Website Privacy Policy

Last modified: 20^thDec 2024

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Introduction

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ANCORAA RESOLUTION PVT. LTD (“Company” or “We”)respect your privacy and are committed to protecting it through our compliance with this policy.

This Policy together with the terms of use and/ or any other document/ information, describes the Company’s policies and procedures on the collection, use and disclosure of the information provided by the user (“You”)whoaccesses the website www.ancoraa.com or the RezolutionEngine® platform on the www.ancoraa.com (hereinafter collectively referredcollectivelyreferred to as “Website”) whether for service or otherwise. The Company does not use Your information in any manner except as provided under this Privacy Policy. Anyone who accesses or uses the Website shall be bound by this Policy.

We feel it is important to post a privacy statement in accordance with best established practices and for the knowledge of customers and anyone who visit our website. The information you share with us will be kept private. We also want to state unequivocally that suitable safeguards have been taken to secure information connected to clients and their interactions with us from malicious and fraudulent individuals.

We are extremely concerned about the confidentiality and privacy of our users. Our personnel treat the information we have about your accounts with the same care and confidentiality that we would like our own financial matters handled. This Policy is hereby published pursuant to existing applicable laws in India. The Policy sets out the type of information collected from You, including the nature of data or information, the purpose, means and modes of usage of such information and how and to whom the Company shall disclose such information. This policy describes the types of information we may collect from you or that you may provide when you visit the website and our practices for collecting, using, maintaining, protecting and disclosing that information.

This policy applies to the information we collect:

On this Website
In email, text, and other electronic messages between you and this Website.
Through mobile and desktop applications you download from this Website or other websites or app stores including but not limited to Apple’s App Store and Google’s Play Store etc. which provides dedicated non-browser-based interaction between you and this Website.
When you interact with our advertising and applications on third-party websites and services if those applications or advertising include links to this policy.
The information you provided while signing up on the Rezolution Engine® platform on our website and the information you feed in it.
The information you provided while signing up on the other such software as a service platform which may be added to the Website from time to time.

It does not apply to information collected by:

Us offline or through any other means, including on any other website or email operated by Company or any third party (including our affiliates and subsidiaries); or
Any third party, including through any application or content (including advertising) that may link to or be accessible from or through the Website.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use the Website.

Notice

By accessing or using this Website, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates. You also acknowledge that the Company reserves the right to remove, preserve, and disclose any Information it deems necessary or appropriate to:

Satisfy any applicable law, regulation, legal process or governmental request.
Enforce this Policy, including investigation of potential violations hereof.
Detect, prevent, or otherwise address fraud, security, or technical issues.
Protect the rights, property, or safety of the Company, You, and/or the general public.
Investigate or defend the Company against third-party claims or allegations.

Information We Collect About You and How We Collect It

We collect several types of information from and about You through the website, including information:

By which you may be personally identified, such as name, postal address, email address, mobile/telephone number, Aadhar No., PAN, CIN, DIN, IP/RP Reg. No., Bar Reg. No. or any such information which help us to identify you so as to provide you an effective and efficient services to you. (“personal information”)
That is about you but individually does not identify you, such as financial as well as non-financial details of any Organization / Individual which may be required for processing the Insolvency Process involving any Corporate Debtor, Financial Creditor, or Operational Creditor, Personal Guarantor(s) and/or any other service which maybe provided by us to you including but not limited to the services provided on the Resolution Engine platform on our website. (“non-personal information”)
That may be directly or indirectly obtained which pertains to any third-party involvement in the matter which would be necessary for providing our services through the RezolutionEngine® or otherwise. Such a third party would include but not limited to Liquidators, Valuers, Receiver, Insolvency Professionals, Lawyers, Accountants, Financial Institutions, other professionals and clients.
Which may be brought on to us by you is of any legal nature or of non-legal nature which can be used in any legal process or requirement while undergoing through the process of Insolvency, Liquidation, Restructuring, reorganization or the services of like nature. It may include any document which is required to be filed in a court of law by us as a service provider / Insolvency Professional.
About your internet connection, the equipment you use to access our website, and usage details.

We collect this information:

Directly from you when you provide it to us while accessing the Resolution Engine platform on the website.
Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and/or other tracking technologies.
From third parties, for example, google account sign up, signing up using IBBI email ID etc.

Information You Provide to Us

The information we collect on or through our website may include:

Information that you provide by filling in forms on our website. This includes information provided at the time of registering/signing up to use our website or the services we provide, subscribing to our service, any posting material, or requesting further services. We may also ask you for information when you enteron the Resolution Engine platform on the website as and when demanded or required, and when you report a problem with our website.
Records and copies of your correspondence (including email addresses), if you contact us through the means and feature of the website.
All such information which is directly provided by you to us for the services we provide which may include but not limited to the financial records such as a record of the default recorded with the information utility or such other document or evidence of default, the name of the resolution professional proposed to act as an interim resolution professional, copy of invoices, demand notice, copy of loan agreement, deed of guarantee, details of personal guarantors, certification of financial institutions, any resolution plans, MoM of Committee of Creditors and other sensitive financial information etc.
Details of transactions you carry out through our website and of the fulfilment of your orders. You may be required to provide financial information before placing an order through our website.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

Details of your visits to our website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the website.
Information about your computer and internet connection, including your IP address, operating system, and browser type.

We also may use these technologies to collect information about your online activities overtime and across third-party websites or other online services (behavioural tracking). The information we collect automatically does/may/is only statistical data and does not include personal information. It helps us to improve our website and to deliver a better and more personalized service, including by enabling us to:

Estimate our audience size and usage patterns.
Store information about your preferences, allowing us to customize our website according to your individual interests.
Speed up your searches.
Recognize you when you return to our website.

The technologies we use for this automatic data collection may include:

Cookies (or browser cookies): A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our website.
Web Beacons: Pages of our Website and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs)that permit the Company, for example, to count users who have visited those pages or [opened an email] and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
Flash Cookies: Certain features of our website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our website. Flash cookies are not managed by the same browser settings as are used for browser cookies.
It is pertinent to note that we do not collect personal information automatically, but we may tie this information to personal information about you that we collect from other sources, or you provide to us.

How We Use/Process Your Information

We use information that we collect about you or that you provide to us, including any personal information:

To present our website and its contents to you.
To provide you with information, products, or services that you request from us.
To fulfil another purpose for which you provide it.
To provide you with notices about your case/resolution details.
To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
To notify you about changes to our website or any products or services we offer or provide through it.
For filing documents to the court of law for your interest and benefit or under any legal obligation.
In any other way we may describe when you provide the information.
For any other purpose with your consent.

Disclosure of Your Information

We may disclose aggregated information about You, and information that does not identify an individual without restriction.

We may disclose personal information that we collect, or you provide as described in this privacy policy:

To our subsidiaries and affiliates.
To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of assets if required under any resolution plan or liquidation process you are part of, whether as a going concern or not, and whether on order or direction of court of law.
To third parties to provide you with more effective and efficient services. Such a third party may include lawyers, accountants, liquidators, valuers or other professionals. We contractually require these third parties to keep personal information confidential and use it only for the purposes for which we disclose it to them.
For any other purpose disclosed by us when you provide the information.
With your consent.
To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
To enforce or apply our terms of use and other agreements, including for billing and collection purposes.
If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of our customers, or others or ourselves. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Data security and storage

All information you send to us or collected by us is securely stored/saved. The Company has put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. If we have provided you(or you have selected) a password to access particular portions of our website/services, you are responsible for keeping such password secure. We recommend that you do not share your password with anybody.

Furthermore, we restrict access to your data to employees, agents, contractors, and other third parties that have a need-to-know basis. Third parties who process your personal or non-personal information will only do so on our instructions and are bound by confidentiality. We have mechanisms in place to deal with any suspected data security breach, and we will inform you if we are legally compelled to do so.

We will store the information in our systems for as long as is necessary to fulfil the reasons for which it was collected, including meeting any legal, accounting, or reporting requirements, or as required to comply with any legal obligations to which we/you are subject to.

Limitation on Liability and Disclaimer

To the maximum extent permitted by law, the Company, its affiliates, licensors, suppliers, or any third parties mentioned on the website shall not be liable for any incidental, direct, indirect, exemplary, punitive, or consequential damages, lost profits, or damages resulting from lost data or business interruption resulting from the use of and/or inability to use the website, the Company systems, information, services, or the content, whether based on warranty, contract, tort, or otherwise. To the extent permissible bylaw, the remedies specified in these terms of service for you are exclusive and limited to those specifically indicated herein.

The internet is an open system, and the Company does not guarantee that data, which the registered user furnishes will not be intercepted or accessed by others and decrypted. The Company or its associates/partners/employees/directors/agents & representatives shall not be liable or responsible, should any confidential or other information provided by you or pertaining to the visitor (including bank account information, passwords, credit/debit card details, transaction details)are intercepted and subsequently misused by an unintended recipient.

Rights of User

In respect to your Personal Information, you have many options. You have the following rights in particular:

receive confirmation that we are processing your Personal Information and a copy of the Personal Information we have on file for you.
request that we update the Personal Information we have on file for you, or request that we correct Personal Information that you believe is wrong or incomplete.
request that we delete or restrict the use of Personal Information we hold about you.
withdraw consent to our processing/use of your Personal Information (to the extent such processing is solely based on previously obtained consent).
receive a copy of the Personal Information concerning you that you have provided to us in a structured, commonly used, and Engine-readable format; and transmit such Personal Information to another party (to the extent the processing is based on consent or a contract); and
object to our processing/use of your Personal Information.

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Payment Privacy Policy

1. Payment Data Collection

When you make a purchase or subscription on our platform, the payment process is facilitated by our third-party payment gateway service provider, Razorpay. As part of this process, certain personal and financial information may be collected and processed by Razorpay to ensure secure and seamless payment transactions.

1.1 Data Collected by Razorpay

Razorpay may collect the following data directly from you:

Payment method details (e.g., card type, card number, expiration date, UPI ID, or bank account details).

Billing address and contact information (e.g., email address and phone number).

Transaction details, including the date, time, and amount of the transaction.

1.2 Purpose of Collection

The data collected is used to:

Process and complete your payment transactions.

Detect and prevent fraudulent activities or unauthorized transactions.

Comply with applicable laws and regulatory requirements.

1.3 Razorpay’s Role and Responsibility

Razorpay operates as an independent data controller with respect to the payment information you provide during transactions. We encourage you to review Razorpay’s Privacy Policy to understand how they manage and protect your payment-related data. You can find their Privacy Policy at [https://razorpay.com/privacy/].

1.4 Our Responsibility

We do not store sensitive payment information such as your full card number, CVV, or banking credentials. However, we may retain transaction-related details (e.g., transaction ID, date, and amount) for record-keeping, customer support, and compliance with legal obligations.

1.5 Your Rights

You have the right to contact Razorpay directly to exercise any data rights related to your payment information. For general inquiries or concerns about how we handle your transaction data, you can contact us at [support@ancoraa.com].

Grievance and Contact

If you want to contact us about any aspect of this Privacy Policy, including, without limitation and subject to applicable data protection law, if you want to exercise any of your data protection rights or file a complaint or grievance, please contact our Head Office using the information provided below.

If you file a complaint against the Company for a violation of relevant data protection rules, the Company will react as quickly as possible to let you know who is in charge of handling your complaint. The Company will examine your complaint and, if necessary, engage with third parties who may have been involved in the processing of your personal data. The Company will respond to any complaints within the periods prescribed by law. If more research is necessary, it will be conducted, and you will be advised of a suggested solution. This will be verified in writing to you.

If you do not get a response from us within the periods allowed by relevant legislation, or if your complaint is not addressed to your satisfaction within that timeframe, you may file a complaint with the appropriate data protection authorities. We will examine any complaint and tell you as soon as possible when a decision has been taken in respect to your complaint.

Note: This Privacy Policy is to be interpreted with and not in derogation to the website’s terms and condition.

Contact Details:

For further details, clarifications or objections, you may reach us at: support@ancoraa.com

By Post:

1412, 14th Floor, Real Tech Park, Sector 30 A, Vashi, Navi Mumbai, Pin-400703.

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