Last Updated: January 14, 2025
This privacy policy ("Privacy Policy”) is incorporated by reference into the Terms and Conditions (the “Terms and Conditions” or “Terms”).
Website https://novhafincorp.com including its mobile application – NOVHA; (collectively referred to as the “Platform”) is owned and operated by NOVHA fincorp, (“NOVHA” “GOLDKaaz” “We” or “Us”) and NOVHAfincorp (“GoldKaaz” or “NOVHA” or “We” or “Us”) collectively referred to as the company (“Company”) to provide you the services.
This Privacy Policy applies to all the Users whose Personal Information has been processed by Us in the course of our business, mobile applications, forums, blogs, and other online or offline offerings.
We respect your privacy and hence handle your personal data with the utmost care and confidentiality.
By visiting the Platform, You (“You” or “Your”), accept and agree to be bound by the terms and conditions of this Privacy Policy. This Privacy Policy is incorporated into and subject to the Terms and Conditions of the Platform (“Terms”) and shall be read harmoniously and in conjunction with the Terms.
We respect your privacy and hence handle your personal data with the utmost care and confidentiality. Please read the Privacy Policy carefully prior to using or registering on the Platform or accessing/availing the services on the Platform inter alia is an online portal that facilitates the Users to purchase/sale/transfer gold and/or other precious metals in digital gold backed by gold bullions and coins with purity as mentioned (“Precious Metal”) operated and managed by NOVHA”(hereinafter referred as “NOVHA”) a company incorporated under the laws of India (“Services”).
This Privacy Policy specifies the type of information collected from You, the manner in which personal data and other information is collected, received, stored, processed, disclosed, transferred, dealt with or otherwise handled by the Company. This Privacy Policy does not apply to information that You provide to, or that is collected by, any third-party (excluding the Company or its Affiliates set out in paragraph 3 below) through the Platform, and any Third-Party Sites that You access or use in connection with the services offered on the Platform.
This Privacy Policy is an electronic record in the form of an electronic contract formed under the Information Technology Act, 2000 and the rules made thereunder. Further, this electronic record is generated by a computer system and does not require any physical, electronic, or digital signature and is a legally binding document between the You and Us. This Privacy Policy is published in compliance with Information Technology Act, 2000, Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information) Rules, 2011 (“SPDI Rules”) and regulation 3(1) of Information Technology (Intermediaries Guidelines) Rules, 2011.
It is important that you read this privacy notice together with any other privacy policy or fair processing notice We may provide on specific occasions or when we are collecting or processing Personal Information about You so that You are fully aware of how and why we are using Your Personal Information. Additionally, we also recommend you to read the terms and privacy policy of Novha which can be accessed at https://www.novhafincorp.app/terms-and-conditions and https://www.novhafincorp.app/privacy-policy.
This privacy notice supplements the other notices/policy and is not intended to supersede them.
DISCLAIMER: DISCLAIMER - BY USING AND ACCESSING THE PLATFORM AND BY AVAILING THE SERVICES OR BY OTHERWISE GIVING US YOUR INFORMATION, YOU WILL BE DEEMED TO HAVE READ, UNDERSTOOD AND AGREED TO THE PRACTICES AND POLICIES OUTLINED IN THIS PRIVACY POLICY AND AGREE TO BE BOUND BY THIS PRIVACY POLICY. YOU HEREBY CONSENT TO OUR COLLECTION, USE AND SHARING, DISCLOSURE OF YOUR INFORMATION AS DESCRIBED IN THIS PRIVACY POLICY. WE RESERVE THE RIGHT TO CHANGE, MODIFY, ADD OR DELETE PORTIONS OF THE TERMS OF THIS PRIVACY POLICY, AT OUR SOLE DISCRETION, AT ANY TIME. IF YOU USE THE SERVICES ON BEHALF OF OR FOR THE BENEFIT OF SOMEONE ELSE OR ANY ENTITY YOU REPRESENT THAT YOU ARE AUTHORIZED BY SUCH INDIVIDUAL OR ENTITY TO (l) ACCEPT THIS PRIVACY POLICY ON SUCH INDIVIDUAL'S OR ENTITY'S BEHALF, AND (II) CONSENT ON BEHALF OF SUCH INDIVIDUAL OR ENTITY TO OUR COLLECTION, USE AND DISCLOSURE OF SUCH INDIVIDUAL'S OR ENTITY'S INFORMATION. BY VISITING THE PLATFORM, YOU AGREE TO BE BOUND BY THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY. IF YOU DO NOT AGREE WITH THE TERMS CONTAINED HEREIN, PLEASE DO NOT USE OR ACCESS OUR PLATFORM OR AVAIL ANY SERVICES ON THE PLATFORM. BY MERE USE OF THE PLATFORM, YOU EXPRESSLY CONSENT TO OUR USE AND DISCLOSURE OF YOUR PERSONAL INFORMATION IN ACCORDANCE WITH THIS PRIVACY POLICY.
COLLECTION OF INFORMATION
To provide you the Services, we collect, use and process your personal information (as defined
below) including your sensitive information (as defined below). The types of personal
information we may collect (directly from you or from Third-Party sources) and our privacy
practices depend on the nature of the relationship You have with the Company and the
requirements of applicable law.
Information that You Provide to Us: While registering on Our Platform for using Our Services, We collect Your Personal Information including sensitive personal information such as name, mobile number, email address, password, date of birth, gender. We also collect Your personal information through the permissions we seek through the applications such as the permission to access gallery, contacts, notification SMS and location. We use your contact information, such as your email address or phone number, to authenticate your account and keep it, to secure our services and to help prevent spam, fraud, and abuse. We also use contact information to personalize our Services, enable certain account features and to send you information about our Services. If you provide us with your phone number and email id, you agree to receive text messages from NOVHA / GoldKaaz to that number. In addition to the Personal Information mentioned above and in order to provide Services to You when you purchase Gold in excess of 30grams. We may also collect your KYC information including Your Proof of identity like Aadhaar number, driving license, PAN number, finger – print details and signature solely for completing the account opening procedures and authenticating Your transactions on the Platform. The act of providing Your Aadhaar is voluntary in nature and the Company, hereby agrees and acknowledges that they will collect, use and store such details in compliance with applicable laws and this Privacy. You may also be asked for certain financial information, including but not limited to Your billing address, bank account details, credit card number, expiration date and/or other payment related details or other payment method data, and debit instructions or other standing instructions to process payments for the Services. All the payment transactions made through the Platform are electronically processed by third party service provider. All UPI payments and/or card payments are subject to authorisation by UPI service providers and/or card issuer and are electronically processed by UPI payment aggregators or approved payment gateway providers. All Our payment processors are Payment Card Industry Data Security Standard (PCI DSS) compliant. If You choose to post messages on our message boards, chat rooms or other message areas or leave feedback, We will collect and store such information You provide to Us. We retain this information as necessary to resolve disputes, provide customer support, respond to queries and inquires, and troubleshoot problems and improve the Services. If You send Us correspondence, such as emails or letters, or if other users or third parties send us correspondence about Your activities or postings on the Platform, We may collect and retain such information into a file specific to You for responding to Your request and addressing concerns in relation to Your use of the Platform. We shall be entitled to retain Your Personal Information and other information for such duration as may be required for the purposes specified hereunder and will be used by Us only in accordance with this Privacy Policy. We may ask You to provide certain additional information about Yourself on a case-to-case basis. All information disclosed by You shall be deemed to be disclosed willingly and without any coercion. No liability pertaining to the authenticity/ genuineness/misrepresentation/ fraud/negligence, etc. of the information disclosed shall lie on the Company nor will the Company be in any way responsible to verify any information obtained from You. You have every right to edit, modify, review or delete any information including Sensitive Personal Information provided to us.
Automated Collected Information
In addition to the information that you provide us directly, we also collect information that
You provide to Novha and other third parties for providing Services and for technology support
like application programming interfaces (APIs) and embeds to make that information available in
our database. . We may retrieve from Your records available with third party including from Know
Your Customer (KYC) Registration Agency (KRA) such as name, KYC details, KYC status, father’s
name, occupation, address details and related documents;
Usage and Log Information: To make our Platform and Services more useful to you, our servers (which may be hosted by a third-party service provider) collect information from you, including your browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, and/or a date/time of your visit. We use this information to examine our traffic and to view how our customers use our website. This type of information will not allow you to be personally identified although we might be able to associate it with your account. We process this usage data to facilitate your access to our services in technical terms (e.g., to adjust our services to the terminal device you are using), and to recognize and stop any misuse. We also use usage data in anonymised form for statistical purposes and to improve our website . Further, We will also collect information about Your transactions including transaction status and details and Your investment behaviour. We process this data to provide you Services. Location Information: When and if You download and/or use the Platform through Your mobile, We may receive information about Your location, Your IP address, and/or Your mobile device, including a unique identifier number for Your device. We may use this information to provide You with location-based Services including but not limited to, search results and other personalized content. You can withdraw Your consent at any time by disabling the location-tracking functions on Your mobile. However, this may affect Your enjoyment of certain functionalities on Our Platform. Third party information: We also collect information from third parties on the tracking technologies to track the activity on our service and hold certain information. Browser based, network based, AD- Tracking, User UX behaviour tracking information is collected from third parties. We collect information to understand and track the behavioural as means for security and connection integrity. We will keep such information for our reference and will never share with any third party. Also, please remember that the manner in which third party services collect, use, store and disclose Your information is governed by the terms and conditions and policies of such third parties, and Platform and/or Company shall have no liability or responsibility for the privacy practices or other actions of any third-party services that may be enabled within the Service.
Cookies: We use cookies and URL information to gather information regarding the date and time of your visit and the information for which you searched and which you viewed. Cookies are small digital signature files that are stored by your web browser that allow your preferences to be recorded when you visit the Platform. Also, they may be used to track your return visits to the website. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Site. Persistent Cookies can be removed by following Internet browser help file directions. Our uses of cookies, web beacons, or other similar technologies fall into the following broad categories: Operationally Necessary. We may use cookies, web beacons, or other similar technologies that are necessary to the operation of our Services. This includes technologies that allow you access to our Services; that are required to identify irregular site behaviour, prevent fraudulent activity and improve security; or that allow you to make use of our functions such as, product information, saved search, or similar functions. Performance Related. We may use cookies, web beacons, or other similar technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how our visitors use our Services, determine if you have interacted with our messaging, determine whether you have viewed an item or link, or to improve our Services’ content, applications, services, or tools; Functionality Related. We may use cookies, web beacons, or other similar technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign into our Services or keeping track of your specified preferences, interests, or past items viewed so that we may enhance the presentation of content on our Services; Advertising or Targeting Related. We may use first-party or third-party cookies and web beacons to deliver content, including ads relevant to your interests, on our Services or on Third Party sites. This includes using technologies to understand the usefulness to you of the advertisements and content that has been delivered to you, such as whether you have clicked on an advertisement. If you would like to opt-out of the technologies we employ on our Platform, services, applications, or tools, you may do so by blocking, deleting, or disabling them as your browser or device permits. The information collected allows Us to provide the Services and features on the Platform that most likely meet Your needs, and to customize the Platform to make Your experience safer and easier. However, You can browse the Platform without telling Us who You are or revealing any Personal Information about Yourself. In such a case, we will only collect and store the non – Personal Information. Once You give us your Personal Information, You are not anonymous to Us. Wherever possible, while providing the information to Us, We indicate which fields are mandatory and which fields are optional for You. You always have the option to not provide the Personal Information to Us through the Platform by choosing to not use a particular Service or feature being provided by Us on the Platform, which requires You to provide such information. We may automatically track certain information about You based upon Your behaviour on the Platform. We use this information to do internal research on Your demographics, interests, and behaviour to better understand, protect and serve You. This information is compiled and analysed by the Company on an aggregated basis and not individually, in a manner that does not specifically identify You.
USE OF YOUR INFORMATION
We use the Personal Information and other non-Personal Information, for the following:
You also specifically agree and consent to Us for collecting, storing, processing, transferring and sharing information (including Personal Information) related to You with third parties solely for the purpose of processing your transaction requests for the Services. Unless and until, You explicitly give Your consent to Us, to do so, We will not share Your Personal Information with another user of the Platform and vice versa.
SHARING OF INFORMATION
We may make Your Personal Information and/or other non-Personal Information, and by agreeing to this
Privacy Policy You consent to use and make available to Our partners, collaborators including third
parties Novha to enable them to provide the Services and any other services provided through the
Platform to You. Please note that all information shared with our partners, collaborators and
affiliates or made available to our partners, collaborators affiliates will be governed by the terms
of this Privacy Policy.
We may also disclose Your Personal Information to third party vendors, consultants and other service providers who work for the Company, who are bound by contractual obligations to keep such personal information confidential and use it only for the purposes for which We disclose it to them. This disclosure may be required for Us, for instance, to provide You access to Our Services and process payments including validation of Your bank accounts, to facilitate and assist Our marketing and advertising activities/initiatives, for undertaking auditing or data analysis, or to prevent, detect, mitigate, and investigate fraudulent or illegal activities related to Our Services.
You also specifically agree and consent to Us for transferring and sharing your sensitive personal information (including your biometric data, financial information, passwords) related to You with Our partners, collaborators and its affiliates, third parties and other service providers solely for the legitimate purpose of proving you the Services.
We do not disclose Your Personal Information to third parties for their marketing and advertising purposes without Your explicit consent.
The Company may disclose Your information, to the extent necessary:
LINKS TO OTHER THIRD-PARTY SITES AND COLLECTION OF INFORMATION
Our Platform may link You to other third-party Platforms (“Third – Party Sites”) that may collect
Your Personal Information including Your IP address, browser specification, or operating system. The
Company is not in any manner responsible for the security of such information or their privacy
practices or content of those Third-Party Sites. These third-party service providers and Third-Party
Sites shall have their own privacy policies governing the storage and retention of Your information
that You may be subject to. Your sensitive and personal information shall be governed by the
respective Third-Party Sites and the Company shall not be liable for the use or misuse of Your
information. This Privacy Policy does not govern any information provided to, stored on, or used by
these third-party providers and Third-Party Sites. We recommend that when You enter a Third-Party
Site, You review the Third-Party Site’s privacy policy as it relates to safeguarding of Your
information. We use third-party advertising companies to serve ads when You visit the Platform.
These companies may use information (not including Your name, address, email address, or telephone
number) about Your visits to the Platform and Third-Party Sites in order to provide advertisements
about goods and services of interest to You. You agree and acknowledge that We are not liable for
the information published in search results or by any Third-Party Sites.
SECURITY PRECAUTIONS AND MEASURES
Our Platform has reasonable security measures and safeguards in place to protect Your privacy and
Personal Information from loss, misuse, unauthorized access, disclosure, destruction, and alteration
of the information in compliance with applicable laws. Further, whenever You change or access Your
account on the Platform or any information relating to it, We offer the use of a secure server. We
cannot however ensure or warrant the security of any information You transmit to the Company or
guarantee that Your Personal Information and/or other non-Personal Information provided for availing
the Services or Platform may not be accessed, disclosed, altered or destroyed by a breach of any of
Our security measures and safeguards.
It is further clarified that You have and so long as You access and/or use the Platform (directly or indirectly) the obligation to ensure that You shall at all times, take adequate physical, managerial, and technical safeguards, at Your end, to preserve the integrity and security of Your data which shall include and not be limited to Your Personal Information. When payment information is being transmitted on or through the Platform, it will be protected by encryption technology. You expressly consent to the sharing of Your information with third party service providers, including payment gateways, to process payments and manage your payment-related information. Hence, the Company cannot guarantee that transmissions of Your payment-related information or Personal Information will always be secure or that unauthorized third parties will never be able to defeat the security measures taken by the Company or the Company’s third-party service providers. The Company assumes no liability or responsibility for disclosure of Your information due to errors in transmission, unauthorized third-party access, or other causes beyond its control. You play an important role in keeping Your Personal Information secure. You shall not share Your Personal Information or other security information for Your account with anyone. The Company has undertaken reasonable measures to protect Your rights of privacy with respect to Your usage of the Platform controlled by Us and Our Services. However, We shall not be liable for any unauthorized or unlawful disclosures of Your personal information made by any third parties who are not subject to Our control.
DATA STORAGE AND RETENTION POLICY
We collect and store your data and Personal Information in AWS cloud as you use services and will
retain the data for as long as necessary to fulfil the purposes for which it was obtained. Processed
and non-identifiable data, however, will be perpetually stored.
To determine the appropriate retention period for Personal Data, we consider the amount, nature, and
sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of
your Personal Data, the purposes for which we process your Personal Data and whether we can achieve
those purposes through other means, and the applicable legal requirements.
The Company will retain your Personal Data only as long as is reasonably necessary to fulfil the
purposes for which the Personal Data was collected and processed and/or in accordance with legal,
regulatory, contractual or statutory obligations as applicable or Company’s internal policies and
procedures. At the expiry of such periods, your Personal Data will be deleted or archived in
compliance with applicable laws.
DISCLAIMER
Company is merely providing a distributor platform of NOVHA that facilitate transaction of sale and
investment for Users and will not be liable in any manner with respect to the products/ services
allotted to You. You hereby agree and acknowledge that the data and information provided on the
Platform does not constitute advice of any nature whatsoever and shall not be relied upon by You
while making any savings decisions and You shall be solely responsible for any such decisions and
for the purchase of any Precious Metal on the Platform. In no event shall the Company be liable to
You for any loss or damage that may cause or arise from or in relation to these Terms of Use and/or
due to use of this Platform or due to any saving made using this Platform. As part of the Platform
Services provided to You, after availing such services, You agree to provide honest feedback/review
about the concerned Platform Service, if required by the Company.
YOUR PRIVACY RIGHTS
Your Consent
By visiting the Platform or setting up/creating an account on the Platform for
availing the Services on the Platform at such time, You signify Your acceptance to the provisions of
the Privacy Policy. You may choose to withdraw Your consent provided hereunder at any point in time.
Such withdrawal of consent must be sent in writing to info@novhafincorp.com . In case You do not
provide Your consent or later withdraw Your consent, we request you not to access the Platform
and/or use the Services and also reserve the right to not provide You any Services through the
Platform. In such a scenario, the Company may delete Your information (Personal or otherwise) or
de-identify it so that it is anonymous and not attributable to You. However, please note that
Company reserves the right to refuse any request to exercise such rights to the extent permitted by
applicable law.
CHANGES TO PRIVACY POLICY
We reserve the unconditional right to change, modify, add, or remove portions of this Privacy Policy
at any time, without specifically notifying You of such changes. Any changes or updates will be
effective immediately. You should review this Privacy Policy regularly for changes. Your acceptance
of the amended Privacy Policy shall signify Your consent to such changes and agreement to be legally
bound by the same.
GRIEVANCE OFFICER
If You have any privacy concerns, please feel free to reach out to the grievance officer, the name
and contact details of this Officer have been provided below:
INFORMATION WE COLLECT
Sensitive Personal Data or Information and Personal Data or Information: In general, We may collect
Personal Information, including Sensitive Personal Data.
“Personal Data or Information” means information that relates to a natural person, which, either
directly or indirectly, in combination with other information available or likely to be available to
a body corporate, is capable of identifying a person.
“Sensitive Personal Data or Information” means such Personal Information which contains information such as (i) financial information such as bank account or credit card or debit card or other payment instrument details, (ii) sexual orientation, (iii) password and biometric information, (iv) medical records and history, (v) physical, physiological and mental health condition, (vi) any detail relating to the above clauses provided to Us for providing the Service, (vii) any of the information received under above clauses by us for processing, stored or processed under lawful contract or otherwise, (viii) visitor details as provided at the time of registration or thereafter; and (ix) call data records.
By providing Personal Information (including Sensitive Data) to us, you consent to the collection, usage, and disclosure of Personal Information (including Sensitive Data), as permitted by applicable laws. By using the Services, you are authorizing us to gather, parse data and retain basic data which are related to the provision of the Services.
Personal Information
We may collect and process your Personal Information and/or Sensitive Personal
Data, including but not limited to the following:
Information provided by you at the time of registration such as your name, address, email ID, phone
number, bank account details, financial information, unique identifiers, and preferences information
including favourites and history;
Information that you provide to us directly via email and/ or electronic communication;
Your bank account statement provided by you through the upload feature during the onboarding process
on Novha Platform to assess your creditworthiness;
Your live selfie for your identity check and verification with your KYC documents. The image
captured through this selfie may be shared with third party for the purpose mentioned in Clause 3.3
herein;
Information that you provide to us over telephone. We may make and keep a record of such information
shared by you;
Information that you provide to us in physical form whether sent through post and / or courier and /
or handed over to our representatives in person;
Any other additional information required to be provided via email/ electronic communication/
telephone/ post/ courier after your registration; and
Hardware model, operating system and versions and identifiers like IMEI number and serial number of
your primary device used for availing Services.
Information from other sources
Domain Name and IP Address
We may collect your domain name which is linked to every computer/
mobile device connected to the internet and a set of numbers that serve as that computer’s Internet
Protocol or “IP” address. When you request a page from any page within the Website, our web servers
automatically recognize your domain name and IP address. The domain name and IP address does not
reveal any further information about you other than the IP address from which you have accessed the
Website.
Cookies
If enabled, we may place cookies on your machine that store small amounts of data on your
computer about your visit to any of the pages of this website. Cookies can identify the pages that
are being viewed and this can assist us in tracking which of our features appeal the most to you and
what content you may have viewed on past visits. We use cookies on our website in order to
personalize our service to you. Users can control the use of cookies at the individual browser
level. If you reject cookies, you may still use our site, but your ability to use some features or
areas of our site may be limited. You may refuse to accept cookies by activating the setting on your
browser which allows you to refuse the setting of cookies. Unless you have adjusted your browser
setting to refuse cookies, our system will issue cookies when you log on to the website.
SMS: We do not collect, read, store or share with third parties your personal SMS, other than the
SMS pertaining to your financial transactions solely to assist our lending partners in assessing
your credit risk.
Phone: We shall take one-time access of certain features of your mobile phone to facilitate on-boarding on the platform and KYC verification:
ANALYTICS
We may use third-party service providers to monitor and analyse Your use of Our Services.
CHILDREN'S PRIVACY
The Company does not knowingly collect or solicit personal information from children under the age
of 18 (eighteen) and the Service or any services on the Platform and its content are not directed at
children under the age of 18(eighteen). In the event that we learn that we have collected personal
information from a child under the age of 18 (eighteen) without verification of parental consent, we
will delete such information as quickly as possible. If you believe that we might have any
information from or about a child under 18(eighteen). Please contact us at info@novhafincorp.com.
This Privacy Policy is incorporated by reference into NOVHA / GoldKaaz Terms of Service (the “Terms”).
Website NOVHA.app and/or the mobile application ‘Novha’ (collectively referred to as the “Platform”)
is owned and operated by Novhafincorp, a partnership firm having its registered office at No. TF 15
AJANTHA ROYAL APARTMENT KONAPPANA AGRAHAGRAHA Bangalore-560100
, which shall include its affiliates and group entities, together referred to as “Company”, “We”,
“Us” or “Our”.
This Privacy Policy applies to all the Users whose Personal Information has been processed by Us in
the course of our business, mobile applications, forums, blogs, and other online or offline
offerings
We respect your privacy and hence handle your personal data with the utmost care and
confidentiality.
By visiting the Platform, You (“You” or “Your”), accept and agree to be bound by the terms and
conditions of this privacy policy (“Privacy Policy”). This Privacy Policy is incorporated into and
subject to the terms of use of the Platform(“Terms”) and shall be read harmoniously and in
conjunction with the Terms.
Digital Gold Services
We respect your privacy and hence handle your personal data with the utmost care and
confidentiality. Please read the Privacy Policy carefully prior to using or registering on the
Platform or accessing/availing the services on the Platform inter alia in relation to
purchase/sale/transfer of Digital Gold from a brand named “Safe Gold” operated and managed by
“Digital Gold India Private Limited”(hereinafter referred as “Safe Gold”) a company incorporated
under the laws of India (“Services”).
This Privacy Policy specifies the manner in which personal data and other information is collected,
received, stored, processed, disclosed, transferred, dealt with or otherwise handled by the Company.
This Privacy Policy does not apply to information that You provide to, or that is collected by, any
third-party (excluding the Company or its affiliates set out in paragraph 4 below) through the
Platform, and any Third-Party Sites that You access or use in connection with the services offered
on the Platform.
By visiting the Platform, You (“You” or “Your”), accept and agree to be bound by the terms and
conditions of this privacy policy (“Privacy Policy”). This Privacy Policy is incorporated into and
subject to the terms of use of the Platform(“Terms”) and shall be read harmoniously and in
conjunction with the Terms.
It is important that you read this privacy notice together with any other privacy policy or fair
processing notice we may provide on specific occasions or when we are collecting or processing
Personal Information about You so that You are fully aware of how and why we are using Your Personal
Information . Additionally, we also recommend you to read the terms and privacy policy of Safe Gold
which can be accessed at https://www.safegold.com/privacy-policy
This privacy notice supplements the other notices/policy and is not intended to supersede them.
COLLECTION OF INFORMATION
To provide you the services, we collect, use and process your personal information including your
sensitive information. The types of personal information we may collect (directly from you or from
Third-Party sources) and our privacy practices depend on the nature of the relationship you have
with the Company and the requirements of applicable law.
Information that You Provide to Us
While registering on Our Platform for using Our Services, We collect Your Personal Information
including sensitive personal information such as name, mobile number, email address, password, date
of birth, gender. We use your contact information, such as your email address or phone number, to
authenticate your account and keep it, to secure our services and to help prevent spam, fraud, and
abuse. We also use contact information to personalize our Services, enable certain account features
and to send you information about our Services. If you provide us with your phone number and email
id, you agree to receive text messages from NOVHA / GoldKaaz to that number. In addition to the
Personal Information mentioned above and in order to provide Services to You when you purchase Gold
in excess of 30grams We may also collect your KYC information including Your Proof of identity like
Aadhaar number , driving license, PAN number, finger – print details and signature solely for
completing the account opening procedures and authenticating Your transactions on the Platform. The
act of providing Your Aadhaar is voluntary in nature and the Company, hereby agrees and acknowledges
that they will collect, use and store such details in compliance with applicable laws and this
Privacy.
You may also be asked for certain financial information, including Your billing address, bank account details, credit card number, expiration date and/or other payment related details or other payment method data, and debit instructions or other standing instructions to process payments for the Services. All the payment transactions made through the Platform are electronically processed by third party service provider. All UPI payments and/or card payments are subject to authorisation by UPI service providers and/or card issuer and are electronically processed by UPI payment aggregators or approved payment gateway providers.
If You choose to post messages on our message boards, chat rooms or other message areas or leave feedback, We will collect and store such information You provide to Us. We retain this information as necessary to resolve disputes, provide customer support, respond to queries and inquires, and troubleshoot problems and improve the Services.
If You send us correspondence, such as emails or letters, or if other users or third parties send us correspondence about Your activities or postings on the Platform, We may collect and retain such information into a file specific to You for responding to Your request and addressing concerns in relation to Your use of the Platform. We shall be entitled to retain Your Personal Information and other information for such duration as may be required for the purposes specified hereunder and will be used by Us only in accordance with this Privacy Policy.
We may ask You to provide certain additional information about Yourself on a case-to-case basis. All information disclosed by You shall be deemed to be disclosed willingly and without any coercion. No liability pertaining to the authenticity/ genuineness/misrepresentation/ fraud/negligence, etc. of the information disclosed shall lie on the Company nor will the Company be in any way responsible to verify any information obtained from You.
You have every right to edit, modify, review or delete any information including sensitive personal information provided to us.
Automated Collected Information
In addition to the information that you provide us directly, we also collect information that You
provide to Safe Gold and other third parties for providing Services and for technology support like
application programming interfaces (APIs) and embeds to make that information available in our
database. 2. We may retrieve from Your records available with third party including from Know Your
Customer (KYC) Registration Agency (KRA) such as name, KYC details, KYC status, father’s name,
occupation, address details and related documents.;
Usage and Log Information: To make our Platform and Services more useful to you, our servers (which
may be hosted by a third-party service provider) collect information from you, including your
browser type, operating system, Internet Protocol (IP)address (a number that is automatically
assigned to your computer when you use the Internet, which may vary from session to session), domain
name, and/or a date/time of your visit. We use this information to examine our traffic and to view
how our customers use our website. This type of information will not allow you to be personally
identified although we might be able to associate it with your account. We process this usage data
to facilitate your access to our services in technical terms (e.g. to adjust our services to the
terminal device you are using), and to recognize and stop any misuse. We also use usage data in
anonymised form for statistical purposes and to improve our website . Further, if You choose to
invest through the Platform, We will also collect information about Your transactions including
transaction status and details and Your investment behaviour. We process this data to provide you
Services.
Location Information: When and if You download and/or use the Platform through Your mobile, We may
receive information about Your location, Your IP address, and/or Your mobile device, including a
unique identifier number for Your device. We may use this information to provide You with
location-based Services including but not limited to search results and other personalized content.
You can withdraw Your consent at any time by disabling the location-tracking functions on Your
mobile. However, this may affect Your enjoyment of certain functionalities on Our Platform.
Third party information: We also collect information from third parties on the tracking technologies
to track the activity on our service and hold certain information. Browser based, network based, AD-
Tracking, User UX behaviour tracking information is collected from third parties. We collect
information to understand and track the behavioural as means for security and connection integrity.
We will keep such information for our reference and will never share with any third party.
Also, please remember that the manner in which third party services collect, use, store and
disclose Your information is governed by the policies of such third parties, and Platform and/or
Company shall have no liability or responsibility for the privacy practices or other actions of any
third-party services that may be enabled within the Service.
Cookies: We use cookies and URL information to gather information regarding the date and time of
your visit and the information for which you searched and which you viewed. Cookies are small
digital signature files that are stored by your web browser that allow your preferences to be
recorded when you visit thePlatform . Also, they may be used to track your return visits to the
website. We may use both session Cookies (which expire once you close your web browser) and
persistent Cookies (which stay on your computer until you delete them) to provide you with a more
personal and interactive experience on our Site. Persistent Cookies can be removed by following
Internet browser help file directions. Our uses of cookies, web beacons, or other similar
technologies fall into the following general categories:
i) Operationally Necessary. We may use cookies, web beacons, or other similar technologies that are
necessary to the operation of our Services. This includes technologies that allow you access to our
Services; that are required to identify irregular site behaviour, prevent fraudulent activity and
improve security; or that allow you to make use of our functions such as, product information, saved
search, or similar functions.
ii) Performance Related. We may use cookies, web beacons, or other similar technologies to assess
the performance of our Services, including as part of our analytic practices to help us understand
how our visitors use our Services, determine if you have interacted with our messaging, determine
whether you have viewed an item or link, or to improve our Services’ content, applications,
services, or tools;
iii) Functionality Related. We may use cookies, web beacons, or other similar technologies that
allow us to offer you enhanced functionality when accessing or using our Services. This may include
identifying you when you sign into our Services or keeping track of your specified preferences,
interests, or past items viewed so that we may enhance the presentation of content on our Services;
iv) Advertising or Targeting Related. We may use first-party or third-party cookies and web beacons
to deliver content, including ads relevant to your interests, on our Services or on Third Party
sites. This includes using technologies to understand the usefulness to you of the advertisements
and content that has been delivered to you, such as whether you have clicked on an advertisement.
If you would like to opt-out of the Technologies we employ on ourPlatform, services, applications,
or tools, you may do so by blocking, deleting, or disabling them as your browser or device permits.
The information collected allows Us to provide the Services and features on the Platform that most
likely meet Your needs, and to customize the Platform to make Your experience safer and easier.
However, You can browse the Platform without telling Us who You are or revealing any Personal
Information about Yourself. In such a case, we will only collect and store the Non – Personal
Information. Once You give us your Personal Information, You are not anonymous to Us. Wherever
possible, while providing the information to Us, We indicate which fields are mandatory and which
fields are optional for You. You always have the option to not provide the Personal Information to
Us through the Platform by choosing to not use a particular Service or feature being provided by Us
on the Platform, which requires You to provide such information. We may automatically track certain
information about You based upon Your behaviour on the Platform. We use this information to do
internal research on Your demographics, interests, and behaviour to better understand, protect and
serve You. This information is compiled and analysed by the Company on an aggregated basis and not
individually, in a manner that does not specifically identify You.
USE OF YOUR INFORMATION - We use the Personal Information and other non-Personal Information, for the following:
You also specifically agree and consent to Us for collecting, storing, processing, transferring and
sharing information (including Personal Information) related to You with third parties solely for
the purpose of processing your transaction requests for the Services. Unless and until, You
explicitly give Your consent to Us, to do so, We will not share Your Personal Information with
another user of the Platform and vice versa.
SHARING OF INFORMATION
We may make Your Personal Information and/or other Non-Personal Information available to Our
partners, collaborators including Safe Gold and its affiliates to enable them to provide Services
through the Platform to You. Please note that all information shared with our partners,
collaborators and affiliates or made available to our partners, collaborators affiliates will be
governed by the terms of this Privacy Policy.
We may also disclose Your Personal Information to third party vendors, consultants, and other
service providers who work for the Company, who are bound by contractual obligations to keep such
personal information confidential and use it only for the purposes for which We disclose it to them.
This disclosure may be required for Us, for instance, to provide You access to Our Services and
process payments including validation of Your bank accounts, to facilitate and assist Our marketing
and advertising activities/initiatives, for undertaking auditing or data analysis, or to prevent,
detect, mitigate, and investigate fraudulent or illegal activities related to Our Services.
You also specifically agree and consent to Us for transferring and sharing your sensitive personal
information (including your biometric data, financial information, passwords) related to You with
Our partners, collaborators including Safe Gold and its affiliates, third parties and other service
providers solely for the legitimate purpose of proving you the Services.
We do not disclose Your Personal Information to third parties for their marketing and advertising
purposes without Your explicit consent.
The Company may disclose Your information, to the extent necessary:
LINKS TO OTHER THIRD-PARTY SITES AND COLLECTION OF INFORMATION
Our Platform may link You to other third-party Platforms (“Third – Party Sites”) that may collect
Your Personal Information including Your IP address, browser specification, or operating system. The
Company is not in any manner responsible for the security of such information or their privacy
practices or content of those Third – Party Sites. These third-party service providers and
Third-Party Sites may have their own privacy policies governing the storage and retention of Your
information that You may be subject to. This Privacy Policy does not govern any information provided
to, stored on, or used by these third-party providers and Third-Party Sites. We recommend that when
You enter a Third-Party Site, You review the Third-Party Site’s privacy policy as it relates to
safeguarding of Your information. We use third-party advertising companies to serve ads when You
visit the Platform. These companies may use information (not including Your name, address, email
address, or telephone number) about Your visits to the Platform and Third-Party Sites in order to
provide advertisements about goods and services of interest to You. You agree and acknowledge that
We are not liable for the information published in search results or by any Third-Party Sites.
SECURITY PRECAUTIONS AND MEASURES
Our Platform has reasonable security measures and safeguards in place to protect Your privacy and
Personal Information from loss, misuse, unauthorized access, disclosure, destruction, and alteration
of the information in compliance with applicable laws. Further, whenever You change or access Your
account on the Platform or any information relating to it, We offer the use of a secure server. We
cannot however ensure or warrant the security of any information You transmit to the Company or
guarantee that Your Personal Information and/or other Non-Personal Information provided for availing
the Services or Platform may not be accessed, disclosed, altered or destroyed by a breach of any of
Our security measures and safeguards.
It is further clarified that You have and so long as You access and/or use the Platform (directly or indirectly) the obligation to ensure that You shall at all times, take adequate physical, managerial, and technical safeguards, at Your end, to preserve the integrity and security of Your data which shall include and not be limited to Your Personal Information. When payment information is being transmitted on or through the Platform, it will be protected by encryption technology. You expressly consent to the sharing of Your information with third party service providers, including payment gateways, to process payments and manage your payment-related information. Hence, the Company cannot guarantee that transmissions of Your payment-related information or Personal Information will always be secure or that unauthorized third parties will never be able to defeat the security measures taken by the Company or the Company’s third-party service providers. The Company assumes no liability or responsibility for disclosure of Your information due to errors in transmission, unauthorized third-party access, or other causes beyond its control. You play an important role in keeping Your personal information secure. You shall not share Your Personal Information or other security information for Your account with anyone. The Company has undertaken reasonable measures to protect Your rights of privacy with respect to Your usage of the Platform controlled by Us and Our Services. However, We shall not be liable for any unauthorized or unlawful disclosures of Your personal information made by any third parties who are not subject to Our control.
DATA STORAGE AND RETENTIONPOLICY
We collect and store your data and Personal Information in AWS cloud as you use services and will
retain the data for as long as necessary to fulfil the purposes for which it was obtained. Processed
and non-identifiable data, however, will be perpetually stored.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
DISCLAIMER
Company is merely providing a distributor platform of Safe Gold that facilitate transaction of sale
and investment for Users and will not be liable in any manner with respect to the products/ services
allotted to You. You hereby agree and acknowledge that the data and information provided on the
Platform does not constitute advice of any nature whatsoever and shall not be relied upon by You
while making investment decisions and You shall be solely responsible for any investment decisions
and for the purchase of any mutual funds on the Platform. In no event shall the Company be liable to
You for any loss or damage that may cause or arise from or in relation to these Terms of Use and/or
due to use of this Platform or due to investments made using this Platform. As part of the Platform
Services provided to You, after availing such services, You agree to provide honest feedback/review
about the concerned Platform Service, if required by the Company.
8.YOUR PRIVACY RIGHTS
Your Consent: By visiting the Platform or setting up/creating an account on the Platform for
availing the Services on the Platform at such time, You signify Your acceptance to the provisions of
the Privacy Policy. You may choose to withdraw Your consent provided hereunder at any point in time.
Such withdrawal of consent must be sent in writing to info@changeNovha.in. In case You do not provide
Your consent or later withdraw Your consent, we request you not to access the Platform and/or use
the Services and also reserve the right to not provide You any Services through the Platform. In
such a scenario, the Company may delete Your information (Personal or otherwise) or de-identify it
so that it is anonymous and not attributable to You. However, please note that Company reserves the
right to refuse any request to exercise such rights to the extent permitted by applicable law.
9. CHANGES TO PRIVACY POLICY
We reserve the unconditional right to change, modify, add, or remove portions of this Privacy Policy
at any time, without specifically notifying You of such changes. Any changes or updates will be
effective immediately. You should review this Privacy Policy regularly for changes. Your acceptance
of the amended Privacy Policy shall signify Your consent to such changes and agreement to be legally
bound by the same.
10. GRIEVANCE OFFICER
If You have any privacy concerns, please feel free to reach out to the grievance officer, the name
and contact details of this Officer have been provided below:
Ready Cash
1. INFORMATION WE COLLECT
1.1 Sensitive Data and Personal Information: In general, We may collect Personal Information,
including Sensitive Data.
“Personal Information” means individually identifiable information that directly or indirectly, in
combination with other information would allow the identification of a specific living person.
“Sensitive Data” means Your Personal Information such as financial information such as bank account
details and/ or any other payment instrument details, sexual orientation, any details that may have
been voluntarily provided by You and any of the information received under above clauses by Us in
connection with availing the Services.
By providing Personal Information (including Sensitive Data) to us, you consent to the collection,
usage, and disclosure of Personal Information (including Sensitive Data), as permitted by applicable
laws. By using the Services, you are authorizing us to gather, parse data and retain basic data
which are related to the provision of the Services.
1.2 Personal Information: We may collect and process your Personal Information, including but not
limited to the following:
1.2.1 Information provided by you at the time of registration such as your name, address, email ID,
phone number, bank account details, financial information, unique identifiers, and preferences
information including favourites and history;
1.2.2 Information that you provide to us directly via email and/ or electronic communication;
1.2.3 Your bank account statement provided by you through the upload feature during the onboarding
process on Novha Platform to assess your creditworthiness;
1.2.4 Your live selfie for your identity check and verification with your KYC documents. The image
captured through this selfie may be shared with third party for the purpose mentioned in Clause 3.3
herein;
1.2.5 Information that you provide to us over telephone. We may make and keep a record of such
information shared by you;
1.2.6 Information that you provide to us in physical form whether sent through post and / or courier
and / or handed over to our representatives in person;
1.2.7 Any other additional information required to be provided via email/ electronic communication/
telephone/ post/ courier after your registration; and
1.2.8 Hardware model, operating system and versions and identifiers like IMEI number and serial
number of your primary device used for availing Services.
1.2.9 Information from other sources.
1.3 Domain Name and IP Address: We may collect your domain name which is linked to every computer/
mobile device connected to the internet and a set of numbers that serve as that computer’s Internet
Protocol or “IP” address. When you request a page from any page within the Website, our web servers
automatically recognize your domain name and IP address. The domain name and IP address does not
reveal any further information about you other than the IP address from which you have accessed the
Website.
1.4 Cookies: If enabled, we may place cookies on your machine that store small amounts of data on
your computer about your visit to any of the pages of this website. Cookies can identify the pages
that are being viewed and this can assist us in tracking which of our features appeal the most to
you and what content you may have viewed on past visits.
We use cookies on our website in order to personalize our service to you. Users can control the use
of cookies at the individual browser level. If you reject cookies, you may still use our site, but
your ability to use some features or areas of our site may be limited. You may refuse to accept
cookies by activating the setting on your browser which allows you to refuse the setting of cookies.
Unless you have adjusted your browser setting to refuse cookies, our system will issue cookies when
you log on to the website.
1.5 SMS: We do not collect, read, store or share with third parties your personal SMS, other than
the SMS pertaining to your financial transactions solely to assist our lending partners in assessing
your credit risk.
1.6 Phone: We shall take one-time access of certain features of your mobile phone to facilitate
on-boarding on the platform and KYC verification:
Camera
Location
SMS
IP Address
1.7 Biometric Data: No Personal Information of yours containing biometric data will be collected or
stored by Novha unless permitted by extant statutory guidelines.
2. HOW WE USE INFORMATION WE COLLECT
Our primary goal in collecting the information is to provide you a platform to render our Services.
We may use the personal information provided by you for one or more of the following:
a. To help provide you the Services;
b. To observe, improve and administer the quality of Services;
c. To analyze how the platform is used and diagnose technical problems;
d. Remember the basic information provided by you for effective access;
e. To confirm your identity in order to determine your eligibility to use the platform and avail the
Services
f. To notify you about any changes to the Website;
g. To enable us to comply with our legal and regulatory obligations;
h. For the purpose of sending administrative notices, Service-related alerts and other similar
communication with a view to optimizing the efficiency of the Website;
i. Doing market research, troubleshooting, protection against error, project planning, fraud and
other criminal activity; and
j. To enforce our Terms of Use.
3. DISCLOSURE OF INFORMATION
3.1 We do not publish your Sensitive Data provided by you.
3.2 We will treat your Personal Information strictly confidential. We will not disclose your
Personal Information to anyone, except in the following cases:
We may disclose your Personal Information in the event it is required to do so by law, rule,
regulation, law, enforcement, governmental official, legal or regulatory authorities and/ or to such
other statutory bodies who have appropriate authorisation to access the same for any specific legal
purposes.
Merger, acquisitions: Information collected from you may be transferred to a third party(ies) as a
result of a sale or acquisition, merger or bankruptcy involving the Company.
We may disclose your information to any of our affiliates or related entities. We will ensure that
our affiliates and related entities maintain the same standards of confidentiality and protection
with respect to the Personal Information shared with them.
We may disclose your information in order to provide you the Services, enforce or apply the Terms
and Conditions of Use, or to protect the rights, property or safety of the Company, its users or
others. This includes providing information to one or more lending partners, and exchanging
information with other companies / agencies that work for fraud prevention.
3.3 Sharing: You hereby consent to sharing your Personal information with credit information
companies, analytics, technical partners, payment facilitators, commercial partners, lending
partners, etc for purposes including but not limited to providing and monitoring Our Services,
onboarding process on the Novha Platform, assessing the creditworthiness, KYC verification, fraud
prevention and risk evaluation. We may share aggregated demographic information with our partners or
affiliates. This is not linked to any personal information that can identify an individual person.
We will not be liable for transfer of any personal identification information resulting from loss or
distribution of data, the delineation or corruption of media storage, power failures, natural
phenomena, riots, act(s) of vandalism, sabotage, terrorism or any other event beyond our control.
Further, our Privacy Policy does not cover the use of cookies by its partners and affiliates since
we do not have access or control over such cookies.
3.4. Consulting: We may partner with other parties to provide specific portions of the Services, if
required. When you sign-up for the Services, we may share some of your Personal Information
(including phone number registered or to be registered with Novha) and Sensitive data to the extent
necessary for the third party to provide these Services. Our contractual arrangements with such
third parties restrict these parties from using personally identifiable information except for the
explicit purpose of assisting in the provision of these Services.
3.5. Promotional Offers: We may send you offers, which may be on behalf of other businesses. If you
do not want to receive such offers, you may request us to adjust your preferences.
4. CHANGE OF INFORMATION
If your Personal Information or Sensitive Data changes, you may correct, delete inaccuracies, or
amend information by reaching out to us at ID: customercare@novhafincorp.com. We may request you to
provide any additional information or documents as may be necessary to verify the changes requested
by you.
5. SECURITY OF INFORMATION
5.1 We take the security of your information very seriously. To this end, we use several security
techniques including secure servers at India, firewalls, and encryptions, as well as physical
safeguard of the locations where the data are stored. We have in place appropriate administrative,
technical, physical safeguards and security measures to protect the personal data you provide to us
against accidental, unauthorized, or unlawful loss, destruction, damage, alteration, access,
disclosure or use and any other unlawful forms of processing. When we collect data, we collect your
personal details on a secure server. We use firewalls on our servers. Whilst we are unable to
guarantee 100% security, this makes it hard for a hacker to decrypt your details. We maintain
physical, electronic, and procedural safeguards in connection with the collection, storage and
disclosure of your information. Our security procedures mean that we may occasionally request proof
of identity before we disclose personal information to you. You are responsible for protecting
against unauthorized access to your password and to your computer.
5.2 The information that is collected from you may be transferred to, stored, and processed at any
destination as permitted under applicable law. By submitting information to us, you agree to this
transfer, storing and/ or processing. We will take such steps as we consider reasonably necessary to
ensure that your information is treated securely and in accordance with this Privacy Policy.
5.3 In using the Services, you accept the inherent security implications of data transmission over
the internet. Therefore, the use of the Website will be at your own risk, and we assume no liability
for any disclosure of information due to errors in transmission, unauthorised third party access or
other acts of third parties, or acts or omissions beyond its reasonable control and you agree not to
hold us responsible for any breach of security.
5.4 In the event we become aware of any breach of the security of your information, we will promptly
notify you and take appropriate action to the best of its ability to remedy such a breach.
6. DATA RETENTION
You may request us to delete your information or revoke the consent to access or opt out of
processing your application by submitting a request for account deletion through the Novha mobile app
via the profile section. On submitting a request to delete Your account, you confirm/understand
that:
1. You have no outstanding credit facility availed on the Novha platform.
2. You have no pending or potential grievances in relation to any of your previous dealings with Us.
3. Your account will be permanently deleted. We will not be able to reactivate your account.
4. You will receive no further communications from Novha.
You however understand that We will be required to or retain, and accordingly use and disclose any
specific data if required by law, rule, regulation, law, enforcement, governmental official, legal,
or regulatory authorities and / or to such other statutory bodies who have appropriate authorisation
or for the purposes of completing any legal obligations or for audit requirements. We will not
retain your Personal Information(including sensitive personal data) for longer than is required for
the purpose for which the information may lawfully be used.
7. NOTIFICATION OF CHANGES
We may update this Privacy Policy at any time, with or without advance notice. In the event there
are significant changes in the way we treat your Personal Information, or in the Privacy Policy
document itself, we will display a notice on the Website or send you an email informing you of such
changes, so that you may review the changed terms prior to continuing to use the Website and our
Services.
Using the Company’s Services or accessing the Website after a notice of changes has been sent to you
or published on the Website will constitute your consent to the changed terms.
It is very important that any Personal Information we hold/pass on to our lending partners about you
is up to date and correct. Please inform us at customercare@novhafincorp.com for any changes to your
Personal Information.
8. ADDRESS FOR PRIVACY RELATED QUESTIONS
To offer optimum support to our customers and to address complaints and grievances in the most
effective manner, we have set out the process for registering and getting the complaint addressed.
In accordance with the Information Technology Act, 2000 and the rules made thereunder, the name and
contact details of the Grievance Officer are provided below.
Name: Mrs. Dhivya gr
Address: No.TF 15 AJANTHA ROYAL KAONAPPANA AGRAHA Bangalore - 560100
Email ID: info@novhafincorp.com
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