‘FatakPay®’ is a trademark applied for registration by FATAKPAY DIGITAL PRIVATE LIMITED, a company incorporated under the provisions of the Companies Act, 2013, having its registered office at FatakPay Digital Private Ltd, Technopolis Knowledge Park, Office No 1, Ground Floor, Mahakali Caves Road, Andheri (East), Mumbai, Maharashtra 400093. We are engaged in the business of providing digital creditworthy borrowers with short-term credit by connecting them with our NBFC partners and carrying out other incidental activities including collection on behalf of our NBFC partners.
Fatakpay (“our”, “us”, “we”, “Company”), various partner banks and financial institutions, as identified hereinbelow (“Lending Partner”) provide lending services, process your loan requests, and ultimately provide a loan to you (“Services”).
You may reach out to the grievance officer, Sanjay Singh at: [email protected] (For the Company) confidentially to enquire about the treatment of your data. You can contact the officer confidentially by email about the treatment of your data by us.
WHAT DATA IS COLLECTED?
We, the Loan Service Provider and our lending partners collect certain information provided by you, some of which is sensitive personal information. We have detailed what data and the manner in which this data is collected.
By using the App and /or accessing https://www.fatakpay.com (“Website”), you consent to providing us, our Lending Partners with your prior and explicit consent, your data in the ways listed below. We and our Lending Partners collect the data you provide to ensure that you are provided with the Services in the best manner possible. We and our Lending Partners use this data to underwrite (i.e., assess the risk it will be taking) any loan we might offer you and to determine the rates and tenure for such loans. The data being asked from you helps us, our Lending Partners, to provide services to you in a robust and user-friendly manner. We have detailed the manner in which we, our lending Partner collect data below:
S.No. Means of
Data Collected i. Data you input in the course of signing up and using our Services Fatakpay Account Data: We collect the data you provide to us when you create or update your Fatakpay Account. This includes your name, phone number, email ID, PAN, date of birth, pin code, nature of employment, official employment email address and name of employer, monthly income, and relationship with the co-applicant (in case the loan is being sought by more than a single applicant). We may require you to share further information on a later date to confirm the veracity of your information or pursuant to any additional features added to the App.
How we use this data: For Enabling the App and its Services; For Loan Processing and KYC Authentication; For Enabling Customer Support; For Research and Development; For Enabling Communications Between You and Us; For Enabling Marketing and Outreach; For Automated Decisions; For Legal Compliance and Requirements.
Financial and KYC Information: We and our Lending Partners collect the data you provide when you accept the tentative terms of the loans. This includes your photograph, Aadhar Number, PAN, parents’ names, bank account number, IFSC, proof of address (which can be your electricity bill, rental/lease agreement, gas bill, passport or driver’s licence, or voter’s identity card or any other document the App may be able to record).
How we use this data:For Enabling the App and its Services; For Loan Processing and KYC Authentication; For Legal Compliance and Requirements; For enabling and servicing of lending Products with our lending Partner.
Other Data Solicited:You may be required to provide further information to us and our lending Partner for the purposes of processing your loan application. Such additional information may include (without limitation) bank statements, goods and services tax returns, salary and income statements. This data shall be supplied to us or our Lending Partners. You may also be required to provide this information to us, our Lending Partners via physical documents, e-mail or other digital and offline methods.
How we use this data:For Enabling the App and its Services; For Loan Processing and KYC Authentication; For assessing the quantum and interest rate of loan to be extended; For Legal Compliance and Requirements; For enabling and serving of lending Products with our lending Partner.
Feedback Data and Other Data: This includes the following:
- If you call our call centres, we may record information provided by you to service you or record the calls for quality and training purposes.
- Data you input when you participate in our referral programs or use any discounts codes offered by us.
- If you provide any feedback or comments to us on the App.
How we use this data: For Enabling the App and its Services; For Loan Processing and KYC Authentication; For Legal Compliance and Requirements.
Geolocation data: We collect the location data from you in two ways: (i) when you add the pin code as part of your Fatakpay Account data; and (ii) from your mobile device when enabled by you to do so. We collect this data when the App is running in the background of your mobile device. You will not be able to use the App if you disable the location services.
How we use this data: For Enabling the App and its Services; For Loan Processing and KYC Authentication; For Enabling Customer Support; For Enabling Marketing and Outreach; For Automated Decisions; For Legal Compliance and Requirements; For enabling and servicing of Co-Lending Products with our Co-Lending Partner.
User Personal Information: The App collects user account data which includes email address, name to log in to the App. This information is required as part of the registration process to access our service and it is also used to auto populate relevant fields in the course of the interface of the App. The App also collects mobile numbers for verification to check the active SIM status on the device, uniquely identify you and prevent fraud and unauthorised access.
How we use this data: For Enabling the App and its Services; For Loan Processing and KYC Authentication; For Legal Compliance and Requirements.
ii. Data we collect from your usage of our Services App Data: We collect the data about your installed applications, including the applications that you have installed on and from the date you create your Fatakpay Account and the manner in which you use them. This also includes having access and permission to send you messages and notifications via your social media and instant messaging applications. You will not be able to use the App if you disable this access.
How we use this data: For Enabling the App and its Services; For Loan Processing and KYC Authentication; For Enabling Customer Support; For Research and Development; For Enabling Communications Between You and Us; For Enabling Marketing and Outreach.
Usage data: We collect data about how you interact with Services. This includes data such as interaction patterns (such as screen actions, gestures: taps, scrolls) access dates and times, App features or pages viewed, App crashes and other system activity, type of browser, and third – party sites or services used before or in the course of interacting with the Services.
How we use the this data: For Enabling the App and its Services; For Enabling Customer Support; For Research and Development; For Enabling Communications Between You and Us; For Enabling Marketing and Outreach; For Automated Decisions; For Legal Compliance and Requirements.
Transaction information: We and our Lending Partners collect transaction information related to the use of our Services, including the type of Services requested, date and time the Service was provided, loan availed, interest payable, EMI selected, and payment method. Additionally, if someone uses your promotion code, Fatakpay may associate your name with that person and their usage of the App.
How we use this data: For Enabling the App and its Services; For Loan Processing and KYC Authentication; For Enabling Customer Support; For Research and Development; For Enabling Communications Between You and Us; For Enabling Marketing and Outreach; For Automated Decisions; For Legal Compliance and Requirements; For enabling and servicing of Co-Lending Products with our Co-lending Partner.
Device data: Fatakpay collects data about the devices used to access Services, including the hardware models, device IP address, operating systems and versions, software, preferred languages, unique device identifiers, advertising identifiers, serial numbers, device motion data, and mobile network data.
How we use this data: For Enabling the App and its Services; For Enabling Customer Support; For Research and Development; For Enabling Communications Between You and Us; For Enabling Marketing and Outreach.
Camera Data: Fatakpay uses your phone’s camera to capture your selfie for verification, for scanning the QR codes and for uploading documents.
How we use this data: For Enabling the App and its Services; For Enabling Customer Support.
iii. Information we receive from other sources We may also be working closely with third parties (including, for example, credit information bureaus, business partners, partner banks and financial institutions, technical sub-contractors, analytics providers, search information providers and valuers) and may lawfully receive information about you and your co-applicant from such sources. Such data may be shared internally and combined with data collected on the App. We may also use the content you have shared publicly, including on third party platforms or applications, to promote our Services ( including by quoting your content, reviews and/or recommendations, or displaying screenshots of your content, reviews and/or recommendations).
How we use this data: For Enabling the App and its Services; For Loan Processing and KYC Authentication; For Enabling Customer Support; For Research and Development; For Enabling Communications Between You and Us; For enabling Marketing and Outreach; For Automated Decisions; For Legal Compliance and Requirements; For enabling and servicing of Lending Products with our Lending Partners
HOW AND WHY IS THE COLLECTED DATA USED?
The Company and our Lending Partners collect and use data collected from you to ensure that the Services are as up to date as possible and provided in the most optimal manner to you. The data that is collected in accordance with Question 2 of the Policy will be used in the manner detailed below:
S.No. Means of
Data Collected i. Enabling the App and its Services Fatakpay uses the data collected to personalise, maintain and improve our Services. This includes using the data to:
- Create and update the Fatakpay Account.
- Analyse your loan eligibility and estimate your loan terms.
- Track the disbursement and repayment of the loan.
- Enable features that allow you to add and remove bank accounts for your loan repayment and disbursements from time to time.
- Enable features that help you check your loan history, credit scores (as provided on government databases), and other such App features as may be added from time to time.
- Perform internal operations necessary to provide Services, including to troubleshoot software bugs and operational problems;to conduct data analysis, testing, and research; and to monitor and analyse usage and activity trends.
ii. Loan Processing
We use the data to analyse your creditworthiness, loan eligibility, KYC documents, current employment verification and the terms of your loans. We collect the Financial and KYC Information. We are required to individually process the loan requests and verify the KYC documentation received. Failing to process such data means that you cannot be provided any loans. You hereby grant us explicit consent to fetch your KYC (Know Your Customer) details from the Central KYC Records Registry using the details provided by you.
We and our Lending Partners also use the data to track disbursement and repayment of your loan.
iii. Enabling and servicing of Lending Products with our Lending Partners Our Lending Partners use the data to analyse your creditworthiness, loan eligibility, KYC documents, current employment verification and the terms of your loans. You hereby grant the Lending Partners explicit consent to fetch your KYC (Know Your Customer) details from the Central KYC Records Registry using the details provided by you. Our Lending partners also uses the data for underwriting, to track disbursement and repayment of your loans. iv. Enabling customer support Fatakpay uses the information to provide customer support, including to resolve your concerns from the use of the Services, and train customer service executives. v. Research & Development Fatakpay may use the data so collected for research, analysis, and product development to improve the UI/UX experience- all of which will ultimately improve how you experience the App. This also helps us develop automated actions to be triggered in certain events, such as to identify if photographs uploaded are not clear, fraud takes place, IFSC is incorrect etc. vi. Enabling communication between you and us Fatakpay may add features that allow you to call us (through the App or otherwise), similarly, Fatakpay may also need to contact you (through the App or any other channels that you give us access to, such as WhatsApp or Facebook). vii. Marketing and Outreach Fatakpay may use the data collected to market the App and its Services. This includes sharing your feedback, ratings and screen names for purely promotion and marketing purposes. Such promotion and marketing may be done via hoardings, banners, pamphlets etc. viii. Automated Decisions The App may provide automated features for customer responses, reimbursement tracking, etc. As the App grows, Fatakpay will keep adding more automated features to the App. ix. Legal Compliance and Requirements We may use the data we collect to investigate or address claims or disputes relating to use of our Services, or as otherwise allowed by applicable law, or as requested by regulators, government entities, and official inquiries. x. Product Innovation Fatakpay may use the data collected to offer new products and services for your use.
HOW DO WE SHARE THE COLLECTED INFORMATION?
Please note that while none of your data is sold, it is shared with third parties on a contractual basis. This data is shared for processing of information and ensuring that you receive the Services.
We are very protective about your data. We may enter into data-sharing agreements or disclose the collected data in order to provide the Services and new product offerings to you. We have detailed the manner in which we share the collected data below.
S.No. Person Shared with Purpose for Sharing i. Sharing with third parties Service Providers: Fatakpay works with third party service providers to execute various functionalities of the App and Fatakpay may share your information with such service providers to help it provide the App.
Some of these functionalities may include:
- Analysing transaction behaviour and cash flows via your bank statements, goods and services tax returns, salary and income statements, income tax returns, basis which your loan offer is generated.
- Validating and authenticating the official verification documents provided you
- Validating your preferred bank account, as well as transferring the loan amounts to you.
- E-signing of the User Loan Agreement or Sanction Letter, populating the User Loan
- Agreement or the Sanction Letter. The information shared with these service providers is retained for auditing of the agreements.
- eNACH/NACH set-up to enable autopay.
- Analysing customer behaviour and to automate our marketing and outreach efforts.
- Detection and flagging of fraud.
- Cloud services.
- Gathering additional information regarding your bank account and statement details, in case adequate information has not been provided by you or through the other service providers we work with.
- For manually collecting any sums owed by you to our Lending Partner.
- Validating and authenticating your employment status, employment information and employment duration.
Affiliates and Group Companies: Subject to applicable law, we may share any data we have collected or collect from you with our affiliates and group companies for product research and development, advertising relevant products to you, and to tailor the products for your benefit.
LINK TO THIRD-PARTY SDK The application has a link to a registered third party SDK which collects data on our behalf and data is stored to a secured server to perform a credit risk assessment. We ensures that our third party service provider(s) take security measures in order to protect your personal information against loss, misuse or alteration of the data.
Our third-party service provider(s) employ separation of environments and segregation of duties and has strict role based access control on a documented, 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(s) provide hosting security – they use industry leading antivirus, anti-malware, intrusion prevention systems, intrusion detection systems, file integrity monitoring, and application control solutions.
Change in Control: While negotiating or in relation to a change of corporate control such as a restructuring, merger or sale of our assets, we may have to disclose our databases and information we have stored in the course of our operations.
ii. Sharing with the Lending Partner We work with identified banks and financial institutions to provide lending products on the App, and we may share your information with such Lending Partner(s). The Fatakpay App is a digital lending application facilitating the loan transactions between us, customers and the Lending Partner. Details of our Lending Partners on our website. iii. Sharing with law enforcement when needed If any governmental authority or law enforcement officers request or require any information and we think disclosure is required or appropriate in order to comply with laws, regulations, or a legal process, we, our Lending Partners may share such required information with the governmental authority or law enforcement officers.
Details of the third parties we and/or NTL share your personal information with are set out below:
S.No. Vendor’s Entity Name Address Email ID i. HyperVerge 12, 17th Cross Rd, Sector 7, HSR Layout, Bengaluru, Karnataka 560102 [email protected] ii. Novel Pattern H 146 - 147, Second floor, H Block, Sector 63, Noida, Uttar Pradesh 201307 [email protected] iii. Equifax 9, Mota Nagar, Andheri East, Mumbai, Maharashtra 400047 [email protected] iv. Razorpay 22, 1ST FLOOR, SJR CYBER, LASKAR-HOSUR ROAD, ADUGODI, BANGALORE- 560030 [email protected]
WHAT ARE YOUR RIGHTS REGARDING THE DATA?
We have identified your rights in the table below and the manner in which you may exercise these rights.
It is important for us that you remain in control of your data. Please write to us at [email protected] if you wish to exercise any of your rights under the Policy. You shall have the following rights:
S.No. Your Right Details i. Right to rectification In the event that any personal data provided by you is inaccurate, incomplete or outdated then you shall have the right to provide us with the accurate, complete and up to date data and have us rectify such data. It may take up to 10 days to process your request. We urge you to ensure that you always provide us with accurate and correct information/data to ensure your use of our Services is uninterrupted. ii. Right to withdraw consent You have the right to withdraw your consent to this Policy by uninstalling the App. However, if you have availed any loans from Us, we shall have the right to continue processing your information till such loan has been repaid in full, along with any interest and dues payable. However, we shall not retain your data and information if it is no longer required by us and there is no legal requirement to retain the same. Do note that multiple legal bases may exist in parallel and we may still have to retain certain data and information at any time. iii. Right to opt-out You can opt out of receiving push notifications through your device settings. Please note that opting out of receiving push notifications may impact your use of the App.
WHAT IS OUR DATA SECURITY PRACTISE?
We aspire to keep your data and information as secure as possible and to that effect we have used state of the art software.
We use requisite technical and organisational security measures to ensure a level of protection for personal data appropriate to the nature, scope and purpose of processing personal data, the risks associated with such processing, and the likelihood and severity of the harm that may result from such processing. The transfer of personal data between your end device and Fatakpay is generally carried out via best-in-class encryption protocols. If you communicate with us by email, access by third parties cannot be ruled out. In the case of confidential information, we recommend using the mail, i.e., post or encrypted e-mail communication (PGP).
By applying for a loan, you have consented to all our data privacy practices. You can write to [email protected] if you wish to revoke any consent.
By using the App and/or accessing the Website, you agree to our processing, storage, usage, and sharing of the data provided by you pursuant to this Policy. If you do not agree with any of the terms of this Policy or the Terms or wish to revoke any consent you have provided to us, please write to us at [email protected]. However, please note that if you revoke any mandatory permissions or revoke the consent to process and store information such as your Fatakpay Account data, Financial and KYC Information and/or any other information needed to facilitate your loan amounts, then we may have to cease the provision of Services to you. You cannot withdraw your consent once you have availed a loan using the App till you have repaid the loan amount and all related charges in its entirety.
We retain your personal data to the extent we need to. Once the legal basis for the retention expires, we will not hold onto it.
We shall retain the information you provide to facilitate your smooth and uninterrupted use of the App, and (i) to provide, improve and personalise the Services; (ii) to contact you about your account and give customer service; (iii) to personalise our advertising and marketing communications; and (iv) to prevent, detect, mitigate, and investigate fraudulent or illegal activities. We do not retain your personal data for longer than required for the purpose for which the information may be lawfully used. Fatakpay stores your personally identifiable data in our servers in encrypted form. For any other information, we may entertain your request for deletion, however, you may not be able to use our Services at all after such deletion.
Our Services are not directed to children, and we do not knowingly solicit or collect personal information from persons under the age of 18 (eighteen). If we find out that a child has given us personal information, we will take steps to delete that information and terminate the relevant Fatakpay Account.
COMMUNICATION FROM US
We may from time to time contact you via calls, SMS, emails, and other communication channels to provide you with information pertaining to our Services, notifications on updates vis-à-vis our Services (when we consider it necessary to do so), educational information and promotions. Fatakpay may also notify you if Fatakpay needs to temporarily suspend the App for maintenance, and keep you informed on security, privacy, or administrative-related communications. By setting up an account on Fatakpay, you consent to us contacting you via call, SMS, push notifications, or through any other communication channel, as we may deem fit.
UPDATES TO THIS NOTICE
We may occasionally update this Policy. Use of our Services after an update constitutes consent to the updated notice to the extent permitted by law. Please take the time to periodically review this Policy for the latest information on our privacy practices.