THIS PRIVACY POLICY ("Policy") has been drafted in accordance with the Information Technology Act, 2000 and the Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011.
FINWINGS TECHNOLOGIES PRIVATE LIMITED (hereinafter shall be referred to as "creditlab" or "Company" or "us" or "we" are the owner of the mobile application by the name creditlab ("App") and website at www.creditlab.in ("Website") (App and Website are hereinafter together referred to as the "Platform") .
THIS POLICY DESCRIBES OUR POLICIES AND PROCEDURES FOR COLLECTION, USE, STORAGE, PROCESSING, DISCLOSURE AND PROTECTION OF ANY INFORMATION, INCLUDING, BUT NOT LIMITED TO, BUSINESS OR PERSONAL INFORMATION PROVIDED BY YOU AS A USER ("YOU/R" or "USER") WHILE USING THE PLATFORM. USER SHALL MEAN ANY PERSON/ PERSONS, WHO VISIT, USES, DEALS WITH AND/ OR TRANSACTS THROUGH THE APP OR AVAILS OUR SERVICES AND INCLUDES A BROWSER.
THIS POLICY CONSTITUTES A LEGAL AGREEMENT BETWEEN YOU, AS THE USER OF THE PLATFORM, AND creditlab, AS THE OWNER OF THE PLATFORM. YOU MUST BE A NATURAL PERSON WHO IS AT LEAST 20 YEARS OF AGE.
BY VISITING/ ACCESSING THE PLATFORM, THROUGH THE WEBSITE OR THE APP AND VOLUNTARILY PROVIDING US WITH INFORMATION (PERSONAL AND/ OR NON- PERSONAL) FOR THE PRODUCTS OR OTHERWISE, YOU ARE CONSENTING TO OUR USE OF IT IN ACCORDANCE WITH THIS POLICY. THIS POLICY DOES NOT APPLY TO THIRD-PARTY WEBSITES/ APPLICATIONS THAT ARE CONNECTED VIA LINKS TO THE PLATFORM. IF YOU DO NOT AGREE WITH THE TERMS AND CONDITIONS OF THIS POLICY, PLEASE DO NOT PROCEED FURTHER TO USE/ ACCESS THIS PLATFORM.
YOUR USE OF THE PLATFORM WILL BE GOVERNED BY THIS POLICY AS APPLICABLE TO THE PLATFORM TOGETHER WITH ALL POLICIES, NOTICES, GUIDELINES, DISCLAIMERS THAT ARE PUBLISHED AND SHARED WITH YOU FROM TIME TO TIME WHICH ARE INCORPORATED HEREIN BY WAY OF REFERENCE INCLUDING BUT NOT LIMITED TO OUR TERMS & CONDITIONS AND SUCH OTHER TERMS AS MAY BE APPLICABLE TO YOU IN YOUR CAPACITY AS A USER OF THE WEBSITE. THIS POLICY SHALL BE ENFORCEABLE AGAINST YOU IN THE SAME MANNER AS ANY OTHER WRITTEN AGREEMENT.
THIS POLICY IS A PART OF THE PLATFORM TERMS & CONDITIONS AND ALL CAPITALIZED TERMS UNDER THIS POLICY THAT HAVE NOT BEEN SPECIFICALLY DEFINED HEREIN SHALL HAVE THE MEANING AS ASCRIBED TO IT UNDER THE PLATFORM TERMS & CONDITIONS.
WE MAY UPDATE THIS POLICY FROM TIME TO TIME. YOU MUST PERIODICALLY REVIEW THE POLICY FOR THE LATEST INFORMATION ON OUR PRIVACY PRACTICES.
1. COLLECTION OF INFORMATION
We will only collect information that is necessary and needed for the specified, explicit and lawful purposes of rendering our services and will not further process it in a manner that is incompatible with those purposes. We may collect the following types of information:
Information you provide to us or upload on our Platform including your contact information (eg.: name, date of birth, gender, photo, postal or e-mail address, fax number, phone number, education, occupation, account details, identification documents, banking information such as salary slips, bank statements, PAN card, bank account number, payment information, or any other information/documents for KYC compliance). This information is a part of registration process and to communicate with you for the loan application process.
Information specific to you that may be assigned by us. We may collect and use information such as your account ID.
Location: We collect and monitor the information about the location of your device to check serviceability of your loan application, prevent fraudulent activity and also provide customised loan offers.
Storage: We require storage permission so that you can easily upload the right KYC related documents for quick submission of loan application. This will help us enhance your experience on our Platform.
Social Media: We collect your public profile data depending on the social media or networking platform used like Facebook/LinkedIn etc. to login to our Platform. The information collected from your social media networking account shall be clearly displayed to you at the time of login to our Platform.
Device information: We collect the unique device identifiers like serial numbers to uniquely identify the device to ensure that unauthorized devices are not able to act on your behalf and to mitigate fraud.
Credit information: We may collect information related to your social activities such as your credit related information (e.g.: credit score) from third parties (under lawful contracts).
Financial information: We may collect information related to your transactions on the Platform such as loan details, transaction history, repayment details.
Log information: We may collect information related to your use of certain functions. For example, cookies and other anonymous identifier technologies, IP addresses, network request information, temporary message history, standard system logs, and crash information.
This list is not exhaustive and, in specific instances we may need to collect additional data for the purposes set out in this Privacy Policy. However, one time access may be required for camera, location or any other facility necessary for the purpose of on-boarding/ KYC requirements.
We may collect other types of Personal Information in exceptional circumstances only. If we do need to process additional types of Personal Information about you, we will make sure that you are informed about the processing of your Personal Information and that there is a valid legal basis for doing so (e.g. your consent).
2. USE OF INFORMATION
You hereby provide explicit consent to Us for the use of Your information provided (including SPD & I) provided by You to Us (as specified above) and to share such information with third parties for the following purposes:
a) Monitor, improve and administer our creditlab Platform.
b) Manage our risks including the risk of fraud that may be committed against us or our partners;
c) Analyze how the creditlab Platform is used, diagnose service or technical problems and maintain security;
d) Send communications notifications, information regarding the products or services requested by You or process queries and applications that you have made on the Website, including marketing and promotion of our Services or our creditlab Platform by way of messages or emails or calls;
e) Manage our relationship with you and provide You with or inform you about other products or services we think you might find of some use;
f) Conduct data analysis in order to improve the Services provided to the User;
g) Use the User information in order to comply with country laws and regulations;
h) To conduct KYC for based on the information shared by the User for the provision of Services and availing the Product. This would include conducting the analysis of your bank statements and eKYC. creditlab, may directly or through third parties, conduct the KYC on its customers. In the event the KYC as detailed under this clause is being conducted by its third-party service providers, creditlab shares your relevant information with such third-party service providers for availing the said services;
i) Use the User information in other ways permitted by law.
j) Use the information obtained from Your Device to control risk, detect fraud, and provide better services to You.
k) We will use and retain Your information for such periods as necessary to comply with Our legal obligations, resolve disputes, and enforce Our agreements.
3. DISCLOSURE OF INFORMATION
You hereby provide explicit consent to the disclosure of your information (including SPD & I) by Us to third parties as per the terms of this Policy. You provide us explicit consent to share Your information with third parties only in such manner and for the purposes as described below:
a) We may disclose Your information to other financial service providers, banks or NBFCs and Our third-party partners and service providers for providing the Services and offering the Products as detailed under the Terms & Conditions;
b) We may share the details of the Product We may share Your information with our third-party partners and service providers in order to conduct data analysis for the purpose of improving the Services and analyzing Your use of the creditlab Platform, and to service you better;
c) We also disclose Your information to our third-party service providers for fraud detection, risk assessment and/or for sending promotional messages and email;
d) We contract with third-party advertising networks, publishers, and other entities to advertise Our Products and Services on creditlab Platform which are not affiliated with us and we shall share the information provided by You and the same shall not be used for any purpose other than to assist Us in Our advertising efforts.
e) We may disclose Your information, without prior notice, if We are under a duty to do so in order to comply with any legal obligation or an order from the government and/or a statutory authority, or in order to enforce or apply Our terms of use or assign such information in the course of corporate divestitures, mergers, or to protect the rights, property, or safety of Us, Our users, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction
f) We may share Your information with third parties under a confidentiality agreement for the provision of Services which inter alia restricts such third parties from further disclosing the information unless such disclosure is for the purpose as detailed under that confidentiality agreement. However, we are not responsible for any breach of security or for any actions of any third parties that receive Your personal information.
g) We will use and retain Your information for such periods as necessary to comply with Our legal obligations, resolve disputes, and enforce Our agreements.
4. STORAGE AND SECURITY OF INFORMATION
We store and process Your personal information, including the information received from Your Device on Google Cloud Servers and other secure cloud service providers. All information received by Us, either directly from You or through Your Device is protected and secured by Us. We adopt multiple safeguards to protect the security of the information and data provided by You, some of the safeguards We use are firewalls and data encryption using SSL, and information access authorization controls.
We use reasonable safeguards to preserve the integrity and security of Your information against loss, theft, unauthorized access, disclosure, reproduction, use or amendment. To achieve the same, we use reasonable security practices and procedures as mandated under applicable laws for the protection of Your information. Information You provide to Us may be stored on Our secure servers located within or outside India.
However, you understand and accept that there's no guarantee that data transmission over the Internet will be completely secure and that any information that You transmit to Us is at Your own risk. We assume no liability for any disclosure of information due to errors in transmission, unauthorized third-party access to our creditlab Platform and databases or other acts of third parties or acts or omissions beyond Our reasonable control and You shall not be entitled to hold creditlab responsible for any breach of security.
5. THIRD PARTY WEBSITES
With this Policy, We're only addressing the disclosure and use of data collected by Us. If You visit any websites through the links on the creditlab Platform, please ensure You go through the privacy policies of each of those websites. Their data collection practices and their policies might be different from this Policy and creditlab does not have control over any of their policies neither does it have any liability in this regard.
6. PHISHING
"Phishing" usually occurs when users of a website are induced by an individual/entity into divulging sensitive personal data by using fraudulent websites and/ or e-mail addresses. In the event You provide information to a website or respond to an e-mail which does not belong to Us or is not connected with Us in any manner, you will be a victim of Phishing. We do not send e-mails requesting a user for payment information, username or passwords. However, we may verify the username, password etc. provided by You from time to time.
7. SEVERABILITY AND EXCLUSION
We have taken every effort to ensure that this Policy adheres to the applicable laws. The invalidity or unenforceability of any part of this Policy shall not prejudice or affect the validity or enforceability of the remainder of this Policy. This Policy does not apply to any information other than the information collected by Us through the creditlab Platform. This Policy shall be inapplicable to any unsolicited information You provide Us through the creditlab Platform or through any other means. This includes, but is not limited to, information posted in any public areas of the creditlab Platform. All unsolicited information shall be deemed to be non-confidential and the Company shall be free to use and/ or disclose such unsolicited information without any limitations.
8. GOVERNING LAW AND DISPUTE RESOLUTION
This Policy shall be governed by and construed in accordance with the laws of the Republic of India. The courts at Products, India shall have exclusive jurisdiction in relation to any disputes arising out of or in connection with this Policy.
9. NO WAIVER
The rights and remedies of available under this Policy may be exercised as often as necessary and are cumulative and not exclusive of rights or remedies provided by law. It may be waived only in writing. Delay in exercising or non-exercise of any such right or remedy does not constitute a waiver of that right or remedy, or any other right or remedy.
10. CONTACT US
If You require any information or clarification regarding the use of Your personal information or this Privacy Policy, you can contact us Grievance@creditlab.in
If You have a grievance with respect to use of Your personal information, please write to Grievance@creditlab.in
creditlab is a company based in India. By browsing/using the Platform, you hereby acknowledge that the Company is not responsible or liable in any manner to comply with any local laws of Your territory except India.
This Agreement shall be construed and governed by the laws of India and shall have exclusive jurisdiction over such disputes without regard to principles of conflict of laws.