MITRO Fintech Limited ("Mitro Finance", "we", "us", or "our") operates the website located at www. https://mitro.io and other related domains, sub-domains, and mobile applications (collectively, the "Platform"), with links to this privacy policy ("Privacy Policy"). Through the Platform, the Company operates a digitalized facility of providing short-term loans ("Services") to the individual(s) or employee(s) ("Employees" / "Individuals" / "Users") of various companies through an employee-wellness scheme. We have developed this Privacy Policy to explain how we collect, use, and disclose information from and/or about you when you use the Platform or the Services.

We respect your privacy, values and the trust you place in us. Set out below is our
'Privacy Policy' which details the manner in which information relating to you is
collected, used and disclosed.

All visitors to the Platform are advised to read and understand our Privacy Policy
carefully, as by accessing the Platform, you agree to be bound by the terms and
conditions of the Privacy Policy and consent to the collection, storage and use of
information relating to you as provided herein.

BY USING THE PLATFORM, YOU AGREE THAT WE CAN COLLECT AND USE
YOUR PERSONAL INFORMATION AS DESCRIBED IN THIS PRIVACY POLICY. BY
USING THE PLATFORM, YOU AGREE TO THE CONTENTS OF THIS PRIVACY
POLICY AND GIVE YOUR IRREOVACABLE CONSENT TO US FOR COLLECTING
YOUR PERSONAL INFORMATION.

Our Privacy Policy explains:
● What information we collect and why we collect it.
● How we use that information.
● The choices we offer, including how to access and update information.

We have tried to keep it as simple as possible, but if you are not familiar with terms like
cookies, IP addresses, pixel tags and browsers, then read about these key terms first.
Your privacy matters to us so please do take the time to get to know our practices – and
if you have any questions feel free to contact us by sending an email to dataprotection@mitro.io.

A. COLLECTION OF INFORMATION
To provide the best experience to you, we collect and store personal information
provided by you from time to time on the Platform. When you contact us, we keep a
record of your communication to help solve any issues you might be facing. The
personal information that we may collect about you broadly falls into the following
categories:

Information you provide to us

If you are an Employee of a company:

● you will be asked to provide certain contact information that is necessary for the
registration of a Platform-account by an Employee, including name, residential /
employer's complete address, updated residential address, phone number, email
address etc.;
● you will be asked to provide certain identity information, tax registration and/or
related information about you, such as your designation in a company, nature of
work in that company, etc.;
● we will process any information provided to us in connection with disputes or to
support complaints in connection with the Platform or Services utilized via the
Platform. Please note, you may submit disputes or complaints regarding the
Services on the Platform, and under such circumstances, we will process data
provided to us by you that is relevant to the disputes or complaints submitted.
This may include data to the extent relevant to the disputes or complaints that
are being reviewed by the Platform and to the extent that the employee(s) has
provided their explicit consent to their data being shared with us for the purposes
of handling the complaints and/or settling the disputes.


Information that we collect automatically

● If you contact us via our customer services department i.e. chat service,
telephone or email, we may record a copy of your correspondence and may ask
for additional information to verify your identity.
● We may collect contact details and other information of Individuals from publicly
available sources for the purposes of verifying the Individuals and performing due
diligence on the Employees.
● We may collect details of the Individual activities, transactions and interactions
on the Platform including information relating to dispute and complaint records,
communications between us and the Individuals and any information disclosed in
any discussion forum.
● From time to time, we may also collect information, including representative
contact names, addresses, phone numbers, fax numbers and email addresses,
about the existing and prospective Individuals, during or in connection with trade
shows, industry events and/or other functions.
● If you visit our Platform, we will automatically collect certain information from your
device. Specifically, this information may include IP addresses, device type,
unique device identification numbers, browser type, broad geographic location
(e.g. country or city-level location), browsing patterns and details of how you
have interacted with our Platform and the Services available on it. In addition, we
gather statistical information about the Platform and visitors to the Platform
including, browser software, operating system, software and hardware attributes,
pages viewed, number of sessions and unique visitors. Collecting this information
enables us to better understand the visitors who come to our Platform, where
they come from, and what content is of interest to them. We use this information
for our internal analytics purposes and to improve the quality and standard of our
Platform. Some of this information may be collected using cookies and similar
tracking technology, as explained further under the section D "COOKIES" below.


Information that we receive from third parties

● We may receive personal information about you from social media platforms if
you choose to register for a Platform account via a social media account. Exactly
what information we receive will depend on your privacy settings with the
applicable platform, but it would typically include basic public profile information
such as:
1. Your user name or nickname;
2. Your profile picture;
3. Contact details etc.
● We may receive personal information about you from third parties that are
engaged by us to assist with providing verification services and conducting
suitable money laundering and KYC (know-your-customer) checks on Individuals
or Employees. This may include your name, email address, company details and
contact information.
● If you choose to participate in reviewing or rating Services on the Platform, we
may receive personal information about you from third parties that work with us
to conduct reviews into our Services and/or rate us.


1. DISCLOSURE OR SHARING OF PERSONAL INFORMATION
We may disclose (or provide access to) personal information to the following categories
of recipients:
1. Third party business partners, service providers and/or affiliates of Mitro
Finance engaged by us or working with us to assist us to provide Services
to you or who otherwise process personal information for purposes
described in this Privacy Policy or notified to you when we collect your
personal information. Categories of these partners or service providers
include:
● Users of Mitro Finance and their respective affiliates and/or their designated
service providers that work with us to provide processing services such as
software, tools, systems and messaging services for purposes described in this
Privacy Policy;
● our business partners (for example, in order for them to provide you with offers
that may interest you);
● marketing and advertising platforms, such as Google, Twitter, Facebook and
Instagram, and providers of analytics services relating to users' behavior, in order
to tailor the content you see when visiting our Platform. These platforms may
combine information they collect on our Platform with data on their platforms and
data they collect from other websites or through other sources in order to conduct
targeted advertising. The processing activities of these third-party marketing
platforms are governed by their own privacy policies, not this Privacy Policy;
● payment service providers who collect and process personal information to assist
you with settling the payments for transactions through the Platform.
● credit risk assessment providers to conduct risk assessment on the Individuals or
Employees to determine whether an Employee or Individual can be permitted to
make a fund withdrawal;
● cloud computing service providers to provide cloud storage services;
● risk control service providers to assess the security of Individual's or Employees'
accounts and transaction risks; and
● Third party rating / reviewing service providers to carry out reviews of our
Services with customers if you choose to participate in reviewing or rating Mitro
Finance Services;
b. To our professional advisers, law enforcement agencies, insurers, government and
regulatory and other organizations where we believe it is necessary to comply with
applicable laws or to exercise, establish or defend our legal rights or protect your vital
interests or those of any other person, we may also disclose and transfer your personal
information or as otherwise required or permitted by the applicable laws.
c. To an existing or potential User (his/her agents or advisers) in connection with any
actual or proposed purchase, merger or acquisition of any part of our business,
provided that we inform the User that his/her personal information will only be used in
accordance with this Privacy Policy.
d. To any other person with your consent to the disclosure.
We may provide aggregated or anonymized data to third parties, but when we do so,
the information we share is in a de-identified format that does not personally identify
you.

C. RETENTION
We may retain your personal information as long as we have an ongoing legitimate
business need to do so, for example, to provide Services to you, or as required or
permitted by applicable laws, such as tax and accounting laws.
When we have no ongoing legitimate business need to process your personal
information, we may either delete or anonymize it or, if this is not possible (for example,
because your personal information has been stored in backup archives), then we will
securely store your personal information and isolate it from any further processing until
deletion is possible.
D. WHAT ARE YOUR DATA PROTECTION RIGHTS?
We make sure that you are fully aware of all of your data protection rights. Every User is
entitled to the following rights which you can exercise at any time by contacting at the
contact details provided in section F "HOW TO CONTACT US?".
1. The right to access
You have the right to request for copies of your personal data, chargeable or free of
cost, depending upon the type and volume of the data requested.
2. The right to rectification
You have the right to request us, based on our legitimate interests, for correcting or
updating any information you believe is inaccurate and completion of any information
you find to be incomplete.
3. The right to erasure
You have the right to request us to erase, remove or delete your personal data, under
certain conditions.
4. The right to restrict processing
You have the right to request us, in limited circumstances, to restrict the processing of
your personal data as specified in this Policy.
5. The right to object to processing
You have the right to object us processing your data, unless and until it interferes with
our rendering of Services to other Users of the Platform.
6. The right to data probability
You have the right to request us to transfer your personal data that we collect directly
from you or other Users as provided in this Policy.
7. The right to opt-out of marketing communications
You have the right to opt-out of marketing communications we send you at any time.
You can exercise this right by clicking on the unsubscribe or opt-out link in the
marketing e-mails we send you. To opt-out of other forms of marketing (such as postal
marketing or telemarketing), please contact us using the contact details provided in
section F "HOW TO CONTACT US?".
8. The right to withdraw
If we have collected and processed your personal information with your consent, then
you have the right to withdraw your consent at any time. Withdrawing your consent will
not affect the lawfulness of any processing we conducted in accordance with the lawful
processing grounds other than consent.
9. The right to complain
You have the right to complain to a data protection authority about our collection and
use of your personal information. For more information regarding your data protection
rights and our use of your personal data please contact your local data protection
authority.
We respond to all requests we receive from individuals wishing to exercise their data
protection rights in accordance with the applicable data protection laws.
If you are aware of any changes or inaccuracies in this Policy, which in your information,
are not in line with the data protection laws, you should inform us of such changes by
contacting us at the contact details given in section F "HOW TO CONTACT US?".
D. COOKIES
This section explains how we use cookies and similar technologies (we'll refer to them
collectively as "cookies") to recognize you when you visit our Platform.
Why we use cookies?
We use first and third-party cookies for several reasons. Some cookies are required for
technical and/or security reasons in order for our Platform to operate. We refer to these
as "essential" or "strictly necessary" cookies. First-party cookies are mainly served to
enable basic functionality on our Platform; including web analytics cookies that help us
understand how users use our web pages and how we can improve their use. For
example, we use essential or strictly necessary cookies to enable us to recognize you
when you sign in to your Mitro Finance account.
In addition, we also use social media cookies. You may register for Platform
membership and "share" Platform content through social media such as Facebook,
Instagram and Twitter. These websites have their own privacy policies which govern
their use of information, which you can find on the respective websites.
We also use cookies to enable us to track and target the interests of Platform visitors to
enhance the experience on our Platform by researching visiting patterns and conduct
interest-based advertising; assisting our partners to track user visits to the Platforms;
and to track progress and participation in promotions. We use first and third-party
cookies for these purposes.
E. CHANGES TO THIS PRIVACY POLICY
We may update this Privacy Policy from time to time in response to changing legal,
technical or business developments. When we update our Privacy Policy, we will take
appropriate measures to inform you, consistent with the significance of the changes we
make. We will obtain your consent to any material Privacy Policy changes if and when
this is required by applicable data protection laws.
Any changes to this Privacy Policy will be communicated by us posting an amended
Privacy Policy on the Platform. Once posted on the Platform, the new Privacy Policy will
be effective immediately. You can see when this Privacy Notice was last updated by
checking the "last updated" date displayed at the top of the Privacy Notice.
Legal basis for data processing
We process personal information for the purposes set out in this Privacy Policy, as
described above. Our legal basis for processing personal information will depend on the
personal information concerned and the specific context in which we collect it. However,
we will normally collect and process personal information about you only where it is:
● necessary for providing the Services pursuant to the agreement between you
and Mitro Finance and/or its affiliates (for example, to provide you with the
Services you request and to identify and authenticate you so you may use the
Platform);
● necessary to comply with legal requirements (for example, to comply with
applicable accounting rules and to make mandatory disclosures to law
enforcement agencies or authorities);
● necessary for our legitimate interests and not overridden by your rights; and/or
● where it is based on your consent.
If we collect and use your personal information in reliance on our legitimate interests (or
those of any third party), this interest will normally be to operate our Platform and
Services, manage our relationship with you and communicate with you as necessary to
provide our Services to you and for our legitimate commercial interest, for instance,
when responding to your queries, improving our Platform and our Services, undertaking
marketing, or for the purposes of ensuring the security of our Platform and Services and
detecting or preventing illegal activities such as fraud. We may have other legitimate
interests and if appropriate we will make clear to you at the relevant time what those
legitimate interests are.
If we ask you to provide personal information to comply with a legal requirement or to
enter into a contract with you, we will make this clear at the relevant time. We will advise
you whether the provision of your personal information is mandatory or not (as well as
of the possible consequences if you do not provide your personal information). In some
instances, you may be required to provide us with personal information for processing
as described above, in order for us to be able to provide you all of our Services, and for
you to use all the features of our Platform.
F. HOW TO CONTACT US?
If you have any requests, questions or concerns regarding this Policy and your data
protection rights, please feel free to contact us at dataprotection@Mitro.io