Privacy Statement

Effective Date: January 15, 2025

Introduction

Decision Machine is a decision-scoring and compliance platform for fintech teams, NBFCs, SME lenders, and enterprise institutions.

We understand that you are aware of and care about your own personal privacy interests, and we take that seriously. This Privacy Notice describes Decision Machine’s policies and practices regarding its collection and use of your personal data, and sets forth your privacy rights. We recognize that information privacy is an ongoing responsibility, and so we will from time to time update this Privacy Notice as we undertake new personal data practices or adopt new privacy policies.

Data Protection Officer

Decision Machine is headquartered in Pune, India. Decision Machine has appointed an internal data protection officer for you to contact if you have any questions or concerns about Decision Machine’s personal data policies or practices. If you would like to exercise your privacy rights, please direct your query to Decision Machine’s data protection officer:

Data Protection Officer · Decision Machine Private Limited · Sprint Antaaya, Baner Rd, Balewadi, Pune, Maharashtra 411045, India · contact@amrutraj.com

How we collect and use (process) your personal information

Decision Machine collects personal information about its website visitors and customers. With a few exceptions, this information is generally limited to: name, employer name, and work email.

We use this information to provide prospects and customers with our services. We do not sell personal information to anyone and only share it with third parties who are facilitating the delivery of our services.

Use of the Decision Machine website

As is true of most other websites, Decision Machine’s website collects certain information automatically and stores it in log files. This may include IP addresses, the region or general location where your device is accessing the internet, browser type, operating system, and other usage information, including a history of the pages you view. We use this information to help us design our site to better suit our users’ needs, diagnose problems with our servers, administer our website, analyze trends, track visitor movements, and gather broad demographic information that assists us in identifying visitor preferences.

Decision Machine has a legitimate interest in understanding how members, customers, and potential customers use its website. This assists Decision Machine with providing more relevant products and services and with providing appropriate support to meet customer needs.

Cookies and tracking technologies

We use cookies and similar tracking technologies (such as pixels and local storage) to operate our website, remember your preferences, and understand how our website is used. This includes strictly necessary cookies required for the site to function, and analytics cookies that help us understand aggregate usage patterns. You can control or delete cookies through your browser settings; disabling certain cookies may affect the functionality of the website.

Use of the Decision Machine service

When Customer uses the Service, Decision Machine processes Customer Data (as defined in our Terms and Conditions) on Customer’s behalf — including account, transaction, and decision-scoring data configured by Customer — solely to provide, maintain, and improve the Service. Decision Machine acts as a data processor with respect to Customer Data and does not use Customer Data for any purpose other than providing the Service, unless otherwise agreed in writing.

When and how we share information with third parties

The personal information Decision Machine collects from you is stored in one or more databases hosted by third parties. These third parties do not use or have access to your personal information for any purpose other than cloud storage and retrieval. On occasion, Decision Machine engages third parties to send information to you, including information about our products, services, and events.

We do not otherwise reveal your personal data to non-Decision Machine persons or businesses for their independent use unless: (1) you request or authorize it; (2) the information is provided to comply with the law; (3) the information is provided to our agents, vendors, or service providers who perform functions on our behalf; (4) it is needed to address emergencies; or (5) it is needed to address disputes or claims, or for persons demonstrating legal authority to act on your behalf. We may also gather aggregated, non-personally-identifiable data about our services and website visitors and disclose the results to partners, service providers, and advertisers for marketing purposes.

The Decision Machine website may connect with third-party services such as LinkedIn and others. If you choose to share information from the Decision Machine website through these services, you should review the privacy policy of that service.

We may disclose your Personal Information to third-party service providers (for example, payment processing and data storage facilities) that we use to provide the Services. We limit the Personal Information provided to these service providers to that which is reasonably necessary for them to perform their functions, and we require them to agree to maintain the confidentiality of such Personal Information. These service providers are not permitted to use the information collected on our behalf except to help us conduct and improve our business.

We may share your Personal Information with other companies under common ownership as Decision Machine, which will use it in the same way as we can under this Privacy Policy unless otherwise specified. In the event we enter into a transaction that alters the structure of our business, such as a merger, reorganization, or sale, we may share Personal Information to facilitate and complete the transaction.

International data transfers

Decision Machine is headquartered in India. Where we or our infrastructure and service providers process personal data outside India — for example, on cloud infrastructure located in the United States or the European Union — we apply appropriate contractual and technical safeguards, including Standard Contractual Clauses where required under the GDPR for our European customers, to ensure your personal data continues to receive an equivalent level of protection.

Decision Machine enters into data processing agreements and model clauses with its vendors whenever feasible and appropriate, and applies suitable technical and organizational safeguards to protect the privacy and security of your personal data consistent with the practices described in this Privacy Statement. For more information, please contact us at contact@amrutraj.com.

Data Subject rights

Depending on your location, you may have rights under India’s Digital Personal Data Protection Act, 2023 (DPDPA), the European Union’s General Data Protection Regulation (GDPR), or other applicable privacy laws. These commonly include: the right to be informed, right of access, right to correction (rectification), right to erasure, right to restrict processing, right of data portability, right to object, and rights related to automated decision-making, including profiling.

If you wish to confirm that Decision Machine is processing your personal data, or to have access to the personal data Decision Machine may have about you, please contact us. You may also request information about the purpose of the processing, the categories of personal data concerned, who else might have received the data, the source of the information (if not provided directly by you), and how long it will be stored. You have a right to correct (rectify) inaccurate personal data, request erasure or restriction of processing (subject to certain exceptions), and object to use of your data for direct marketing.

Reasonable access to your personal data will be provided at no cost. If access cannot be provided within a reasonable time frame, Decision Machine will provide you with a date when the information will be provided, or an explanation if access is denied. For questions or complaints, email contact@amrutraj.com. You may also lodge a complaint with India’s Data Protection Board, or, if applicable, your own national data protection authority.

Security of your information

We maintain administrative, technical, and physical safeguards designed to protect the personal information we process from loss, misuse, unauthorized access, disclosure, alteration, and destruction. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

Data storage and retention

Your personal data is stored by Decision Machine on its servers, and on the servers of the cloud-based database management services Decision Machine engages. Decision Machine retains service data for the duration of the customer’s business relationship with Decision Machine and for a period of time thereafter, to analyze the data for Decision Machine’s own operations, and for historical and archiving purposes associated with Decision Machine’s services. Decision Machine retains prospect data until such time as it no longer has business value and is purged from Decision Machine systems. All personal data that Decision Machine controls may be deleted upon verified request from Data Subjects or their authorized agents.

Children’s data. We do not knowingly attempt to solicit or receive information from children.

Data for AI and model training. Decision Machine is fully committed to protecting your data and does not use Customer Data to train third-party artificial intelligence or machine learning models. Decision Machine does not share Customer Data with third-party model providers for the purpose of improving their products or models. To further protect your information, we have established Data Processing Addendums (DPAs) with our third-party providers, ensuring they do not use Customer Data to improve their products or models. If you wish to opt out of any data being sent from your Decision Machine account to a third-party integration, please email contact@amrutraj.com.

Third-party integrations. Decision Machine may provide the ability to connect to third-party systems, such as core banking platforms, data warehouses, and messaging tools. These services operate independently from Decision Machine and have their own privacy policies, which you should review individually. Decision Machine is not responsible for the content or privacy practices of third-party sites or systems it does not own.

Data Protection and Security Measures

Decision Machine implements comprehensive technical and organizational measures to protect your personal information, particularly sensitive data.

Technical safeguards include: data encryption in transit using TLS 1.3 or higher; data encryption at rest using AES-256 encryption standards; regular security assessments and penetration testing; secure API endpoints with authentication and authorization controls; and network segmentation and firewall protection.

Organizational safeguards include: access controls limiting data access to authorized personnel only; regular employee security training and background checks; data minimization practices; incident response procedures for potential data breaches; and regular security audits and compliance assessments.

For sensitive personal information, we apply enhanced protection measures including additional encryption layers, restricted access on a need-to-know basis, enhanced monitoring and logging of access, and secure deletion procedures when data is no longer needed.

Questions, concerns, or complaints

If you have questions, concerns, complaints, or would like to exercise your rights, please contact us at:

Decision Machine Private Limited · Sprint Antaaya, Baner Rd, Balewadi, Pune, Maharashtra 411045, India · contact@amrutraj.com

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