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Privacy Policy

 

Privacy Policy

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.

This policy makes description of our policies and procedures for the collection, use, processing, disclosure and protection of any information by you as a user(“You” “Your” or “User”) while using this mobile application platform and / or any mobile or internet connected device or otherwise (“App”) (collectively, the “Platform”) which is owned and operated by Easy Loan(hereinafter referred to as “we”, “us”, “Platform” or “our”) you hereby agree to comply to terms and conditions of this Privacy Policy.

While accessing the platform or any part thereof only, you expressly agree with our use and disclosure of your personal information in accordance with this privacy policy. This privacy policy has been incorporated into and governed by the terms and conditions of the platform.

Please do not use or access our Platform or any part thereof,if you do not agree to this Privacy Policy or any part hereof.

1. Collection of Personally Identifiable Information

1.1. We collect and store your information provided by you from time to time while you visit our platform, whether from our platform. The primary goal of us doing so is to provide you the safety, efficiency, smooth and customized experience and services which makes us to provide facilities and features that meets your needs, and also we customize our Platform to make your experience safer and easier and to improve the facilities provided by us. What’s more, we collect personal information from you that we consider necessary in order to achieve the aforementioned purpose.

1.2. In general, you can browse the Platform without telling us who you are or revealing any personal information about yours. In addition, to create an account on the Platform, you must provide us with certain basic information required to provide customized services. The information that we collect from you may also be used in order to check your credit rating with third parties for assessing your credit worthiness and eligibility to avail of the facilities and services that are offered by the Platform. The information we collect from you, inter alia, shall include: (i) your full name, (ii) email, (iii) mailing address, (iv) postal code, (v) family details, (vi)phone number, (vii)university / college details, (viii) permanent account number (PAN), (ix) academic records and certificates, (x) related details of your income or filings thereof, and (xi) details of your occupation or vocation.

1.3. What’s more, there are mandatory and the optional fields. You always have choices of whether to provide your personal information by using specific services or functions on the platform. If you choose to not provide certain information sought by us, we may not be able to extend any of the facilities, functions or services you apply for, and you agree and understand that our inability to be of service to you shall not constitute a deficiency of service, or give rise to any legal liability on our part.

1.4. We also collect other identifiable information (your payment card details and transaction histories on the Platform) from you when you set up a free account on our platform. While you can browse some sections of our Platform without being a registered member as mentioned above, certain activities (such as availing of loans from the third-party lenders on the Platform) requires registration and for you to provide the above details. The Platform shall clearly display the categories of personal information that it requires from you, and you have the option to not provide such personal information. However, this will limit the services, facilities and features provided to you on the Platform.

2. Collection of Other Non-Personal Information

2.1. We also may track certain information of yours and/or the features, facilities or service that you avail from us, based on your behavior on our Platform.This information are used to do internal research on our users' demographics, interests, and behavior for better understanding, protecting and serving our users and to improve our services. This information is compiled and analyzed on an aggregated basis. We also collect your Internet Protocol (IP) address and the URL used by you to connect your computer to the internet, etc. This information may include the URL that you just came from (whether this URL is on our Platform or not), which URL you next go to (whether this URL is on our Platform or not), your computer browser information, and your IP address.

2.2. Cookies are small data files that a Platform stores on your computer. We will use cookies on our Platform similar to other lending websites / apps and online marketplace websites / apps. Use of this information helps us identify you in order to make our Platform more user friendly. Most browsers will permit you to decline cookies but if you choose to do this it might affect service on some parts of Our Platform.

2.3. We retain this information as necessary to resolve disputes, and to provide support and troubleshoot problems to our users as permitted by law.

2.4. If any personal correspondences sent by you, such as emails or letters, or sent by other users or third parties about your activities or postings on the Platform, we will collect such information into a file specific to you.

3. Collection of Device Information

3.1. We collect and use your information depending on how you manage your privacy controls on your device.

3.2. By accessing the Platform or installing the application, we’ll store the information and collect with unique identifiers tied to the device you are using.

3.3. We collect information from the device when you download and install the App and explicitly seek permissions from You to get the required information from the device.

3.4. The information we collect from your device includes the unique ID.

3.5. We collect information about your device to provide automatic updates and additional security so that your account is not used in someone else’s devices. In addition, the information provides us valuable feedback on your identity as a device holder as well as your device behavior, thereby allowing us to improve our services and provide an enhanced customized user experience to you.

3.6. We offer loans / credit to our users by reviewing other network data. In order to evaluate each user and give them a credit limit and credit report, we need to get additional permissions from our users, such as access to contacts, storage, SMS, Bluetooth and camera. This helps us analyze individual's profile. All of these details will be stored on our highly secure servers and will not be shared under any circumstances with anyone who is not relevant.

3.7. The key information collected from the device is further detailed below. Note that depending on your version of App, some or all of these may be applicable.

3.8. Contacts

3.8.1. We require references from the loan applicant, as a part of our loan experience. Therefore, when filling out the form on our platform, we will collect your contact information to detect your close contacts, so that you can automatically fill in the data during the loan application process.

3.8.2. We also collect contact information from your device to analysis risks by enabling us to detect credible references. The more credible the references are, the lower is the risk associated to a User.

3.9. Storage

3.9.1. We require the storage information permission to enable the Platform to enable you to upload photos and/or documents to complete the application form during your loan application journey.

3.9.2. At the same time we need to upload album information to conduct risk analysis, the more credible the information tested from the album, the lower risk related to users will be.

3.10. Camera

3.10.1. We need your camera information permission for you to easily/smoothly use the camera during the loan application process and click on the photos of your KYC file and other necessary documents and upload them to the platform.

3.11 SMS

3.11.1 We collect and upload your list, content and time of SMS for helping us to understand your income and spending patterns and generate a credit report in our system to determine your credit limit.

3.12. Bluetooth

3.12.1 Your Bluetooth information is needed for analyzing risk and testing the related information are matched and identify user reliability.

4. Use and Disclosure of your Personal and Other Information

4.1. We use personal information to provide the services you request, to customize your user experience and to improve our services. To the extent we intend to use your personal information to market any product to you, we will provide you the ability to opt-out of such uses.

4.2. We use your personal information to: (i) resolve disputes, (ii) troubleshoot problems, (iii) help promote a safe service, (iv) analytical analysis, (v) measure consumer interest and satisfaction in our products and services, (vi) inform you about online and offline offers, products, services, and updates, (vii) customize your experience, (viii) detect and protect us against suspicious or illegal activity, fraud and other criminal activity, (ix) enforce our terms and conditions, (x) improvement of our services and as otherwise described to you at the time of collection, (xi) check your creditworthiness.

4.3. We exert to continually improve our service offerings, we collect and analyze demographic and profile data about our users' activity on our Platform.

5. Use of your Device Information

5.1. We use the information provided by you as follows: (i) to establish identity and verify the same, (ii) monitor, improve and administer our Platform, (iii) provide our service i.e. perform credit profiling for the purpose of facilitating loans to You, (iv)analyze how the Platform is used, diagnose service or technical problems and maintain security, (v)manage our relationship with You and inform You about other products or services we think you might find of some use, (vi) design and offer customized services offered by our affiliated or third-party financial partners, (vii) send communications notifications, information about the service you requested, or processing queries and applications you raised on the platform,(viii)use the User information in order to comply with country laws and regulations,(ix)conduct data analysis in order to improve the Services provided to the User,(x) to conduct KYC for our third-party lending partners based on the information shared by the User, (xi) use the User information in other ways permitted by law to enable You to take financial services from our lending partners.

5.2. We will use and retain Your information for such periods as necessary to provide You the Services on our Platform, to comply with our legal obligations, to resolve disputes, and enforce our agreements.

6. Disclosure to Third Parties:

6.1. We will share your information with third parties, including our regulated financial partners for provision of services on the Platform and/or for facilitation of a loan / facility to You. We will share Your information with third-parties only in following manners : (i) we disclose and share Your information with the financial service providers, banks or NBFCs and Our third-party partners and for facilitation of a loan or facility or line of credit or purchase of a product, (ii) we share Your information with our third-party partners in order to conduct data analysis in order to serve you better and provide services on our Platform, (iii) we may, without prior notice, disclose Your information, if we are under the responsibility to do so 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 and conditions 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, (iv) we and our affiliates may share your information with another business entity should we (or our assets) merge with, or be acquired by that business entity, or re-organization, amalgamation, restructuring of business for continuity of business, (v) we will disclose the information to our third-party technology and credit partners to perform credit checks and credit analysis like Credit Bureaus or third-party data source providers, (vi) we will disclose the data / information provided by a User with other technology partners to track how the User interact with Platform on our behalf,Should such a transaction occur than any business entity (or the new combined entity) receiving any such information from us shall be bound by this Privacy Policy with respect to your information, (vii) We will disclose your Information in accordance with non-disclosure agreements with third parties and limit their use of your Information only for the above purposes.

6.2. In case we use or disclose Your information for any purpose not specified above, we will take your explicit consent.

7. Your Privacy Controls

7.1. You have certain options over the information we collect and how it is used: (i) device-level settings: Your device may have controls that determine what information we collect, (ii) delete your entire App account, (iii) you can also request to remove content from our servers based on applicable law or by writing to our Grievance Officer.

8. Security Precautions

8.1. The Platform is built with strict security features that continuously protect your information.

8.2. Our platform may take stringent and appropriate security measures for protecting the loss, misuse and alteration of information under control. We safeguard and ensure the security of the information provided by you. We use Secure Sockets Layers (SSL) based encryption, for the transmission of the information, which is currently the required level of encryption in India as per the law.

8.3. We endeavour to protect from unauthorized access, alteration, disclosure or destruction of information we hold, including: (i) we exert encryption to keep your data safe while in transit, (ii) we offer security feature like an OTP verification for you to protect your account, (iii) we review our information collection, storage, and processing practices, including physical security measures, to prevent unauthorized access to our systems, (iv) we restrict access to personal information to our employees, contractors, and agents who need that information in order to process it. Anyone with this access is subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations, (v) compliance & cooperation with regulations and applicable laws, (vi) we regularly review this Privacy Policy and make sure that we process your information in ways that comply with it, (vii) data transfers.

8.4. We maintain your information on servers located in India. Data protection laws vary among countries, with some providing more protection than others. We also comply with certain legal frameworks relating to the transfer of data as mentioned and required under the Information Technology Act, 2000.

8.5. If we receive formal written complaints, we shall respond by contacting the person who made the complaint. We work with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of your data that we cannot resolve with you directly.

8.6. We will enquire with one or more Credit Bureaus on one or more Non-Banking Financial Company’s (NBFC) behalf to provide you with your loan amount.

9. Choice / Opt-Out

9.1. We provide all users with the right to opt-out of receiving non-essential (promotional, marketing-related) communications from us on behalf of our partners, and from us in general, after setting up an account.

9.2. If you want to remove your contact information from the Platform lists and newsletters, please visit unsubscribe.

10. Links to Other Sites

10.1. Our Platform links to other websites that may collect personally identifiable information about you. We have responsibility for the privacy practices or the content of those linked websites. With this Privacy Policy we are only addressing the disclosure and use of data collected by Us. If You visit any websites through the links on the Platform, please ensure You view the privacy policies of each of those websites. Their data collection practices and their policies might be different from this Privacy Policy and We do not have control over any of their policies neither do we have any liability in this regard.

11. Advertisements on the Platform

11.1. While visiting our platform, we serve advertisements by using the third party advertising company. These companies may use information (not including your name, address, email address, or telephone number) about your visits to our Platform and other websites/ app in order to provide advertisements about goods and services of interest to you.

12. Your Consent

12.1. Using the Platform and/ or providing your information to us, you agree to us collecting and using the information you disclose on the Platform in accordance with this Privacy Policy, which includes but not limited to your agreement for collecting, using, sharing and disclosing your information as per this Privacy Policy.

12.2. If we make changes to our Privacy Policy, we will post those changes on this page so that you are always aware of what information we collect, how we use it, and under what circumstances we disclose it.

13. LINK TO THIRD-PARTY SDK

Our application has a link to a registered third party SDK that collects data on our behalf and data is stored to a secured server to perform a credit risk assessment. We ensure that our third party service provider takes extensive security measures to protect your personal information against loss, misuse or alteration of the data.

Our third-party service provider employs separation of environments and segregation of duties and have strict role-based access control on a documented, authorized, need-to-use basis. The stored data is protected and stored by application-level encryption. They enforce key management services to limit access to data.

Furthermore, our registered third party service provider provides hosting security – they use industry-leading anti-virus, anti-malware, intrusion prevention systems, intrusion detection systems, file integrity monitoring, and application control solutions.

14. CHANGES IN THIS PRIVACY POLICY

Easy Loan owns the right to change, modify, add, or remove portions of this Privacy Policy at any time for any reason. In the even of any changes are made in the Privacy Policy, we shall update the same on the Website. Once posted, those changes are effective immediately, unless stated otherwise. We encourage you to periodically review this page for the latest information on our privacy practices. Continued access or use of the Services constitute Your acceptance of the changes and the amended Privacy Policy.

15. Grievance Officer

15.1. According to the Information Technology Act 2000 and rules made there under, the name and contact details of the Grievance Officer are provided below:

Telephone No : 01141171710

16. Governing law and Jurisdiction

16.1. This Privacy Policy is governed by and construed according to the laws of India. Any dispute arising out of or in connection with the use of the Platform or this Privacy Policy shall be subject to the exclusive jurisdiction of the courts in India.

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