TERMS AND CONDITIONS

I. Restrictions on Use:

The Website is owned, operated, and maintained by PHRENOLOGICAL INFO AUDIT AND APP SOLUTION PRIVATE LIMITED ("Company"), a Non-Banking Financial Company engaged in housing finance and related financial services. The Website contains material, information, data, text, graphics, interfaces, reports, financial products information, software, proprietary tools, calculators, algorithms, trademarks, service marks, trade names, logos, and other content (collectively, the "Content"), which is derived in whole or in part from materials supplied by the Company, its affiliates, group entities, licensors, content partners, third-party service providers, various news agencies, and other sources. All such Content is protected by applicable copyright, trademark, patent, trade secret, and other intellectual property laws, including international conventions.

Subject to these Terms, the Subscriber is granted a limited, non-exclusive, non-transferable, revocable license to access and use the Website and its Content strictly for personal, informational, and non-commercial purposes. Except as expressly authorized in writing by the Company, the Subscriber shall not:

1. Modify, adapt, translate, reverse engineer, decompile, disassemble, or create derivative works from any Content, including any software, source code, scoring models, underwriting criteria, risk assessment tools, or proprietary algorithms made available on or through the Website.
2. Copy, reproduce, republish, upload, post, transmit, distribute, display, license, sell, rent, lease, assign, or otherwise exploit any Content for commercial purposes.
3. Use the Website or its Content for the purpose of competing with the Company or for developing, marketing, or offering competing housing finance, loan aggregation, credit facilitation, or financial products or services.
4. Scrape, extract, harvest, collect, or mine data (including borrower data, interest rates, eligibility criteria, product structures, pricing information, or property-related data) by automated or manual means, including through bots, crawlers, spiders, or similar technologies.
5. Remove, obscure, or alter any copyright, trademark, confidentiality, or other proprietary notices contained in or displayed on the Website.
6. Misuse any loan application interface, eligibility calculator, EMI calculator, document upload facility, or customer portal for fraudulent, unlawful, or unauthorized purposes.
7. Access or attempt to access non-public areas of the Website, servers, systems, underwriting modules, customer databases, or secured environments without proper authorization.
8. Use the Website in any manner that violates applicable laws, including but not limited to housing finance regulations, RBI/NHB guidelines, data protection and privacy laws, anti-money laundering laws, or consumer protection laws.
9. Impersonate any person or entity, misrepresent affiliation, or provide false, misleading, or incomplete information in connection with any housing loan or financial product application.
10. Use the Content in any manner that may damage, disable, overburden, or impair the Website's infrastructure or interfere with any other user's access and enjoyment of the Website.

II. Compliance with Terms

1. By accessing or using the Website, you expressly acknowledge and agree to be bound by these Terms and Conditions, as amended from time to time. If you do not agree to these Terms, you must immediately cease use of the Website. The right granted to you to access and use the Website, including any housing finance products, loan application interfaces, customer dashboards, document upload facilities, account statements, repayment modules, or related services (collectively, the "Services"), is personal, limited, non-exclusive, non-transferable, and revocable. Such right may not be assigned, sublicensed, transferred, or otherwise made available to any other individual or entity without the prior written consent of the Company.
2. Where access to certain features of the Website requires registration, creation of an account, or the use of login credentials (including user IDs, passwords, OTPs, or other authentication mechanisms), you shall:
   a) Be solely responsible for all activities conducted through or under your account, whether authorized by you or not.
   b) Ensure that all information provided by you in connection with any housing loan application, property details, income documentation, KYC documentation, repayment instructions, or other financial information is accurate, complete, and not misleading.
   c) Use your account strictly for lawful purposes and in compliance with applicable laws, including but not limited to housing finance regulations, RBI/NHB guidelines, anti-money laundering laws, KYC norms, and data protection laws.
3. You shall be solely responsible for maintaining the confidentiality and security of your login credentials, passwords, OTPs, and any other authentication information. You agree not to disclose, share, or permit the use of your credentials by any third party. Any access or use of the Website through your credentials shall be deemed to have been undertaken by you.
4. You shall immediately notify the Company in writing of any unauthorized use of your account, suspected breach of security, loss or compromise of credentials, or any other incident that may affect the integrity or security of your account.
5. The Company shall not be liable for any loss, damage, liability, or claim arising out of or in connection with your failure to safeguard your credentials or your breach of these obligations. The Company reserves the right to suspend, restrict, or terminate your access to the Website or Services, without prior notice, if it reasonably believes that your account has been misused, compromised, or used in violation of these Terms or applicable regulatory requirements governing Housing Finance NBFCs.

III. Changed Terms

1. The Company reserves the absolute right, at its sole discretion, to amend, modify, supplement, vary, or replace these Terms and Conditions, or any part thereof, at any time. The Company may also introduce, modify, or withdraw any feature of the Website or Services, including but not limited to housing loan products, eligibility criteria, interest rates (to the extent permissible by applicable law), processing fees, service charges, documentation requirements, repayment mechanisms, digital interfaces, or other related facilities, subject to applicable regulatory guidelines governing Housing Finance NBFCs.
2. Any such amendment, modification, addition, deletion, or introduction of new terms (collectively, "Revised Terms") shall become effective upon notification. Notification may be provided by any legally permissible means, including but not limited to:
   (i) publication or posting on the Website;
   (ii) display within the user account or customer dashboard;
   (iii) electronic communication to the registered email address or mobile number of the user; or
   (iv) any other mode of communication recognized under applicable law.
3. Where required under applicable laws, including directions, circulars, or guidelines issued by the Reserve Bank of India, National Housing Bank (if applicable), or any other regulatory authority, the Company shall provide prior notice of material changes in the manner prescribed by such regulations.
4. Continued access to or use of the Website or Services after the effective date of the Revised Terms shall constitute deemed acceptance of such Revised Terms by the user. If the user does not agree to the Revised Terms, the user must discontinue use of the Website and Services; however, such discontinuation shall not affect any outstanding obligations, liabilities, or loan repayment commitments incurred prior to such termination.
5. The Company further clarifies that no modification to these Terms shall affect the validity or enforceability of any executed loan agreement, sanction letter, security document, or other binding financial arrangement, except as may be expressly agreed in writing between the parties or as required under applicable law.

IV. Use of Information and Materials

1. The information, data, materials, content, calculators, tools, illustrations, loan product details, interest rate indications, market updates, property-related information, graphics, text, links, interfaces, and other materials (collectively, the "Content") made available on this Website are provided solely for general informational purposes and do not constitute an offer, invitation, solicitation, recommendation, advice, or commitment to lend or provide any financial accommodation.
2. Nothing contained on this Website shall be construed as financial, legal, tax, investment, property, or professional advice. The Content is not intended to form the basis of any decision relating to housing loans, property acquisition, refinancing, or assumption of any financial obligation. Users are strongly advised to exercise independent judgment and to seek appropriate professional advice before applying for any housing finance facility or entering into any financial transaction.
3. Any eligibility indication, EMI computation, loan illustration, interest rate display, or product feature description provided on the Website is indicative and for illustrative purposes only. The actual sanction of any loan facility shall be subject to the Company's internal credit policies, underwriting criteria, risk assessment, property valuation, legal due diligence, regulatory requirements, and execution of definitive loan and security documentation.
4. The Content is provided strictly on an 'as is' and 'as available' basis, without warranties of any kind, whether express or implied. The Company does not warrant the accuracy, completeness, adequacy, reliability, timeliness, or continued availability of the Content and expressly disclaims all liability for any errors, omissions, or inaccuracies therein. The Company shall not be liable for any loss or damage (including, without limitation, direct, indirect, incidental, consequential, or special damages) arising out of or in connection with the use of, or reliance upon, the Content.
5. All intellectual property rights in the Content are owned by or licensed to the Company. Except as expressly permitted in writing by the Company, users shall not:
   A. Copy, reproduce, republish, upload, post, transmit, display, modify, distribute, or create derivative works from the Content.
   B. Download, store, or reproduce the Content in any medium for commercial purposes.
   C. Circulate, disseminate, or otherwise distribute the Content to any third party.
   D. Use the Content for competing housing finance, lending, aggregation, or financial services activities; or
   E. Remove or alter any proprietary notices contained in the Content.
   F. Unauthorized use of the Website or its Content may result in civil, criminal, and/or regulatory action under applicable laws.
6. The Company reserves the right to modify, withdraw, suspend, or discontinue any part of the Content or Website at any time without prior notice and without incurring any liability.
7. The content on this website shall not be regarded as an offer, solicitation, invitation, advice, or recommendation to buy or sell investments, securities or any other instrument or financial products/ scheme of the company, or any of its holding, subsidiary or affiliates.

V. Loan Specific Disclaimers

1. The submission of any application, inquiry, or request for a housing loan or other financial facility through the Website shall not constitute or be deemed to constitute approval, sanction, commitment, or offer of finance by the Company. Any acknowledgement of receipt of an application shall not be construed as acceptance or approval thereof.
2. All loan facilities are subject to the Company's sole and absolute discretion and shall be sanctioned only upon completion of its internal credit appraisal process and satisfaction of such conditions as the Company may deem necessary, including but not limited to:
   a) Verification of identity and address in accordance with applicable Know Your Customer (KYC) norms.
   b) Assessment and validation of income, employment, repayment capacity, and financial standing.
   c) Obtaining and evaluating credit reports, credit scores, and repayment history from CIBIL and/or other credit information companies registered with the Reserve Bank of India.
   d) Legal due diligence of the title and ownership of the property proposed to be mortgaged.
   e) Technical evaluation and valuation of the property by empaneled valuers; and
   f) Compliance with the Company's internal credit policy, risk assessment framework, and applicable regulatory guidelines issued by the Reserve Bank of India or any other competent authority.
3. The Company reserves the right, at its sole discretion and subject to applicable law and regulatory guidelines, to approve, modify, defer, or reject any loan application without being required to assign any reasons. Nothing contained on the Website shall obligate the Company to grant any loan facility.
4. Any interest rates displayed on the Website are indicative in nature and subject to change. The applicable interest rate for any sanctioned lo an shall be as specified in the sanction letter and/or loan agreement and may be fixed, floating, hybrid, or linked to an external or internal benchmark, in accordance with the Company's interest rate policy and applicable regulatory norms.
5. All fees and charges, including but not limited to processing fees, administrative charges, legal and technical evaluation charges, documentation charges, and applicable taxes, shall be payable as per the sanction terms. Unless otherwise expressly stated in writing and in compliance with applicable regulatory requirements, processing fees and other charges paid in connection with a loan application shall be non-refundable, irrespective of whether the loan is sanctioned, partially sanctioned, or declined.
6. The sanction and disbursement of any loan shall be subject to execution of definitive loan and security documents and fulfilment of all pre-disbursement conditions stipulated by the Company.

VI. Fair Practices Code and Regulatory Compliance

1. The Company has adopted and implemented a Fair Practices Code ("FPC") in accordance with the applicable directions and guidelines issued by the Reserve Bank of India. The FPC, as amended from time to time, is available for review on the Company's Website.
2. In line with the FPC and applicable regulatory requirements, the Company ensures transparency in its dealings with customers, including clear disclosure of its interest rate policy, methodology for determination of interest rates, penal charges framework, foreclosure and prepayment norms, and all applicable fees and charges. Any foreclosure or prepayment charges, where applicable, shall be levied strictly in accordance with prevailing RBI regulations.
3. The Company shall not discriminate on grounds prohibited under applicable law and shall process loan applications in a fair, objective, and non-discriminatory manner, consistent with its internal credit policies and regulatory obligations.

VII. Data Privacy and Consent

1. By accessing the Website and/or applying for any loan or financial facility, the user expressly consents to the collection, storage, use, processing, and retention of their personal information, financial information, sensitive personal data, and any other information or documents submitted, in accordance with applicable laws and the Company's Privacy Policy, as amended from time to time.
2. The user further authorizes the Company to:
   a. Obtain, access, and share information with credit information companies (including CIBIL and other RBI-registered credit bureaus) for the purposes of credit appraisal, verification, reporting of repayment behaviour, and regulatory compliance.
   b. Share or disclose such information, on a need-to-know basis, with the Company's affiliates, service providers, business correspondents, technical and legal consultants, valuers, insurers, auditors, collection agencies, and other third parties engaged for processing, servicing, securitization, assignment, recovery, or enforcement of any loan facility.
   c. Process Aadhaar, CKYC, and other officially valid documents for identity verification, authentication, and compliance with applicable KYC, AML, and regulatory requirements, where permissible under law; and
   d. Use and disclose such information for the purposes of enforcing contractual rights, initiating recovery proceedings, reporting to regulators, or complying with legal and statutory obligations.
   e. Any consent provided electronically, including through digital acceptance, OTP authentication, electronic signatures, click-wrap agreements, or other legally recognized digital modes, shall constitute valid and binding consent under the Information Technology Act, 2000 and other applicable laws.

VIII. Credit Bureau Authorization and Reporting

1. The user/applicant hereby expressly authorizes the Company to obtain, access, and verify their credit information from Credit Information Companies ("CICs"), including but not limited to TransUnion CIBIL, Experian, Equifax, CRIF High Mark, or any other credit bureau registered with the Reserve Bank of India, at any time and from time to time, for the purposes of processing, appraisal, sanction, review, renewal, enhancement, restructuring, collection, or recovery of any loan or financial facility.
2. The user further consents to the Company furnishing, reporting, and updating information relating to the loan account, including but not limited to disbursement details, outstanding amounts, repayment performance, defaults (if any), settlement status, restructuring, write-offs, and closure status, to such CICs and to any other statutory or regulatory authority as may be required under applicable law.
3. The user acknowledges and agrees that any delay, default, or non-payment of dues under the loan facility may be reflected in their credit report and credit score maintained by the CICs, and that such reporting may adversely impact their creditworthiness and ability to obtain credit facilities from the Company or other financial institutions in the future.
4. The Company shall report such information in accordance with applicable laws, regulations, and guidelines issued by the Reserve Bank of India and other competent authorities and shall not be liable for any consequences arising from accurate and lawful reporting of such information.

IX. Limitation of Liability

1. To the fullest extent permitted under applicable law, the Company shall not be liable for any loss, damage, cost, or expense (whether direct, indirect, incidental, consequential, special, punitive, or exemplary) arising out of or in connection with the access to, use of, or inability to use the Website or any Services.
2. Without prejudice to the generality of the foregoing, the Company shall not be liable for any loss or damage arising from or attributable to:
   a) Any interruption, suspension, delay, or unavailability of the Website or Services due to technical downtime, scheduled maintenance, system upgrades, or infrastructure failure.
   b) Any system errors, defects, omissions, inaccuracies, or technical glitches affecting loan applications, EMI calculations, account statements, transaction processing, or other digital interfaces.
   c) Any failure, delay, default, or deficiency attributable to third-party service providers, including but not limited to payment gateways, credit bureaus, valuers, technical consultants, insurers, telecom service providers, or technology partners.
   d) Any cyber-attack, hacking incident, malware intrusion, data breach, or unauthorized access to systems, where the same is beyond the reasonable control of the Company and despite the Company maintaining industry-standard security measures.
   e) Any act of government, regulatory authority, financial market disruption, force majeure event, or other circumstances beyond the Company's reasonable control.
3. Nothing contained herein shall be construed as limiting or excluding liability where such limitation or exclusion is prohibited under applicable law or regulatory directions.
4. In any event, and subject to applicable law, the aggregate liability of the Company, if any, arising out of or in connection with the use of the Website or Services shall not exceed the amount of fees, if any, actually paid by the user to the Company in connection with the specific transaction giving rise to such claim.
5. The user acknowledges that access to and use of the Website and related Services is at their sole risk and that the Company does not guarantee uninterrupted or error-free operation of its digital platforms.

X. Indemnity

1. The user/applicant ("Indemnifying Party") shall fully indemnify, defend, and hold harmless the Company, its affiliates, directors, officers, employees, agents, and representatives (collectively, the "Indemnified Parties") from and against any and all claims, demands, liabilities, losses, damages, costs, or expenses (including reasonable legal fees and expenses) arising out of or in connection with:
   a) Any misrepresentation, misstatement, omission, or false information provided by the user in relation to their personal, financial, employment, or property-related details.
   b) Any fraudulent act, misconduct, or deception committed or facilitated by the user in connection with the loan application, sanction, disbursement, repayment, or any other facility provided by the Company.
   c) Submission or use of forged, altered, or falsified documents, certificates, proofs, or other information provided to the Company.
   d) Any breach or non-compliance by the user of applicable laws, regulations, or guidelines, including but not limited to the Reserve Bank of India directions, housing finance regulations, KYC/AML norms, anti-money laundering and anti-terrorist financing laws, or other statutory obligations.
   e) Any claims, suits, proceedings, demands, or actions brought by third parties arising directly or indirectly from the user's conduct, acts, omissions, or failure to comply with these Terms or any applicable legal or regulatory requirement.
2. The indemnity under this clause shall survive the termination, closure, or completion of any loan account, transaction, or relationship with the Company and shall remain in full force and effect until all obligations of the user under these Terms and under applicable law have been satisfied.
3. The Company reserves the right to assume exclusive control of the defence and settlement of any matter subject to indemnification, and the Indemnifying Party shall provide all reasonable cooperation, including execution of documents and provision of information, to enable such defence.

XI. Grievance Redressal

1. In accordance with the guidelines issued by the Reserve Bank of India for Housing Finance Non-Banking Financial Companies, the Company has established a structured grievance redressal mechanism to address complaints and concerns raised by customers.
2. Grievance Redressal Officer (GRO): The Company has designated a Grievance Redressal Officer to handle and resolve customer complaints. All complaints may be submitted via email, written communication, or through the customer care channels provided on the Website. The contact details of the GRO are available on the Website and may be updated from time to time.
3. Escalation Matrix: If a complaint is not resolved to the satisfaction of the customer within the specified time, the customer may escalate the matter to the Chief Compliance Officer or any senior authority designated by the Company for dispute resolution.
4. Turnaround Timelines: The Company endeavours to acknowledge complaints promptly and resolve grievances within the timelines prescribed under RBI guidelines, subject to the complexity of the issue and regulatory requirements.
5. Nothing in this clause shall limit the Company's rights under applicable law to take protective or corrective action in relation to loan accounts or customer obligations, nor shall it affect the user's obligation to comply with the terms of any loan agreement.
6. Details of Grievance Redressal Officer:
   In accordance with the Information Technology Act, 2000 and the rules made thereunder, the name and contact details of the Grievance Officer of the company are provided below:
   Name: Shailendra Pandey
   Address: Centura Square, Unit 113 1st Floor Plot No B-44 & B-44A. Road No 27, Wagle Estate, MIDC, Thane (W) 400 604
   Phone Number:7208002957
   Email Id: support@phrenological.com

XII. Governing Law and Jurisdiction

1. These Terms and Conditions, the use of the Website, and any transactions, applications, or agreements entered into through the Website shall be governed by and construed in accordance with the laws of India.
2. The courts and tribunals in Kolkata shall have exclusive jurisdiction to adjudicate any disputes, claims, or proceedings arising out of or in connection with these Terms, the Website, or any loan, financial facility, or related service provided by the Company.
3. Notwithstanding the foregoing, the Company reserves the right, at its sole discretion, to refer any dispute, controversy, or claim arising under or in connection with these Terms, the Website, or any loan facility to arbitration in accordance with the provisions of the Arbitration and Conciliation Act, 1996, as amended from time to time. The arbitration shall be conducted by a sole arbitrator or a panel of arbitrators appointed by the Company. The award of the arbitrator(s) shall be final, binding, and enforceable in any court of competent jurisdiction.
4. Nothing in this clause shall limit the Company's rights to initiate or continue legal proceedings in any court of competent jurisdiction for the protection of its rights, recovery of dues, or enforcement of security in accordance with applicable law.

XIII. Cybersecurity Disclaimer

1. The Company has implemented industry-standard security measures to protect the integrity, confidentiality, and availability of its Website, digital platforms, and services. However, the Company does not guarantee that its systems, applications, or communications are immune to unauthorized access, hacking, malware, viruses, phishing attacks, or other cybersecurity threats.
2. By accessing or using the Website, the user acknowledges and agrees that:
   a) The user is responsible for maintaining the confidentiality of their login credentials, passwords, OTPs, and any other authentication information.
   b) The Company shall not be liable for any loss, damage, or liability arising from unauthorized access, cyberattacks, data breaches, system failures, or any other security incident beyond its reasonable control.
   c) Users must ensure that their devices, networks, and systems are adequately secured and free from malware, viruses, or other vulnerabilities when accessing the Website.
   d) The Company reserves the right to suspend, restrict, or block access to the Website or Services if it reasonably suspects any security threat, fraudulent activity, or breach of these Terms; and
   e) Any communications, data transmissions, or transactions conducted through the Website are at the user's own risk, and the Company shall not be responsible for any interception, loss, or corruption of data during transmission.
   The user agrees to promptly notify the Company of any actual or suspected cybersecurity incidents or breaches affecting their account or use of the Website.
3. Nothing in this clause shall be construed as limiting the Company's obligations under applicable law to maintain data security or report breaches to regulatory authorities, including the Reserve Bank of India.

XIV. Amendment to the Terms:

The Company reserves the right, at its sole discretion, to amend, modify, update, or supplement these Terms and Conditions, including any provisions relating to the Website, Services, or the processing of personal data.

• Notification: The Company may notify users of such amendments by posting on the Website, sending electronic communication, or any other reasonable means.
• Consent Requirement: Where an amendment involves changes to the collection, use, or sharing of personal data, the Company shall obtain the user's explicit consent in accordance with the Digital Personal Data Protection Act, 2023, before such amendments take effect.
• Deemed Acceptance: Continued use of the Website or Services after such notification shall constitute acceptance of the amended Terms, except where fresh consent is required for personal data processing.

XV.

In the event of any breach of these Terms by the user, including misuse of the Website or provision of false, fraudulent, or misleading information, the Company shall have the right to:

1. Suspend, restrict, or terminate the user's access to the Website or Services.
2. Take any legal or regulatory action, including reporting the matter to relevant authorities.
3. Recover any dues or enforce any security or contractual rights without prejudice to other remedies available under law; and
4. Pursue remedies for any loss, damage, or liability arising from such breach.

The rights and remedies of the Company under this clause are cumulative and without prejudice to any other rights or remedies available under applicable law or these Terms.