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Privacy Policy

This Privacy Policy outlines Paisabazaar’s (“Paisabazaar Marketing and Consulting Private
Limited”) approach to processing of Data by HDFC Bank Limited [directly or through its
service providers including Paisabazaar as a Lending Service Provider (LSP) (as defined under
the Reserve Bank of India’s Guidelines on Digital Lending dated September 02, 2022 as may
be amended, modified or replaced from time to time) of HDFC Bank to the extent allowed
by it].

Paisabazaar and HDFC Bank are committed to treating data privacy seriously. It is important
that you know exactly what HDFC Bank (directly or through its service providers including us
to the extent allowed by HDFC Bank) does with the personal data you and others provide to
HDFC Bank, its service providers or us, why it is processed and what it means to you. Please
read this Privacy Policy carefully.

Definitions

The following capitalised terms shall have the meanings assigned to them as under:

“Covered Person(s)” or “You” shall have the meaning as ascribed to the term in the
‘Applicability’ section of this Privacy Policy.

“Data” shall have the meaning as ascribed to the term in the ‘Data’ section of this Privacy
Policy.

“Derivation” shall have the meaning as ascribed to the term in the ‘Data’ section of this
Privacy Policy.

“Derivative Data” shall have the meaning as ascribed to the term in the ‘Data’ section of
this Privacy Policy.

“HDFC Bank” or “Bank” shall mean HDFC Bank Limited having its registered office at
Senapati Bapat Marg, Lower Parel (West), Mumbai 400013, Mumbai, India.

“Non-Mandatory Data” shall have the meaning as ascribed to the term in the ‘When and
how we collect Data about you?’ section of this Privacy Policy.

“Non-Mandatory Purposes” shall have the meaning as ascribed to the term in the ‘Purposes
of processing Data’ section of this Privacy Policy.

“Processing Entity” shall have the meaning as ascribed to the term in the ‘Who we share
your Data with?’ section of this Privacy Policy.

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“Product(s)” shall mean the products and services of HDFC Bank, including where the
initiation of any request, application or transaction is through us or any service provider of
the Bank or through any Processing Entity or where HDFC Bank is acting as distributor or
agent or acting under any referral arrangement for products or services of any other person
or as an intermediary or a sponsor bank.

“Specified Purposes” shall collectively mean purposes of credit assessment, risk assessment,
risk analysis, obtaining credit information reports, scores, scrubs, fraud checks, fraud
detections, fraud prevention, detecting and preventing crime including crime/ terror
funding, detecting malpractices or discrepant documents or information, prevention of
misuse, assessment of credit worthiness, financial standing, due diligence, background
check, physical and other inspections, verifications, obtaining any reports for any of the
above, KYC/ AML checks, customer service, monitoring, collections, default detection,
default prevention, default investigation, recovery, any legal proceedings, actions, enquiries,
investigations, pursuing any remedies, enforcing rights, reporting including credit reporting,
KYC reporting, default reporting, filing, perfections etc., whether any of these are
undertaken internally by the Bank or through any of its Processing Entities including us, as
applicable, or through a combination of multiple options.

Applicability

This Privacy Policy applies to personal data of any natural person (“Covered Person(s)” or
“You” or any cognate variations thereof). Please note that the Products’ terms and
conditions will cover specific matters in addition to this Privacy Policy and this Privacy Policy
does not limit any of those specific matters or any other consent that you may have given or
may give to or for the benefit of HDFC Bank. The Privacy Policy of HDFC Bank as available at
Paisabazaar shall also be applicable to the Covered Persons. Therefore, please also read
such specific terms and conditions in relation to the Products, such other consents,
wherever applicable, and the said privacy policy.

Who we are

Throughout this document, “we”, “us”, “our” and “ours” or any cognate variations thereof
refer to Paisabazaar

Website: https://www.paisabazaar.com/

Our contact details are given at the end of this Privacy Policy.

Data

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The personal data collected or received falls into various categories as under:

 Identity & contact information

o Name, address, signatures, biometric data, date of birth, copies of identity cards (ID),
contact details including email id and phone number, address, previous names, maiden
names, marital status, relatives information, nomination, medical condition, domicile,
origin, citizenship, nationality, residence, any legal or other identifiers like Permanent
Account Number (PAN)/ Taxpayer Identification Number (TIN)/ National ID/ Social
Security Number/ or its equivalent, Photograph and Gender.
o Data that identifies (whether directly or indirectly) a particular individual, such as
information you provide on any forms, surveys, online applications or similar online
fields.
o Demographic information that you provide and aggregated or de-identified Data.

 Financial details/circumstances
o Bank account details, investments history, credit/debit card details, prepaid payment
instrument details, any other instrument/ modality/ function details, UPI handles,
income details, history in relation to these, to the extent applicable.
o Employment/ occupational information.
o Residential status under banking, general and tax laws.
o Spending/saving/investing/payments/receipts/borrowing history.
o Risk profile, financial objectives, financial knowledge and experience, preferences and
any other information to assess the suitability of the Products to you.
o Information collected when you make or receive payments.
o Other information such as information relating to occupation and financial situation
such as employer’s name and address, if self-employed, type of account, and nature
and volume of anticipated business dealings, with the conventional bank licensee,
income proof, bank statements, income tax returns, salary slip, contract of
employment, passbook, expenditure, assets and liabilities, source of wealth and
signature.
o Data that is collected when you make financial and non-financial transactions. Data may
include information associated with the transaction such as amount sent or requested,
amount paid for Products or merchant information and/or loan related information
such as loan amount applied for, interest rate, tenure, repayment schedule, security
etc.

 Information you provide about others or others provide about you

o If you give information or data about someone else (for example, information or data
about a spouse or financial associate provided during the course of a joint application
with that person), or someone gives information about you, may be added to any Data

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that is already held about you and can be used in the ways described in this Privacy
Policy.
o Your Data from third party providers: In order to enhance our ability to provide relevant
marketing, offers, and services to you, Data about you is obtained from other sources
with your consent, such as email service providers, public databases, joint marketing
partners, social media platforms, as well as from other third parties as appropriate.
o Information including Data from credit information companies/ credit reference
agencies, risk management and fraud prevention agencies, national and government
databases.
o Information including Data from other parties and entities where we are a part of a
transaction in one or more roles even though we may not be directly interfacing you.
o Data of authorised signatories or authorised persons or representatives of non-
individual applicants/ customers/ users of any services, whether direct or indirect.

 Information from online activities.

o Information about your internet activity is collected using technology known as cookies,
which can often be controlled through internet browsers. For detailed information on
the cookies used and the purposes for which they are used, see our Cookie Policy,
which is available on our website.
o Your digital and electronic devices where various checks are performed are designed to
ascertain and verify your residency to ensure we meet our regulatory obligations. These
checks include identifying and collecting your location (with your specific permission)
and the IP address your device connects from and the collection of information about
your use of the website or mobile app (including device type, operating system, screen
resolution, and the way you interact with us).
o Information about your Internet browser, IP address, information collected through
tracking technologies.
o Unique device identifier such as International Mobile Equipment Identity (IMEI)
number, technical usage data, contact lists (in some cases where specific permission is
obtained), technical data about your computer and mobile device including details
regarding applications and usage details.
o Generation and storing password or PIN in encrypted form, for any of our apps/
platforms.

 Other personal information

o Information in relation to data access, correction, restriction, deletion, porting requests
and complaints.
o CCTV images and Data at our offices (but only for security reasons and to help prevent
fraud or crime).
o Conversations during meetings/calls/correspondences/discussions with our staff.

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o Social relationships detail such as your father’s name, spouse’s name and mother’s
name.
o Behavioural details as to how to utilise our Products, offers etc., your browsing actions,
patterns and online activity.
o Records of correspondence and other communications with you, including email,
telephone conversations, live chat, instant messages and social media communications
containing information concerning your grievances, complaints and dispute.
o Any other information, Data or records which you may consent to be collected or used.

Out of the aforesaid data points, the following are ‘sensitive personal data or information’:
i. Password for any of our apps/ platforms;
ii. financial information such as Bank Account or Credit Card or Debit Card or other
payment instrument details;
iii. physical, physiological and mental health condition;
iv. sexual orientation;
v. medical records and history; and
vi. any detail relating to the above clauses as provided by you.

Provided that, any information that is freely available or accessible in public domain or
furnished under the Right to Information Act, 2005 or any other law for the time being in
force shall not be regarded as ‘sensitive personal data or information’.

Any of the aforesaid data (whether personal data or sensitive personal data or information),
information, know your customer (KYC) related data, any derivative thereof ("Derivative
Data”) like any credit scores or behavioural projections, profiling, analytical results, reports
(prepared by us or others) including through any algorithms, analytics, software,
automations, profiling etc., and whether such derivative is from the information collected
from you or in combination with any other information sourced from any other person,
database or source whether by us or HDFC Bank or others, shall collectively be referred to
as “Data” and any part of the process relating to arriving at the Derivative Data as above,
whether through internal or external sourcing, shall be referred to as “Derivation”.

When and how your Data is collected?

We and/or HDFC Bank may collect or possess the Data through any of the following:
o When you submit the Data including when you ask or request us or HDFC Bank (directly
or through any Processing Entity) to provide you with certain Products.
o When you use the Products.
o During the course of transactions.
o When you apply for the Products, make enquiries or engage with us or HDFC Bank or
with any other person where we or HDFC Bank are involved for any other person in the
transaction concerning you.

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o Data collected during credit assessment, risk assessment, fraud checks, fraud
detections, processes undertaken for fraud prevention, detecting malpractices or
discrepant documents or information, prevention of misuse, assessment of credit
worthiness, evaluation of financial standing, due diligence, background check, physical
and other inspections, verifications, KYC/ Anti Money Laundering (AML) checks,
monitoring, collections, recovery, customer service etc.
o When you use our website and online products/ services provided by us or HDFC Bank
(including mobile applications) and visit our/ HDFC Bank’s branches, offices, stores or
premises.
o When you email or call or respond to our or HDFC Bank’s emails/phone calls or during
meetings with our or HDFC Bank’s staff or service providers or representatives.
o When you or HDFC Bank or others give the Data verbally or in writing. This Data may be
on application forms, in records of your transactions with us or HDFC Bank or if you
make a complaint.
o From information publicly available about you. When you make Data about yourself
publicly available on your social media accounts or where you choose to make the Data
available to us or HDFC Bank through your social media account, and where it is
appropriate for us or HDFC Bank to use it.
o During or as a result of Derivation, from any person possessing the same or sourcing
any Data therefor.
o Data collected through cookies.
By accepting this Privacy Policy or by applying for or using any Product (including where the
initiation of any transaction is not directly with us or HDFC Bank but is with a relevant
Processing Entity), you agree that any person who submits any Data or part thereof to us or
HDFC Bank or the Processing Entity or from whom such Data is sourced (including
Derivation), shall be deemed to have been authorised by you to submit such Data to us or
HDFC Bank and you hereby further authorise us or HDFC Bank to process any such Data for
any of the purposes mentioned in this Privacy Policy.

[Our apps may be required by you to delete/ forget the Data submitted by you on such App
which is specified as ‘Non-Mandatory Data’ during the application process for a digital
lending Product (“Non-Mandatory Data”) (however subject to any contrary legal/
regulatory requirements), by following the process in this regard.]

How is your Data processed?

Whether we or HDFC Bank is/are using it to confirm your identity, to help in the processing
of an application for any Product or to improve your experiences with us or HDFC Bank, your
Data is always handled with care and the principles outlined in this Privacy Policy are always
applied.

Purposes of processing Data

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The processing of the Data may be done by HDFC Bank (directly or through its service
providers including us to the extent allowed by HDFC Bank) or any of the Processing Entities
for any of the following purposes, and you agree and consent to the same:
o To provide you with Products.
o To process your loan application and for undertaking related processes such as loan
sanction/ approval, disbursement, recovery and customer service.
o To manage relationships with you.
o For enabling your use of Products.
o For processing, executing transactions.
o For enabling any applications/ requests for any Products, for processing any such
applications/ requests, for performing any contract pursuant thereto and for
undertaking any Specified Purposes in relation to any of the above.
o To perform activities such as data analysis, audits, usage trends to determine the
effectiveness of HDFC Bank’s campaigns and as input into improving Products.
o For credit scoring, credit analysis, risk analysis, obtaining any reports, credit scores,
credit information, scrubs, for assessing and undertaking/ evaluating financial standing,
fraud check, fraud probability, reference checks, due diligence, inspections, etc.
including from or through any credit information companies, bureaus, fintech entities
or service providers.
o For enabling use of our website, platforms, and online services (including mobile or web
applications) and visiting our branches, offices.
o To contact you or to establish contact with you or your whereabouts.
o To allow you to utilize features on platforms/ apps by granting us access to Data from
your device.
o For security, business continuity and risk management.
o For system or product development and planning, audit and administrative purposes.
o To personalize your platform/ app experience.
o To improve customer/ user experience.
o To inform you about important information regarding our Products, changes to terms,
conditions, and policies and/or other administrative information; Where processing is
necessary for the performance of a contract to which you are a party or in order to take
steps prior to entering into a contract. To allow HDFC Bank to take actions that are
necessary in order to provide you with the Products (performance of a contract), for
example, to make and receive payments.
o Where processing is necessary because of a legal or regulatory obligation that applies to
us or HDFC Bank.
o Where processing is necessary for the purposes of the legitimate interests pursued by
HDFC Bank. Processing may be required by HDFC Bank or its service providers to meet
HDFC Bank’s legitimate interests, for example, to understand the customer behaviour,
customer expectations, to build analytical models, or to understand how customers use
or respond to the Products, or to develop new Products, as well as improve the

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Products. This may also include sharing of your Data by HDFC Bank either as part of a
sample or specifically or generally with its potential or actual service provider or
consultant or vendor or third party or Processing Entity, for the purposes of testing by
HDFC Bank of proof of concept, where HDFC Bank may test the utility, workability,
efficacy, authenticity of any solution or service proposed or being rendered by any such
person, and any such person may process such Data along with any other data it may
have or source externally, for the purpose of running or pilot running or testing of the
proposed solution or service and to submit the results to HDFC Bank along with the
Data and any other data which such person may have or source. You agree that such
sharing of Data and processing thereof and testing of proof of concept is in HDFC Bank’s
legitimate interest to improve HDFC Bank’s efficiency, customer service, product
delivery, to prevent frauds, etc. and ultimately is a necessary part of developing the
ecosystem where its customers and potential customers including you, benefit.
o Subject to a specific consent (obtained separately from this Privacy Policy), to allow you
to participate in surveys and other forms of market research, contests and similar
promotions and to administer these activities. Some of these activities have additional
rules, which may contain additional information about how Data is used and shared.
o To allow you to apply for Products including to pre-populate any Data during any
application whether directly by us or through any service provider on any platform.
o Where we or HDFC Bank have your consent to do so.
o In connection with Products, we or HDFC Bank may also contact you or send you
messages, notifications or alerts by post, telephone, text, email, through social media
POS machines and other digital methods, including for example via ATMs, mobile
applications or push notifications, or online banking services (and new methods that
may become available in the future).
o For assessing, examining and/or determining by HDFC Bank, whether directly or
through us (to the extent allowed by HDFC Bank), from time to time, your eligibility
(including pre-eligibility), suitability or credit worthiness for any of the Products from
time to time (and to undertake Specified Purposes therefor).
o For any purposes which are incidental or necessary to any of the aforesaid purposes.

The purposes where it has been expressly specified above that such purpose is a non-
mandatory purpose, shall be referred to as “Non-Mandatory Purposes”.

Subject to what is stated in this Privacy Policy for the Non-Mandatory Purposes, you agree
that HDFC Bank may engage with any Processing Entity, for any of the aforesaid purposes or
part thereof for any incidental or ancillary purposes, and may accordingly share Data with
any of them and allow them to further process/ share the same, for the said purposes.

Automated processing

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The way HDFC Bank (directly or through its service providers including us to the extent
allowed by HDFC Bank) analyses personal information in relation to the Products including
applications, credit decisions, determining your eligibility for the Products, may involve
automated profiling and decision making, this means that HDFC Bank may process your Data
using software that is able to evaluate your personal aspects and predict risks or outcomes
as also where the decision making may be automated.

HDFC Bank may, directly or through us or through its service providers, also carry out
automated anti-money laundering and sanctions checks. This means that it may
automatically decide that you pose a fraud or money laundering risk if the processing
reveals your behaviour to be consistent with money laundering or known fraudulent
conduct, is inconsistent with your previous submissions, or you appear to have deliberately
hidden your true identity.

Who we share your Data with?

We may share the Data with the following persons and/or in the following circumstances:
 With HDFC Bank in relation to or in connection with the Products.

HDFC Bank (either directly or through its service providers) may share the Data with the
following persons and/or in the following circumstances:
 With HDFC Bank’s subsidiaries and/or affiliates in an effort to bring you improved
services across its family of Products, when permissible under relevant laws and
regulations or with consent.
 With HDFC Bank’s service providers, vendors, agents etc. who perform services for it or
assists it/ its subsidiaries/ affiliates to operate the business or provide the Products or
services (own or where it/ its subsidiaries/ affiliates distribute, refer or act as agent
etc.), intermediaries or consultants.
 Entities or persons with whom HDFC Bank has tie-ups for the co-branded services,
products or programs, any rewards programs or loyalty programs, any benefits, offers,
features or any similar arrangements.
 With co-lenders, co-originators, collaborators, and persons with whom HDFC Bank may
have a tie-up for any Products.
 Other third parties to comply with legal requirements such as the demands of
applicable warrants, court orders; to verify or enforce HDFC Bank’s terms of use, HDFC
Bank’s other rights, or other applicable policies; to address fraud, security or technical
issues; to respond to an emergency; or otherwise to protect the rights, property or
security of HDFC Bank’s customers or third parties.
 HDFC Bank may share your Data, without obtaining your consent or without intimating
you: (a) with governmental, statutory, regulatory, executive, law-enforcement,
investigating or judicial/ quasi-judicial authorities, departments, instrumentalities,
agencies, institutions, boards, commissions, courts, tribunals, who ask for such Data

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including by way of an order, direction, etc; or (b) with any person, where disclosure is
necessary for compliance of any legal or regulatory obligation. Wherever the Data is
shared by HDFC Bank as above, it will not have control over how such Data is further
processed by such authorities, persons, etc. (both under ‘a’ and ‘b’ above).
 Credit information companies, bureaus, fintech entities or service providers for the
purposes of obtaining any reports, credit scores, credit information, scrubs, financial
standing, fraud check, fraud probability, reference checks, due diligence, inspections,
risk analysis etc.
 With any persons involved in Derivation.

The Data may also be shared by any of the aforesaid entities/ persons (with whom the Data
is shared by the Bank or on behalf of HDFC Bank), to the extent as may be allowed by HDFC
Bank, with their service providers, consultants, agents, HDFC Bank’s subsidiaries, affiliates,
co-brand entity/partner, distributors, selling/ marketing agents, any partners, fintech
companies, other players/ intermediaries in any ecosystem of which HDFC Bank are a part,
TPAPs, HDFC Bank’s collaborators, co-lenders, co-originators, merchants, aggregators, lead
generators, sourcing entities, clients, customers or other persons with whom HDFC Bank
has a tie-up or contract for any products or services etc. for any of the aforesaid purposes or
any purposes incidental or necessary thereto. Any person or entity with whom the Data or
any part thereof is shared by HDFC Bank or on its behalf or further shared by any of them to
the extent allowed by HDFC Bank, for any of purposes under this Privacy Policy, shall be
referred to as a “Processing Entity”. [Wherever the Data is shared with any Processing
Entity (with whom HDFC Bank has a direct contract), HDFC Bank will through such contracts
restrict the processing by them of such Data for the aforesaid purposes.]

For further information, please refer to the Products’ specific terms and conditions and
application form.

Period of storage of the Data

HDFC Bank (directly or through its service providers including us to the extent allowed by
HDFC Bank) will keep the Data collected about you for as long as required for the purposes
set out above or even beyond the expiry of HDFC Bank’s transactional or account based
relationship with you: (a) as required to comply with any legal and regulatory obligations to
which we are subject, or (b) for establishment, exercise or defence of legal claims, or (c) as
specified in this Privacy Policy, or (d) in accordance with specific consents. Provided that you
may during the application process for a Product, deny the consent for retention of Non-
Mandatory Data however subject to any contrary legal/ regulatory requirements.

Implications of not providing Data or Withdrawing Consent

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Wherever in this Privacy Policy it is specified that you may withdraw a particular consent,
you may choose to withdraw such consent, but doing so may limit the products and/or
services or the deliverability thereof of HDFC Bank, unless such consent is not the only legal
or contractual basis for processing and there are other legal or contractual basis as well.
Thus, if you withdraw such consent, it will not affect the lawfulness of processing by or for
HDFC Bank based on your consent before its withdrawal or even any further processing
pursuant to other legal or contractual basis, if any, which HDFC Bank may have for such
processing.]

Reasonable security practices and procedures

Paisabazaar is ISO 27001:13 compliant. HDFC Bank is ISO 27001:13 compliant. We and HDFC
Bank seek to use reasonable organizational, technical and administrative measures to
protect Data within our respective organizations. However, if you have reason to believe
that your interaction with us/ HDFC Bank is no longer secure, please immediately notify us/
HDFC Bank in accordance with the ‘How to contact us/ HDFC Bank’ section.

Links/ Re-direction to Other Websites/ Platforms

From time to time, our/ HDFC Bank’s website/ webpage/ platform/ apps may contain links
or have a mechanism of re-direction to and from other websites/ webpages/ platforms/
apps of other networks, advertisers, affiliates and Processing Entities. If you follow a link or
such re-direction to any of these websites/ webpages/ platforms/ apps, please note that
these websites/ webpages/ platforms/ apps may have their own privacy notices and that
HDFC Bank and we do not accept any responsibility or liability for any such notices. Please
check such notices, where available, before you submit any Data to these websites/
webpages/ platforms/ apps.

Right to review
Please note that the accuracy of the Data provided is essential, among others, for the
provision of Products to you. It is therefore mandatory that you ensure the accuracy and
completeness of all Data disclosed or shared. Without prejudice to any rights and remedies
of the Bank under any contract in this regard, you shall be able to review the Data that you
had provided and correct or amend as feasible any such Data which you find to be
inaccurate or deficient. You may do this by following the process prescribed by HDFC Bank
in this regard. For knowing the process you may contact HDFC Bank.
Provided that HDFC Bank/ we shall not be responsible for the authenticity of the Data
supplied by you to us / HDFC Bank or any other person acting on behalf of HDFC Bank.

Cookies

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HDFC Bank may use cookies and similar technologies on its websites, mobile apps, and
emails. Cookies are text files that get small amounts of information, which your computer or
mobile device stores when you visit a website or use a mobile app. For more details in this
regard, you may please refer to HDFC Bank’s Cookie Policy available on its website.

How to contact us/ HDFC Bank

You may contact our Privacy Contact at https://www.paisabazaar.com/contact-us
You may contact HDFC Bank’s Privacy Contact
at https://www.hdfcbank.com/personal/need-help/contact-us

Changes to this Privacy Policy

HDFC Bank’s products, services, facilities, features, functionalities, and nuances thereof
change constantly and this Privacy Policy may change also. You will be responsible for
apprising yourself about the Privacy Policy and change, if any, on each use of the websites
or Apps, platforms or while applying for or making service requests for any Product or
during usage of any Product or usage of any functionality. Without limiting your
responsibility to keep yourself updated as above, we/ HDFC Bank may update you that a
change has been made through any channels of communication including in App
notifications, general banner on website, sms, e-mail, social media messages, etc. The
changed Privacy Policy shall be effective as soon as it is published/posted/hosted on the
website/respective Apps/platforms. If you use the website or Apps, platforms or make any
application/request for any Product or use any Product or make any service requests for or
during usage of any Product or if you use any functionality provided by or for HDFC Bank,
such act of any of aforesaid uses shall by itself amount to your acceptance of the Privacy
Policy with change, if any.

This Privacy Policy shall be governed by the laws of India and any disputes arising out of or
in relation to this Privacy Policy shall be subject to the jurisdiction of courts/ tribunals of
Mumbai, India.

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