Finequs
FINEQUS PRIVACY AND SECURITY POLICY

   1.
INTRODUCTION:

Finconvenio Services Private Limited (“Company”, “Finequs”, “We” “Us”, “Our”) is a technology-based financial services aggregator providing financial products in the offline and online marketplace via portal, websites, mobile apps, and other digital media, distributors, distribution partners, merchants and individuals (“Platform”). Finequs is committed to privacy and confidentiality of Your personal information on our Platform. We have implemented all the necessary and reasonable measures in conjunction with the applicable laws and regulations to protect Your personal/sensitive information. This privacy & security policy (“Policy”) explains how We protect Your personal information which has been provided to us on our Platform and how We use the information received to provide our services ("Service"). The Users shall read this Policy in conjunction with our General Terms of Use, Terms of service for Credit Information Report, Customer Terms and Conditions and Merchant Terms and Conditions.
Any undefined capitalised terms used herein shall have the same meaning as set out in the General Terms of Use.

   2.
APPLICABILITY:


2.1 This Policy applies to all the users of the Platform (“Users”, “You”, "Your”) who avail or intends to avail our Services. This Policy applies to all current and visitors to the Platform. The Policy shall apply to Information including but not limited to the details pertaining to your name, parentage, marital status, nationality, state/city of residence, residential address, e-mail address, date of birth, gender, contact number/mobile number, user ids, passwords, recent photograph, signature image, income proof, PAN, credit score, credit information report, and such other know your customer (KYC) documents like address proof, identity proof, officially valid documents/details (OVDs) accepted for concluding a financial transaction (“Personal Information”), which may be shared/ uploaded by You, as and when You avail any products or use the Platform and to which Finequs may become privy to.

2.2 We reserve the right, to change or otherwise modify the Policy at our sole discretion.. It shall be your sole responsibility to visit the website periodically to review and comply with the most current version of the Policy. Your continued access or use of this Platform signifies Your acceptance of the updated or modified Policy.

   3.
MODES OF INFORMATION GATHERED:


3.1 Creation of Your Account:
To provide efficient Services, We will collect all details of Your Personal and any other relevant information from You that is required by the lending partners to process Your application. In order to process Your loan Application, You shall provide relevant bank statements of the relevant financial year. We shall submit Your bank statements to potential lenders for them to assess credit score & to verify Your bank details. We shall not be liable to You against any liability or claims which may arise out of such transactions being carried on Your own accord. We will use Loan Application Information to evaluate, process, and if necessary, underwrite the application on behalf of our lending partners. To the extent permissible in law, We may use the email, physical address, and phone number provided in the Loan Application to deliver marketing communications to You via email, post or to contact You for information about Your experience with our Platform and services.
3.2 Cookie and Tracking Information:
We use cookies, i.e., small portions of data that are sent by us to your device, to improve Your experience. These cookies help us understand your patters such as the number of times our website/ application is accessed, the duration of the log in of any User, etc. You may choose to not consent to usage of the cookies; however, you will not be able to best utilize the Services provided by us. We use internet protocol address (“IP Address”) and such other Information to help diagnose problems with our servers, track user traffic patterns and administer our Platform. We make use of a standard feature of browser software (“Cookies”) to assign You a unique, random number. Our Platform uses cookies to recognize You as a user of our Platform, to direct You to our home page or other pages on our Platform, and to help keep track of what You do on the Platform. We track user activity on our Platform, such as automatically collecting the date and time of Your access to our Services.
3.3 User Supplied Information
You may be asked to provide certain Personal Information in order to receive information on Services, that You request. Except where prohibited by law, We may use the email address provided to deliver marketing communications to You or to communicate information pertaining to the Services.
3.4 Other Information
We collect Your Personal Information when You register on our Platform. During registration, You shall be asked to provide Your contact number and other details. We may use those details to send SMS, electronic mail, notifications, and WhatsApp messages about the Services to Your wireless device. We receive and store certain types of information whenever You interact with us. We may also receive/store information about Your location and Your mobile device, including a unique identifier for Your device. We have our presence in both physical and digital sphere and thus, We do deploy digital tools towards our business and marketing objectives. We might collect Your details from social medias using tracking metrics solely for marketing purposes. However, We are not responsible for any information collected or shared or used by any other third-party website due to your browser settings.
   4.
EXPRESS CONSENT


4.1 By making use of the Platform or connecting with any of our channels, and furnishing Your Personal Information, You hereby expressly consent and agree:
a. to receive communications through emails, telephone, WhatsApp, SMS, or any other form of messaging/ communication or any other physical, electronic or digital means/mode (“Mode of Communication”) as deemed fit from Us or such third parties.
b. If at any point in time User wishes to opt out User may withdraw any consent previously given, by written communication or by sending e-mail from registered e-mail address of the User. Upon User's refusal to provide data /information or withdrawal of consent, We reserve the right to refuse to provide or discontinue its products and services.
c. that You are interested in knowing more or availing and/or purchasing various products, services, offers, campaigns or other promotional material that Us or any other third party may offer/provide/share/send You from time to time through any Mode of Communication.
d. That we will share the data to assist third parties like our business partners and/or Service providers in facilitating and delivering Services to You, processing payments and Your Loan Applications;
e. that we will send You any administrative notices, offer alerts and other communications relevant to Your use of the Platform;
f. that you information will be used to conduct market research, project planning, troubleshooting issues, detecting and protecting against error, fraud or other criminal activity;
g. that we will provide You with location-based Services. You may opt out of location-based services at any time by visiting ‘Settings’ of Your browser;
h. display customized offers to You and assist You to apply for certain Services;
i. That We may contact You either through email or phone, to understand Your interest in the selected products and services and to fulfil Your demand or complete Your
application.
j. That We may share Your Personal Information with its subsidiaries, group companies, vendors, Service providers, business partners, agents and other third parties, as may be required for marketing purposes/offering/cross-selling various other products and services and/or to provide You with various value-added services, in relation with the Services selected by You or generally otherwise.
k. to authorize Us to derive Your Personal Information from any other source or public registry, as may be necessary to complete Your profile or Your Loan Application on the Platform.
l. to authorize Us or any third parties authorized by Us to conduct due diligence on You, assess Your eligibility for the Services and conduct know-your-customer (“KYC”) checks to process Your application through this Platform.
m. That We shall not be liable towards any liability or claims which may arise out of any transactions because of Your express consent.

   5.
CREDIT INFORMATION REPORT


5.1 We have no control over the accuracy or substance of the information provided in Your credit information by Credit Information Companies ("CICs"), who get Your credit information (credit score and credit information report) through a "soft search" of Your credit records. Only when you agree to designate us as Your authorised agent/representative for collecting Your credit information do we obtain this information from CICs for and on your behalf. You acknowledge and accept that We will only process Your credit information report with Your permission and after you have confirmed the one-time password (OTP) which shall be sent to you on Your registered mobile number.
5.2 You shall successfully complete the necessary identification authentication in order to access Your credit information through Us for security and privacy reasons. If You are unable to pass such identity authentications and are unable to read and/or use Your credit information, we will not be held liable for the circumstances.
5.3 We may analyse and profile Your credit information in order to assist You better, and manage Your credit score/rating, identify and inform You of credit products that are likely to be suited to Your circumstances, identify whether You may benefit from additional guidance concerning Your credit score and steps You can take to improve Your score and credit history etc. For more details, please access Finequs’ Terms of Service for Credit Information Report.

   6.
PURPOSE AND USAGE OF YOUR PERSONAL INFORMATION


6.1 We will not sell or rent Your Personal Information to anyone for commercial purposes. The Personal Information shared by the User will not be shared with anyone in a way that is contrary to the applicable law or is other than as set forth in this Policy.
6.2 Notwithstanding the foregoing, We may share Your Personal Information with an affiliate and/ or business partner. We may also share or transfer Your Personal Information to any successor-in-interest as a result of a sale of any part of our business or upon the merger, reorganization, or consolidation of it with another entity on a basis that it is not the surviving entity.
6.3 We limit the collection and use of Your Personal Information only for the purposes described herein. We may make anonymous or aggregate Personal Information and disclose such data only in a non-personally identifiable manner. Such information does not identify You individually. Access to Your account information and any other Personal Information is strictly restricted and used only in accordance with specific internal procedures, and applicable laws.
6.4 There are number of products/services such as loans, and credit cards offered on the Platform by third parties, such as lenders, banks, and credit card issuers. In the event You choose to apply for these separate products or Services, you shall disclose Your Personal information to these providers separately. Please note that their use of Your Personal Information is solely governed by their privacy policies. We encourage You to visit and read about the privacy policies and security procedures adopted by these third parties/providers when You apply for their products or services.
6.5 We may also use third-party service providers to provide the Service to You, such as sending e-mail messages on our behalf or hosting and operating a feature or functionality of the Service. Our contracts with these third parties outline the appropriate use and handling of Your information and prohibit them from using any of Your Personal Information for purposes unrelated to the product or Service they're providing. We require such third parties to maintain the confidentiality of the information provide to them.
6.6 Access to Information by Service Providers. We may share Information with service providers with whom we have contracted to perform Services on our behalf or behalf of our lender partners, such as companies that help process and Service loans, and, where permitted by law, companies that market products and Services. We may use third-party service providers to store information and facilitate communication with You. All contracted third-party service providers are contractually required to safeguard all Information.
6.7 We do not disclose Personal Information of a user except as required under the applicable law or pursuant to the consent received from the User. No Personal Information is shared with third parties unless any one of the following conditions is met:
a. Where the disclosure is necessary for compliance of a legal obligation or as required by law, such as to comply with a notice/ summons or similar legal process;
b. When we believe in good faith that disclosure is necessary to protect our rights, protect Your safety or the safety of others, investigate fraud, or respond to a government request;
c. We shall not be held liable for disclosure of the Personal Information when used in accordance with this Privacy Policy or in terms of the ‘general terms of use’ or an agreement, if any, with the Users of the Platform

   7.
RETENTION OF YOUR PERSONAL INFORMATION


7.1 We will retain Your information during the term of Your account being active.
7.2 Post-termination of Your account, We may continue to use Your anonymised data aggregated or in combination with anonymised data of other users. We use this aggregated anonymised data for data analysis, profiling and research purposes, for example to gain insights about our Users and their profiles. Further, we may utilise the anonymised data (if any) for fraud prevention purposes and for the exercise/ defense of a legal claim or for providing evidence in legal proceeding(s).

   8.
CONSENT FOR TESTIMONIALS, BLOGS ETC. ON FINEQUS PLATFORM

We may post any testimonial from You with Your specific consent. You may choose to have the testimonial removed by intimating Us at any time. If You use a blog, comments section or other public forum on Platform, any information You submit there can be read, collected or used by other users and could be used to send You messages and all such information will be owned by Us. We shall not be held responsible for the Personal Information You choose to submit in these forums.

   9.
SECURITY PRACTICE BY US:


9.1 We follow generally accepted standards to protect the Personal Information submitted to Us, both during transmission and once we receive it. Since there is no method of transmission over the Internet, or method of electronic storage that is 100% secure, We cannot guarantee its absolute security.
9.2 We transmit information such as Your login credentials for Platform or account credentials securely.
9.3 Our data is managed and stored in secure cloud-based servers and follow the applicable protocols of security as are provided by these servers.
9.4 All communications between Your device and our Platform that contain any Personal Information are encrypted. This enables customer and server applications to communicate in a way that is designed to prevent eavesdropping, tampering and messageforgery.

   10.
SECURITY PRACTICES BY THE USERS:


10.1 You are responsible for maintaining the security of Your own credentials and should not share the same with any third party. We are not responsible if someone else accesses Your account.
10.2 If You have any security-related concerns, please contact us immediately.

   11.
RIGHTS OF THE USERS


11.1 The Users, shall have the following rights with respect to Our use of their Personal Information:
a. You can, at any time, request for deletion or removal of their Personal Information, from the database of the Company and its Platform.
b. You can, at any time, revoke the consent granted here in whole or in part and can have Your Information removed from the Platform in whole or part. However, such revocation shall only apply prospectively; and shall not apply with respect to Your data already shared by Us with its partners upon Your prior consent.
c. You can avail the right of deletion or denial of consent in accordance with the Privacy Policy of Finequs. However, if You place a request not to receive such communication/marketing material going forward, it shall be applied prospectively only.

   12.
CONTACT US (GRIEVANCE REDRESSAL):


In the event of any grievance or complaint, questions, comments, concerns, or feedback regarding the processing of information or regarding this Privacy Policy or regarding any concern, You may contact us on the following coordinates.
Name: Mr. Amrish Krishnan
E-mail: grievance@finequs.com.
Address: 12, Kanchi Nilayam, South Usman Road, T. Nagar, Chennai 600 017