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Privacy Policy

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.

SCOPE

This privacy policy (“Privacy Policy”) is an electronic record in the form of an electronic contract formed under the Information Technology Act, 2000 and the rules made thereunder. This Privacy Policy does not require any physical, electronic or digital signature. This Privacy Policy is a legally binding document between you and FlexiLoans. The terms of this Privacy Policy will be effective upon your acceptance of the same, by clicking on the “I Accept” checkbox available at https://loans.flexiloans.com/ and will govern the relationship between you and FlexiLoans for your use of the Website. By clicking on the “I Accept” checkbox, you also authorize us to contact you if you are registered with DND/NDNC registry. This Privacy Policy describes the information that we collect from you, how We collect this information (directly or through third parties or which is automatically generated, when you interact with our Website and our mobile application (Mobile App)) and what We do with it after We collect it.

GENERAL DEFINITIONS

Reference to “you” or “your” in this Privacy Policy refers to any natural person (including the employees of FlexiLoans) who provides to FlexiLoans any information referred in Schedule 1 of this document or any user(s) of FlexiLoans Website or business applications whether or not, you avail the Services offered by FlexiLoans. “Act” shall mean the Information Technology Act, 2000 and Rules thereunder as amended from time to time. “Information” shall mean and include Personal Information and Sensitive Personal Data or Information as may be collected by FlexiLoans. “Personal Information” shall have the same meaning as under Rule 2 (i) of the Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011 as amended from time to time. For ease of reference Rule 2 (i) of the Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011 is re-produced under Schedule 1. “Rules” shall mean the Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011 as amended from time to time. “Registered User” shall mean such user whose registration is accepted by FlexiLoans. “Sensitive Personal Data or Information” shall mean and include information under Rule 3 of the Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011 as amended from time to time. For ease of reference Rule 3 of the Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011 is re-produced under Schedule 1. “Services” for the purpose of this Privacy Policy shall mean any person who by way of registration has sought or in any manner has requested the services of FlexiLoans. All words and expressions used and not defined in this document but defined in the Act or the Rules shall have the meanings respectively assigned to them in the Act or the Rules. FlexiLoans is fully committed to respecting your privacy and shall ensure that your Information is safe. This Privacy Policy sets out the practices adopted in respect of Information, including the types of Information that is collected, how the Information is collected, how the Information is used, how long the Information is retained and with whom it is shared. This Privacy Policy is published in compliance with the provisions of the Act and the Rules made thereunder that require publishing the Privacy Policy on FlexiLoans Website. FlexiLoans urges you to read this Privacy Policy carefully before you use or opt to access any services of FlexiLoans or decide to part with any Personal Information including the information listed under Schedule 1.

USER CONSENT

By clicking on the “I Accept” checkbox, you expressly consent and confirm to FlexiLoans collecting, maintaining, using, processing and disclosing your Sensitive Personal Data or Information and other Information in accordance with the terms set out in this Privacy Policy. If you do not agree with this Privacy Policy in its entirety, you must not use this Website or products and/or services provided on it. If you have any questions or comments regarding this Privacy Policy, please contact us atconnect@flexiloans.in

PRIVACY PRINCIPLES

At FlexiLoans, we may ask for and use your Sensitive Personal Data or Information/Personal Information and are committed to keeping this Information secure. In order to maintain the confidentiality of your Information, we maintain the following privacy principles including but not limited to the following: We only collect Sensitive Personal Data or Information/Personal Information that is relevant and is required to gauge your financial abilities and to conduct our business. We use your Sensitive Personal Data or Information/Personal Information to provide you with better customer services and products. We may pass your Sensitive Personal Data or Information/Personal Information to our affiliates or any agent or third-party service provider unless prohibited by laws and regulations. We will not disclose your Sensitive Personal Data or Information/Personal Information to any external organization unless we have your consent or are required by laws and regulations. We may disclose your Sensitive Personal Data or Information/Personal Information required by any regulatory agencies, but we will only do so under proper authority. We maintain strict security systems designed to prevent unauthorized access to your Sensitive Personal Data or Information/Personal Information by anyone, including our staff. This Privacy Policy talks about why we ask for Sensitive Personal Data or Information/Personal Information and how we keep it secure. We request you to review our Privacy Policy from time to time because your use of our products and services implies your acceptance of the prevailing Privacy Policy, including any amendments thereto.

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

FlexiLoans allows you to sign up and log in using your Facebook account. If you sign up using Facebook, Facebook will ask your permission to share certain information from your Facebook account with FlexiLoans. This includes your first name, last name, email address in order for us to verify your identity and gender, general location, a link to your Facebook profile, your time zone, birthday, home town, education history, work history, tagged places, profile picture, relationship status, your “likes” and your list of friends. This Information is collected by Facebook and is provided to us under the terms of Facebook’s privacy policy. You can control the Information that we receive from Facebook using the privacy settings in your Facebook account.

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.
To comply with any legal obligation, or in order to enforce or apply the Terms of Use (displayed on the Website), or to protect the rights, property or safety of FlexiLoans, its Users or others. This includes exchanging information with other companies/agencies that work for fraud prevention and credit reference.
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

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.

INFORMATION SECURITY

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.

SECURITY ASSURANCE

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

You may be able to access third party websites directly from our FlexiLoans website. With this Privacy Policy, we are only addressing the disclosure and use of data collected by us. If you visit any other websites through the links on the FlexiLoans website, you should properly review the privacy policies of each of those websites. Their data collection practices and their policies might be different and FlexiLoans does not have control over any of their policies and FlexiLoans disclaims all responsibility or liability with respect to these policies or the websites. If it so happens that FlexiLoans is part of a merger, acquisition or amalgamation, your data might be part of the deal with that third party and will be transferred to them.

REFERRALS

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 connect@flexiloans.in to request that this information be removed from FlexiLoans’ database.

TESTIMONIALS

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 connect@flexiloans.com

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 connect@flexiloans.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.

CHANGES TO PRIVACY POLICY

In the event FlexiLoans modifies this Privacy Policy, the same will be updated on the Website. In case of any material changes to the Privacy Policy, you will be notified by email (sent to the email address specified in the Users’ mail account) or by means of a notice on this Website prior to the change becoming effective. The Users are encouraged to periodically review this page for the latest information on its privacy practices.

SEVERABILITY

FlexiLoans has made every effort to ensure that this Privacy Policy adheres with the applicable laws. The invalidity or unenforceability of any part of this Privacy Policy shall not prejudice or affect the validity or enforceability of the remainder of this Privacy Policy.

SECURITY

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

FlexiLoans may from time to time update this Privacy Policy. FlexiLoans will ensure to place a notice on the top of this page with the latest updated date. Accordingly, you should check the Privacy Policy on a regular basis for the most current privacy practices. Each time you access, use or browse the Website, you signify your acceptance of the then-current changes to the Privacy Policy applying to your Information collected by us, on and from the effective date of such changes.

LIMITATION OF LIABILITY

Notwithstanding anything contained in this Privacy Policy or elsewhere, FlexiLoans shall not be held responsible for any loss, damage or misuse of your Sensitive Personal Data or Information/Personal Information, if such loss, damage or misuse is attributable to a Force Majeure Event (as defined below).
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.

OPT-OUT

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.

CONTACT US

If you have any questions about this Privacy Policy, please e-mail them to connect@flexiloans.com or call us at 022-68219546

GRIEVANCE OFFICER

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: compliance@epimoney.com

SCHEDULE 1

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.