12. CONFIDENTIAL BUSINESS INFORMATION

Aroon Fintech recognises that businesses may provide commercially sensitive information.

This may include:

• financial information;

• business plans;

• pricing;

• customer information;

• supplier information;

• contracts;

• intellectual property;

• trade secrets;

• financial models;

• transaction structures;

• strategic plans;

• expansion plans;

• investment proposals;

• financing proposals; and

• other non-public business information.

​

Aroon Fintech will take reasonable measures to protect confidential information against unauthorised access, use, disclosure or loss.

​

Where appropriate, confidentiality obligations may additionally be governed by:

• non-disclosure agreements;

• engagement letters;

• mandates;

• transaction documents; or

• other contractual arrangements.

This Privacy Policy does not replace or limit any separate confidentiality agreement.

​

13. PROFESSIONAL ADVISERS AND SERVICE PROVIDERS

Aroon may disclose information, where appropriate and lawful, to professional advisers and service providers assisting with our business or a transaction.

These may include:

• lawyers;

• accountants;

• auditors;

• tax advisers;

• compliance advisers;

• transaction advisers;

• consultants;

• technology providers;

• cloud service providers;

• document-management providers;

• cybersecurity providers;

• identity-verification providers;

• KYC/AML providers;

• communications providers;

• data-processing providers; and

• other service providers.

​

Such parties may process information only to the extent reasonably necessary for the relevant service and subject to applicable contractual, legal and security requirements.

​

14. LEGAL, REGULATORY AND COMPLIANCE DISCLOSURES

We may collect, use or disclose information where reasonably necessary to:

• comply with applicable law;

• comply with regulatory requirements;

• respond to lawful requests;

• comply with court orders;

• respond to government authorities;

• cooperate with law enforcement;

• meet AML or KYC obligations;

• prevent fraud;

• investigate suspected unlawful activity;

• protect legal rights;

• establish or defend legal claims;

• enforce contractual rights; or

• protect Aroon Fintech, its clients, partners or other persons.

Such disclosure will be made only to the extent permitted or required by applicable law.

​

15. INTERNATIONAL DATA PROCESSING

Aroon Fintech is incorporated in India but may conduct business and work with clients, capital providers, advisers and service providers located in different countries.

Accordingly, information may be:

• transferred;

• stored;

• accessed;

• processed; or

• disclosed

in countries other than the country in which you reside or conduct business.

​

These countries may include India, the United Kingdom, countries within the European Economic Area, the United States, the UAE, Singapore, other Southeast Asian countries and other jurisdictions in which our business or service providers operate.

​

Where applicable law restricts international transfers, Aroon will seek to use an appropriate lawful transfer mechanism and reasonable safeguards.

​

For example, where GDPR applies, international transfers may require mechanisms such as an adequacy decision, Standard Contractual Clauses or another legally recognised transfer mechanism.

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16. EUROPEAN ECONOMIC AREA AND UNITED KINGDOM

Where applicable, Aroon Fintech will seek to comply with relevant data protection requirements applicable to individuals in the European Economic Area and the United Kingdom.

​

The GDPR may apply to organisations located outside the EU where they offer goods or services to individuals in the EU or monitor their behaviour, subject to the GDPR's territorial scope.

​

Where GDPR or equivalent legislation applies, individuals may have rights including, subject to applicable limitations:

• access;

• rectification;

• erasure;

• restriction;

• objection;

• data portability;

• withdrawal of consent;

• objection to direct marketing;

• rights concerning certain automated decision-making; and

• the right to lodge a complaint with the relevant supervisory authority.

Where UK data protection legislation applies, equivalent rights may be available under applicable UK law.

​

17. UNITED STATES AND OTHER JURISDICTIONS

Privacy rights vary significantly between jurisdictions.

​

Depending on where an individual is located and which law applies, additional rights may exist under applicable federal, state, provincial or national legislation.

​

Aroon will assess applicable requirements based on the relevant jurisdiction, nature of the processing and relationship with the individual.

​

Nothing in this Privacy Policy is intended to remove or restrict a privacy right that cannot lawfully be excluded under applicable law.

​

18. INDIA

Aroon Fintech is incorporated in India and may process personal data subject to applicable Indian data-protection legislation.

​

India's Digital Personal Data Protection Act, 2023 establishes a framework governing the processing of digital personal data and recognises individual rights and lawful processing requirements.

​

The application and commencement of particular provisions may depend on applicable government notifications and the relevant circumstances.

​

Aroon will comply with applicable Indian privacy and data-protection requirements as they become applicable to its processing activities.

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19. DATA SECURITY

Aroon Fintech maintains reasonable technical and organisational measures designed to protect information against:

• unauthorised access;

• unauthorised disclosure;

• alteration;

• misuse;

• destruction;

• accidental loss;

• cyber threats; and

• other unlawful or unauthorised processing.

Depending on the nature of the information and applicable requirements, safeguards may include:

• access controls;

• authentication mechanisms;

• encryption;

• secure transmission;

• restricted access;

• confidentiality obligations;

• monitoring;

• backups;

• cybersecurity controls;

• incident-management procedures;

• vendor controls; and

• periodic security reviews.

However, no method of electronic transmission, storage or processing can be guaranteed to be completely secure.

​

20. DATA BREACHES AND SECURITY INCIDENTS

If Aroon becomes aware of a security incident involving personal information, we will assess and respond to the incident in accordance with applicable law.

​

Where legally required, Aroon may notify:

• affected individuals;

• regulators;

• supervisory authorities;

• government authorities; or

• other relevant parties.

The timing, content and scope of any notification will depend on the applicable law and circumstances of the incident.

 

21. DATA RETENTION

Aroon Fintech may retain information for as long as reasonably necessary for:

• providing services;

• maintaining business records;

• completing transactions;

• maintaining advisory records;

• complying with legal requirements;

• complying with KYC/AML obligations;

• resolving disputes;

• preventing fraud;

• enforcing agreements;

• protecting legal rights;

• maintaining financial and accounting records;

• legitimate business purposes; or

• other lawful purposes.

When information is no longer reasonably required, we may delete, anonymise or securely dispose of it, subject to applicable legal and regulatory retention obligations.

​

22. YOUR PRIVACY RIGHTS

Depending on the jurisdiction and applicable law, you may have rights concerning your personal information.

These may include:

Right of Access

You may have the right to request information about whether we process your personal information and to obtain a copy where legally required.

Right to Correction

You may request correction of inaccurate or incomplete information.

Right to Deletion

You may request deletion of personal information in circumstances permitted by law.

Right to Restriction

You may have the right to request restriction of certain processing.

Right to Object

You may have the right to object to particular processing activities, including certain forms of direct marketing.

Right to Withdraw Consent

Where processing is based on consent, you may withdraw consent, subject to applicable law.

Right to Data Portability

Where applicable, you may request certain personal information in a structured, commonly used and machine-readable format.

Rights Relating to Automated Decision-Making

Where applicable law provides such rights, you may have rights concerning certain automated decision-making or profiling activities.

The availability and scope of these rights depend on the applicable jurisdiction and legal basis for processing.

​

23. HOW TO EXERCISE YOUR PRIVACY RIGHTS

​

To submit a privacy request, contact:

Aroon Fintech Private Limited
2524, Block-G, Sainik Colony, Sector-49,
Faridabad, Haryana – 121001, India

Email: support@aroonfintech.com

​

Please use the subject:

“Privacy Request – Aroon Fintech”

Your request should, where reasonably possible, include:

• your name;

• contact details;

• nature of your request;

• relevant company or transaction reference;

• information necessary to identify the relevant records; and

• reasonable information required to verify your identity.

​

We may request additional information where necessary to protect against unauthorised access to personal information.

​

We will respond within the period required by applicable law.

​

24. DIRECT MARKETING

Subject to applicable law, Aroon Fintech may send communications relating to:

• financial advisory services;

• capital markets;

• business finance;

• financing opportunities;

• investment opportunities;

• industry developments;

• market information;

• research;

• events;

• newsletters;

• corporate announcements; and

• Aroon Fintech services.

Where required, we will obtain consent before sending certain forms of marketing communication.

​

You may unsubscribe from marketing communications at any time by using the relevant unsubscribe mechanism or contacting us.

​

You may continue to receive essential service, transaction, security, legal or administrative communications where permitted by law.

​

25. AUTOMATED PROCESSING AND DECISION-MAKING

Aroon Fintech may use technology for purposes including:

• website administration;

• analytics;

• operational processes;

• fraud detection;

• cybersecurity;

• document processing;

• workflow management; and

• administrative efficiency.

​

Unless expressly stated otherwise, submitting information to Aroon Fintech does not itself constitute an automated approval or rejection of a financing or investment request.

​

Potential lenders, investors and other capital providers may independently conduct their own assessments and make their own financing or investment decisions.

​

Where applicable law grants specific rights relating to automated decision-making or profiling, those rights will be respected.

​

26. THIRD-PARTY WEBSITES AND SERVICES

Our website or communications may contain links to third-party websites, platforms or services.

Aroon Fintech does not control the privacy practices, security measures or content of independent third parties.

Your interaction with such third parties may be governed by their own:

• privacy policies;

• terms of use;

• cookie policies; and

• other contractual or legal terms.

We encourage you to review the applicable policies before providing information to third parties.

​

27. CHILDREN'S PRIVACY

Aroon Fintech's services are intended primarily for businesses, professionals, companies, investors, project sponsors and other adults engaged in commercial or professional activities.

​

Our services are not intentionally directed toward children.

​

Where applicable law requires specific protections for children's data, Aroon will comply with those requirements.

​

28. INFORMATION RELATING TO BUSINESSES AND LEGAL ENTITIES

Aroon Fintech primarily works with businesses and legal entities.

​

Information relating to a company or organisation may not itself constitute personal information in certain jurisdictions.

However, corporate information may contain information relating to identifiable individuals, including:

• directors;

• shareholders;

• beneficial owners;

• promoters;

• employees;

• officers;

• authorised representatives;

• consultants; and

• business contacts.

​

Where such information constitutes personal information under applicable law, it will be handled accordingly.

​

29. ACCURACY OF INFORMATION

Individuals and organisations providing information to Aroon Fintech should ensure that the information provided is:

• accurate;

• complete;

• current;

• lawful; and

• provided with appropriate authority.

You should notify us if relevant information changes or if you become aware that information previously provided is inaccurate.

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30. LEGAL BASES FOR PROCESSING

Where a law requires Aroon Fintech to identify a legal basis for processing personal information, the applicable basis may include:

• consent;

• performance of a contract;

• steps taken before entering into a contract;

• compliance with legal obligations;

• legitimate interests;

• protection of legal rights;

• prevention of fraud or unlawful activity;

• regulatory or compliance requirements; or

• another lawful basis recognised under the applicable jurisdiction.

The applicable legal basis may differ depending on the country, nature of the information and purpose of processing.

 

31. INTERNATIONAL AND JURISDICTION-SPECIFIC PRIVACY RIGHTS

Aroon Fintech operates internationally and recognises that privacy legislation differs between countries.

Accordingly:

• this Policy is intended to operate as a global baseline;

• additional rights may apply depending on your jurisdiction;

• local mandatory privacy requirements will prevail where applicable;

• separate notices may be provided where required;

• additional consent mechanisms may be used where legally required; and

• contractual or regulatory safeguards may apply to specific transactions.

This Policy should therefore be read together with any jurisdiction-specific privacy notice that Aroon may provide.

 

32. CONFIDENTIALITY DOES NOT GUARANTEE FUNDING

Providing information to Aroon Fintech for advisory or capital-arranging purposes does not guarantee:

• financing;

• investment;

• loan approval;

• capital raising;

• transaction completion;

• specific financing terms;

• a specific interest rate;

• valuation;

• investment amount; or

• transaction closing.

Aroon Fintech acts as an independent adviser and capital arranger.

Final financing and investment decisions are made independently by the relevant lender, investor, financial institution or other capital provider.

 

33. CHANGES TO THIS PRIVACY POLICY

Aroon Fintech may update this Privacy Policy from time to time to reflect:

• changes in applicable law;

• regulatory developments;

• changes to our services;

• changes to technology;

• changes to our business;

• new data-processing activities; or

• improvements to our privacy practices.

​

The updated version will be published on our website with a revised “Last Updated” date.

​

Where required by law, we may provide additional notice or obtain consent before implementing material changes.

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34. GOVERNING LAW AND MANDATORY LOCAL RIGHTS

​

Aroon Fintech Private Limited is incorporated in India and operates from India.

​

Subject to mandatory rights and protections applicable in the jurisdiction of the individual concerned, this Privacy Policy is intended to be interpreted consistently with applicable Indian law and other applicable data-protection laws.

​

Nothing in this Policy is intended to exclude, restrict or waive any mandatory privacy right that cannot lawfully be excluded or restricted.

​

Where local legislation provides greater or additional protection, the applicable mandatory provisions of that legislation will apply to the relevant processing.

​

35. CONTACT US

For privacy-related questions, requests or concerns, please contact:

​

Aroon Fintech Private Limited

​

Registered Office:
2524, Block-G, Sainik Colony, Sector-49,
Faridabad, Haryana – 121001, India

​

Email: support@aroonfintech.com

Website: www.aroonfintech.com

​

Subject: Privacy Request – Aroon Fintech

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36. ACKNOWLEDGEMENT

By accessing our website, submitting information, making an enquiry, requesting advisory services, participating in a financing or capital-raising process, or otherwise interacting with Aroon Fintech, you acknowledge that information may be collected and processed as described in this Privacy Policy, subject to applicable law.

​

Where applicable law requires consent, consent will be obtained through an appropriate mechanism.

​

Your use of Aroon Fintech's services remains subject to applicable contractual terms, engagement letters, mandates, confidentiality agreements, disclaimers and other applicable terms.

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AROON FINTECH PRIVATE LIMITED

Independent Financial Consulting, Advisory & Capital Arranging

Aroon Fintech assists businesses, companies and project sponsors in evaluating and accessing potential sources of debt, equity, structured finance and other forms of capital through independent advisory and capital-arranging services.