Fair Practice and Code

AUXILO FINSERVE PRIVATE LIMITED (Auxilo /Company) being a Non-deposit taking NonBanking Financial Company (Category II) registered with Reserve Bank of India having customer interface is required to formulate its Board approved Fair Practices Code (FPC/Code).

Fair Practices code is formulated pursuant to the Reserve Bank Directives - Non-Banking Financial Company – Non-Systemically Important Non-Deposit taking Company (Reserve Bank) Directions, 2016. The Code aims to enhance the scope of the spirit underlying these directions of the Reserve Bank of India.

The Code lays down Auxilo’s commitment towards its customers/borrowers (used interchangeably) to deliver the financial services and products in a fair and transparent manner.
The Code aims to lay down the standards of transparency in all its dealings, such that the customers are able to take an informed decision while adopting Auxilo’s products and services
The standards so set shall be the guidelines for its management and employees to follow strictly in all its dealing with the customers.

Application

FPC shall apply to all employees of the Company and other persons authorized to represent it in the course of its business with respect to all products and services. It shall apply across all aspects of its operations including marketing, loan origination, processing, servicing and collection activities.

Broad principles on which the Code is built

Clear and transparent information to be given about the products and services and the same to be in the language understood by the customers.
The terms and conditions of each of the product and services to meet the spirit of the RBI guidelines and applicable laws.
Prompt customer grievance redressal, no discrimination amongst the customers on the basis of age, race, caste, gender, marital status, religion or disability.
Information to the customer – Updated version of the Code shall be displayed on the Company’s website and at each branch office in a conspicuous place. A copy of the Code to be provided on request to the customer/prospective customer

APPLICATION FOR LOANS AND THEIR PROCESSING

All communication to the borrower shall be in the language understood by the borrower. The essential information which affects the interest of the customers should be communicated to the borrower so as to help them carry out a meaningful comparison before choosing Auxilo’s products and services. Hence while sourcing, at the minimum the interest rates, the processing fees and any other charges including prepayment charges and options shall be communicated to the customer.

The Loan application form shall also provide the list of document required to be submitted by the customer. Additional documents required for processing the application shall be sought promptly from the customer through an appropriate channel of communication.

On receipt of completed application form an appropriate acknowledgement shall be provided indicating the time frame within which the loan application will be disposed. The time frame for disposing the loan application complete in all respect shall not be more than 30 days from the date of receipt of all the requisite information/data from the Customer. The customer shall be informed about time frame being subject to the requirement of special verifications, checks and investigations, if any, arrived upon the assessment of application. The Customer shall be informed about the extended time frame in such cases.

LOAN APPRAISAL AND TERMS / CONDITIONS

It shall be conveyed in writing to the borrowers in the language understood by them by means of a sanction letter about the sanction of the loan. The Sanction letter shall indicate the amount of loan sanctioned along with the terms and conditions including annualized rate of interest and method of application thereof. The borrowers’ acceptance of these terms and conditions shall be kept on record.

The loan agreement shall be signed physically by both the parties that is the company and the borrower and where the agreement is to be signed digitally, the same shall be signed by both the company as well as the borrower electronically pursuant to the provisions of Information Technology Act.

The loan agreement to be signed with the borrower shall mention the penal charges that would be charged for late repayment in bold. An electronic or physical copy of the executed loan agreement along with its enclosures quoted therein shall be furnished to the Customer upon disbursement of loan.

PENAL CHARGES IN LOAN ACCOUNTS

The Board approved Policy on Fair Lending Practices – Penal Charges in Loan Accounts approved on November 3, 2023 shall be adhered to which governs the levying penal charges.

DISBURSEMENT OF LOANS INCLUDING CHANGES IN TERMS AND CONDITIONS

Notice shall be given to the borrowers in an event of any change in the terms and conditions in reference to the disbursement schedule, interest rates, service charges and the prepayment charges, in the language understood by the borrower clearly indicating the changed terms. Notice may be given by sending a Short Messaging Service (SMS), courier, electronic mail, email, registered or certified mail or facsimile where available. With the constant technological developments the means of communication have been enlarging and due to the ease thereof the customers may prefer the use of those means in addition to the above specified options. The company may explore these options and if found feasible can provide the customers the list of options to choose from. If the customer opts to be provided notice by any specific means of communication, the same shall be used to send out any kind of notice.

Changes in the interest rates and charges shall be effected only prospectively.

Any decision to recall/accelerate payment or performance shall be in consonance with the loan agreement.

All securities shall be released on repayment of all dues or on realization of the outstanding amount subject to any of the company’s legitimate right or lien for any other claim it may have against the borrower. If such right of set-off is to be exercised, the Company shall give notice to the borrower about the same with full particulars about the remaining claims and the conditions under which it is entitled to retain the securities till the relevant claim is settled / paid.

GENERAL

The Company shall refrain from interference in the affairs of the borrower except for the purposes provided in the terms and conditions of the loan agreement (unless new information, not earlier disclosed by the borrower, has come to its notice).

Transfer of loan request – If the borrower requests for transfer of the loan account, the company shall either accord its consent or intimate its objection, if any to the same, and convey its decision in writing within 21 days from the date of receipt of request. Such transfer shall be as per the contractual terms entered into with the borrower and should be in consonance with law.

iThe Company shall not charge foreclosure charges/ pre-payment penalties on any floating rate term loan sanctioned for purposes other than business to individual borrowers, with or without co-obligant(s).

COLLECTION OF DUES

The customer shall be promptly informed about the repayment process, schedule including the amount, tenure and periodicity of repayment. The customers shall be provided all the information regarding dues and shall endeavour to give sufficient notice for payment of dues/ or repossession of security if any. The customer shall be reminded by sending notice or by making personal visits. It shall be ensured that the entire process of enforcing the security, valuation and realization thereof be fair and transparent.

In the matter of recovery of loans, undue harassment for example persistently bothering the borrowers at odd hours, use of muscle power for recovery of loans, etc., shall be strictly avoided. The recovery methods should be courteous, fair and persuasive. The Company employees and the persons authorized to represent the company shall always deal with the customers in a polite manner. They shall identify themselves and display the authority letter issued by the company.

Guidelines for the collection of dues:

Privacy of the Customer should be respected at all times
Contacting the customer
The Customers shall not be called at odd hours unless special circumstances of the borrower's business require to call them otherwise”
The company representatives approaching the customer for collection should always maintain decorum, decency and interact with the customer in a civil manner.
The Company’s endeavour should be to assist the customer to clear the differences, if any, about the dues and help resolve the disputes, if any, in an amicable manner

The odd hours shall be construed in accordance with the guidelines issued by Reserve Bank of India from time to time.

RATE OF INTEREST AND GRADATION OF RISK

The Board approved Interest rate policy (ANNEX II) laid down for determining the interest rates, processing and other charges shall be adhered to.

The rate of interest applicable to customers would be based on Company’s Benchmark Lending Rate which in turn is dependent on factors such as cost of funds, margin, etc., plus a spread which is determined on the risk gradation of each application. The rate of interest would also differ depending on the category of customer.

Gradation of risk depends on factors such as student's academic background, employability of the selected course from a selected college and country of study, financial strength of the co-borrower, loan repayment capability, credit history, collateral offered or not, serviceability of the loan through Company’s branch network, cost/s associated with underwriting and servicing the loan.

The application form shall include the rate of interest and indicate that the differential rate of interest shall be chargeable pursuant to the guidelines issued by the Reserve Bank of India from time to time. The sanction letter for the information of the customer shall indicate the same.

RESET OF FLOATING INTEREST RATE ON EQUATED MONTHLY INSTALMENTS (EMI)

The Board approved Policy on Reset of Floating Interest Rate on Equated Monthly Instalments (EMI) approved on November 3, 2023 shall be adhered to which interalia mandates the Company to communicate to the borrowers about the possible impact of change in benchmark interest rate on the loan leading to changes in EMI and/or tenor or both, provides for the procedures for resetting the interest rate to switch over to a fixed rate, mandates providing of options to choose between enhancement in EMI or elongation of tenor or for a combination of both options to prepay, either in part or in full, at any point during the tenor of the loan and other terms to ensure transparency and clarity in accordance with the applicable regulations.

PERIODICAL REVIEW

The Managing Director/Chief Executive Officer of the Company shall submit to the Board on a quarterly basis on the review of the compliances under the code and functioning of the greivances redressal mechanism at various levels of management.

GUARANTORS

The Guarantor(s) shall be informed about their liability as Guarantor in terms of amount and the circumstances when the liability would arise. The Guarantors shall also be given an understanding about the recourse available with the company if he/she fails to pay the amount guaranteed for payment.

The Company shall also inform the guarantor of any material adverse change/s in the financial position of the borrower for whom he / she stands as a Guarantor.

PRIVACY AND CONFIDENTIALITY

The Company shall always maintain confidentiality with respect to the personal information of customers. Following would be the exception to this:

With the prior consent of the customer, when such an information is to be given as a reference
On the Customers’ request to provide the information
Required to be provided under the provisions of laws/regulations
Being a duty towards the public to reveal the information
In the Company’s interests for reasons like to prevent fraud

The customers shall be informed about their rights under the existing legal framework for accessing the personal records that the company holds about them.

NO DISCRIMINATION

There shall be no discrimination amongst the customers on the basis of age, race, caste, gender, marital status, religion or disability, including but not limited for processing of loan applications or for redressing their grievances.

CREDIT REFERENCE AGENCIES

The customer shall be informed that the law mandates the company to pass the borrowers account information to credit reference agencies.

The customer shall be intimated in writing that the company intends to give information about the debts of the customer to the credit reference agencies. The intimation to the customer shall explain the role of credit reference agencies and the effect of the information provided by them will have on their ability to get credit.

On customer’s request, a copy of the information sent to credit reference agencies shall be provided.

GRIEVANCE REDRESSAL MECHANISM

The Grievance Redressal Mechanism (GRM) laid out under Annex 1 provides for resolving any disputes arising out of the decisions of the company’s functionaries. All disputes arising out of the Company’s functionaries shall be heard and disposed of at least at the next higher level. The Grievance Redressal Mechanism shall also deal with the issues relating to services outsourced by the Company and are provided by outsourced Service Provider, if any.

The GRM shall provide for the following:

The system and the procedure for receiving, registering and disposing of complaints and grievances in each of its offices.
The procedure defines - where and how the complaint/grievance (used interchangeably) is to be filed, turnaround for the reply, appellate mechanism if not satisfied with the initial resolution of complaint.
Acknowledgement shall be provided with the reference number for the complaints received.
The process of informing the customer about the above stated system and procedure for redressing their complaints at a faster pace.
The complaints received shall be resolved in a maximum of 30 days period

The GRM shall nominates a Company’s official as the Grievance Redressal Officer who can be approached by the public for resolution of complaints against the Company.

For the benefit of the customers at the operational level, the company shall display the name and contact details (Telephone/Mobile no. and Email address) of the Grievance Redressal officer prominently at each of its branches and places where the business is transacted.

For the information of the Customers, if the customer's complaint / dispute is not redressed by the Grievance Redressal Officer within a period of one month, the customer may appeal to the Officer-in Charge of the Regional Office of the Department of Non-Banking Supervision (DNBS) of the Reserve Bank of India (RBI), Mumbai under whose jurisdiction the registered office of the Company falls.

NODAL OFFICER/ PRINCIPAL NODAL OFFICER

The Nodal Officer/ Principal Nodal Officer shall be appointed under the Integrated Ombudsman Scheme, 2021.

REVIEW OF THE FAIR PRACTICES CODE

The Code shall be reviewed annually or earlier if deemed necessary by the Board of Directors of the Company.

GRIEVANCE REDRESSAL MECHANISM

Grievance Redressal Mechanism herein provides the process of resolving any disputes/complaints arising out of the decisions of the company’s functionaries.

Level 1

The Customer/Borrower having any grievance/complaint can register the complaint giving the details of the complaint and the name of the officer/employee of the company concerned in the following ways, which shall be addressed in a maximum of ten working days:

Call the Customer helpdesk no 022 6246333
Email at customercare@auxilo.com
Can be submitted in writing at the Branch office/place where the business is transacted addressing it to the Branch Manager followed by the location name captioning it as “Under GRM"
Can be posted to the address Auxilo Finserve Pvt Ltd, Office No. 63, 6th floor, Kalpataru Square,

Branch manager herein will also refer to the manager concerned of the non-branch office where the company’s business is transacted. If the complaint is against the Branch Manager, same should be addressed to the Customer Grievance Redressal Officer.

In case the customer is not satisfied with the resolution/response provided by the customer engagement team/s as above, then customer shall escalate to Level 2 as given below.

Grievance submission by the customers can be submitted at the Branch office also

Level 2

If the Customer is not satisfied with the initial resolution or the complaint is against the Branch Manager, the complainant can send the complaint addressing to the Customer Grievance redressal officer quoting the acknowledgment number of initial complaint. Below mentioned are the details of Customer Grievance redressal officer:

Name : Deepika Thakur Chauhan
Address : Auxilo Finserve Private Limited
Registered office - Office No. 63, 6th floor, Kalpataru Square, Kondivita Road, Andheri East, Mumbai 400059
Email : gro@auxilo.com
Telephone : 022 6246 3333
FAX : 022 6246 3334

We will make our best efforts to resolve customer’s complaint at this level.

Level 3

If the complaint/ dispute is not redressed within a period of one month, the customer may appeal to the following authority

Officer-in-Charge
Reserve Bank of India,
Department of Non-Banking Supervision,
RBI Building, Opp. Mumbai Central Railway Station,
Near Maratha Mandir,
Byculla, Mumbai – 400 008

Annex II

Introduction

Auxilo Finserve Private Limited (“the Company”) is a Non-Banking Financial Company (NBFC) committed to providing customized financial solutions in the education sector. This Interest Rate Policy outlines the principles and procedures for determining interest rates for the loans offered to varied customer segments in alignment with the Company’s mission, associated risks and customer-centric approach and Regulatory Framework.

The policy adheres to the Reserve Bank of India (RBI) guidelines, including:
- RBI/DoR/2023-24/105 DoR.F1N.REC.No,45/03.10.119/2023-24 dated October 19, 2023: Master Direction Reserve Bank of India (Non-Banking Financial Company—Scale Based Regulation) Directions, 2023, and updated guidelines from time to time.
- RBI circularRBI/2024-25/30 DoS.CO.PPG.SEC.1/11.01.005/2024-25 dated April 29, 2024 Fair Practices Code for Lenders – Charging of Interest.
- Fair Lending Practice - Penal Charges in Loan Accounts - DoR.MCS.REC.28/01.01.001/2023-24 dated August 18, 2023 and DoR.MCS.REC.61/01.01.001/2023-24 dated December 29, 2023.
- RBI’s provisions on interest rate reset, penal charges, and customer communication.
Objective
- To establish a transparent and risk oriented framework for determining interest rates.
- To ensure compliance with regulatory requirements while achieving sustainable business growth.
- To align with the market dynamics and competitive scenarios.
Rate of Interest

The Company may offer fixed and floating rate loans to its customers based on the type of loan product. The rate of interest offered to the customer may vary for various customers based on the loan product offered and, associated risks involved.

Fixed Rate Loans

For fixed rate loans Auxilo Benchmark Lending Rate (ABLR) may be used for reference but the loans shall not be linked to subsequent ABLR changes in the future. The rate of interest (ROI) offered to the customer at the time of origination of loan shall remain fixed for the full tenure of the loan or for the tenure specified in the sanction and loan documentation.

Floating rate loans

The floating rate loans shall be linked to the ABLR. The effective ROI applicable to the customer shall constitute of ABLR and Spread.

Computation of Auxilo Benchmarking Rate (ABLR)

The Company shall use external and internal micro and macro economic parameters, competitive scenario, market dynamics and, operating costs to determine the benchmark rate. The benchmark rate shall be called Auxilo Benchmark Lending Rate “ABLR” and shall be used for pricing of all loans advanced by the company. The floating rate loans shall be linked to “ABLR.”

The following factors shall be used to determine the ABLR:

Cost of Borrowings: This includes the interest rate of borrowings, processing fees and associated costs related to the loan. Cost of all borrowings, including term loans, debentures, and other sources to be considered to determine ABLR.
Cost of Equity: The expected return on equity, based on market scenario, company’s growth prospects equity to be considered to determine the benchmark rate.
Market volatility and Market dynamics: Market dynamics like repo rate, interest rate scenarios, MCLRs of various banks, liquidity in the market, regulatory framework to be considered to determine ABLR.
Operating Costs: Operating costs of the company along with credit costs to be considered for determining the ABLR related to loan processing, administration, and collection.
Regulatory Requirements: The cost of regulatory capital required to be maintained shall be considered for determining ABLR.
Risk premium: The risk premium (considering market dynamics) as envisaged with the product to be considered for the calculation of the ABLR.

The Benchmark rate is determined as below:

Parameter	Rate
Cost of borrowing (i)	A%
Cost of equity (ii)	B%
Market Volatility and Market Dynamics(iii)	C%
Operating expenses (including credit costs) (iv)	D%
Regulatory requirements (v)	E%
Risk Premium(vi)	F%
ABLR: Final Benchmark rate	(i+ii+iii+iv+v+vi)

The ABLR shall be reviewed by the Asset Liability Management Committee (ALCO) committee periodically. Any increase decrease in ABLR may be decided based on the above factors. The ALCO committee shall be empowered to fix a different ABLR than as calculated above considering market dynamics and decide on the applicability of these changes to various classes of borrowers.

Computation of Spread

The spread on a specific loan shall be derived considering multiple factors, which may include, borrowers’ profile, credit and repayment history, loan ticket size, repayment option chosen, collateral security, loan tenure, associated risks and competitive market landscape to ensure a balanced risk-based pricing. In addition, for education loan to students, their past and future academics and their future earning potential may be considered. The rate of interest for the same product and tenor availed during same period may vary for different customers depending upon consideration of all or combination of above factors. The company may review the spreads being charged to customers at appropriate intervals and may change the spreads being charged considering the performance and conduct of the account.

Other Charges

Besides interest, other financial charges such as one time processing fee, cheque/NACH bouncing charges, cheque/NACH swap charges, interest rate reset charges, etc. as applicable would be charged by the Company wherever considered necessary as detailed in the ' Service Charges & Fees ' on the Auxilo website.

Any revision in charges would be updated on Auxilo website and would be levied prospectively to the customers as applicable.

Penal Charges and Loan Documentation

Penal Charges:

Penal charges shall be applicable for non-compliance with loan terms.
Penal fees /charges will be clearly communicated to borrowers and will not be included in the capitalized loan amount, ensuring transparency and compliance with fair practices.
No interest shall be charged on Penal fees/charges.

Interest Rate Reset and Switching Options

Rate Reset Provisions:

The ABLR reset period for floating rate loans would be decided the ALCO committee. Interest rates will be reset as per the company policy in line with the extant RBI guidelines..

Switching Options:

Borrowers shall be given an option of switching from floating to fixed interest rates as per the company policy in line with the extant RBI guidelines, as detailed in the 'Conversion of Floating to Fixed Rate of Interest' note available on the Auxilo website, ensuring greater flexibility.

Policy Review

This policy will undergo an annual review or updates as necessitated by regulatory changes or market dynamics, with revisions approved by the Board of Directors based on recommendations from the ALCO committee.

Annexure – I: Product wise Interest Rate Range

Loan Type	Range of Interest Rate
Education Loan	9.5% to 24.0%
Education Institution Loans	11.0% to 24.0%

Note: Above are the indicative ranges of rate of interest offered for specific loan products. However, the final risk pricing shall be determined by the relevant loan sanctioning authority.

Introduction

Auxilo Finserve Private Limited (“Auxilo”) is a company incorporated under the laws of India, with its registered office at [Office No. 63, 6th floor, Kalpataru Square, Kondivita Road, Andheri East,

Mumbai 400059, Maharashtra, INDIA] and having CIN [U65990MH2016PTC286516]. Auxilo is a non-banking financial company registered with the Reserve Bank of India (“RBI”) which provides credit facilities to its customers through a digital lending platform (“Financial Products”). Auxilo owns the domain name “www.auxilo.com” as well as the digital application which is accessible on devices which support the Platform and its application.

These terms and conditions ("Terms") forms a legally binding relationship between Auxilo and the visitor or guest users or registered users (“User”) of the website/mobile application (“Platform”) owned and operated by Auxilo. For the purpose of these Terms, wherever the context so requires "You" or "Your" or "Yourself" or "User" shall mean any natural or legal person who has agreed to these Terms on behalf of a corporate or any other legal entity. The term "We", "Us", "Our" shall mean Auxilo.

By clicking on the button “[Get Started ]” option or any other button/checkbox/confirmation of similar nature, or by the virtue of usage of Site or continued usage thereof, You agree to the following:

General

You are required to read these Terms carefully. If You access the Platform or avail any services on the Platform, You shall be subject to the policies that are applicable to the Platform. By mere use of the Platform, You shall be contracting with these Terms including the other policies of Auxilo constitute Your binding obligations, with Auxilo. In the event You do not agree to these Terms, You should not access the Platform or avail the services available on the Platform. You further understand that the access to the Platform and the offer of Financial Products by Auxilo is conditional upon Your irrevocable consent and acceptance of all the terms, conditions and obligations contained herein (as may be amended from time to time). In the event of any conflict between the terms and conditions of specific Financial Products and these Terms, the conditions specific to such Financial Products shall prevail, to the extent it is applicable. The Privacy Policy as provided at [https://www.auxilo.com/privacy-policy.html] (“Privacy Policy”) shall be treated as part of these Terms. You undertake that You shall carefully read through the Privacy Policy and shall strictly comply with the terms of the Privacy Policy.

These Terms constitute an electronic contract formed under the Information Technology Act 2000 (“IT Act”) and rules made thereunder and the amended provisions pertaining to electronic documents / records in various statutes as amended by the IT Act. These Terms do not require any physical, electronic or digital signature. This document is published and shall be construed in accordance with the provisions of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules 2011 (“SPDI Rules”) under the IT Act.

The right to use the Platform is personal to You and is not transferable to any other person or entity. You are responsible for all use of Your User Account and for ensuring that all use of Your User Account complies fully with the provisions of these Terms.

Consent for Age

The use of this Platform is limited to persons who can form legally binding contracts under Indian Contract Act, 1872. Persons who are "incompetent to contract" within the meaning of the Indian Contract Act, 1872 including minors, un-discharged insolvents etc. are not eligible to use the Platform. Minors i.e. persons under the age of 18 years of age, are restricted from creating an account as a User on the Platform and such persons shall not transact on or use the Platform. If it is brought to the notice of Auxilo that You are under the age of 18 years, Auxilo reserves the right to terminate Your User Account and / or refuse to provide You with access to the Platform.

Account and Registration Obligations

You may access and use the Platform either as a registered user or as a visitor. When You use the Platform as a registered user after creating an account (“User Account”) in order to avail any of the Financial Products provided by Auxilo, You will be responsible for maintaining the confidentiality and security of the information of the User Account, and will be fully responsible for all activities that occur under Your User Account.

You agree to immediately notify Auxilo of any unauthorized use of Your User Account or any other breach of security in relation to Your User Account. You also undertake to ensure that You exit from Your User Account by using the ‘log-out’ and/or ‘sign-out’ button at the end of each session. Auxilo cannot and will not be liable for any loss or damage arising from Your failure to comply with this section.

You may be held liable for losses incurred by Auxilo or any other user of or visitor to the Platform due to authorized or unauthorized use of Your User Account as a result of Your failure in keeping the information of Your User Account secure and confidential.

You shall ensure that the information provided by You on the Platform at the time of creating Your User Account as well as subsequently at the time of browsing or availing the Financial Products is complete, accurate and up-to-date. Use of another user's information for availing the Financial Products is expressly prohibited. If You provide any information that is untrue, inaccurate, expired or incomplete (or becomes untrue, inaccurate, expired or incomplete), or We have reasonable grounds to suspect that such information is untrue, inaccurate, expired or incomplete, or not in accordance with these Terms, We reserve the right to terminate, block access or suspend for an indefinite period of time Your membership and access to the Platform as well as your User Account.

Financial Products

The Financial Products are available only at the discretion of Auxilo and its affiliates, subject to the individual contractual terms and conditions of such Financial Products on which they are offered and such Financial Products may be withdrawn or amended at any time without notice. The full range of the Financial Products may not be available in all locations. The User acknowledges that certain functions of the Platform would require an active internet connection which can be Wi-Fi or the Local Area Network (LAN) connection. Auxilo does not assume any responsibility/liability if the Platform is not fully functional due to absence/ insufficiency of the required internet connection.

All rates, charges and fees quoted / stated for various Financial Products and schemes and interest rates cited as examples of rates which may be in effect from time to time are indicative rates only and are subject to change at any time at the sole discretion of Auxilo and applicable Indian laws. These charges, fees and rates may change depending upon the assessment made by Auxilo in individual cases upon receiving necessary information and documents.

Data Protection

For accessing the Platform and creating the User Account, Users are required to provide some personal information to Auxilo. The storage, usage and transmission of all information obtained by Auxilo through the Platform, shall at all times be in accordance with the IT Act read with the SPDI Rules and all other applicable laws. If Auxilo obtains any personal data or confidential information while providing Financial Products to the Users, it shall only undertake the processing of such personal data / sensitive information reasonably required in connection with the performance of its obligations in relation to the Financial Products which includes verification of the information of the Users in accordance with the ‘Master Directions on Know Your Customer’ issued by the RBI and in case of Aadhaar based authentication or verification, the Aadhaar and Other Laws (Amendment) Act, 2019 and other rules and regulation framed by Unique Identification Authority of India and confirmation of credit worthiness of such Users. You hereby give your irrevocable consent and authorize Auxilo, to make any enquiries with any government authority including the Unique Identification Authority of India, Reserve Bank of India, other finance company / bank / registered credit bureaus regarding Your credit history with them verification of information provided to Auxilo.

Auxilo has appropriate technical and organisational measures in place to:

i. prevent unauthorised or unlawful processing of any personal data / sensitive information;

ii. protect any personal data / sensitive information against accidental loss, destruction or damage;

iii. ensure the reliability of its employees/contractor having access to the personal data / sensitive information;

You can update the mobile phone number or email address registered with Auxilo or any other information provided by You to Auxilo by submitting a request on the Platform or sending an email at customercare@auxilo.com

Privacy

We view protection of Your privacy as a very important principle. We understand clearly that You and Your personal information is one of Our most important assets. Personal and sensitive data including financial information collected (as defined under the IT Act) in stored on computers that are equipped with reasonable technological security measures and procedures in accordance with the IT Act and Rules thereunder. Our current Privacy Policy is available at [https://www.auxilo.com/privacy-policy.html]. If You object to Your personal information being transferred or used in this way please do not use the Platform. By using the Platform, you agree and acknowledge our Cookies Policy which is available at [https://www.auxilo.com/cookie-policy.html].

By using the Platform or availing the Financial Products, You authorize Auxilo, directly or through third parties, to make any inquiries we consider necessary to validate Your identity and to collect information about You in accordance with our Privacy Policy. This may include asking You for further information that will allow us to reasonably identify You, requiring You to take steps to confirm ownership of Your email address, or verifying Your information against third party databases or through other sources. We may also ask You for identifying documents to help us validate Your identity. Auxilo reserves the right to close, suspend, or limit access to Your User Account and/or the Financial Products in the event we are unable to obtain or verify any necessary information. By availing the Financial Products from Auxilo, You also agree to provide Your consent and full cooperation in enabling Auxilo to validate Your identity and to collect information about You in accordance with our Privacy Policy.

You agree to provide unconditional and absolute consent to Auxilo to use and share the information provided by You in relation to the Financial Products with its affiliates and other partner entities in the ordinary course of business. You also agree and consent to Auxilo to assess the information, based on Your usage of the Platform and Auxilo agrees to take all reasonable steps to ensure that the information received from You is secure, and is accessible only to the relevant persons.

If, at a future date, We (or Our assets) get merged with or are acquired by another business entity, or if We undergo re-organization, amalgamation, restructuring of business or for any other reason whatsoever, all or some of Your personal information may be conveyed, sold, transferred, shared or licensed to other business entities, pursuant to such re-organisation or amalgamation or demerger or restructuring. In the event of such a transaction or situation, the other business entity or the new combined entity will be required to follow the Privacy Policy with respect to Your personal information. Once you provide Your information to Us, You provide such information to Us and our affiliate and We and Our affiliate may use such information to provide You with various services with respect to Your transaction.

Representations, Warranties and Undertakings

You represent and warrant that:

a. You are above 18 years of age, of sound mind and are competent to understand and adhere to the provisions of these Terms;

b. These Terms are a legal, valid and binding obligation on You, enforceable against You in accordance with its terms;

c. If You choose to access the Platform from locations other than India, You shall do so at Your own risk and You would be solely liable and responsible for compliance with applicable local laws and regulations of such location/territory. We accept no liability whatsoever, direct, or indirect or consequential, for non-compliance with the laws of any country other than the Republic of India. The mere fact that the Platform can be accessed through the internet by You in a country other than India will not be interpreted to imply that the laws of the said country govern these Terms and/or use of the Platform;

d. You confirm that You are authorised and not restricted by any legal/regulatory/judicial/quasi-judicial/other authority, to access the Platform and avail of the facilities offered thereon, including to avail the Financial Products. You agree to use the Platform only for purposes that are permitted by: (i) these Terms; and (ii) any applicable law;

e. The information provided by You to Auxilo are correct and true;

f. You acknowledge and agree that Auxilo is entitled to remove any / all the information on the Platform at any time in the manner deem fit by Auxilo; and

g. You understand that Auxilo does not provide any warranties in relation to the use of Platform and shall not be made liable for any claims made by You or any third party. In this regard, You undertake to accept and be solely liable for your actions while using the Platform.

Third Parties and Links

We may pass Your details to other companies in our group. We may also pass Your details to Our agents and subcontractors to help Us with any of Our uses of Your data set out in Our Privacy Policy. For example, We may use third parties to assist Us with delivering the Financial Products to You, to help Us to collect payments from You, to analyse data and to provide Us with marketing or customer service assistance. We may exchange information with third parties for the purposes of fraud protection and credit risk reduction. We may transfer our databases containing Your personal information if We sell our business or part of it. Other than as set out in these Terms, We shall NOT sell or disclose Your personal data to third parties without obtaining Your prior consent unless this is necessary for the purposes set out in these Terms or unless We are required to do so by law.

The Platform may contain advertising of third parties and links to other websites or frames of other websites of the affiliates of Auxilo. The Platform may also contain links to external websites, having further linked websites, controlled or offered by third parties (non-affiliates of Auxilo), in order to help you find relevant websites, services and/or products which may be of interest to you, quickly and easily. Please be aware that We are not responsible for the privacy practices or content of those third parties or other sites, nor for any third party to whom We transfer Your data in accordance with these Terms and Our Privacy Policy. The Contents displayed or products / services offered on such linked websites or any quality of the products/ services are not endorsed, verified or monitored by Auxilo. Auxilo are also not responsible for the owners or operators of such external links or websites or for any products or services they supply or for the contents of their websites and do not give or enter into any conditions, warranties, express or implied; or other terms or representations in relation to any of these or accept any liability in relation to any of these (including any liability arising out of any claim that the content of any external websites to which the Platform includes a link infringes the intellectual property rights of any third party).

Communications and Notifications

When You use the Platform or send emails or other data, information or communication to us, You agree and understand that You are communicating with Us through electronic records and other methods using services of paid service providers (including telecom service providers). Standard mobile, message, or data rates may apply and You are responsible for any such fees. and You consent to receive communications via electronic records from Us periodically and as and when required. We may communicate with You by email or by such other mode of communication, electronic or otherwise as decided by Us from time to time.

You agree that Auxilo (either directly or through its affiliate or subsidiary) may provide You communications about Your User Account and the Financial Products electronically or through phone calls, sms, whatsapp messenger application, or any other electronic media as deem fit by Auxilo, or in writing. Any electronic communications will be considered to be received by You within 24 hours of the time we email it to You or otherwise send it to Your attention (such as via SMS or other online notification, through whatsapp messenger application). We may assume You have received any communications sent to You by postal mail 2 days after we send it.

You hereby express Your intent to know through telephonic calls, whatsapp messenger application or SMS on Your mobile number mentioned in the application form or any other alternate number of yours as well as in this undertaking, or through any other communication mode, various loan offer schemes or loan promotional schemes or any other promotional schemes or any other information in relation to the existing Financial Products and hereby authorize Auxilo and its employee, agent, associate to do so. You confirm that laws in relation to the unsolicited communication referred in “National Do Not Call Registry” as laid down by Telecom Regulatory Authority of India will not be applicable for such communication/calls/ SMS/messages through whatsapp messenger application received from Auxilo, its employees, agents and/or associates.

Use of the Platform, its Contents and Restrictions

The material, information, data, news items, texts, graphics, links, illustrations, audio clips, video clips, etc. (“Content”) contained on the Platform is provided for general information only and should not be used as a basis for making commercial decisions. You are advised to exercise due caution and/or seek independent advice before availing any Financial Product or facility or entering into any financial obligation based on the Content contained on the Platform.

The Platform is controlled and operated by Auxilo. The Content contained on the Platform or other data are provided on an "as is", "as available" basis and are protected by copyright.

All Contents on the Platform, including images, illustrations, audio clips, and video clips, are protected by copyrights, trademarks, and other intellectual property rights. Contents of the Platform are solely for Your personal, non-commercial use. You must not copy, reproduce, republish, upload, post, download, publish, transmit or distribute such material in any way, including by email or other electronic means and whether directly or indirectly and You must not assist any other person to do so. Without the prior written consent of Auxilo, modification of the Contents, use of the Contents on any other website or networked computer environment or use of the Contents for any purpose other than personal, non-commercial use is a violation of the copyrights, trademarks and other proprietary rights, and is prohibited. Any use of the Contents for which You receive any remuneration, whether in money or otherwise, is a commercial use for the purposes of this clause.

You agree and undertake to use the Platform only to find out about and/or avail the Financial Products provided by Auxilo. By way of example, and not as a limitation, You agree and undertake that when using the Platform or interacting with the representatives of Auxilo, You will not:

i. defame, abuse, harass, stalk, threaten or otherwise violate the legal rights of the representatives of Auxilo;

ii. publish, post, upload, distribute or disseminate any inappropriate, profane, defamatory, infringing, obscene, indecent, illegal or unlawful topic, name, material or information;

iii. upload files that contain software or other material protected by intellectual property laws unless You own or control the rights thereto or have received all necessary consents;

iv. upload or distribute files that contain viruses, corrupted files, or any other similar software or programs that may damage the operation of the Platform or another's computer;

v. conduct or forward surveys, contests, pyramid schemes or chain letters;

vi. falsify or delete any author attributions, legal or other proper notices or proprietary designations or labels of the origin or source of software or other material contained in a file that is uploaded;

vii. violate any code of conduct or other guidelines, which may be applicable for or to any particular Financial Product;

viii. violate any applicable laws or regulations for the time being in force in or outside India; and

ix. violate any of the provisions of these Terms or any other terms and conditions for the use of the Platform contained elsewhere herein.

x. exploit any of the services. We reserve the right to refuse any of our Financial Products to a User, terminate User Accounts, and/or cancel Financial Products at our discretion, including but not limited to, if we believe that the conduct of a User violates applicable law or is harmful to our interests.

xi. You shall not make any derogatory, defamatory, abusive, inappropriate, profane or indecent statement/s and/or comment/s about Auxilo, its associates and partners on any property owned by Auxilo.

Disclaimer of Warranties and Liability

It is in Auxilo’s interest to ensure that all the information on the Platform is correct, but Auxilo neither warrants nor makes any representations regarding the quality, accuracy or completeness of any data, information, product or service or a Financial Product. In no event shall Auxilo be liable for any direct, indirect, punitive, incidental, special, consequential damages or any other damages resulting from: (a) the use or the inability to use the Platform by the User; (b) unauthorized access to or alteration of the User's transmissions or data; (c) any other matter relating to the Platform or the Financial Products; including, without limitation, damages for loss of use, data or profits, arising out of or in any way connected with the use of the Platform or performance of the obligations in relation to the Financial Products availed by the Users.

You understand that any material or data downloaded from the Platform is done at Your own risk and discretion and You will be solely responsible for any damage to computer systems or loss of date resulting from such downloaded material. Auxilo is not responsible for any delay or inability to use the Platform or related services, the provision of or failure to provide Services, or for any information, software, products, services and related graphics obtained through the Platform, or otherwise arising out of the use of the Platform, whether based on contract, tort, negligence, strict liability or otherwise. Further, Auxilo shall not be held responsible for non-availability of the Platform during periodic maintenance operations or any unplanned suspension of access to the Platform that may occur due to technical reasons or for any reason beyond Auxilo's control.

Any information published on the Platform including details of any Financial Product(s) as reflected on the Platform may be displayed incorrectly due to some technical issue or a typographical error. We do not warrant that any of the content of the Platform is accurate, complete, reliable, current, or error-free and assumes no liability in this regard. You expressly agree that Your use of the Platform is at your sole risk. Neither Auxilo, its affiliates nor any of their respective employees, agents, third party content providers or licensors warrant that the Platform will be uninterrupted or error free; nor do they make any warranty as to the results that may be obtained from use of the Platform, or as to the accuracy, reliability or content of any information, service, or merchandise provided through the Platform.

This disclaimer of liability applies to any damages or injury, caused by any failure of performance, error, omission, interruption, deletion, defect, delay in operation or transmission, computer virus, communication line failure, theft or destruction or unauthorized access to, alteration of, or use of record, whether for breach of contract, tortious behaviour, negligence, or under any other cause of action.

Indemnity

Auxilo, its owner, licensee, affiliates, subsidiaries, group companies (as applicable) and their respective officers, directors, agents, and employees shall be indemnified and held harmless by You, from any claim or demand, or actions including reasonable attorneys' fees, made by any third party or penalty imposed due to or arising out of Your breach of these Terms, Privacy Policy and other policies, or Your violation of any law, rules or regulations or the rights (including infringement of intellectual property rights) of a third party.

Applicable Law

These Terms shall be governed by and interpreted and construed in accordance with the laws of India. The place of jurisdiction shall be exclusively in Mumbai.

Limitation of Liability

In no event will Auxilo, or any person or entity involved in creating, producing or distributing the Platform or the Financial Products, be liable for any damages, including, without limitation, direct, indirect, incidental, special, consequential or punitive damages arising out of the use of or inability to use the Platform. You hereby acknowledge that the provisions of this section shall apply to all content on the Platform.

Grievance officer

In accordance with the IT Act and the rules made thereunder, the name and contact details of the Grievance Officer are provided below:

Name: [Ms. Deepika Thakur Chauhan ]

Address: [Auxilo Finserve Pvt. Ltd. Office No.63, 6th floor, Kalpataru Square, Kondivita Road, Andheri (East),

Mumbai - 400059]

Phone No: [022 6246 3333]

Email id : [gro@auxilo.com]

Revision of the Terms

Auxilo shall have the right at any time to change or modify the terms and conditions applicable to the Users' use of the Platform, or any part thereof, or to impose new conditions, including but not limited to, adding fees and charges for use. Such changes, modifications, additions or deletions shall be effective immediately upon notice thereof, which may be given by any means, including but not limited to, posting on the Platform, or by electronic or conventional mail, or by any other means by which you obtain notice thereof. Any use of the Platform by the User after such notice shall be deemed to constitute as acceptance by You of such changes, modifications or additions.

General Terms and Conditions

These Terms may be varied, amended or modified, in whole or in part, by Auxilo at any time without notice to the Users.

These Terms constitute a principal-to-principal relationship between Auxilo and the Users and do not attempt to create any agency relationship. The Users are being rendered by Auxilo as an independent entity and nothing contained herein shall be deemed to create any association, partnership, joint venture or relationship of principal and agent or master and servant, or employer and employee between Auxilo and the Users hereto or any affiliates or subsidiaries thereof or to provide either Auxilo or the User with the right, power or authority, whether express or implied to create any such duty or obligation on behalf of the other party, i.e. either Auxilo or the User.

Auxilo may assign, in whole or in part, the benefits or obligations of these Terms to its associates of affiliates of other group company, or any other company, in circumstances including but not limited to pursuant to a restructuring or re-organization or demerger of its organization or operations causing a change in management or something of the nature. Auxilo shall not require approval or consent of the User, it can at its discretion provide an intimation of such assignment to the Users. However, the User shall not assign, in whole or in part, the benefits or obligations of these Terms, without the prior written permission of Auxilo.

Auxilo shall not be liable for its failure to perform under these Terms as a result of occurrence of any force majeure events like acts of God, fire, wars, sabotage, civil unrest, labour unrest, action of statutory authorities or local or central governments, change in laws, rules and regulations, affecting the performance of Auxilo. Unless otherwise expressly stated, failure to exercise or delay in exercising a right or remedy, hereunder shall not constitute a waiver of the right or remedy or a waiver of any other rights or remedies, and no single or partial exercise of any right or remedy, hereunder shall prevent any further exercise of the right or remedy or the exercise of any other right or remedy.

The Terms, by their nature and content are intended to survive the performance hereof by any or all parties hereto shall so survive termination.

If any provision, hereunder becomes, in whole or in part, invalid or unenforceable but would be valid or enforceable if some part of that provision was deleted, that provision shall apply with such deletions as may be necessary to make it valid. If any court/tribunal of competent jurisdiction holds any of the provisions, hereunder unlawful or otherwise ineffective, the remainder shall remain in full force and the unlawful or otherwise ineffective provision shall be substituted by a new provision reflecting the intent of the provision so substituted.

The User warrants that it shall not directly or indirectly solicit for employment, nor offer employment to, nor enter into any contract of services with any person employed by Auxilo.

It is agreed and clarified that the arrangement set out by these Terms between Auxilo and the Users is on a non-exclusive basis.

Aux Alerts

Fair Practice & Code

Application

Broad principles on which the Code is built

APPLICATION FOR LOANS AND THEIR PROCESSING

LOAN APPRAISAL AND TERMS / CONDITIONS

PENAL CHARGES IN LOAN ACCOUNTS

DISBURSEMENT OF LOANS INCLUDING CHANGES IN TERMS AND CONDITIONS

GENERAL

COLLECTION OF DUES

RATE OF INTEREST AND GRADATION OF RISK

RESET OF FLOATING INTEREST RATE ON EQUATED MONTHLY INSTALMENTS (EMI)

PERIODICAL REVIEW

GUARANTORS

PRIVACY AND CONFIDENTIALITY

NO DISCRIMINATION

CREDIT REFERENCE AGENCIES

GRIEVANCE REDRESSAL MECHANISM

NODAL OFFICER/ PRINCIPAL NODAL OFFICER

REVIEW OF THE FAIR PRACTICES CODE

GRIEVANCE REDRESSAL MECHANISM

Annex II

Introduction

Objective

Rate of Interest

Fixed Rate Loans

Floating rate loans

Computation of Auxilo Benchmarking Rate (ABLR)

Computation of Spread

Other Charges

Penal Charges and Loan Documentation

Penal Charges:

Rate Reset Provisions:

Switching Options:

Policy Review

Annexure – I: Product wise Interest Rate Range