This Privacy Policy ("Policy") outlines how Lending Spheres Private Limited and the Loan Providers (as identified in the Terms of Use) collect, store, use, transfer, and process your data (excluding non-personal data/information) to provide you with the Platform and/or Services (as defined in the Terms of Use available on the Platform).
Acceptance of The Privacy Policy:
By using our services, you confirm that you have read and understood this Policy, and you give your explicit consent for us and our loan providers to collect, retain, share, process, and store your personal and sensitive information in accordance with this Policy. If you do not agree with this Policy, please refrain from using or accessing the Platform or any services/products offered by the loan provider.
We and the Loan Providers will use the personal information including any sensitive personal data / information provided by You only in accordance with the purposes in this Policy or as per the requirements of the applicable laws.
Except as provided herein or as clearly disclosed to You at the time of seeking or collection of sensitive personal data, we do not solicit any sensitive personal information about you. However, if you share such sensitive or personal information with us or the Loan Providers voluntarily, we will not be liable for any actions, claims, costs, expenses or other liabilities that may arise because of any unauthorized use or misuse of such sensitive personal information. Any personal information including your sensitive personal information provided by you on the Platform or to us or to the Loan Provider/s, will be deemed as an authorisation given by you to us and the Loan Providers to use, store, process and share such personal information for the purpose as stated out on the Platform, the applicable laws, the policy wording and this Policy.
During your use of Platform, you may provide and/or we may collect and process such personal information from you, including but not limited to the below:
Ⅰ. Personal Information provided by You:
You may provide the personal information to us or Loan Providers:
a) by filling in application forms or signing-up for an account on the Platform or completing the Know-Your-Customer (“KYC”) or at the time of the on-boarding process or for availing any service on the Platform or any product of the Loan Provider. This may include contact information such as name, email address, mailing address, phone number, KYC documents like Voter ID, PAN, Driving License, etc.
b) voluntarily, when you call or write directly to us or Loan Provider (including by e-mail, feedback and/or surveys).
c) You may be required to provide further information to us or the Loan Providers for the purposes of loan processing and disbursement. Such additional information may include (without limitation) your financial data, bank statements, loan statement/s, salary and income statements as prompted on the relevant page. You may also be required to provide this information to us or the Loan Providers via physical documents, e-mail or other digital and offline methods.
d) You agree to provide current, true, latest and correct information and documents at any and all times, including for KYC or other purposes. The said KYC details and other documents may be used by Us or the Loan Providers or our affiliates to perform KYC, financial or other checks and extend the services to you, as further detailed in this Policy. In the event of any changes to any personal information or KYC documents or financial information in the KYC or other documents (as the case may be), you will promptly notify us via email and/or update the details under Your Account section immediately.
e) You also consent to the use, disclosure and sharing of the personal information about You, including but not limited to information about your financial history, loan obligations, credit score, etc. by Lending Spheres, the Loan Providers, Our affiliates and/or Our group companies. This will help You avoid repeat queries/checks, and also help You avail the additional products, services or other new offerings by Lending Spheres or Loan Providers, Our affiliates and/or Our group companies as per the terms of this Privacy Policy.
f) In the event of any changes to any personal information or KYC documents or financial information in the KYC or other documents (as the case may be), You will promptly notify us via email and/or update the details under “Your Account” section immediately.
Ⅱ. Personal Information Collected from Third Parties:
a) We and/or Loan Provider may also be working closely with third parties (including, for example, business partners, partner banks and financial institutions, technical sub-contractors, analytics providers, etc.) and may lawfully receive information about you from such sources. Such personal data may be shared internally and combined with data collected on the Platform.
b) We and /or Loan Provider may also use the content you have shared publicly, including on third party platforms or applications including any social media channel, to promote our Services and/or Our Platform and/or Loan Providers, or their services / platform (including by quoting your content, reviews and/ or recommendations, or displaying screenshots of your content, reviews and/ or recommendations).
Ⅲ. Personal Information Collected by Us and/or the Loan Providers:
a) We and the Loan Providers collect user account data which includes both personal and non-personal data, including but not limited to the email address, IP address, name to log in to the Platform. This information is required as part of the registration and on-boarding process to (i) create Your Lending Account; (ii) provide our Service and Platform; (iii) enable the Loan Providers to provide you with products and/or services; (iv) perform verification and KYC checks on you; (and it is also used to auto populate relevant fields when you apply for any product or service of the Loan Provider.
b) We and the Loan Provider may also collect mobile numbers for verification to check the active SIM status on your device, uniquely identify you and prevent fraud and unauthorized access. When you grant us access to the address book on your mobile device, then we and the Loan Providers access the names and contact information from your address book to facilitate invitations and to assess your phone usage and habits.
c) As part of your journey on the Platform, we access your phonebook contacts which includes their contact names, phone numbers, account types, favorites (starred) and contact labels to enrich your profile.
d) We and Loan Provider shall collect transaction information related to the use of our Services, the Platform and/or the products and services of the Loan Provider, including the type of Services requested, date and time the Service was provided and payment method.
e) Additionally, if someone uses your promotion code, we or the Loan Provider may associate your name with that person and their usage of the Platform/ Services.
f) If you call our call centers, we or the Loan Providers may record information provided by you to service you as per the Terms of Use and this Policy, including for quality and training purposes.
g) When you grant us access to the SMSs on your mobile device, then we and our Loan Provider collect financial SMS data stored on your mobile or other device. We and the Loan Provider use this data to analyse your financial profile and enable provisioning of best offers by us and/or Loan Providers with respect to the Platform, Services and/or products offered by us or the Loan Providers.
h) We may collect non-personal data as specified in the section below.
Ⅰ. “Non-Personal Information” means and includes any information that does not reveal Your specific identity, such as, browser information, information collected through Cookies (as defined below), pixel tags and other technologies, demographic information etc. Our Platform gathers some information automatically when You visit the Platform or avail any Service and stores it in your log files.
Ⅱ. We and the Loan Providers may collect certain non-personal information about Your computer or other electronic device through which you have accessed Platform or our Services or the products / services of the Loan Provider to facilitate, evaluate and verify your use of Platform or Your Lending Spheres Account or your interactions / communications with the Loan Provider.
Ⅲ. We and the Loan Providers collect non-personal data about the devices used to access our / their 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.
Ⅳ. We collect non-personal data about how you interact with our Services, Platform and/or with the Loan Provider. This includes data such as access dates and times, features or pages viewed, Platform crashes and other system activity, type of browser, and third-party sites or services used before or in the course of interacting with our Services and/or the services/products of the Loan Providers.
Ⅴ. “Cookies” are small files that reside on Your computer's/ electronic devices hard drive and generally contain an anonymous unique identifier and are accessible only by Platform that placed them there and not any other sites. You may refuse to accept Cookies by activating the setting on Your browser which allows You to refuse the setting of Cookies. However, if You do not provide such information, you may be unable to access certain parts of Platform. Unless You have adjusted Your browser setting so that it will refuse Cookies, our system may issue Cookies when You log on to Platform. The use of Cookies by Our partners, advertisers or service providers is not covered by this Policy.
Ⅵ. We collect the location data from you in two ways: (a) when you add the pin code as part of your account creation process; and (b) from your mobile device when enabled by you to do so.
Ⅶ. We collect the data about your installed applications, including the applications that you have installed on and from the date you create your account on the Platform and the manner in which you use them.
Ⅷ. IT IS REITERATED THAT THIS POLICY DOES NOT APPLY TO NON-PERSONAL DATA / INFORMATION INCLUDING PROCESSING OF ANY DATA IN ANONYMISED, AGGREGATED OR DE-IDENTIFIED FORM AVAILABLE WITH US OR COLLECTED BY US OR PROVIDED TO US / THE LOAN PROVIDERS. THE USE OF SUCH NON-PERSONAL DATA / INFORMATION (INCLUDING RETENTION, SHARING AND PROTECTION) SHALL BE AT OUR / THE LOAN PROVIDERS SOLE DISCRETION AND REQUIREMENTS.
Ⅰ. With Our other affiliates and/or our group companies: We may also share the personal information or details provided by you or collected by us with our other affiliates or members of our group companies for the purposes specified under Section 3 (How We Use Your Personal Data) of this Policy. We reserve the right to exchange, share or provide the personal information relating to your personal, financial details and other sensitive information with our affiliates and other group companies as required, and you will not hold us/our affiliates and/or our any other group companies and their agents liable for use, processing, retention or sharing of the personal information for use as per Section 3 (How We Use Your Personal Data) of this Policy. This right is in addition to the rights of the Loan Provider to access, use, store and share your personal data as per Section 3 (How We Use Your Personal Data).
YOU UNDERSTAND AND AGREE THAT WE AND THE LOAN PROVIDER MAY DISCLOSE YOUR PERSONAL INFORMATION, TO ANY MEMBER OF OUR GROUP OR OUR AFFILIATES OR A RELATED PARTY, FOR THE PURPOSES SPECIFIED UNDER SECTION 3 (HOW WE USE YOUR PERSONAL DATA) TO THIS POLICY, AND YOU PROVIDE YOUR EXPRESS AND UNCONDITIONAL CONSENT FOR THE SAME.
Ⅱ. With Third Party Service Provider/s: We or the Loan Providers or our other affiliates may use third-party service providers to help us operate our business, perform KYC checks, manage the Platform, provide the Services or administer activities on our, Loan Providers / our other affiliates’ behalf, such as sending out newsletters, surveys or questionnaires or other marketing activities with respect to us, the Loan Provider or our other affiliates’ products / services, including any new offerings. We may disclose your personal information to third parties (including any foreign third parties to the extent permitted by the applicable laws) for the purposes mentioned under Section 3 (How We Use Your Personal Data) to this Policy, inter alia, in order to perform KYC checks, provide You with customer support facilities, to comply with our / Loan Providers legal obligations including prevention of money laundering or otherwise as prescribed by the relevant regulatory authority or under any applicable laws, to enforce the Terms of Use, to facilitate marketing and advertising activities for us, Loan Provider and/or our other affiliates, to conduct analysis, to provide You services, to facilitate services for You, to send notifications, reminders or to prevent, detect, mitigate, and investigate fraudulent or illegal activities related to Platform or the products / services of the Loan Provider and to avail services from third parties for data analysis and market research.
Ⅲ. With Authorities or the Government: We may disclose or share your personal information if we are under a duty to comply with any legal obligation or an order from the government and/or a statutory authority, or in order to enforce or apply the Terms of Use or assign such personal information during corporate divestitures, mergers, or to protect the rights, property, or safety of the Company, the Users, or others. This includes exchanging personal information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
Ⅳ. For Business Requirements: In the event the Company is merged with or acquired by another company or in case of re-organization or re-structuring of business, we, the Loan Provider or our other affiliates may share your personal information, wholly or in part, with another business entity/ies.
We, at Lending Spheres, have appropriate data collection, storage, and processing practices. Our and the Loan Providers' security measures protect against unauthorized access, alteration, disclosure or destruction of your personal information. All kinds of private information exchange and transactions on the Platform happen through secured communication channels and are encrypted and protected with digital signatures.
We or the Loan Provider assume no liability for any disclosure of personal information due to errors in transmission, unauthorized third-party access, or other acts of third parties, or acts or omissions beyond our / Loan Providers' reasonable control and you agree that you will not hold us / Loan Provider responsible for any breach of security or unauthorized disclosure. In using Platform and/or availing the services or products of the Loan Provider, you accept the inherent security implications of data transmission over the internet, and the world wide web cannot always be guaranteed as completely secure. Therefore, your use of Platform including to avail any products / services offered by the Loan Provider will be at your own risk.
We and the Loan Providers 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 personal including sensitive information and does not extend to any non-personal data provided by you or collected by us / our Loan Provider / other affiliates / by our service providers.
This Policy shall be inapplicable to any unsolicited information you provide us through Platform or otherwise. This includes, but is not limited to, information posted in any public areas of 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. We and the Loan Providers reserve the right to update this Policy at any time, so you are advised to review this Policy statement frequently. Your access to or continued use of the Platform after the changes have been posted on this page shall confirm your equivocal acceptance of the revised privacy policy.
If you have any questions, feedback, or concerns regarding our privacy policy, please feel free to contact our Grievance Office at the details provided below
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