This website https://www.FlexiLoans.com (“Website”) and Flexiloans Mobile App (Android) is available on Google playstore. “FlexiLoans” is owned and operated by Epimoney Private Limited (“FlexiLoans/ We/ Us” which expression shall mean and include its affiliates, successors and permitted assigns), having its registered office at No. 249 A, Ambujammal Street, Off TTK Road, Alwarpet, Chennai-600 018 and its Corporate address at One World Center, Indiabulls Financial Center Tower-2, 7th Floor, South Annexe, 841, Senapati Bapat Marg, Saidham Nagar, Lower Parel, Mumbai, Maharashtra 400013. The Website is an online lending platform for users to avail financial services. FlexiLoans is committed in protecting and respecting your privacy.
INFORMATION WE COLLECT
During your use of the Website and Mobile App, we will collect such Information from you when you provide to us including but not limited to the below mentioned: Sensitive Personal Data or Information/Personal Information that you provide to us while interacting with us such as your name, gender, date of birth, mobile number, password, email address, mailing address, telephone number, aadhar card details, pan number ,tan no., sales tax details, service tax details, bank account details, business financials, passport number, driving license number, purpose of loan, sources of your income and family income, demographic information like residential address and office address, pay slips, your family details, information relating to income and expenses obtained through bank SMS scraping and through integration with such service providers, credit related information that is collected from other sources like the credit bureau, information collected through Facebook, Twitter, LinkedIn or other social media accounts of the Users which have been linked to the account on the Website, information that you provide when you write directly to us (including by e-mail) or provide us over telephone, any other information that FlexiLoans is required to collect as per specific mandate from any bank or as a requirement under applicable law and other relevant financial information. You will at all times have the option of not providing Flexiloans with Sensitive Personal Data or Information/Personal Information that Flexiloans seeks to collect. Even after you have provided Flexiloans with any Sensitive Personal Data or Information/Personal Information, you will have the option to withdraw the consent given earlier. Further, you have the right to request for access to your Sensitive Personal Data or Information/Personal Information and to review and amend such Sensitive Personal Data or Information/Personal Information. In such cases, Flexiloans will have the right to not provide or discontinue the provision of any service that is linked with such Sensitive Personal Data or Information/Personal Information. We also collect Non-Sensitive Personal Data or Information/Personal Information from you, such as your browser type, the URL of the previous website you visited, information about the pages viewed on website, how you navigate through the website and interact with webpages etc., your ISP, operating system types, clickstream patterns, and your Internet protocol (IP) Address (“Non-Sensitive Personal Data or Information/Personal Information”). Non-Sensitive Personal Data or Information cannot be easily used to personally identify you. We also contract with several online partners to help manage, monitor and optimize our Website and services and to help us measure the effectiveness of our advertising, communications and how visitors use the Website. To do this, we may use web beacons and cookies. In addition to collecting information via our Website and Mobile App, we may also conduct a site visit to collect Information and obtain Information and external data used by lenders to process applications and complete and manage transactions, e.g., from credit reporting agencies and other vendors, as well as from social media.
INFORMATION WE COLLECT AUTOMATICALLY
There is certain Information that we collect automatically as the result of your use of the Website, or through the use of web analytics services. This Information includes but is not limited to: The Internet Protocol (IP) address of the device from which you access the Website (this can sometimes be used to derive the country or city from which you are accessing the Website). The specific actions that you take on the Website, including the pages that you visit, connecting your Facebook or Google+ account. The time, frequency and duration of your visits to the Website. Your browser type and operating system. The nature of the device from which you are accessing the Website, for example, whether you are accessing the Website from a personal computer or from a mobile device. Your location data (e.g. GPS), calling history, contact list and messages when using FlexiLoans Application.
INFORMATION FROM OTHER SOURCES
HOW WE USE THIS INFORMATION
Any Information shared by you is used by us and/or authorized third parties/service partners to support your interaction with us, to offer you services in the best possible manner and to contact you again about other services and products that we offer. After submitting your Sensitive Personal Data or Information/Personal Information to FlexiLoans, by clicking on the ‘I Accept’ checkbox, you expressly acknowledge and consent to FlexiLoans to use such information and to process the same in a manner deemed fit by FlexiLoans. We may use this Information provided by you in the following ways but not limited to:
(a) To capture, save, compile and analyse the Information required to perform credit and risk scoring models and establish identity and assess applications. To design and improve the products and services, customer relationship management processes to operate the business.
(c) To monitor metrics such as total number of views, visitors, traffic and demographic patterns.
(d) To carry out contractual obligations entered into between FlexiLoans and you.
(e) To conform to the legal requirements, compliance/reporting to administrative and judicial authorities, as may be required and to comply with regulatory guidelines.
(f) To protect and defend the rights or property of the website owners of FlexiLoans, or your rights. To communicate with you to send order confirmations, respond to customer service requests, send marketing communications, and send account update notifications.
(g) To share the Information with multiple financial institutions and other lenders for customization of offers and provision of services. To undertake research, troubleshooting, fraud and risk management and prevention of other criminal activity. To post and review your comments on our blog.
(h) To manage your employment and related compliances, process payroll and other compensations, managing employee benefits, tracking attendance, etc. We may also collect and use this Information in other ways permitted by law. We will take utmost care to ensure that your Sensitive Personal Data or Information/Personal Information is not shared with the public and that your transactions on the Website are confidential. If we use any third parties for any of these transactions, we will also make sure that confidentiality is maintained. We may also provide Sensitive Personal Data or Information/Personal Information about our customers to other organizations. We will take reasonable care that any Sensitive Personal Data or Information/Personal Information we disclose to them is only used for the specific task we ask them to perform.
DISCLOSURE TO THIRD PARTY SERVICE PROVIDERS AND ONLINE PARTNERS
We may contract with various third parties who help us provide, maintain and improve the website and the FlexiLoans services. We do not sell your Sensitive Personal Data or Information/Personal Information to third parties. FlexiLoans guarantees that it is going to keep all Information confidential except in the following cases:
To any agent or third-party service provider who provides administrative, analytics, telecommunications, computer, payment or other services to FlexiLoans in connection with the operation of its business. To any other person under a duty of confidentiality to FlexiLoans including an affiliate or group company of FlexiLoans which has undertaken to keep such Information confidential;
To credit reference agencies, and, in the event of default, to debt collection agencies;
To any person to whom FlexiLoans is under an obligation to make disclosure under the requirements of any law binding on FlexiLoans or any of its branches. To any actual or proposed assignee of FlexiLoans or participant or sub-participant or transferee of FlexiLoans’ rights in respect of the customer. To governmental and other statutory bodies who have appropriate authorization to access the same for any specific legal purposes.
FlexiLoans discloses your Sensitive Personal Data or Information/Personal Information to companies that provide products and services to Us in relation to employee management, such as payroll and benefits providers, pension providers, human resources service providers, recruitment agencies, compliance consultants, etc.
ACCESS TO YOUR GMAIL ACCOUNT
Where you allow FlexiLoans to fetch your bank statements from your Gmail account, FlexiLoans will access your Gmail account through using https://www.googleapis.com/auth/gmail.readonly API in Mobile App or Web Portal and extract your bank statements of past six months for the purpose of determining your loan eligibility. No other information or emails from your Gmail account will be read, opened, accessed or viewed. All such bank statements extracted by FlexiLoans shall be kept in our records till such time as maybe required for Loan assessment and for adhering with rules/regulations of Reserve Bank of India.
COLLECTION OF FINANCIAL SMS INFORMATION
Our FlexiLoans Mobile Applications collect and monitor only financial SMS sent by alphanumeric senders from your inbox which helps us in identifying the various bank accounts that you may be holding, cash flow patterns, description and amount of the transactions undertaken by you as a user to help us perform a credit risk assessment which enables us to determine your risk profile and to provide you with the appropriate credit analysis and offers. This process will enable you to take financial facilities from the regulated financial entities available on the Website. This financial SMS data also includes your historical data. While using the application, it periodically sends the financial SMS information to our affiliate server and to us.
COLLECTION OF CONTACT INFORMATION
As a part of our Mobile Application loan journey, we require references from the Loan applicant. In this regard, during filing the form on our application, we collect and monitor your Information such as contact information which includes name, phone number, account type, contact last modified, favorites and other optional data like relationship and structural address to enable you to autofill the data during the loan application process. This Information is required for the purposes of risk analysis, enabling us to detect credible references, assess your risk profile and to determine your loan eligibility.
Cookies are small bits of information that are automatically stored on a person’s web browser in his computer that can be retrieved by this Website. Cookies allow web servers to recognize your computer each time you return to our Website including the date and time of visits, page view history, time spent at our website, and the websites visited just before and just after our website, verify your registration or password information (in case of a Registered User) during a particular session so that you do not have to input your password multiple times as you navigate the site and suggest products or services that may interest you. This information is collected on an aggregate basis. None of this information is associated with you as an individual. We might also use other technology to track how you interact with our portal and employ some third-party agencies to use the data on our behalf. We might also use this information to display advertising from third party companies. Should you wish to disable these cookies you may do so by changing the setting on your browser. Most browsers will let you decline cookies but if you choose to do this it might affect service on some parts of our Website.
We store and process your Sensitive Personal Data or Information/Personal Information on reputed web service cloud servers. We protect your Information using physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure, and alteration. Some of the safeguards we use are firewalls and data encryption using SSL, and information access authorization controls.
However, you understand and accept that there’s no guarantee that data transmission over the Internet will be completely secure and that any information that you transmit to us is at your own risk. We assume no liability for any disclosure of your Information due to errors in transmission, unauthorized third-party access to our Website and databases or other acts of third parties or acts or omissions beyond our reasonable control and you shall not be entitled to hold FlexiLoans responsible for any breach of security.
Both you and FlexiLoans play an important role in protecting against online fraud. You should be careful that your bank account details and other related information, including your User ID(s) and/or passwords/personal identification numbers (PIN) are not compromised by ensuring that you do not knowingly or accidentally share, provide or facilitate unauthorized use of it. Please do not share your User ID and/or password or allow access or use of it by others. We endeavor to put in place high standards of security to protect your interests.
You should safeguard your unique User ID(s) and Passwords/PINs by keeping it secret and confidential. Kindly never write them down or share these details with anyone. Except in the course of a transaction, FlexiLoans will never ask you for your passwords/PINs, in order to ensure that you are the only person who knows this information. When choosing your unique User ID and password for the first time, do not create it using easily identifiable information such as your birthday, telephone number or a recognizable part of your name. If you think your User ID and/or passwords/PINs have been disclosed to the third party is lost or stolen and unauthorized transactions may have been conducted, you are responsible to inform us immediately.
USE OF THIRD PARTY WEBSITES
If you choose to provide a few referrals to introduce FlexiLoans and/or its Website to any other person/ entity, we may ask you to provide such person/ entity’s name and email address, provided you have obtained consent for disclosing such personal information about the person / entity you refer to us. FlexiLoans will automatically send such person/ entity an email inviting it or to visit the FlexiLoans website. FlexiLoans stores this information for the purpose of sending this email and keeping a record of the number of persons / entities so referred by the Users and may send additional emails to the said person / entity in connection with services offered by FlexiLoans. Such person/ entity may contact FlexiLoans at email@example.com to request that this information be removed from FlexiLoans’ database.
We may display personal testimonials of satisfied customers on our Website in addition to other endorsements. With your consent, we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us by email at firstname.lastname@example.org
RETENTION OF DATA
We may retain the Information about you as long as your User account is active or as needed to provide services to you. If you wish to cancel your account or request that FlexiLoans no longer use your Information to provide services, you may contact FlexiLoans at email@example.com. Although FlexiLoans may have to retain and use your Information if necessary to comply with its legal obligations, resolve disputes, and enforce its agreements. If you are no longer an employee of FlexiLoans, please note that We will not retain your Sensitive Personal Data or Information / Personal Information longer than is necessary for the purposes for which it was obtained, unless it is required to be retained as part of a statutorily mandated obligation.
FlexiLoans understand that storing data in a secure manner is important. We store Sensitive Personal Data or Information/Personal Information using industry standard, reasonable and technically feasible, physical, technical and administrative safeguards against foreseeable risks, such as unauthorized access. Any transactions that take place on the Website are processed through our secure server in order to make every reasonable effort to ensure that your Sensitive Personal Data or Information/Personal Information is protected.
While FlexiLoans strives to protect your Sensitive Personal Data or Information/Personal Information, it cannot ensure or guarantee that the Sensitive Personal Data or Information/Personal Information or private communications you transmit to us will always remain confidential, and you do so at your own risk. If a password is used to help protect your accounts and Sensitive Personal Data or Information/Personal Information, you are responsible for keeping your password confidential. Do not share this information with anyone. If you are sharing a computer with anyone you should always log out before leaving the Website or service to protect access to your information from subsequent users.
While no website can guarantee security, we have implemented appropriate administrative, technical, and physical security procedures to help protect the Sensitive Personal Data or Information/Personal Information you provide to us as specified under applicable laws. We ensure that only authorized employees are permitted to access Sensitive Personal Data or Information/Personal Information, and they only may do so for permitted business functions. Please be aware that the Website and data storage run on software, hardware and networks, any component of which may, from time to time, require maintenance or experience problems or breaches of security beyond our control.
CHANGES IN POLICY AND ACCEPTANCE
LIMITATION OF LIABILITY
A “Force Majeure Event” shall mean any event that is beyond the reasonable control of FlexiLoans and shall include, without limitation, sabotage, fire, flood, explosion, acts of God, civil commotion, strikes, lockouts or industrial action of any kind, riots, insurrection, war, acts of government, computer hacking, civil disturbances, unauthorised access to computer data and storage device, computer crashes, breach of security and encryption, and any other similar events not within the control of FlexiLoans and which FlexiLoans is not able to overcome.
You have the option to ‘opt-out’ of all FlexiLoans’ newsletters and other general e-mail marketing communications by way of links provided at the bottom of each mailer. FlexiLoans respects your privacy and in the event that you choose to not receive such mailers, it shall take all adequate steps to remove you from such lists. However, you will not be able to opt-out of receiving administrative messages, customer service responses or other transactional communications.
In accordance with the Act and Rules made there under, the name and contact details of the Grievance Officer are provided below: Name: Mr. Manish Lunia Address: One World Center, Indiabulls Financial Center Tower-2, 7th Floor, South Annexe, 841, Senapati Bapat Marg, Saidham Nagar, Lower Parel, Mumbai, Maharashtra 400013 Phone: 022-68219546 Mobile: 9594050156 Email: firstname.lastname@example.org
Rule 2 (i)“Personal information” means any information that relates to a natural person, which, either directly or indirectly, in combination with other information available or likely to be available with a body corporate, is capable of identifying such person. Rule 3“Sensitive personal data or information” of a person means such personal information which consists of information relating to:-password; financial information such as Bank account or credit card or debit card or other payment instrument details; physical, physiological and mental health condition; sexual orientation; medical records and history; Biometric information; any detail relating to the above clauses as provided to body corporate for providing service; any of the information received under above clauses by body corporate for processing, stored or processed under lawful contract or otherwise: Provided that, any information that is freely available or accessible in public domain or furnished under the Right to Information Act, 2005 or any other law for the time being in force shall not be regarded as sensitive personal data or information for the purposes of these rules.