H2B Product Testing Policy

H2B is in the process of testing their Alpha Product Launch for which they use the data about the households and families who consented to participate in the user experience exercise to improve their software application. The participants have certain rights with respect to participating in the testing process and use of their personal information for the specific purpose and are set forth hereinafter.

Applicability

H2B’s privacy policies, practices, and the terms and conditions apply to all the participants in the Alpha Product Launch Testing of H2B and the Fintech partners.

Participants Privacy Policy

Effective Date: August 15, 2022

Our Participants Privacy Policy is aimed to help the participants and the Fintech API partner understand how H2B collect, use, and share participants’ information to enhance and enrich user experience – operate, improve, develop, and enable protection of H2B’s software application. Please take some time read this policy carefully.

Extent of Applicability: this policy applies to H2B Household Buddy Inc., and affiliates and subsidiaries. Wherever the context requires, the terms “H2B”, or “we”, or “our”, and or “us” are used interchangeably.

Our User Experience Participants’ Privacy Policy sections are set forth below:

1. Our Genesis

2. Methodology of using data

• Data collection and sources
• Information we collect from your financial accounts
• Our Retention and Deletion Practices
• Protection of data
• User data protection rights
• User Privacy Controls
• Changes to This Policy
• Contacting H2B Household Buddy
• Summary of Processing Activities by Category of Data

Our Genesis

Our mission is to empower families and individuals achieve sustained financial stability in the age of disruptions. Why should we worry about and what are we going to do about this? First, one should have knowledge understanding of household behavior and the barriers that inhibit them. Toward this, we conducted a detailed review of household behavior research evidences and our analysis is based on deductive reasoning, inferences, and suppositions. We found that families want to achieve financial stability and for that they need to do financial planning and budgeting. This is a classic case of learned helplessness and is due to lack of basic financial knowledge, planning skills, structure, methodology, and time. Recent studies show how families realized the importance of financial stability, especially, during the Covid-19 and what they are going to do about it? And the realization is moving to conscious savings behavior from unconscious spending choices. For this, they need a technology solution that will help them overcome the cognitive barriers to family finance planning. Our technology solution will make managing families finance simpler, easier, guide and nudge families and individuals to actionable intel toward realizing their goals.

Our application software using fintech APIs platforms will upload users’ bank accounts statements and credit card statements of the last three months to assess the state of the family financial health using our H2B Multidimensional family financial score module. Based on the family financial score, the software application adopts a user-specific budgeting model that integrates the user-family’s present and future financial needs. Our H2B software application then further divide the needs and wants allocation into specific consumption categories. After budgeting, the software application tracks daily transactions of users and account them again each category of the budget heads and provides real-time information about their budget versus actuals and alerts the user about variance. Real-time data alerts about the current balance in their bank accounts, credit card account and other accounts. Besides, the software provides information about what are the upcoming committed payments amount, their due date, and the creditor information. Finally, our chat bot will interact with the users about their performance in managing their finance: where they are faring poorly and where they are doing well and what needs to be done about to avoid crisis situation. This will nudge them to take timely action and prevent financial distress in the future.

Usability Tests and Methodology of Using Data

Usability test involve asking prospective customers (Focus Group) to complete specific tasks (called “use Cases”) with a working prototype or an actual product version. The goal is to identify potential problems with ease of use. Usability tests are conducted during all stages of product development and product launching. At every stage of the product development process, usability tests may involve collecting quantitative data (such as the time required to complete registration; or the number of clicks on a given tab) in order to improve specific features (visual, shape, sequence, etc.).

This part outlines H2B’s software application user experience data practices with regard to collection and processing of data about user participants and may use the information for the specific purposes of improving the software application feature for the benefits of families and households.

Data collection and their sources

H2B may collect the following data from the Focus Group:

• Focus Group Identifiers (for example, name, phone, email, and user name);
• Focus Group location information (for example, state, and device location);
• Focus Group financial information (for example, financial accounts name & type, account holder name, number, and balance, and transaction history such as statement of accounts);
• Focus Group Electronic network activity information (for example, your device hardware model and operating system, and browser data);
• Focus Group Employment and Education information (for example, employed, self-employed level);
• Focus Group Income information(For example, income range)
• Inferences that we have derived from the information we have collected from Focus Group.

Information you provide. When you connect with your financial accounts with us, we connect your financial accounts through its Fintech partners, we collect identifiers and login information provided by them such as username. In some cases, we also collect date of birth, phone number, email address, security questions and answers, and one-time password (OTP) to help verify your identity and connect your financial accounts. When providing this information, you give H2B and Fintech partner the authority to act on your behalf to access and transmit your information from the relevant bank or other entity that provides your financial accounts (financial product and service providers in this policy). You may also need to provide us identifiers and other information, including your name, email address, and phone number, when you contact H2B or enter such information on our websites.

Information we collect from your financial accounts

The information we receive from Fintech Partners about your financial accounts varies depending upon a number of factors including what and how information is made available by Fintech partners. Depending upon these factors, the information we collect may include identifiers, commercial information, financial information and professional information from you. Particularly, this may include the following type of information:

• Financial account information: financial institution name, account name, account type, account holder name, branch number, IBAN, BIC, account number, routing number, and sort code; information about an account balance, including current and available balance;
• Credit accounts information: due dates, balances owed, payment amounts, and dates, transaction history, credit limit, repayment status, and interest rate;
• Information about loan accounts: due dates, repayment status, balances, payment amounts and dates, interest rate, guarantor, loan type, payment plan, and terms;
• Information about investment accounts: transaction information, type of asset, identifying details about the asset, quantity, price, fees, and cost basis;
• Identifiers and information about the account owner(s): including name, email address, phone number, date of birth, and address information;
• Information about account transactions; amount, date, payee, type, quantity, price, location, involved securities, and a description of the transaction.

We will use the data provided by Fintech Partners and the data may include information from all your accounts (for example, checking, saving and credit card) accessible through a single set of account credentials.

Information we receive from your devices. When you use your device to connect to our software application, we receive identifiers and electronic network activity information about that device, including internet protocol (IP) address, time zone setting and location, device location, hardware model, operating system, which features within our services you access, browser data, and other technical information about the device. We also use cookies or similar tracking technologies to collect usage statistics and to help us provide and improve our services.

Information we receive about you from other sources. We also receive identifiers and commercial information about you directly from our Fintech partners or other third parties, including our service providers, bank partners, and identity verification services.

Inferences we derive from the data we collect. We may use the information we collect about you to derive inferences. Here are a few examples of the types of inferences we may derive from data we have collected about you from you or other sources:

• Your geolocation or your annual income;
• The type of account or subaccount you’ve chosen to connect―for example, when you connect your loan accounts, we can know whether the account is for a mortgage, student loan, or credit card;
• We may derive inferences from your financial information, including your transaction data, and from other sources to help enable us to provide a better user experience to you.

How We Use Your Information

We use your information only to improve and redesign the software application and the key features to enhance ease of use. More specifically, we use your information as follows:

• Improve: Test our product version and collect data about focus group to improve our software application
• Redesign key features: Use your data improve, enhance, modify, delete, and add features;
• Help Prevent Fraud or Protect Privacy: To help protect your personal data from fraud, malicious activity, and other privacy and security-related concerns.
• Provide Support: To provide customer support to you, including to help respond to your inquiries related to our software applications.
• Investigate Misuse and Misconduct: To investigate any misuse of our product fintech API applications, including violations of our usability testing policy, criminal activity, or other unauthorized access to our services.
• For Legal Purposes: To comply with contractual and legal obligations under applicable law and for other legal purposes such as to establish and defend against claims.
• With Your Consent: For other notified purposes at your direction.

How We Share Your Information

We share our Usability Test Information:

• With the fintech API service provider we are using and as directed by the fintech API service provider (such as with another third party if directed by you);
• With our data processors and other service providers, partners, or contractors in connection with the Usability Test;
• With your connected financial institution(s) to help establish or maintain a connection you’ve chosen to make;
• We believe in good faith that disclosure is appropriate to comply with applicable law, regulation, or legal process (such as a court order or subpoena);
• We believe reasonably appropriate to protect the rights, privacy, safety, or property of you, fintech API, our partners, and others; or
• For any other notified purpose with your consent or at your direction.

We do not sell or rent personal information that we collect.

Our Retention and Deletion Practices

We retain Usability Test information to fulfil for the purposes for which it was collected and used, as described in this Policy, unless a longer retention period is required under applicable law. As However, your information will only be processed as required by law or in accordance with this Policy. H2B’s systems are designed to automatically delete your personal information when the purpose for which it was collected and used to improve our software for user experience was completed. You will be duly notified just before and after deletion of your information from the testing activities.

Protection of Information

H2B implements security policies and practices designed to protect the confidentiality and integrity of information about you, including the information you provide to us, as well as any other information we collect about you. H2B implements control measures designed to limit access to this information to personnel who have a business reason to know it and prohibits its personnel from unlawfully disclosing this information.

Your Data Protection Rights

Under applicable law, and subject to limitations and exceptions provided by law, you may have certain rights in relation to the information collected about you and how it is used, including the right to:

• Access information collected about you;
• Request that we rectify or update your information that is inaccurate or incomplete;
• Request, under certain circumstances, that we restrict the processing of or erase your information;
• Object to our processing of your information under certain conditions provided by law;
• Where processing of your information is based on consent, withdraw that consent;
• File a complaint regarding our data protection practices with a supervisory authority.

Changes To This Policy

We may update or change this Policy from time to time suiting to the context. If we make any updates or changes, we will post the new policy on H2B’s website at www.h2b.co.in and update the effective date at the top of this Policy. We will also notify Fintech API partners, of any material changes in accordance with our Usability Test agreements and they will notify their partners about such changes to this Policy, as appropriate.

Contacting H2B Household Buddy

If you have any questions or complaints about this Policy, or about our privacy practices generally,

you can contact us at: