1. Introduction

Agiwal Fintech Private Limited ("AGI Moneey," "we," "our," or "us") respects your privacy and is committed to protecting your personal information. This Privacy Policy ("Policy") describes how we collect, use, disclose, share, store, and protect your information when you access and use the AGI Moneey mobile application ("App") and the website www.agimoneey.com ("Website") — collectively referred to as the "Platform."

Our website is an informational platform that provides details about our services and does not collect any personal or sensitive user data. No cookies, tracking technologies, or analytics tools are used on the Website for user identification.

Our Mobile App is a financial wellness and workforce management solution that allows salaried employees ("you," "User," or "Employee") to access services such as Earned Wage Access (EWA) and other salary-linked financial benefits in partnership with employers and regulated financial institutions, including Non-Banking Financial Companies (NBFCs). The App also enables employees to mark their attendance using geo-location tracking, where location is captured only at the time of punch-in and punch-out.

To provide these services, we collect and process personal, employment-related, precise location, and financial information as described in this Policy.

By using the AGI Moneey Platform, you acknowledge and agree to the terms outlined in this Privacy Policy, including the specific consents detailed in Section 2 (Consent). If you do not agree, you may choose not to use the Platform or may withdraw your consent in the manner described herein.

This Policy is an electronic record in the form of an electronic contract under the provisions of the Information Technology Act, 2000, and does not require any physical or digital signature. By continuing to access or use the AGI Moneey App, you consent to the practices set forth in this Policy and agree to the collection and processing of your data in accordance with:

• The Information Technology Act, 2000 and associated rules,
• The Digital Personal Data Protection Act, 2023 (DPDPA),
• And applicable RBI Guidelines for Lending Service Providers.

If you do not agree with our practices or do not wish to share your data, you may choose to discontinue using the AGI Moneey Platform and withdraw your consent. Continued use of the Platform after any amendments to this Policy shall be deemed as your acceptance of the updated terms.

2. Consent

By using or accessing the AGI Moneey Platform, you hereby freely, expressly, and voluntarily consent to the following:

• The collection, receipt, storage, processing, usage, disclosure, and transfer of your personal data, including sensitive personal data or information, in accordance with this Privacy Policy.
• Receiving service-related communications, including updates, confirmations, transactional alerts, reminders, and customer support messages, via SMS, email, phone calls, or push notifications.
• Sharing of your data with your employer, regulated financial institutions (including NBFC partners), and authorized third-party service providers, strictly for the purposes outlined in this Policy, such as enabling salary advances, verifying attendance, or providing support and compliance-related services.

You may withdraw your consent at any time by:

• Deleting your account from the AGI Moneey App, or
• Writing to us at support@agimoneey.com, clearly requesting withdrawal of consent.

Please note that withdrawal of consent may impact your ability to access some or all features of the AGI Moneey Platform, including but not limited to the Earned Wage Access facility and geo-location-based attendance features. Upon such withdrawal, we may continue to retain your data only to the extent required to comply with applicable laws or to defend legal claims.

3. Information We Collect

AGI Moneey may collect the following information:

• Identity Details: Name, date of birth, gender, PAN, Aadhaar (for KYC verification).
• Contact Details: Phone number, email address, residential address.
• Employment Details: Employer name, employee ID, salary account, attendance records
• Banking Details: Account number, Bank Name and IFSC Code
• Device & Usage Data: IP address, device ID, OS Version, app usage patterns, location data (with permission).
• Attendance & Location (HRMS): We collect device's precise location data only at the time employee/user initiate a punch-in or punch-out for attendance purposes. This is a one-time collection per interaction.

We do not collect location data continuously or in the background, and we do not collect location at any other time.

Location permissions are requested solely for attendance validation and are never used for tracking, advertising, or profiling purposes.

4. How We Use Your Information

We use the information collected through the AGI Moneey Platform for the following purposes:

• To register, verify, and manage your user account
• To facilitate Earned Wage Access (EWA) and salary-linked financial services
• To comply with KYC, AML, and other legal or regulatory requirements
• To provide customer support and respond to service requests
• To improve platform functionality, features, and user experience
• To send service-related updates and, where applicable, promotional communications (you may opt out of marketing messages)
• We use your precise location data only when you attempt to mark attendance to confirm that you are physically present at your assigned workplace. This ensures integrity of attendance records and enables your employer to validate location-based attendance.

Your location data is not used for any other purpose, is not stored for historical analysis, and is not shared with third parties except:

• With your employer for attendance validation;
• As required to comply with legal or regulatory obligations.

5. Data Sharing & Disclosure

We may share your information with third parties only as necessary to provide our services and as permitted by applicable law. This includes:

• Employers: For processing attendance, salary information, and enabling Earned Wage Access (EWA).
• Financial Institutions/NBFCs: For credit underwriting, disbursal of EWA, and repayment tracking.
• Service Providers: Trusted third parties engaged for KYC verification, payment processing, customer support, data hosting, analytics, and communication services.
• Regulatory Authorities: When required by law, regulation, or legal process.
• With Your Consent: In any other circumstance where you have explicitly authorized us to share your information.

We ensure all third parties follow strict data protection standards and contractual obligations to safeguard your personal data. We do not sell your personal data to advertisers.

6. Data Security

We take reasonable and industry-aligned precautions to protect your personal information. We follow reasonable data protection practices in line with industry standards.

• Data is transmitted securely using encryption protocols TLS version 1.3
• Access to systems and servers is strictly limited to authorized personnel
• We implement routine monitoring, internal audits, and security checks to detect and mitigate risks

While we strive to safeguard your data, we urge you to protect your login credentials. We are not liable for any unauthorized access resulting from your failure to maintain the confidentiality of your account information.

7. Your Rights

As a user of the AGI Moneey Platform, you have the following rights under applicable data protection laws:

• Access your personal data and review the information we hold about you
• Correct any inaccurate or incomplete personal information
• Withdraw your consent for data processing at any time
• Request deletion of your personal data, subject to applicable legal and regulatory obligations

To exercise these rights or raise any data privacy concerns, please contact us at: support@agimoneey.com

We will respond to your request within a reasonable time in accordance with applicable law.

8. Data Retention

We retain your personal data for as long as:

• Your account remains active, or
• It is required to comply with legal, regulatory, or contractual obligations (up to 5 years or more for KYC, audit, and tax requirements)

We may retain anonymized or aggregated data—stripped of personal identifiers—for analytics, reporting, and service improvement purposes, even after your account is deleted.

9. Grievance Officer

In accordance with the Information Technology Act, 2000, and the Digital Personal Data Protection Act, 2023, the following Grievance Officer has been appointed to address any complaints or concerns regarding the processing of your personal data:

10. Policy Updates & Changes

We may update or modify this Privacy Policy from time to time to reflect changes in legal requirements, business practices, or our services.

When we do, we will revise the "Last Updated" date at the top of this Policy. We encourage you to review this page periodically to stay informed.

Your continued use of the AGI Moneey Platform after any changes to this Policy will be deemed as your acceptance of those changes.

AGI Moneey By Agiwal Fintech Private Limited