your data or send it to another controller: you can obtain a copy of the data you provided us in a machine-readable format. In addition, where certain conditions apply, you have the right to have such information transferred directly to a third party.

• Object to the use of your data: you can ask that we no longer use your personal data where that use is based on a legitimate interest.

• Restrict the use of your data: You have the right to ‘block’ or suppress further use of your information in certain circumstances (for example, where you think the information we are using about you is inaccurate, whilst we verify its accuracy). When usage is restricted, we can still store your information, but may not use it further.

• Right to withdraw consent: If you have given your consent for us to use your information, you have the right to withdraw your consent at any time. This can be done by contacting our Grievance Officer.

For the exercise of any of your rights, you can also contact us at [email protected]

YOU HEREBY REPRESENT TO THE COMPANY THAT:

i. The information you provide to the Company from time to time is and shall be authentic, correct, current and updated and you have all the rights, permissions and consents as may be required to provide such information to the Company.

ii. Your providing the information to Company’s consequent storage, collection, usage, transfer, access or processing of the same shall not be in violation of any third party agreement, laws, charter documents, judgments, orders and decrees.

Your information will primarily be stored in electronic form however certain data may also be stored in physical form. We may enter into agreements with third parties (in or outside of India) to store or process your information or data. These third parties may have their own security standards to safeguard your information or data and we will on commercial reasonable basis require from such third parties to adopt reasonable security standards to safeguard your information / data.

ACCOUNT PROTECTION:

Your personal data are treated strictly confidential. To this purpose, the Company uses several security techniques including secure servers, firewalls and encryptions, as well as physical safeguard of the locations where the data are stored. We have in place appropriate administrative, technical, physical safeguards and security measures to protect the personal data you provide on this Website against accidental, unauthorized or unlawful loss, destruction, damage, alteration, access, disclosure or use and any other unlawful forms of processing. When we collect payment card details electronically, we use encryption coding.

In accordance with Information Technology Act 2000 and rules made there under, the name and contact details of the Grievance Officer are provided below: The Grievance Officer:

Name of the Company: Moon Ventures Private Limited

Address: 8/102 Shanti Garden Sec-6CHS Ltd Opp. Surya Shopping Centre, BHD Royal Col, Thane – 401107, Maharashtra, India.

YOUR RESPONSIBILITY FOR THE INFORMATION YOU PROVIDE:

You may complete a sign up process as part of your use of this Website which may include the creation of a username, password and/or other identification information. Any username, password and/or other identification information must be kept confidential by you and must not be disclosed to, or shared with, anyone.

COPYRIGHT, TRADEMARK, AND OTHER INTELLECTUAL PROPERTY PROTECTION:

Atmoonpe and its logo is a registered trademark of Atmoonpe and all materials on this Website are protected by copyright, trademark, and other intellectual property rights. Any unauthorized use of any such information or materials may violate copyright laws, trademarks laws, intellectual property laws, and other laws and regulations.

We have copyright over this Privacy Notice. Use by third parties, even by way of extract, for commercial purposes is not allowed. Infringements may be subject to legal action.

TERMINATION:

You or we may suspend or terminate your account or your use of this Website at any time, for any reason or for no reason. You are personally liable for any charges incurred through your account prior to termination. We reserve the right to change, suspend, or discontinue all or any aspects of this Website at any time without notice.

INDEMNIFICATION

You agree to defend, indemnify and hold the Website and the Company harmless, on demand, from and against any and all claims, damages, costs, and expenses, including attorneys’ fees, arising from or related to your use of the Website.

CHANGES WE MAKE TO OUR PRIVACY NOTICE:

Any changes we may make to our Privacy Notice in the future will be posted on this page and, where we decide it is appropriate, notified to you by email. Please check back frequently to see any updates or changes to our Privacy Notice.

CONTACT US:

You can address any questions, comments, complaints or requests regarding this Privacy Notice to the Grievance Officer at 02/8 Shanti garden sector 6 Mira road east, 401107, Maharashtra.

DISPUTE RESOLUTION:

In the event of any dispute, difference or claim arising out of this Privacy Notice the same shall be settled in accordance with the Laws of India through regular judicial process and the courts of Mumbai, India shall have exclusive jurisdiction.

CONSENT TO THIS NOTICE:

By accessing our Website, you agree to this Privacy Notice. This document supersedes any prior communication on this topic and reflects the entire and exclusive Privacy Notice for this Site. We may change our Policy by posting a new version of it on our Website.

Cookies Policy

OVERVIEW OF OUR COOKIE POLICY: The Company uses cookies for a variety of purposes, including ensuring that our website functions as expected, remembering your preferences and gathering data on the users of our website and our services.

By using our website (through any device) you agree that this Cookies Policy, together with our Privacy Notice and Terms, applies to that use. References to our website below include references to our apps.

We are committed to protecting you and any information (anonymous or otherwise) that we collect about you online. This section tells you about how and why we use cookies, and how this allows us to improve our service

If you wish to use our website, but would like us not to set cookies in your browser, you can disable or remove the cookies. Details on how to do this are set out below. Please note that disabling or removing the cookies we or our third party service providers set may impact the functionality and security of our website and our ability to provide our services to you.

We reserve the right to make changes to our Cookies Policy. Any changes we may make to our Cookies Policy in the future will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our Cookies Policy. Your continued use of our website is taken as your agreement to any such changes.

WHAT ARE COOKIES:

Cookies are files containing small amounts of information downloaded to your device. We and our third party service providers use both session cookies and persistent cookies. We use cookies for a range of purposes (please click here for more information), including to remember any preferences you’ve set and to improve usability of the website for you and other users.

Cookies are files containing small amounts of information which are downloaded to the device you use when you visit a website. Your web browser (such as Internet Explorer, Mozilla Firefox, Google Chrome or Safari) then sends these cookies back to our website or application on each subsequent visit.

We and our third party service providers use the information we obtain about you through the use of cookies for the following purposes:

• to recognize your device(s) when you visit our website and to remember if you’ve set any preferences on our website. This enables us to personalize our content for you and greet you by name.

• to temporarily store data as part of, for example, customer surveys.

• to test new content and evaluate its effectiveness.

• to remember if you’ve been informed of our Cookies Policy, Privacy Notice and other Terms before.

• to recognize and count the number of visitors to our website and see how you navigate our website when you are visiting it (including tracking page usage and paths used by visitors through our website; and tracking use of our Internet banner advertisements and other links from our marketing partner’s websites to our website).

• to improve our website’s usability and keep our services easy to use and up to date.

• to allow you to share pages with social networks such as LinkedIn, Facebook and Twitter / to support social media components, like Facebook or Twitter (where our website uses a plugin from these third party platforms).

• to ensure you don’t miss information that is relevant to you (including targeting our website content, targeting our marketing campaigns and direct marketing emails, targeting our Internet banner advertisements on our website and on other websites).

• to analyse use of our website (including for performance and statistical analysis, sales and marketing research). To stop us setting these cookies you will need to set up your browser to reject all cookies (see further below).

We may also combine this web usage data with other information we have collected about you. We store this information so that we have a better and more specific understanding of the way users are using our website, and their preferences and interests, for the purposes set out above.

Cookies may be either “persistent” cookies or “session” cookies, depending on how long they are used.

• Persistent cookies remain on your device after you have closed your browser, and allow a website to remember your actions and preferences. They are activated each time you visit the website where the cookie was generated. Sometimes persistent cookies are used by websites to provide targeted advertising based on the browsing history of the device. They are stored by the browser and remain valid until their set expiry date (unless deleted by the user before the expiry date).

• Session cookies only last for the duration of your visit and are deleted when you close your browser. They facilitate tasks such as allowing a website to identify that a user of a particular device is navigating from page to page, supporting website security or basic functionality.

Many of the cookies we use are session cookies. For example, they help us to ensure the security of your session, and can also keep you signed in to your account while you move between pages.

MORE ABOUT THE COOKIES WE USE This section describes more about the different types of cookies we use. The cookies are both cookies that we set (first party cookies) and cookies that are managed for us by third parties.

Whether a cookie is a first or third party cookie depends on which website the cookie comes from.

• First party cookies are those set by or on behalf of the website visited. All other cookies are third party cookies.

• Third party cookies: In some cases, some of these cookies are managed for us by third parties, but we don’t allow the third party to use the cookies for any purpose other than those listed above.

• Web analytics services: In order to keep our services easy to use and up-to-date, we also use web analytics services to help us understand how people use our website. For example, we can see which parts of our services are most popular, identify when errors occur and test different versions of a page or feature to see which one works best. These web analytics services may be designed and operated by other companies on our behalf. They do this using small invisible images known as “web beacons” or “tracking pixels” that may be included in the digital services on our website.

These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose. We use retargeting and online behavioral advertising to market the Company which employs targeting cookies to deliver you more targeted advertising.

You can read more about the cookies we and our trusted service providers use below.

By using our website, you agree that we can place both first party and third party cookies and web analytic services on your device.

TURNING COOKIES OFF:

You can reject cookies within your browser, but please note that certain parts of our website may no longer function as expected.

In all modern browsers you may elect to reject cookies and/or enable do not track features, and we provide instructions on how to do this below. Please note however that by doing so parts of our website may no longer function as expected. For example, if you delete cookies any preferences they record will be lost. This includes for example where you have opted out from cookies, as this requires an opt-out cookie to be set.

If your concerns are based around third party cookies, then we recommend you just reject those cookies, rather than all cookies so that we can still provide you with the functionality you expect.

If you do wish to stop your browser from accepting cookies, see the following pages:

• Mozilla Firefox: http://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences.

• Google Chrome: https://support.google.com/chrome/bin/answer.py?hl=en&answer=95647&p=cpn_cookies.

• Internet Explorer: http://windows.microsoft.com/en-us/windows-vista/block-or-allow-cookies.

• Safari: https://support.apple.com/kb/ph21411?locale=en_GB.

CONTACT US :

If you have any questions about our cookies or this Cookies Policy, please contact us on [email protected].