Privacy Policy
This Privacy Policy (“Policy”) of FatakPay Digital Private Limited (“FDPL”, “FatakPay”, “we”, or “us” or “our”) is aimed at informing the users, members, unregistered visitors, and any person(s) using or accessing the Platform (as defined below) (hereinafter collectively referred to as the “Users” or “You” or “Your” or “Yours”) of the practices in relation to the storage, use, processing, and disclosure of personal information and personal data that You have chosen to share with us, when You use or access our website hosted at www.fatakpay.com(“Website”) and/ or download and use our mobile application namely ‘FatakPay’ (“App”). The Website and the App shall hereinafter be collectively referred to as (the “Platform”).
FatakPay is a fintech company which is engaged in the business of facilitating provision of various products and services. Through the Platform, we facilitate provision of Credit Facility, insurance products, mutual fund portals, digital gold investments, Bharat Bill Payment Services (“BBPS”) and also offer services, such as job portal access, access to credit reports based on Your consent, and various reward programs, in association with our partners (collectively, “Services”). Our Services, inter alia includes provision of short-term credit facilities to borrowers (“Credit Facility”), by connecting them with various non-banking financial company (“NBFC”) partners and Scheduled and Commercial Banks, who are authorized by the Reserve Bank of India (“RBI”) to offer and sanction such Credit Facility (“Lending Partners”) on the Platform.
FatakPay, through this Policy, aims to demonstrate its commitment towards protecting Your personal data and respecting Your privacy in compliance with the Information Technology Act, 2000 and Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information), Rules, 2011 (“Rules”), RBI Guidelines on Digital Lending and any other guidelines that maybe issued by RBI from time to time (all of such guidelines, “ RBI Guidelines”).
This Policy is applicable to all the information collected, received, owned, controlled, stored, dealt with, shared with, accessed by, or handled by FatakPay in respect of a User. Please read this Policy along with the Terms and Conditions available at www.fatakpay.com.
1. USER ACKNOWLEDGEMENT AND CONSENT
1.1 User acknowledges that by accessing the Platform, User expressly consents and confirms to collection, maintenance, usage, handling, storage and disclosure of User information, including sensitive personal data, by FatakPay in connection with the Services we offer to You through the Platform, in accordance with this Policy.
1.2 Users acknowledge that they have the option to not provide or agree to the collection of personal data. If a User chooses to not grant us access to such personal data when requested, we will not be in a position to provide the User with the Services. In such an event, we encourage You to stop using the Services and accessing the Platform. In addition to this, in the event You do not consent to our access to Your personal data, we may have to terminate, suspend or limit Your access to the Services or Platform or part thereof, as may be the case.You have the option not to provide personal data. However, certain services may not be available without your consent.
2. PURPOSE OF COLLECTION OF INFORMATION
2.1 Our primary goal in accessing, collecting and using Your information, is to provide You with a safe, efficient, smooth and customized experience of our Services. More importantly, we only collect and process basic minimal personal information of the User that we consider necessary for providing the Services and enabling Your use of our Platform.
2.2 In general, you can browse the Website of FatakPay without disclosing Your identity or revealing any personal information about Yourself. However, to create an account on the Platform You will be required to provide us with certain basic minimal information in connection with the Services.
3. WHAT WE COLLECT AND HOW WE USE YOUR PERSONAL DATA
3.1 FatakPay collects the following types of data sets from You for facilitating provision of Credit Facility:
a) Identity and profile-related data: This includes Your first and last name, date of birth, gender, employment status/occupation, contact information (including addresses, email IDs and phone numbers) and other details as may be necessary as per the RBI Guidelines or as required by our Lending Partners and one-time camera access as per the RBI Guidelines. The foregoing details shall be used by the Platform for following reasons:
Your first name and last name: shall be used for identity verification, registering an account/onboarding on the Platform.
Date of birth: shall be used for age verification of the User at the time of onboarding/establishing an account-based relationship on the Platform. Minors who are under the age of 18 are restricted from accessing the Platform for availing the Services.
Gender: shall be used for identity verification purposes.
Occupation of a User shall be used to verify financial credibility before sanctioning of a Credit Facility.
Contact information: will be used for identity verification purposes or verify Your credit worthiness and/or establishing communication with the Users in relation to any Credit Facility availed by such User or any application made for availing a Credit Facility.
b) KYC data: This includes identification documents issued by the government or other authorities, and includes details of or pertaining to Your Aadhaar, PAN card etc. Such data shall be used for identity verification, address verification, prevention of fraudulent/illegal activities.
c) Financial data: This includes Your bank account details, and bank account statements, NACH mandates. FatakPay collects Your bank account details to facilitate disbursement of Credit Facility directly to Your account by the Lending Partners while Your bank statements enables the evaluations of Your income flow, expenses and financial stability which will be used to verify Your credit worthiness and check Your eligibility for the Credit Facilities offered on the Platform, FatakPay collects NACH mandates in order to facilitate automatic deduction of EMIs or repayments with respect to any Credit Facility availed by You from the Your account on scheduled dates.
3.2 FatakPay collects the following types of data sets from You for providing You access to Your credit reports:
a) Your name
b) Date of birth
c) Full address
d) Mobile number
e)PAN details
3.3 FatakPay collects the following types of data sets from You for providing You access to insurance products, BBPS and digital gold investments, mutual funds investments, insurance products, facilitating reward programs and job portals:
a) Your name
b) Pincode
c) Mobile number
3.4 Other information that we may require or have access to provide You Services:
a) Transaction data: This includes details of transactions that may occur through the Platform or in connection with the Services. For example, transaction data may include the Services You have sought or availed through the Platform or confirmations of such Services.
b) Data from SMSs: With Your permission, we may collect, transmit and store transactional SMS data from Your phone on our secured server to verify and analyse Your financial position, to determine Your cash flow, credits, income, and spending pattern. We do not collect, read or store any personal SMSs, account details, OTP etc.
c) 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 server. This data is collected for the purpose of data analytics.
d) App data: We may collect, transmit, and store the installed application's information on our secured server. We only use the package name of each installed application to assess the creditworthiness and to provide customized loan offers.
e) Marketing and communications data: This includes Your preferences in receiving marketing messages from us and our third parties and Your communication preferences.
3.5 Personal Data Collected from Third Parties
This type of data is personal data about You received from various third parties and public sources including our third-party service providers for advertising and User analytics purposes, and other publicly available sources in connection with our provision of Services to You, or in connection with Your use of the Platform or Services that You choose to avail. 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 any third-party misuse of such data.
4. USE OF PERSONAL DATA
By using our Platform and submitting Your personal data to FatakPay, You expressly acknowledge and consent to use of such information in a manner specified under this Policy. Such personal data can be used for various purposes including:
4.1 To register You as a user of the Platform and verifying User identity;
4.2 Facilitating User’s usage of Platform and our Services. Please note that certain data sets may only be used/collected if the User intends to use the Service for a specific product on the Platform as indicated above. In the event that the User wishes to avail any Services such as, insurance products and mutual funds, certain data sets shall be shared with third parties solely for the purpose of providing You such Services;
4.3 To manage our relationship with You, including notifying You of changes to any Services;
4.4 For extension of Credit Facility and other Services to the User from regulated entities including but not limited to Banks, NBFC and other financial partners, etc;
4.5 To ensure compliance with all legal obligations of Lending Partners, vis-à-vis Know-your Customer, Prevention of Money Laundering, CKYRC requirements, etc for the purposes of facilitation of the Services;
4.6 For fraud prevention and detection;
4.7 To send User surveys and marketing communications that FatakPay believes may be of User’s interest;
4.8 To facilitate for repayment of the Credit Facility availed or recovery of outstanding payments on behalf of the NBFC Partner;
4.9 To diagnose technical problems, provide support and help Users in addressing troubleshoot problems;
4.10 To send and receive communications, show advertisements, notifications and make promotional offers;
4.11 To prepare reports, review and filing as per applicable laws;
4.12 To contact Users regarding Lending Partners and the various Services being facilitated through FatakPay, third party services and offers;
4.13 To understand User preferences requirements;
4.14 To permit User to participate in interactive features offered through the Platform;
4.15 To improve the content, our business and delivery models and protect the integrity of the Platform;
4.16 To increase/improve the Services offered on the Platform;
4.17 To ensure compliance with all applicable laws;
4.18 To respond to court orders, establish or exercise our legal rights, or defend ourselves against legal claims;
4.19 To perform our obligations that arise out of the arrangement we are about to enter or have entered with You; and
4.20 To enforce our Terms and Conditions available at [www.fatakpay.com.
5. HOW YOUR PERSONAL DATA IS SHARED
5.1 Except as required under applicable laws or pursuant to a court/government order or for purposes set forth in clause 5.2 below, any information or data shared by us with third parties shall be undertaken after obtaining Your explicit consent, solely to render the Services to You. Except as required under applicable laws or pursuant to a court/government order or for purposes set forth in clause 5.2 below, any information or data shared by us with third parties shall be undertaken after obtaining Your explicit consent, solely to render the Services to You.
5.2 We will share Your information with third parties to facilitate provisioning of Services by us to You only in such manner as described below:
a) We may disclose Your information to our Lending Partners on the Platform to facilitate provision of Credit Facility for You;
b) We may disclose Your information to our third-party service providers for providing the Services, such as mutual funds and insurance products, as detailed under the Terms & Conditions or for recovery of outstanding Credit Facility sanctioned to You by the Lending Partners;
c) We may 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;
d) We may disclose Your information, without prior notice, if required under any law or 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 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.
e) We may share Your data with our affiliates and/or group companies for data processing and analysis;
f)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.
5.3 If You fail to provide consent for sharing of such data when requested by us, we may not be able to provide the Services to You.
5.4 Third parties with whom we may share Your data for providing services are available on the vendor-list.
6. COOKIES
6.1 FatakPay may use "cookies" as required on the Website. “Cookies" is a term generally used for small text files a web site uses to recognize repeat users, facilitate the User's ongoing access to and use of the site, allow a site to track usage behaviour and compile aggregate data that will allow content improvements and targeted advertising, preferences etc. Cookies themselves do not personally identify the User, but it identifies User devices. For the purpose of this Policy, Users are informed that cookies also exist within mobile applications when a browser is needed to view certain content or display an advertisement within the application. Generally, cookies work by assigning a unique number to the computer that has no meaning outside the assigning site.
6.2 Users are being made aware that FatakPay cannot control the use of cookies or the resulting information by advertisers or third parties hosting data on FatakPay’s Platform. If Users do not want information collected through the use of cookies, they may change the settings in the browsers that allows them to deny or accept the cookie feature as per User discretion and in the manner agreed by them.
6. WEB BEACONS
The web pages of the Website contain electronic images known as “web beacons”, sometimes called single-pixel gifs and are used along with cookies to compile aggregated statistics to analyse how the Website is used. Web beacons may also be used in some of FatakPay’s emails so as to know which emails and links recipients have opened, allowing it to gauge the effectiveness of its customer communications and marketing campaigns.
8. DATA PROTECTION AND SECURITY
8.1 Pursuant to Information and Technology Act, 2000, Rules and RBI Guidelines, FatakPay endeavors to protect sensitive personal and personal data of the Users.
8.2 We store and process Your personal information on cloud servers located in India. Some of the safeguards we use are firewalls and bit data encryption using (Secure Sockets Layer) 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.
9. YOUR LEGAL RIGHTS
9.1 Data Storage and Revocation of Consent:
a) We will store Your information and/or data for such period as may be required by FatakPay/Lending Partners to (i) enforce or enable NBFC Partner to enforce its legal rights and obligations against You; (ii) to ensure compliance with its obligations and responsibilities or the NBFC Partner’s obligations and responsibilities under applicable laws, as specified by the RBI.
b) You may, however, withdraw Your consent at any time. Such a request shall be complied with by Us subject to the applicable laws and the terms of the Credit Facility availed through the Platform. You further understand and agree that neither the repayment of a Credit Facility, nor the deletion of Your account with the Platform, automatically rescinds the consents You have provided to us under the Policy.
c) You may request Your data deletion by writing to us at [email protected].
9.2 Data Retention
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 as required for defending future legal claims against us or our financial partners. All the other details will be deleted upon Your request for the deletion of the data, provided there is no active Credit Facility or Service being availed by You.
9.3 Data destruction protocol
You can request the erasure of Your personal data. This enables you to ask us to forget personal data. We shall comply with any request, subject to applicable laws, retention of any data required to defend us in a future legal action, and the terms of the Credit Facility that are sanctioned through the Platform.
10. UPDATE USER INFORMATION
Users are required to update their information available with FatakPay as and when there are any changes. Users are also entitled to review the information provided and ensure that any personal information or sensitive personal data or information found to be inaccurate or deficient be corrected or amended as feasible. Such corrections/updations may be done by the User’s account on the Platform.
11. 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.
12. THIRD-PARTY WEBLINKS
User acknowledges that the Platform may contain links to other websites. If a User clicks on a third- party link, the User will be directed to that website. Note that these external sites are not operated byFatakPay. Therefore, it is strongly advised that Users review the privacy policy of these websites/external links. FatakPay has no control over and assumes no responsibility for the content, privacy policies, or practices of any third-party sites or services.
13. CHANGES TO PRIVACY POLICY
In the event that FatakPay modifies this Policy, the same will be updated on the Platform. In case of any material changes to the Policy, the Users will be notified by means of a notice on Platform prior to the change becoming effective. The Users are encouraged to periodically review this page for the latest information on FatakPay’s privacy practices.
14. GRIEVANCE REDRESSAL OFFICER
FatakPay has designated a Grievance Officer. Users can contact the Grievance Redressal Officer (GRO) with respect to any complaints or concerns regarding the handling, storage, or disclosure of User Information.
All queries, disputes, issues and questions regarding the Policy can be addressed at the following:
Grievance Redressal Officer Name: Ms. Adv. Varsha Manoharan
Email address:[email protected]
Contact number:+91-9076096209
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15. COMPLAINTS TO THE NBFC PARTNER
If the grievance is not resolved by the GRO within ten days of lodging the grievance, or if the User who has availed the Credit Facility or other Services from the NBFC Partner is not satisfied with the response received from FatakPay, such User may approach the NBFC Partner to have such grievance resolved. The grievance redressal mechanism of the NBFC Partner is accessible at https://www.fatakpay.com/redressal