FinMet Technologies Private Limited, a company incorporated under the Companies Act, 2013, having its office at S.F. No. 357/1B, NGR Puram, Behind ESI Compound, Irugur, Coimbatore, Tamil Nadu - 641103 (“FinMet”, “we”, “us” or “our”), is committed to protecting the privacy and security of personal data processed through ScreenMate™ (“Platform”).

This Privacy Policy explains how FinMet collects, uses, processes, stores and discloses personal data in connection with the Platform and its related services and features. This Policy shall be read together with the ScreenMate Terms and Conditions, applicable Letter of Engagement, order form and other contractual terms agreed with the Client.

1. INFORMATION WE COLLECT

Depending upon the use of the Platform, FinMet may collect or receive:

• a. Identity and Contact Information: Name, email address, mobile number, designation and other contact details.
• b. Business Information: Company/organisation name, address, GSTIN, billing details and authorised representative details.
• c. Account Information: Username, authentication information and account/access details.
• d. Screening Information: Names and identifying information submitted for screening, search inputs and results, date and time of searches, User/account details and related audit or activity logs.
• e. Transaction Information: Subscription, billing, payment status and transaction-related information. Payment details processed through third-party payment providers may be subject to their respective terms and privacy practices.
• f. Technical and Usage Information: IP address, browser/device information, access logs, usage data, diagnostics and security-related information.
• g. Communication Information: Information contained in enquiries, support requests and other communications with FinMet.

FinMet shall collect and process information only to the extent reasonably necessary for the relevant purpose.

2. SOURCE AND PURPOSE OF PROCESSING

Information may be obtained directly from Users, Clients and their authorised representatives, through use of the Platform, automatically through technical systems, from Clients submitting information for screening, from publicly available sources and, where applicable, from third-party service or technology providers.

FinMet may process such information for:

• a. providing and administering the Platform and its services;
• b. creating and managing User accounts and access;
• c. carrying out screening searches requested by authorised Users;
• d. maintaining search records, audit logs and Platform security;
• e. processing subscriptions, billing and payments;
• f. providing support and service-related communications;
• g. maintaining, securing and improving the Platform;
• h. detecting and preventing fraud, misuse or unauthorised access;
• i. providing AI-enabled or decision-support features, where applicable;
• j. complying with applicable legal, regulatory or governmental requirements; and
• k. establishing, exercising or defending FinMet’s legal rights and interests.

3. CLIENT DATA AND DISCLOSURE

The Client and/or authorised User is responsible for ensuring that personal data submitted to the Platform is collected and provided lawfully and that any required authority, notice, consent or other lawful basis has been obtained. This does not limit FinMet’s obligations in respect of processing undertaken by FinMet under applicable law.

Where FinMet processes information submitted by a Client or User, such processing shall be undertaken in accordance with the applicable contractual arrangements, this Privacy Policy and applicable law.

FinMet may disclose or provide access to personal data, where reasonably necessary, to hosting and cloud providers, technology and cybersecurity providers, payment processors, professional advisers, auditors, third-party data or service providers, AI/API providers and governmental, regulatory, judicial or law-enforcement authorities where required or permitted by law.

FinMet shall use reasonable efforts to ensure that relevant service providers are subject to appropriate confidentiality and data protection obligations.

4. SCREENING AND AUDIT LOGS

ScreenMate enables authorised Users to submit names and related information for screening against the sources and lists supported by the Platform.

FinMet may retain search inputs, results, date and time of searches, User/account details and audit logs for providing the service, security, support, monitoring and maintaining appropriate records.

Screening results depend on the information submitted, applicable screening methodology and available sources. Such results are intended to support the Client’s or User’s compliance and due-diligence processes and do not by themselves constitute a determination regarding any person or entity.

The Client and User remain responsible for appropriate verification, due diligence and independent decision-making.

5. AI-ENABLED FEATURES

Certain Platform features, including the Disposition Tool, may use artificial intelligence, publicly available information and third-party data or technology.

Information submitted by the User and relevant information obtained from applicable sources may be processed to generate such outputs. Third-party AI or API providers may process relevant information in accordance with applicable contractual and privacy terms.

AI-assisted outputs are provided for informational and decision-support purposes only and may contain errors or inaccuracies. They do not constitute legal advice, professional advice, KYC findings, compliance determinations or a substitute for human review and due diligence.

FinMet does not independently verify all information obtained from public or third-party sources.

6. SECURITY AND RETENTION

FinMet maintains reasonable technical and organisational safeguards designed to protect personal data against unauthorised access, disclosure, alteration, loss or misuse.

Personal data shall be retained only for as long as reasonably necessary for providing the Platform, complying with contractual or legal obligations, maintaining security and business records, resolving disputes and establishing or defending legal claims.

Where personal data is no longer required and no lawful basis for retention exists, FinMet shall take reasonable steps to delete, anonymise or otherwise dispose of such information in accordance with applicable law.

7. THIRD-PARTY AND CROSS-BORDER PROCESSING

The Platform may use third-party infrastructure, hosting, technology, payment, cybersecurity, analytics, AI and other service providers.

Accordingly, personal data may be processed or stored in India or outside India, subject to applicable law and appropriate safeguards.

FinMet shall not be responsible for the independent privacy practices of third parties, except to the extent required under applicable law or contractual obligations.

8. RIGHTS AND GRIEVANCES

Subject to applicable law, individuals may have rights relating to their personal data, including access, correction, updating, deletion or erasure where applicable, withdrawal of consent where processing is based on consent, and the right to raise a grievance.

Requests may be submitted to FinMet using the contact details below. FinMet may undertake reasonable verification before processing such requests.

Where personal data has been submitted by a Client or another organisation, FinMet may, where appropriate, coordinate with or refer the individual to the relevant Client.

9. COOKIES AND UPDATES

The Platform may use cookies and similar technologies for authentication, security, functionality, analytics and performance.

FinMet may amend this Privacy Policy from time to time to reflect changes in the Platform, applicable law or processing practices. The revised Policy shall be published on the Platform with the updated “Last Updated” date.

10. APPLICABLE LAW

This Privacy Policy shall be read and interpreted in accordance with the laws applicable in India, including applicable data protection and privacy laws, rules and regulations in force from time to time.

11. CONTACT

By accessing or using the Platform, you acknowledge that you have read and understood this Policy. Where consent is required under applicable law, such consent shall be obtained through the applicable mechanism provided by FinMet.