Welcome to the FundFlow-Loans. (which may also be referred to as “we,” “us,” and “our”) Privacy Policy. This Privacy Policy describes how we collect, use, and disclose your information in connection with our website (the “Site”) and mobile application (the “FundFlow-Loans App”, and, together with the Site, the “FundFlow-Loans Platform”). The Site and the FundFlow-Loans App are operated by MILLIONAIRE CLUB FINANCE PRIVATE LIMITED, with its registered office located atKhasra No 44/1 Ground Floor Village Khera Kalan near BABA Properities 110082 Delhi. As a professional financial consulting institution, we have established a strategic partnership with Vaishali Securities Limited, an authorized bank and financial institution, to provide users with efficient, compliant loan products, and related financial services (collectively referred to as "Services").

FundFlow-Loans has been created to provide our visitors (“you,” “your”) with information about our company and with online content, tools, products, services, and other offerings, including financial products and services (collectively, “Services”). This Privacy Policy describes how FundFlow-Loans collects, uses, and discloses information from users of the Services, including information that can be used to identify you, directly or indirectly, as defined by applicable laws (“Personal Information”). For residents of Indian, please see our Notice at Collection below.

WHY THIS MATTERS

We built the FundFlow-Loans Platform to give everyone the power to make their best financial decisions. Knowing certain things about our users helps us do that better. Please be sure to read this entire Privacy Policy and our Financial Privacy Notice before using or submitting information through the Services. By using or submitting information through the Services, you are indicating that you agree to the collection, transfer, manipulation, processing, storage, disclosure, and other uses of your Personal Information as described in this Privacy Policy, and you agree to be bound by the terms of this Privacy Policy and our Financial Privacy Notice. You also agree that such Personal Information may be transferred from your current location to our offices and servers. This Privacy Policy is incorporated by reference into FundFlow-Loans’s Terms of Service and any other agreement entered into by and between you and FundFlow-Loans. If you do not agree with any aspect of this Privacy Policy, our Financial Privacy Notice, or the Terms of Service, you should immediately discontinue access to or use of our Services.

CONTENTS WHAT PERSONAL INFORMATION WE COLLECT HOW WE USE PERSONAL INFORMATION HOW WE DISCLOSE PERSONAL INFORMATION OTHER IMPORTANT INFORMATION NOTICE OF FINANCIAL INCENTIVE YOUR STATE PRIVACY RIGHTS/NOTICE AT COLLECTION

WHAT PERSONAL INFORMATION WE COLLECT

Because we are a financial institution regulated, the Personal Information that we collect in connection with your request for consumer financial products and services constitutes “nonpublic personal information” subject to our Financial Privacy Notice, and we may be exempt from certain state privacy laws. When you visit the FundFlow-Loans Platform or use our Services to apply for a financial product or service, to open or maintain an account with us, to enroll in a membership, to take advantage of deals and other offerings, or, in the context of a business - to - business relationship, to complete vendor and partner due diligence, you signify acceptance to the terms of this Privacy Policy and the Financial Privacy Notice and consent to the collection, use, and disclosure of your Personal Information as described herein and therein.

I. PERSONAL INFORMATION THAT YOU PROVIDE OR AUTHORIZE US TO COLLECT

The Personal Information you will be asked to provide when using our Services may vary depending on your business relationship with us and the type of financial product or service you are seeking. This information may be directly provided by you, sourced from identity verification and fraud prevention partners or public databases, collected from our affiliates and non - affiliated third - party partners, pulled from any external accounts that you may link, or obtained from consumer reporting agencies when we perform a “soft” credit inquiry, in connection with your enrollment in credit monitoring services, or as otherwise appropriate where there is a legitimate business need in connection with a transaction initiated by you, in each case in accordance with your instructions.

The Personal Information that you provide or authorize us to collect may include:

PRODUCTS AND OFFERS INFORMATION: To the extent that you navigate to the “Products and Offers” tab on our FundFlow-Loans App or page on our Site, you may be asked to provide any of the information described in the section of the Engine by FundFlow-Loans Privacy Policy entitled “WHAT PERSONAL INFORMATION WE COLLECT” in connection with your search for financial products or services. Please refer to that document for additional information on the Personal Information that we collect in this context, including how we use and disclose that Personal Information.
CONTACT AND DEMOGRAPHIC INFORMATION: This may include your name, username (e.g., RoarTag), date of birth, address, phone number, email address, telephone number, Social, Pan card number or other similar identifiers.
PROFESSIONAL OR EMPLOYMENT INFORMATION: This may include the name of your employer, the amount of your income, the frequency of your pay cycles, and the dates on which you receive direct deposits.
FINANCIAL ACCOUNT INFORMATION: This may include account balances, trading activity, loan amounts and account history for any FundFlow-Loans accounts, as well as information about external linked accounts, such as your bank account number, account balance, account activity (including, but not limited to, direct deposit or spending activity and trading activities), account history, and any other transaction data, to the extent you have chosen to link an external account to your FundFlow-Loans account.

IDENTITY VERIFICATION AND AUTHENTICATION INFORMATION: In limited circumstances we may receive Personal Information such as photographic images, including selfies or images from your government - issued photo identification. We partner with third parties to complete identity verification, some of whom may collect biometric identifiers, such as your faceprint, from these images (such identifiers, “Biometric Data”).

LOCATION INFORMATION: This may include precise location information, device motion information, or both, to the extent you choose to use certain features in the FundFlow-Loans App. We may also collect location information based on your IP address and the geolocation of your device.
SUPPORT INFORMATION: This may include audio, electronic or similar information, such as the information collected when you email or call our customer support center, which may include your name, email address, voice recording, and any other content or communications that you send to or share with us.
INFERENCES: We may also derive Personal Information about you in the form of inferences, which are derivations of information, data, assumptions, or conclusions from facts, evidence, or other sources of information or data about you. These inferences may be derived from the Personal Information that you provide to us or authorize us to collect, from the Personal Information automatically collected, from the Personal Information that we collect from third parties, as well as from the information collected by cookies, web beacons, and other tracking technologies. By voluntarily providing us with Personal Information, you represent that the Personal Information you provide is true, accurate, current, and complete, and that you are authorized to provide it to us. If you’d like to view a summary of our data collection, use, and disclosure practices in table format, please see Appendix A below.

II.PERSONAL INFORMATION AUTOMATICALLY COLLECTED

Whenever you interact with the Services, FundFlow-Loans may automatically receive and record information from your computer, browser and/or mobile device, which may include the following:

IP ADDRESS:

Your interactions with FundFlow-Loans may transmit your IP address (the Internet address of your computer). We may use visitors’ IP addresses for various purposes, including to display customized content, to analyze and report upon usage of the Services, to diagnose and prevent service or technology problems affecting the Services, and to monitor and prevent fraud and abuse. We may also use the IP address associated with your login to determine your general location in order to comply with applicable privacy regulations and serve you necessary notifications and/or consent mechanisms.

DEVICE IDs:

We may collect information on the type of device you are using, operating system, settings, browser and OS information, unique device identifiers, mobile carrier, browser type and language, network information and other device - specific information. The information collected may depend on the type of device you use and its settings. We collect this data to better tailor our services to you, to audit ad impressions, and for compliance with various specifications and standards.

Location: In addition to the location data collected if you enroll into our Driver Score feature, we may collect location data based on your IP address and the geolocation of your device. We collect this data to better tailor our services to you and to help provide service offerings available to you in your geographic area.

Device Information: Our application gathers and monitors a range of phone-related information, including hardware specifications, operating system details, serial numbers, user profiles, and mobile network data. This enables us to uniquely identify each device and safeguard against unauthorized access or actions on your behalf.

Camera: In the FundFlow-Loans app, we might request your assistance to kickstart the onboarding process by guiding you through completing the KYC (Know Your Customer) procedure. This could involve providing necessary documents to verify your personal information, taking photos to create profiles, or uploading required documents for loan applications. Any camera data captured will be securely uploaded to our app server, https://api.fundfwl.asia, and will be treated with utmost confidentiality. Rest assured, your data will not be used for any other purposes. You have the flexibility to revoke or re-authorize camera permissions at your convenience. Should you have any inquiries, feel free to reach out to our dedicated customer support team.

AppList: In order to provide more accurate credit assessments and personalized services, we need to access information about the applications on your device. This will help us gain a comprehensive understanding of your spending habits, financial situation, and credit risk, enabling us to tailor credit products that best suit your needs. In order to ensure accurate credit assessment and considerate service, we need to obtain your application list information and fully understand your consumption habits, financial status and credit risks to customize the most suitable credit products. Only the application name and type are accessed and all data transmission is encrypted to ensure privacy and security.

USAGE INFORMATION: We collect information about how you use our Services, such as the types and categories of content that you view or engage with, the features you use, the actions you take, and the time, frequency, and duration of your activities on the Site. We use data analytics with this usage information to better understand your use of the Services and to improve the Services offered.

III.COOKIES, WEB BEACONS, AND SIMILAR TECHNOLOGIES:

In operating the Services, we may use cookies, web beacons, fingerprinting, and similar technologies to collect and use Personal Information about you, including for analytics purposes, and to serve you interest - based advertising. This Privacy Policy covers the use of these technologies by FundFlow-Loans only. Uses of these technologies by third - party advertisers or websites linked from the Services, including third parties with which we partner, are governed by each such third party’s privacy policy.

COOKIES & ANALYTICS:

A cookie is a small text file placed in visitors’ computer browsers to store their preferences. Cookies help provide additional functionality to the Services, customize users’ experiences with the Services and help us analyze Services usage more accurately for research, advertising, and marketing purposes. On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive notifications when you are receiving a new cookie and on how to turn cookies off. We recommend that you leave cookies turned on because they allow you to take advantage of some of the Services’ features, and, if you block or delete cookies, the FundFlow-Loans Platform may not work properly.

Google Analytics: Please note that we use Google Analytics cookies for data analytics purposes. You can find more information on how Google uses data from these cookies. You may choose to opt - out of Google Analytics by installing their opt - out browser.

IV.PERSONAL INFORMATION COLLECTED FROM OTHER SOURCES:

We may collect Personal Information about you from third parties to operate the FundFlow-Loans Platform and to provide you with our Services. As previously discussed, this may include information about you from one or more consumer reporting agencies, in connection with your use of our “Products and Offers” marketplace, your enrollment in credit monitoring services, or your application for a Credit Builder Loan.

HOW WE USE PERSONAL INFORMATION

We may use the Personal Information we collect for the following purposes:

A)TO PROVIDE PRODUCTS AND SERVICES

To verify your identity, set up, and maintain your account (if applicable). To provide information relevant to the underwriting models and eligibility criteria of our marketplace partners, who may provide you with personalized offers. To personalize the Services when you visit our Site and/or use one of our online forms, tools, widgets, or content items. To monitor your use of the Services. To maintain our Services and operations.

To perform identity verification in compliance with applicable laws and regulations.
To detect and protect against security incidents and malicious, deceptive, fraudulent, or illegal activity, and prosecute the same. To debug to identify and repair errors in our systems.
To verify or maintain the quality of our services, and to improve, upgrade, or enhance our services.
To conduct due diligence or other reviews in connection with our vendor onboarding processes

C) FOR ANALYTICS, RESEARCH, AND SERVICE IMPROVEMENT

To monitor and measure your use of our products and Services in an effort to better understand you and our other users.
To conduct testing, research, and surveys to understand how our Services are being used and how they can be improved.
To conduct analytics, such as usage trends.
To perform financial analysis to better understand pricing and other financial matters.
To improve the content and functionality of the Services.
To test and improve the quality of our matching process.
To better understand user needs.
To pre-populate certain fields in our forms, helping to streamline your experience.

D) FOR QUALITY ASSURANCE AND TRAINING PURPOSES

To monitor communications and interactions with you to ensure the quality of our support services and the appropriate training of our people, and to respond to and resolve your inquiries.

E) TO COMMUNICATE WITH YOU

To contact you by email, postal mail, push notifications, in-app messages, phone, or SMS, as permitted by applicable law, to provide you with:
Information regarding your application status, or other transactional information relevant to your account.
Opportunities, alerts, and promotions related to your submitted request(s) available through the services or products of our marketplace partners that we think may be of interest to you.
Information or content – such as articles, white papers, and event registrations – that we believe would be of interest to you.

Each marketing-related e-mail communication we send you will contain instructions permitting you to “opt-out” of receiving future marketing communications. Generally, you can unsubscribe from our marketing emails or direct mail by submitting an unsubscribe request through our Preference Center.

F) TO COMPLY WITH ANY APPLICABLE LAWS, REGULATIONS OR LEGAL PROCEEDINGS

To investigate disputes or claims related to our Services.
To respond to legal, government or regulatory requests.
To comply with applicable laws.

G) FOR SAFEGUARDING AND DEFENDING OUR VITAL INTERESTS, FOR EXERCISING ANY RIGHTS, ASSERTING ANY CLAIMS, AND FOR ANY OTHER LAWFUL BUSINESS PURPOSE

This includes any incidental business purpose related to or in connection with any of the above, or any other purpose disclosed to you at the point at which we collect your Personal Information.

H)FOR ANY OTHER LEGITIMATE BUSINESS PURPOSES NOT OTHERWISE PROHIBITED BY LAW

HOW WE DISCLOSE PERSONAL INFORMATION

We may disclose your Personal Information to the following categories of recipients for our business or commercial purposes:

A) CONSUMER REPORTING AGENCIES: We may disclose basic Personal Information to consumer reporting agencies, either for purposes of completing a “soft” credit inquiry with your authorization, or as part of data studies, with the consumer reporting agencies acting in a service provider capacity, which are intended to test the reliability of our internal data and improve the quality of our Services.

B) POTENTIAL PARTIES TO A CORPORATE TRANSACTION (AND THEIR AGENTS AND ADVISORS): We may disclose your Personal Information to actual or potential buyers (and their agents and advisors) in connection with any actual or proposed purchase, merger, acquisition, reorganization, financing, bankruptcy, receivership, sale of company assets, or transition of service to another provider. In this event, we will inform the transferee that it must use your Personal Information only for the purposes disclosed in this Privacy Policy.

C) LAW ENFORCEMENT BODIES, REGULATORS, GOVERNMENT AGENCIES, COURTS OR OTHER THIRD PARTIES: We may disclose your Personal Information to competent law enforcement bodies, regulators, our insurers, external legal advisors, government agencies, courts, or other third parties where we believe disclosure is necessary: (i) to comply with applicable law; (ii) to exercise, establish, or defend our legal rights; (iii) to protect your rights or vital interests or those or any other person; or (iv) to detect, prevent, or otherwise address security, fraud, or technical issues.

OTHER IMPORTANT INFORMATION

CHILDREN’S PRIVACY ONLINE: FundFlow-Loans Services are not directed to, or intended for, minors. FundFlow-Loans does not knowingly collect Personal Information from minors. If you are under the age of 18, please do not submit any Personal Information through the Services. We encourage parents and legal guardians to monitor their minor children’s Internet usage and to help enforce our Privacy Policy by instructing their minor children never to provide Personal Information on the Services without their permission. If you have reason to believe that a minor has provided Personal Information to FundFlow-Loans through the Services, please contact us at contact@millionaireclubfinance.com, and we will delete that information from our databases located at Khasra No 44/1 Ground Floor Village Khera Kalan near BABA Properities 110082 Delhi.

SECURITY:
We take steps to ensure that your Personal Information is treated securely and in accordance with this Privacy Policy. We maintain commercially reasonable administrative, technical and physical safeguards (which vary depending on the sensitivity of the Personal Information) designed to protect against unauthorized use, disclosure or access to Personal Information, and we regularly adapt these controls to respond to changing requirements and advances in technology.

UPDATES TO FundFlow-Loans’S PRIVACY POLICY:
We may update our Privacy Policy from time to time to reflect changes to our businesses and to account for changing privacy laws. We will obtain your consent to any material changes if and where this is required by applicable laws. Please review this Privacy Policy periodically, and especially before you provide any Personal Information. This Privacy Policy was last updated on the date indicated above. Your continued use of the Services after any changes or revisions to this Privacy Policy shall indicate your agreement with the terms of such revised Privacy Policy.

YOUR STATE PRIVACY RIGHTS/NOTICE AT COLLECTION

This section discusses applicable privacy rights as required by certain U.S. state privacy laws, including California, Oregon, and other future U.S. states that pass privacy legislation to which we are subject. This section includes our Notice at Collection for California residents, including those with whom we interact in our business-to-business relationships.

HOW WE COLLECT, USE, AND DISCLOSE YOUR INFORMATION

For details on how we currently and over the past 12 months collect, use, and disclose your Personal Information, see Appendix A. All categories exclude text messaging originator opt - in data and consent, which won't be shared with non - affiliated third parties.

YOUR PRIVACY RIGHTS

Under applicable law, you may have these rights:

YOUR STATE PRIVACY RIGHTS/NOTICE AT COLLECTION

Right to Know: Request, up to twice a year, details like specific Personal Information collected, its categories, collection purposes, third parties with whom it's shared, data sources, and if any has been sold or shared in the past 12 months.
Right to Deletion: Ask us to delete your collected Personal Information. We'll try to honor it, but may retain some for business or legal reasons.
Right to Rectification: Correct inaccurate Personal Information we hold about you. We may offer self - correction tools.
Right to Withdraw Consent: Revoke prior consent for collection and sharing of your Personal Information.
Right to Opt - Out of Profiling: Opt out of profiling for decisions with legal or significant effects.
Right to Limit Use/Disclosure of Sensitive Personal Information: Limit use of your sensitive data as per state laws. FundFlow-Loans only uses/discloses such data as legally permitted.
Right to Opt - Out of Sale/Sharing/Use for Targeted Advertising: Opt out of sharing Personal Information for cross - contextual behavioral advertising or sales (as defined by some states). Our use of cookies, etc., may count as “sharing”.

We won't discriminate against you for exercising these rights.

APPEALS:

We make every effort to fulfill your request. However, we reserve the right to deny requests as permitted by applicable state law, such as where your identity cannot be confirmed, where we have a reasonable belief that the request is fraudulent, or where we must retain your information to comply with retention requirements under applicable laws.

Depending on your state of residence, you may have the right to appeal a decision made in response to your request.

If you would like to submit an appeal, you may do so via the Data Rights Request Form. Our response to your appeal will inform you of decisions and actions in response to your appeal, including an explanation of the reasons for the decisions.

CONTACTING US:

If you have questions about this Privacy Policy or our privacy practices generally, feel free to contact us as follows:

Email: contact@millionaireclubfinance.com

GRIEVANCE RESOLUTION

In the event that you have any complaints concerning the terms and conditions of this Policy, you are encouraged to get in touch with the appointed Grievance Resolution Officer. This officer is committed to addressing the issue within a reasonable time frame. The name and contact information of the said officer are made available on the Platform.