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Privacy Policy

Effective Date: 1 Aug, 2025

Entity: BatFIN Private Limited ("BatFIN", "Company", "We", "Us", "Our")

By accessing or using this website, mobile application, or any service offered by BatFIN Private Limited, you (“Visitor,” “Vendor,” “User,” “You,” or “Your”) consent to the collection, use, processing, and disclosure of your information in accordance with this Privacy Policy (“Policy”). By submitting your information to BatFIN, you are deemed to have given your express permission for the processing of your information in the manner set out in this Policy.

This Privacy Policy constitutes an electronic record under the Information Technology Act, 2000, and the rules framed thereunder, and it does not require any physical, electronic, or digital signatures.

1. Introduction

BatFIN Private Limited, engaged in the business of Battery Leasing and related financial services, respects your right to privacy and is committed to protecting your personal and sensitive personal data or information (collectively “Information”).

Our approach is guided by the principle of Privacy by Design and Privacy by Default, ensuring that your data is collected, processed, and stored lawfully and ethically, with adequate safeguards and transparency.

This Policy explains:

  • What types of Information we collect
  • Why we collect and process it
  • How we store, retain, disclose, and secure it
  • Your rights regarding your Information
  • How you can contact us for clarifications

BatFIN complies with applicable privacy laws, including but not limited to:

  • The Information Technology Act, 2000 – Section 43A
  • The Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011
  • Any subsequent amendments, regulations, or sector-specific data protection obligations

2. Scope

This Privacy Policy applies to all:

  • Visitors of BatFIN’s website and mobile applications
  • Vendors, dealers, customers, and business partners who interact with BatFIN
  • Users availing leasing, financing, or other services from BatFIN
  • Applicants submitting information to BatFIN for onboarding, registration, or partnership

This Policy does not apply to information collected by third-party websites, applications, or services you may access through our platform.

3. Definitions

For clarity, the following terms are defined:

  • Personal Information (PI): Any information related to a natural person that can directly or indirectly identify them (e.g., name, address, email, contact number, date of birth).
  • Sensitive Personal Data or Information (SPDI): Information including, but not limited to:
    • Passwords
    • Financial details such as bank account, debit/credit card, or UPI details
    • Biometric information
    • Health-related information
    • Sexual orientation
    • Any information received or processed under lawful contracts deemed “sensitive” under Indian law
  • Non-Personal Information (NPI): Information that cannot directly identify you (e.g., browser type, cookies, anonymized analytics data).
  • Processing: Any operation performed on Information, such as collection, storage, retrieval, usage, disclosure, or deletion.
  • Visitor/Vendor/User: Any individual who accesses or interacts with BatFIN’s platform.

4. Categories of Information We Collect

4.1 Personal Information

  • Full name
  • Gender
  • Date of birth
  • Residential/office address
  • Email address
  • Mobile number
  • Identity proof (PAN, Aadhaar, Voter ID, etc.) for regulatory compliance
  • Photographs or scanned documents submitted during KYC

4.2 Sensitive Personal Data or Information (SPDI)

  • Bank account details, payment card numbers, or UPI information
  • Passwords or PINs used for accessing BatFIN services
  • Biometric identifiers (if collected during onboarding or verification)
  • Health or disability information, only if relevant for insurance or contractual obligations
  • Any information relating to financial status, creditworthiness, or repayment history

4.3 Device & Technical Information

  • IP address
  • Device identifiers (IMEI, MAC address)
  • Geo-location data (only where required for service delivery or compliance)
  • App usage statistics, crash logs, and interaction data

4.4 Vendor/Partner Information

  • Company name, GST number, business address
  • Authorized representative details
  • Payment and settlement accounts
  • Compliance certifications

4.5 Information via Permissions

  • Access to contacts (for referrals or emergency communication, only upon explicit consent)
  • Call logs or history (restricted to service-related verifications and fraud prevention)
  • SMS or email data (only where necessary for automated KYC or OTP validation)

5. Purpose of Collecting Information

Service Delivery

  • To onboard vendors, dealers, and customers into BatFIN’s leasing ecosystem
  • To process lease contracts, payments, settlements, and renewals

Regulatory & Compliance

  • To perform KYC/AML checks
  • To comply with RBI, SEBI, or other statutory requirements
  • To meet obligations under tax and corporate laws

Business Operations

  • To verify identity and prevent fraud
  • To maintain internal records, accounts, and audits
  • To enhance and improve BatFIN’s services

Communication

  • To send service-related alerts, confirmations, and updates
  • To share promotional or marketing material (subject to opt-out rights)
  • To contact users for feedback, surveys, or dispute resolution

Emergency & Safety Features

  • For driver safety or vendor communication in case of emergencies
  • To enable SOS responses if such features are available in BatFIN’s platform

6. Method of Collection

  • Online forms and registrations
  • Mobile application integrations
  • Uploaded documents during KYC
  • Automated systems (cookies, analytics, app tracking)
  • Third-party verification partners (with due consent)

We ensure that only minimum necessary Information is collected to serve the above purposes.

7. Retention & Storage of Information

  • Information is retained only for as long as necessary to fulfil the purposes outlined in this Policy or to meet legal/regulatory obligations.
  • Financial and compliance-related records may be retained for up to 8 years, as per Indian law.
  • Information that is no longer required is securely deleted, anonymized, or destroyed.
  • Data is stored on secure servers located in India, with restricted access. Where cross-border transfers are necessary, adequate contractual and security safeguards are implemented.

8. Security Practices

BatFIN adopts Reasonable Security Practices in line with ISO 27001 and other international standards, including:

  • Encryption of data in transit and at rest
  • Firewalls, intrusion detection, and monitoring systems
  • Role-based access controls
  • Regular security audits and vulnerability assessments
  • Incident response protocols

Despite these measures, BatFIN does not guarantee that unauthorized access, hacking, data loss, or breaches will never occur.

9. Rights of Users

As a user, you have the following rights:

  • Right to Access: Obtain a copy of the personal data we hold about you.
  • Right to Rectification: Correct inaccuracies or update incomplete Information.
  • Right to Withdraw Consent: Revoke permissions at any time, subject to contractual/legal obligations.
  • Right to Deletion: Request deletion of your Information, where retention is no longer required.
  • Right to Restrict Processing: Limit how we process your data under certain circumstances.
  • Right to Data Portability: Receive your Information in a structured, machine-readable format (where applicable).

Requests can be submitted to the Grievance Officer listed in Section 12.

10. Disclosure of Information

BatFIN shall not sell or rent your Information. Disclosure is restricted to:

  • Legal & Regulatory: To comply with court orders, investigations, or statutory authorities.
  • Business Partners: Vendors, service providers, or affiliates who process Information on BatFIN’s behalf, subject to confidentiality agreements.
  • Emergency Situations: To protect safety, property, or public interest.
  • Corporate Transactions: In case of mergers, acquisitions, or restructuring, your Information may be transferred, with notice provided.

11. Cookies & Tracking Technologies

Our website and app may use cookies, beacons, and analytics tools to:

  • Authenticate users
  • Remember preferences
  • Measure performance and improve services
  • Deliver targeted advertisements (with consent)

Users can control cookie settings via browser or device options, but disabling cookies may limit certain functionalities.

12. Grievance Redressal

In compliance with the Information Technology (SPDI) Rules, 2011, BatFIN appoints a Grievance Officer at legal@batfin.in.

Any concerns or requests regarding your Information will be acknowledged within 48 hours and resolved within 30 days.

13. Children’s Privacy

The platform is not intended for minors below the age of 18. If you are under 18, you may access BatFIN’s services only with the involvement of a parent/guardian who consents to this Policy.

14. International Data Transfers

If BatFIN transfers Information outside India, such transfers shall only occur where:

  • The receiving entity provides equivalent levels of data protection
  • Contractual clauses and security safeguards are implemented
  • User consent has been obtained (where legally required)

15. Updates to this Policy

BatFIN reserves the right to update or amend this Privacy Policy from time to time to reflect technological, legal, or business changes. Updated versions will be posted on our website/app with a revised effective date.

Users are encouraged to review the Policy periodically. Continued use of the platform constitutes acceptance of the updated Policy.

16. Governing Law

This Privacy Policy shall be governed by and construed in accordance with the laws of India. Any disputes arising from this Policy shall be subject to the exclusive jurisdiction of the courts in New Delhi, India.