Faircash
PRIVACY POLICY
1. INTRODUCTION
1.1. This Privacy Policy ("Policy") outlines KUMBHAT FINANCIAL SERVICES LIMITED's ("FairCash", "we", or "us") practices in relation to the storage, use, processing, and disclosure of personal data that you have chosen to share with us when you download and use our mobile application "FairCash: Personal Loan App" or use the services made available on https://www.faircash.store/ (the app is referred to as the "App" and the App and the website are collectively referred to as the "Platform").
1.2. The services we offer you on or through the Platform are referred to as "Services". Please note that unless specifically defined in this Policy, capitalised terms shall have the same meaning ascribed to them in our Terms and Conditions, available at https://www.faircash.store/termsOfService ("Terms"). Please read this Policy in consonance with the Terms.
1.3. At FairCash, we are committed to protecting your personal data and respecting your privacy. Please read the following terms of the Policy carefully to understand our practices regarding your personal data and how we will treat it. This Policy sets out the basis on which any personal data we collect from you, we collect about you, or that you provide to us, will be processed by us.
1.4. By providing us with the consent to process your personal data, you acknowledge that we will collect, store, use, and disclose your personal data in accordance with this Policy.
2. THE DATA WE COLLECT ABOUT YOU
2.1. We collect, transmit, and store personal data about you on our secured FairCash server (https://www.faircash.store) after obtaining your consent, to provide you with, or in connection with, the Services. Please note that we only collect and process a minimal amount of your personal data to provide you with the Services. Such personal data includes:
1. Mobile phone number:We will collect your mobile phone number and device name for the credit risk assessment of the loan to verify your eligibility for the loan, speed up the loan application process, and send you a message to notify you to pay the loan if your bill is overdue.We collect, transmit and store mobile phone number data from your phone on our secured FairCash server (https://www.faircash.store) and these data guaranteed to be used only by our application and will not be disclosed to third parties
2. Data from SMSs: With your permission, we collect, transmit and store SMS data from your phone on our secured FairCash server (https://www.faircash.store) to verify and analyse your financial position, to determine your cash flow, credits, income, and spending pattern. These SMSs data guaranteed to be used only by our application and will not be disclosed to third parties
3. Geolocation Data: We will collect approximate location information from your device to find and verify your real location information in order to keep your account secure and better assess your risk level.Your location information will be encrypted, transmitted, stored, and processed on our server (https://www.faircash.store) to ensure that it is only used by our application and will not be disclosed to third parties.
4. Identity and profile-related data: This includes your first and last name, gender, employment status, company name and marital status.
5. KYC data: This includes identification documents issued by the government or other authorities, and includes details of or pertaining to your Aadhaar and PAN card.
6. Camera: We will collect camera permissions from your device to take identification photos and selfies to verify your identity and ensure that you are using the FairCash service for faster processing of your loan application.
7. Calendar Data: We will request access to your calendar in order to schedule the respective payment date and reminders. This way, we manage our credit risk and avoid overdue payments.
8. Device data: This includes your IP addresses, browser types and versions, time zone settings, operating systems, and device information. We collect, transmit, and store such data on our secured FairCash server (https://www.faircash.store).These device data guaranteed to be used only by our application and will not be disclosed to third parties.
2.2. We do not access your mobile phone resources such as contact list, call logs, telephony functions, and files & media (except as disclosed above in order to enable you to upload documents). We do not collect your biometric data.
2.3. We are required to collect your personal data to provide you with access to the Platform and Services. In certain cases, we are required to collect personal data as required by law, or under the Terms. If you fail to provide us that data as and when requested by us, we will not be able to perform our obligations under the arrangement we have with you or are trying to enter into with you (for example, to provide you with features of the Services). In this case, we may have to cancel or limit your access to the Services (or part thereof).
3. HOW WE COLLECT DATA ABOUT YOU
3.1. We use different methods to collect and process personal data about you. This includes:
1. Information you provide us: This is the information (including identity, contact, KYC, financial, and device data) you consent to give us when you use our Services or when you correspond with us (for example, by email or chat, or through the Platform). It includes information you provide when you register to use the Services, use a Platform feature, share data through the Platform, or when you report a problem with the Platform and our Services. If you contact us, we will keep a record of the information shared during the correspondence.
2. Information we collect about you and your device: Each time you visit the Platform or use the Services, we will automatically collect personal data through the use of tools like cookies.
3. Information we receive from other sources including third parties and publicly available sources: We will receive personal data about you from various third parties and public sources including our third parties, Google analytics for advertising and user analytics purposes, and other publicly available sources.
3.2. Please note that we do not have any control over personal data that you may choose to make publicly available. For example, if you post reviews, comments, or messages on public sections of the Platform or on an application store (such as the Play Store), you do so at your own risk. We are not liable for third-party misuse of such data.
4. HOW WE USE YOUR PERSONAL DATA AND FOR WHAT PURPOSES
4.1. We will only use your personal data in accordance with the applicable law. Most commonly, we will use your personal data to provide you with the Services, or where we need to comply with a legal obligation.
4.2. You agree and acknowledge that by using our Services and creating an account on the Platform, you authorise us, our associate partners, and affiliates to contact you via email, phone, or otherwise. This is to ensure that you are aware of all the features of the Services.
4.3. In general, we use your personal data for the following purposes and activities undertaken without direct human supervision or control:
· To register you as a user of the Platform;
· To provide you with the Services;
· To facilitate your application to avail loan and otherwise in connection with your obtaining of credit facilities from regulated entities including our lending partners
· To manage our relationship with you, including notifying you of changes to any Services;
· To administer and protect our business and the Platform, including troubleshooting, data analysis, system testing, and performing internal operations;
· To deliver content to you;
· To send you communication, including through WhatsApp business messages, in relation to your use of the Platform or Services;
· To monitor trends so we can improve the Platform and Services;
· To improve our business and delivery models;
· To perform our obligations that arise out of the arrangement we are about to enter or have entered with you;
· To enforce our Terms;
· To undertake marketing services, including sending you promotional messages;
· To respond to court orders, establish or exercise our legal rights, or defend ourselves against legal claims;
· In compliance with the Reserve Bank of India's norms, to contact you or locate you in case of any default; and
· To ensure compliance with applicable laws.
5. HOW WE SHARE YOUR PERSONAL DATA
5.1. You agree and acknowledge that any and all information pertaining to you, whether or not you directly provide it to us (via the Services or otherwise), including but not limited to personal correspondence such as emails, instructions from you, etc., may be collected, compiled, and shared by us with third parties after obtaining your explicit consent, solely in order to render the Services to you (that is, in connection with loan applications and your loan journey). This may include but not be limited to Lenders (as defined in the Terms), storage providers, data analytics providers, consultants, lawyers, and auditors. We may also share this information with other entities in the FairCash group in connection with the above mentioned purposes. If you fail to provide consent for sharing of such data when requested by us, we may not be able to perform our obligations under the arrangement we have with you or are trying to enter into with you. In this case, we may not be able to provide the Services to you.
5.2. You agree and acknowledge that by using our Services and creating an account on the Platform, you authorise us, our associate partners, and affiliates to contact you via email, phone, or otherwise. This is to ensure that you are aware of all the features of the Services.
5.3. You agree and acknowledge that we may share data where we are required by law, any court, a government agency, or authority to disclose such information. Such disclosures are made in good faith and belief that it is reasonably necessary to do so for enforcing this Policy or the Terms, or in order to comply with any applicable laws and regulations.
6. ACCESS AND UPDATING YOUR PERSONAL DATA
You hereby warrant that all personal data that you provide us with is accurate, up-to-date, and true. When you use our Services, we make best efforts to provide you with the ability to review and correct inaccurate or deficient data, subject to any legal requirements. We shall verify the accuracy of the new personal data you provided to us.
7. DATA SECURITY
We implement appropriate security measures and access controls to protect your personal data from unauthorised access, and follow technology standards prescribed by applicable law, including the Information Technology Act, 2000, Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, the RBI and directions issued by the Indian Computer Emergency Response Team.
8. DATA RETENTION AND DESTRUCTION
For information about our retention and destruction practices, please refer to the Schedule to this Policy.
9. YOUR LEGAL RIGHTS
9.1. Under certain circumstances, you have the right to:
1. Request the erasure of your personal data: This enables you to ask us to delete or remove personal data. We shall comply with any request, subject to applicable laws and the terms of the loans that are sanctioned through the Platform.
2. Right to deny consent: This enables you to deny us the consent necessary to process your personal data. If you exercise this right, it may impact or restrict our ability to provide Services to you.
3. Right to revoke consent:: This enables you to withdraw consent at any time. We shall comply with any request, subject to applicable laws and the terms of the loans that are sanctioned through the Platform.
9.2. We will facilitate your request to exercise such rights subject to the provisions of applicable laws relating to the processing and storage of data. If you wish to exercise any of the rights set out above, please write an email to the Grievance Officer, whose details are mentioned in Section 15 of this Policy, providing in as much detail as possible, the right(s) you wish to exercise. Please also include a description of the personal data you believe we hold or process about you, so that we may be able to locate such personal data. In the event that we need additional information from you, our Grievance Officer will contact you further.
9.3. We will be able to reply to your request(s) within 30 (Thirty) days of raising the request. In the event that we are not able to respond to or acknowledge your request within 30 (Thirty) days of receipt due to any reason, we will inform you.
10. TRANSFER OF PERSONAL DATA
Please note that all your data, including financial data, is only stored on systems located in India. We shall not transfer your personal data to any third country.
11. LINKS TO THIRD PARTY WEBSITES
Our Services may, from time to time, contain services provided by or links to and from the websites of our partner networks, service providers, financial institutions, advertisers, and affiliates ("Third Party Services"). Please note that the Third Party Services that may be accessible through our Services are governed by their own privacy policies. We do not accept any responsibility or liability for the policies or for any personal data that may be collected through such Third Party Services. Please check their policies before you submit any personal data to such websites or use their services.
12. COOKIES
12.1. Cookies are small data files that are stored on your device. We use cookies and other tracking technologies to distinguish you from other users of the Services and to remember your preferences. This helps us provide you with a good experience when you use our Services and also allows us to improve the Services.
12.2. We identify you by way of using cookies. The cookies shall not provide access to data in your device such as email addresses or any other data that can be traced to you personally. The data collected by way of cookies will allow us to administer the Services and provide you with a tailored and user-friendly service. The cookies shall enable you to access certain features of the Services. Most devices can be set to notify you when you receive a cookie or prevent cookies from being sent. If you prevent cookies from being sent, it may limit the functionality that we can provide when you visit the Platform or try to access some of the Services.
12.3. Additionally, you may encounter cookies or other similar technologies on certain pages of the Platform that are placed by third parties. We do not control the use of cookies by such third parties.
13. BUSINESS TRANSITIONS
You agree and acknowledge that in the event we go through a business transition, such as a merger, acquisition by another organization, or sale of all or a portion of our assets, your personal data might be among the assets transferred.
14. CHANGE IN PRIVACY POLICY
14.1. We keep our Policy under regular review and may amend it from time to time, at our sole discretion.
14.2. The terms of this Policy may change and if it does, these changes will be posted on this page and, where appropriate, notified to you by email or phone number through SMS.
15. GRIEVANCE OFFICER
You may contact our Grievance Officer with any enquiry relating to this Policy or your personal data.
Address: 5th Floor, Kumbhat Complex No. 29, Rattan Bazaar, Chennai Tamil Nadu 600003
Email Address: contact@faircash.store
SCHEDULE
DATA RETENTION AND DESTRUCTION POLICY
1. OVERVIEW
This Data Retention and Destruction Policy describes FairCash's policy on data retention and destruction.
2. HOW LONG DO WE STORE YOUR DATA
You agree and acknowledge that your personal data will continue to be stored and retained by us as required or permitted by applicable laws or regulatory requirements, or as required for defending future legal claims. The details relating to KYC, device location and SMS data will be deleted or render the data into anonymised data, so that it no longer constitutes personal data, within three months from the application date. All the other details will be deleted or render the data into anonymised data upon the request of the customer for the deletion of the data, provided there is no active loan or service being availed by you. However, in some instances, we will be unable to facilitate requests for the deletion of your data in compliance with legal obligations, or in accordance with applicable laws, which may require us to store data for longer periods of time.
3. OUR DATA DESTRUCTION PROTOCOLS
Upon completion of the retention period for each category of personal data as described above, we shall delete or destroy, to the extent technically possible, personal data in our possession or control, or render the personal data into anonymised data, so that it no longer constitutes personal data.