1. INTRODUCTION

This Privacy Policy describes how ContriveLabs (“Company”, “we”, “us”, “our”), collects, uses, stores, processes, and protects information when users (“User”, “you”) access and use our financial workflow management application Fynanz ("Application").

By registering or using the Application, you consent to the practices described in this Privacy Policy and Terms & Conditions.

2. NATURE OF THE APPLICATION

The Application is a financial workflow management software tool designed to help lenders manage loan records, borrower details, repayment tracking, and related operational data.

The Company:

• Does not provide loans
• Does not act as an NBFC
• Does not collect or process borrower repayments
• Does not access bank accounts
• Does not perform credit underwriting

3. INFORMATION WE COLLECT

We may collect the following categories of information:

4. DATA OWNERSHIP

All loan and borrower data entered into the Application remains the property of the User.

The Company does not claim ownership of User data.

5. PURPOSE OF DATA COLLECTION

We collect and process data for:

• Account creation and authentication
• Subscription management
• Application functionality
• Customer support
• Security monitoring
• Legal compliance

We do NOT sell personal data.

6. DATA STORAGE & RBI DATA LOCALIZATION COMPLIANCE

In alignment with applicable Indian regulatory principles, including data localization requirements applicable to financial data:

• All financial and transactional data is stored on servers located in India.
• No financial data is stored outside India.
• Cross-border transfer, if any, shall be limited to non-financial operational metadata and shall comply with applicable Indian laws.

Users are responsible for ensuring that their use of the Application complies with all applicable RBI regulations and data handling laws relevant to their business.

7. DATA SECURITY

We implement industry-standard safeguards, including:

• SSL encryption
• Encrypted database storage
• Role-based access controls
• Secure authentication mechanisms
• Periodic security monitoring

However, no digital Application can guarantee absolute security.

8. DATA RETENTION

We retain User data:

• For as long as the User maintains an active subscription
• As required by applicable law
• For legitimate business and legal purposes

Users may request deletion of account data by contacting us at: support@contrivelabs.org

Additional account deletion points:

• Account deletion requests are processed through our support channel.
• Account deletion is permanent and may result in loss of access to records and reports.
• Certain records may be retained for a limited duration where required for legal, compliance, security, or operational obligations.

For more details, please visit: https://contrivelabs.org/delete-account

9. USER RESPONSIBILITY

Users are solely responsible for:

• Lawful collection of borrower information
• Obtaining borrower consent where required
• Compliance with RBI, NBFC, IT Act, and other applicable laws
• Lawful recovery practices

The Company does not monitor borrower communications or recovery activities.

10. THIRD-PARTY SERVICES

We may use third-party service providers for:

• Cloud hosting
• Analytics
• Payment processing
• Customer support

Such providers are bound by confidentiality and security obligations.

11. CHILDREN’S PRIVACY

The Application is not intended for individuals under 18 years of age.

12. LIMITATION OF LIABILITY

The Company shall not be liable for:

• Accuracy of data entered by Users
• Misuse of borrower information
• Loan disputes
• Recovery practices
• Regulatory violations by Users
• Financial losses arising from User decisions

Use of the Application is at the User’s sole risk.

13. CHANGES TO POLICY

We may update this Privacy Policy at any time. Continued use of the Application constitutes acceptance of changes.

14. CONTACT

For privacy concerns:

support@contrivelabs.org

1. NATURE OF SERVICE

The Application is a software-as-a-service (SaaS) tool providing loan record management and workflow tracking functionalities.

The Company:

• Is NOT a Non-Banking Financial Company (NBFC)
• Is NOT a bank
• Is NOT a lending institution
• Does NOT provide loans
• Does NOT collect EMIs
• Does NOT process borrower payments
• Does NOT engage in recovery activities
• Does NOT access bank accounts

The Company is solely a software provider.

2. USER ELIGIBILITY

You represent that:

• You are legally competent to contract
• You are engaged in lawful business activities
• You comply with all applicable laws

3. USER RESPONSIBILITIES

You are solely responsible for:

• Loan documentation
• Borrower agreements
• Interest calculations
• Compliance with RBI & Incme Tax regulations
• Fair Practices Code adherence (if applicable)
• Recovery methods
• Consumer protection compliance

The Company does not verify or validate loan legality.

4. DISCLAIMER OF REGULATORY RESPONSIBILITY

The Application does NOT:

• Underwrite loans
• Approve borrowers
• Act as intermediary
• Facilitate credit disbursement
• Provide financial advice

All regulatory compliance obligations rest entirely with the User.

5. SUBSCRIPTION & PAYMENT

• Subscription fees are billed monthly or yearly.
• Payments are non-refundable unless required by law.
• Failure to pay may result in suspension.

App store billing policies may apply.

6. NO LIABILITY FOR USER CONDUCT

The Company shall not be responsible for:

• Harassment or unlawful recovery practices
• Regulatory violations
• Fraudulent loans
• Data misuse
• Borrower disputes
• Litigation involving Users

The User indemnifies and holds harmless the Company from any claims arising from User activities.

7. LIMITATION OF LIABILITY

To the maximum extent permitted by law:

• The Application is provided “AS IS”.
• The Company makes no warranties regarding accuracy, reliability, or uninterrupted service.
• Total liability shall not exceed the subscription fee paid in the preceding 3 months.

8. INDEMNIFICATION

The User agrees to indemnify and defend the Company against:

• Government penalties
• Borrower claims
• Legal proceedings
• Regulatory investigations
• Third-party damages arising from User conduct

9. TERMINATION

We may suspend or terminate access if:

• Laws are violated
• Terms are breached
• Fraudulent activity is suspected

10. INTELLECTUAL PROPERTY

All software, design, branding, and technology remain the exclusive property of the Company.

Users receive a limited, non-transferable license.

11. FORCE MAJEURE

We are not liable for delays due to events beyond reasonable control.

12. GOVERNING LAW

These Terms are governed by the laws of India.

Jurisdiction: Courts of Bengaluru, India.

13. ACCEPTANCE

By clicking “I Agree” during registration, the User:

• Confirms understanding
• Accepts all terms & conditions
• Agrees to be legally bound