Regulatory

INTRODUCTION:

This document is an electronic record in terms of the Information Technology Act, 2000 and rules thereunder as applicable and the provisions pertaining to electronic records in various statutes as amended by the Information Technology Act, 2000. This electronic record is generated by a computer system and does not require any physical or digital signatures.

This document is published in accordance with the provisions of Rule 3(1) of the Information Technology (Intermediaries Guidelines) Rules, 2011 that requires publishing the rules and regulations, privacy policy and terms of use for access or usage of this website.

The domain name FlexiLoans.com (“Website”) is owned by Epimoney Private Limited, a RBI registered Non-banking Financial Company (NBFC) and a private company incorporated under the Companies Act, 2013 with its registered office at No.119, 2nd Floor, Greenways Towers, St. Mary's Road, Abhiramapuram, Chennai – 600 018 and its Corporate Office at 7th Floor, South Annexe, Tower 2, One World Centre 841, Senapati Bapat Marg, Saidham Nagar, Lower Parel, Mumbai – 400013 (hereinafter referred to as “FlexiLoans”, which expression shall, unless it be repugnant to the context or meaning thereof, be deemed to include its successors, affiliates, partners and permitted assigns). The objective of the Website is to facilitate the lending and borrowing of capital, in accordance with the terms of the loan agreement to be executed between you and Epimoney.

For the purpose of these Terms of Use (“Terms”), wherever the context so requires, the term:

“Borrower” shall mean a proprietorship concern, partnership firm, limited liability partnership and an incorporated company carrying on business in India, which is willing to borrow, using the Website and is registered as a ‘borrower’ on the Website.

“Epimoney’s Lending Partner” shall mean one or more financial institutions with whom Epimoney may propose to jointly extend credit facilities to the Borrower.

“Force Majeure Event” shall mean any event that is beyond the reasonable control of FlexiLoans and shall include, without limitation, sabotage, fire, flood, explosion, act 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, virus attacks, breach of security and encryption, and any other similar events not within the control of FlexiLoans and which FlexiLoans is not able to overcome.

FlexiLoans reserves the right, at its sole discretion, to change, modify, add or remove portions of these Terms of Use (“Terms”), at any time without any prior written notice to the Borrower. It is the Borrower’s sole responsibility to review these Terms periodically for updates or changes. The Borrower’s use of the Website or availing the Services through the Website in any way following the posting of changes shall be deemed to mean that the Borrower accepts and agrees to the revisions. As long as the Borrower complies with these Terms, FlexiLoans grants the Borrower a personal, non-exclusive, non-transferable, limited privilege to access and use the Website.

Accessing, browsing or otherwise using the Website which includes but is not limited to availing the Services provided through the Website, indicates that Borrower has read, understood and agreest to all the terms and conditions under these Terms. Borrower is advised to read these Terms carefully before proceeding. By impliedly or expressly accepting these Terms, the Borrower also accepts and agrees to be bound by all FlexiLoans’ policies, including but not limited to its Privacy Policy as amended from time to time.

MEMBERSHIP ELIGIBILITY:

Use of the Website is available only to persons who can enter into legally binding contracts under the Indian Contract Act, 1872. Persons who are “incompetent to contract” within the meaning of the Indian Contract Act, 1872 including minors, un-discharged insolvents and persons of unsound mind are not eligible to use the Website. Any person under the age of 18 shall not register as a Borrower on the Website and shall not transact on or use the Website. FlexiLoans reserves the right to terminate any person’s membership and/or refuse to provide such person with access to the Website if it is brought to FlexiLoans’ notice or if it is discovered that such person is not eligible to use the Website. In case you are using the Website and opening an account on the Website on behalf of an incorporated entity, it is presumed that you have been authorised by the entity and your use of the Website shall bind the entity with respect to these Terms. If the user violates any of these Terms and Condition from time to time and such revision/modification shall be effective upon posting by us on the website. The member should agree to be bound to any changes to this Terms & Condition when they use such services after such modification is posted. It is therefore important that the members review the Terms & Conditions regularly upon each use of the services to ensure any updates as to changes. The Website is intended for users within India only.

ACCEPTANCE OF TERMS AND CONDITIONS:

We, at FlexiLoans provide an independent online service which facilitates your access to loans and related financial services and other products or services provided by our partner financial institutions whilst using this Website. We receive a fee and/or commission from the partners when you use our service to purchase products or services from them.

By making use of this Website and furnishing your personal/contact details, you hereby agree that you are interested in availing and purchasing the services that you have selected. You hereby agree that FlexiLoans/ FlexiLoans’ partner financial institutions may contact you either electronically or through phone, to understand your interest in the selected products and services and to fulfil your demand. You also agree that FlexiLoans reserves the right to make your details available to any of our authorized members/ agents or partners/Epimoney’s Lending Partner and you may be contacted by them for information and for sales through email, telephone and/or text message. You agree to receive promotional materials and/or special offers from FlexiLoans through email or text message. If you are in any doubt as to the suitability, adequacy or appropriateness of any product or service referred to on this Website, we suggest that you seek independent professional advice before you obtain any product or service via this Website.

As a user of this Website (hereinafter referred to as the “User(s)”) you have agreed to the Terms & Conditions that FlexiLoans has provided hereunder or anywhere else in this Website, including but not limited to disclaimers on this Website. You agree to read and understand the said Terms & Conditions and the Terms and Conditions establish a contractual relationship between the User and FlexiLoans. The Offer of Services on the Website is conditional upon the User’s irrevocable consent and acceptance of all the terms, conditions and obligations contained in the Terms and Conditions, which may be amended from time to time.

You undertake and acknowledge that,
I. For the purpose of assessing your credit worthiness, Epimoney is authorized to pull from CIBIL and/or any other agency authorized by RBI, data of the applicant(s), directors, group companies, and any other individuals who are involved in the said business, on behalf of which this loan application is made;
II. CIBIL and any other agency so authorized may use, process the said information and data disclosed by Epimoney in the manner as deemed fit by them;
III. CIBIL, and any other agency so authorized may furnish for consideration, the processed information and data or products thereof prepared by them, to banks/financial institutions and other credit grantors or registered users, as may be specified by the RBI in this behalf;
IV. For the purpose of verification of my/our personal data, Epimoney is authorized to pull from Central KYC Records Registry, ‘Know Your Customer’ data of the applicant(s), directors, group companies, and any other individuals who are involved in the said business, on behalf of which this loan application is made; and
V. For the purpose of assessing our credit worthiness, Epimoney is authorized to fetch Goods and Service Tax returns/data, of the applicant(s), group companies, on behalf of which this loan application is made.

BORROWER’S ACCOUNT:

The Website allows very limited and restricted access to the Services for unregistered users.In order for a Borrower to avail the Services from FlexiLoans through the Website, the Borrower is required to create an account on the Website (“Account”) and provide FlexiLoans with certain user information/documentation for verification, which shall include your name, phone number, your address, your date of birth, your e-mail address, your gender, your financial information such as bank account, bank account statement or credit card or debit card or other payment details, your permanent account number, aadhar number, details of your income tax returns (hereinafter collectively referred to as “Customer Data”). You hereby understand and provide an explicit consent to FlexiLoans and Epimoney to share the Customer Data with any co-lending partner of Epimoney for the following purposes: (1) Collection, storage, preservation, analysis, publishing and dissemination, at any time, of all the Customer Data, as the case may be; (2) Verification or authentication of Customer Data, making related enquiries on the basis of the Customer Data for the purpose of assessing eligibility for loan and/or value added services opted/ availed by me from/ through Epimoney and any co-lender; and (3) for complying with the laws applicable from time to time.

In addition to the above, FlexiLoans reserves the right to request the Borrower to provide such other information/documentation as it may deem fit. FlexiLoans reserves the right to reject the request for creation of the account, at its sole discretion, if the information submitted appears to be incomplete, incorrect or fraudulent.

BORROWER OBLIGATIONS:

The Borrower will be responsible for maintaining the confidentiality of the login credentials and the Account information and shall be fully responsible for all activities that occur under the Account. The Borrower agrees to, (i) immediately notify FlexiLoans of any unauthorised use of the Account information or any other breach of security; and (ii) ensure that the Borrower exits from the Account at the end of each session. FlexiLoans cannot and will not be liable for any loss or damage arising from the Borrower’s failure to comply with this Clause. The Borrower may be held liable for losses incurred by FlexiLoans or any user or visitor of the Website due to authorised or unauthorised use of the Account, as a result of the Borrower’s failure in keeping the Account information confidential.

The Borrower shall ensure that the Account information provided by the Borrower in the Website’s registration form is complete, accurate and up-to-date. Use of another Borrower’s account information for availing the Services of the Website is expressly prohibited.

The Borrower agrees that if the Borrower provides any information that is untrue, inaccurate, not current or incomplete, (or becomes untrue, inaccurate, not current or incomplete) or if FlexiLoans has reasonable grounds to suspect that such information is untrue, inaccurate, not current, incomplete, or not in accordance with the these Terms, FlexiLoans shall have the right to indefinitely suspend or terminate or block access to the Account on the Website and refuse to provide the Borrower with access to the Website..

USE OF WEBSITE:

The Borrower agrees, undertakes and covenants that, during the use of the Website, the Borrower shall not host, display, upload, modify, publish, transmit, update or share any information that:

• Belongs to another person or entity and to which the Borrower does not have any right.

• Is grossly harmful, harassing, blasphemous, defamatory, obscene, pornographic, paedophilic, libellous, invasive of another’s privacy, hateful or racially or ethnically objectionable, disparaging or encouraging money laundering or gambling, or otherwise unlawful in any manner whatsoever.

• Is misleading in any way.

• Involves the transmission of “junk mail”, “chain letters”, or unsolicited mass mailing or “spamming”.

• Infringes upon or violates any third party’s rights including, but not limited to, intellectual property rights, rights of privacy (including without limitation unauthorized disclosure of a person’s name, email address, physical address or phone number) or rights of publicity.

• Tries to gain unauthorized access or exceeds the scope of authorized access to the Website or to profiles, blogs, communities, account information, bulletins, or other areas of the Website or solicits passwords or personally identifying information for commercial or unlawful purposes from other Borrowers.

• Interferes with another Borrower’s use and enjoyment of the Website.

• Refers to any website or URL that, in FlexiLoan’s sole discretion, contains material that is inappropriate for the Website or any other website, contains content that would be prohibited or violates the letter or spirit of these Terms.

• Contains software viruses or any other computer codes, files or programs designed to interrupt, destroy or limit the functionality of any computer resource; or contains any trojan horses, worms or other computer programming routines that may damage, detrimentally interfere with, diminish value of, surreptitiously intercept or expropriate any system, data or personal information.

MONITORING OF WEBSITE AND MEMBER’S ACCOUNT:

FlexiLoans has the right and liberty to monitor the content of the Website at all times which shall include information provided in your account. The monitoring of the Website is important to determine the veracity of the information provided by you and that every User remains in consonance with the Terms & Conditions provided herein. Subject to the Terms & Conditions mentioned herein FlexiLoans shall also have the liberty to remove any objectionable content which is in contravention of the Terms & Conditions herein or share such information with any governmental authority as per procedures laid down by the law for the time being in force in India.

LICENSE AND SITE ACCESS:

FlexiLoans grants you a limited license to access and make personal use of the Site. This license does not include any downloading (other than page caching) or modifying it, or any portion of it (except with express written consent of FlexiLoans); unauthorized hypertext links to the Site and the framing of any content available through the Site; uploading, posting, or transmitting any content that you do not have a right to make available (such as the intellectual property of another party); uploading, posting, or transmitting any material that contains software viruses or any other computer code, files or programs designed to interrupt, destroy or limit the functionality of any computer software or hardware or telecommunications equipment; any action that imposes or may impose an unreasonable or disproportionately large load on FlexiLoans’ infrastructure; or any use of data mining, robots, or similar data gathering and extraction tools. This website or any portion of this website (including but not limited to any copyrighted material, trademarks, or other proprietary information) may not be reproduced, duplicated, copied, sold, resold, visited, distributed or otherwise exploited for any commercial purpose without express written consent of FlexiLoans and / or its affiliates, as may be applicable. The member may not bypass any measures used by FlexiLoans to prevent or restrict access to the Site. Any unauthorized use by them shall terminate the permission or license granted to you by FlexiLoans. By using this Site and by accepting to agree to these Terms & Conditions they also agree that they shall not hack or otherwise hire some third party to hack the Site or use any other unauthorized means without a written consent of FlexiLoans and access any third-party information. The members shall in such an event be liable of a criminal offence and FlexiLoans shall institute appropriate legal proceedings to claim damages.

FEEDBACK:

FlexiLoans may allow members to post their review and experience of using the Website and the Services (“Reviews “) in order to improve the Website, the Services and the user experience.

User, being the originator of the Reviews, are responsible for the Reviews that they upload, post, publish, transmit or otherwise make available on the Website. Members represent that all such Reviews will be in accordance with applicable law. They acknowledge that FlexiLoans does not endorse any Reviews on the Website and is not responsible or liable for any Reviews. FlexiLoans reserves the right to disable access to the Reviews on the Website.

User hereby grant FlexiLoans a perpetual, non-revocable, worldwide, royalty-free and sub-licensable right and license to use, copy, distribute, display, publish, transmit, make available, reproduce, modify, adapt the Reviews in any manner as deemed appropriate by FlexiLoans in any form including but not limited to print, broadcast, online and across any and all websites and platforms owned by FlexiLoans.

Users further represent and warrant that while posting any Reviews on the Website they shall not use any offensive, libellous, derogatory, hateful or racially or ethnically objectionable language. Further, they shall not post any content on the Website that is obscene, pornographic, constitutes an “indecent representation of women” as provided in the Indecent Representation of Women (Prohibition) Act, 1986.

CONFIDENTIALITY:

As elaborated under the Privacy Policy, FlexiLoans will keep all confidential information confidential, including the Borrower’s personal and business information, and shall not disclose it to anyone except as required by law, and shall ensure that such confidential information is protected with security measures and a degree of care that it would apply to its own confidential information. FlexiLoans acknowledges that its employees, directors, agents and contractors shall use the confidential information only for the intended purpose for which it is provided. FlexiLoans shall use all reasonable endeavours to ensure that its employees, directors, agents and contractors acknowledge and comply with the provisions of these Terms of confidentiality as if such person was subject to these Terms of confidentiality.

ADVERTISERS / LINKS TO THIRD-PARTIE’S WEBSITE:

The Website may contain links and interactive functionality interacting with the websites of third parties. FlexiLoans is not responsible for and has no liability for the functionality, actions, inactions, privacy settings, privacy policies, terms, or content of any such website. Before enabling any sharing functions to communicate with any such website or otherwise visiting any such website, FlexiLoans strongly recommends that the Borrower reviews and understands the terms and conditions, privacy policies, settings, and information-sharing functions of each such third-party website.

INDEMNIFICATION:

The Borrower shall indemnify, save and hold harmless FlexiLoans, its owner, licensors, licensee, affiliates, contractors, subsidiaries, group companies (as applicable) and their respective officers, directors, agents, and employees, from any claim or demand, or actions including reasonable attorneys’ fees, made by any third party or penalty imposed due to or arising out of the Borrower’s breach of these Terms, Privacy Policy and other policies, or the Borrower’s violation of any law, rules or regulations or the rights (including infringement of any intellectual property rights) of a third party. FlexiLoans reserves the right, at your expense, to assume the exclusive defense and control of any matter for which you are required to indemnify FlexiLoans, including rights to settle, and you agree to cooperate with FlexiLoans’ defense and settlement of these claims. FlexiLoans will use reasonable efforts to notify you of any claim, action, or proceeding brought by a third party that is subject to the foregoing indemnification upon becoming aware of it.

TERMINATION:

FlexiLoans, in its sole discretion, may modify, suspend, or terminate access to, all or any portion of the Website at any time for any reason including termination for breach of any of these Terms.

None of the Borrower’s content shall remain accessible on the Website upon termination. This information cannot be recovered by the Borrower, once the account is terminated.

The disclaimer of warranties, the limitation of liability, and the governing law provisions shall survive any termination of these Terms.

DISCLAIMER OF WARRANTIES:

The website and all information, content, materials and services included on or otherwise made available to the borrower through the website (collectively, the “contents “) are provided by Flexiloans on an “as is,” “as available” basis, without representations or warranties of any kind. Flexiloans makes no representations or warranties of any kind, express or implied, as to the operation of the website, the accuracy or completeness of the contents and the accuracy of the information or receipt of loans. Flexiloans shall have no responsibility for any damage to the borrower’s computer system or loss of data that results from the download of any content, materials, document or information or any other losses incurred by the borrower for failure to receive loans. The borrower expressly agrees that the use of the website is at the borrower’s sole risk. Flexiloans will not be liable for any damages of any kind arising from the use of the website or the services or the contents including, without limitation, direct, indirect, consequential, punitive, and consequential damages, unless otherwise specified in writing. To the full extent permitted by law, Flexiloans disclaims any and all representations and warranties with respect to the website and its contents, whether express or implied, including, without limitation, warranties of title, merchantability, and fitness for a particular purpose or use. No advice or information, whether oral or written, obtained by you from FlexiLoans through or from the service will create any warranty not expressly stated in these Terms & Conditions.

LIMITATION OF LIABILITY:

In no event shall Flexiloans, its directors, employees or agents, be liable for any special, incidental, indirect or consequential damages whatsoever resulting from any (i) errors, mistakes, or inaccuracies of content; (ii) personal injury or property damage, of any nature whatsoever, resulting from the borrower’s access to and use of the website; (iii) any unauthorized access to or use of the secure servers and/or any and all personal and/or business and/or financial information stored therein; (iv) any interruption or cessation of transmission to or from the website; (v) any bugs, viruses, trojan horses, or the like, which may be transmitted to or through the website by any third party; and/or (vi) any errors or omissions in any content or for any loss or damage of any kind incurred as a result of the use of any content posted, emailed, transmitted, or otherwise made available via the website, whether based on warranty, contract, tort, or any other legal theory, and whether or not Flexiloans is advised of the possibility of such damages. Subject to the above and notwithstanding anything to the contrary contained in these terms, the maximum aggregate liability (whether in contract, tort (including negligence) or equity) of Flexiloans vis-à-vis any borrower, regardless of the form of claim, shall be limited to the aggregate of fees, if any, paid by the borrower to Flexiloans. The foregoing limitations of liability will apply notwithstanding the failure of essential purpose of any limited remedy herein. This limitation of liability clause shall prevail over any conflicting or inconsistent provision contained in any of the documents / content comprising this Terms & Conditions. It is up to you to take precautions to ensure that whatever you select for your use is free of such items as viruses, worms, malware, Trojan horses and other items of a destructive nature.

SEVERABILITY:

If a provision of these Terms is determined by any court or other competent authority to be unlawful and/or unenforceable, the other provisions will continue in effect. If any unlawful and/or unenforceable provision would be lawful or enforceable if part of it were deleted, that part will be deemed to be deleted, and the rest of the provision will continue in effect.

CONTENT AND INTELLECTUAL PROPERTY RIGHTS:

FlexiLoans solely and exclusively owns copyrights, trademarks, service marks, logos, trade names, and other intellectual and proprietary rights associated with the Website and content on the Website and is protected under Indian law.

You hereby acknowledge that the Website constitutes original work and has been developed, compiled, prepared, revised, selected, and arranged by FlexiLoans through the application of methods and standards of judgment developed and applied through the expenditure of substantial time, effort, and money and constitutes valuable intellectual property of us and such others. You thereby agree to protect the proprietary rights of FlexiLoans during and after the term of these Terms. You may not selectively download portions of the Website without retaining the copyright notices. You may download material from the Website only for your own personal use and for no commercial purposes whatsoever.

Any infringement shall lead to appropriate legal proceedings against you at appropriate forum for seeking all available remedies under applicable laws of the country.

FORCE MAJEURE:

FlexiLoans shall not be liable to you for its failure to perform or for delay in providing you access to your Account or to the Website, to the extent such failure or delay results from causes beyond its control, including, without limitation, acts of God, fires, explosions, wars or other hostilities, insurrections, revolutions, strikes, labour unrest, earthquakes, floods, epidemics or quarantine restrictions, unforeseeable governmental restrictions or controls or a failure by a third party hosting provider or internet service provider or on account of any change or defect in the software and/or hardware of your computer system.

GOVERNING LAW AND DISPUTE RESOLUTION:

These Terms shall be governed by and interpreted and construed in accordance with the laws of India. The place of jurisdiction shall exclusively be in Mumbai, Maharashtra, India. In the event of any dispute arising out of these Terms the same shall be settled by a binding arbitration conducted by a sole arbitrator, appointed jointly by both parties and governed by the Arbitration and Conciliation Act, 1996. The venue of arbitration shall be Mumbai, Maharashtra and the arbitration proceedings shall be conducted in English language. If any provision of these terms is found to be invalid or unenforceable by a Court of Law, such invalidity or unenforceability will not affect the remainder of the Terms & Conditions which will continue in full force and effect

ASSIGNMENT:

It is expressly agreed by the parties that FlexiLoans may assign all or part of its rights or duties under these Terms without such assignment being considered a change to these Terms and without notice to you, except to the extent provided by law.

GRIEVANCE REDRESSAL MECHANISM:

In accordance with the Information Technology Act, 2000 and Rules made thereunder, the name and contact details of the Grievance Officer are provided below:

Name: Mr. Manish Lunia

Address: 7th Floor, South Annexe, Tower 2, One World Centre 841, Senapati Bapat Marg, Saidham Nagar, Lower Parel, Mumbai – 400013.
Phone: 022-62603800
E-mail: nodal.grievance@epimoney.com

HOW TO CONTACT US:

If you have questions or concerns about this Policy, please contact us at compliance@epimoney.com or call us on 022-62603800.

• Preamble:

The Reserve Bank of India (RBI) vide its Master directions dated September 01, 2016 and as amended from time to time, issued guidelines on Fair Practices Code (FPC) for all NBFCs to be adopted by them while doing lending business.

• Introduction

The Domain name flexiloans.com (“website”) is owned by Epimoney Private Limited,
(“the Company”). The Company is a Non-Banking Finance Company registered with Reserve Bank of India (“RBI”) having its registered office at No.119, 2nd Floor, Greenways Towers, St. Mary's Road, Abhiramapuram, Chennai – 600 018 and its corporate address at 7th Floor, South Annexe, Tower 2, One World Centre 841, Senapati Bapat Marg, Saidham Nagar, Lower Parel, Mumbai – 400013 is in the business of providing different types of collateral free loans for business which includes Working Capital Loan, Invoice Financing etc., to its various customers. Such credit facilities are extended to different types of customers, which include Individuals, Partnership Firms, Companies and other Legal entities.

The Company has framed and adopted a voluntary code, which sets out the principles for fair practice standards when dealing with customers. As per the RBI directives, we have adopted and will implement this Code in our organization which has been duly approved by Board of Directors of the Company. This Fair Practices Code applies to the all categories of products and services offered by the Company (currently offered or which may be introduced at a future date).

It is, and shall be, our policy to make credit products available to all qualified applicants without discrimination on the basis of race, caste, color, religion, sex, marital status, age (over that of majority), or handicap and the Company will provide appropriate clarification to the customers, if there is any sort of discrimination in the product offered, interest charged and grievance sought by the customer.

Our policy is to treat all the clients consistently and fairly. Our employees will offer assistance, encouragement and service in a fair, equitable and consistent manner. 
We will also communicate this Fair Practice Code (“Code”) to our customers by placing it on the Company’s website. 

We shall ensure that charges/fees which affect the interest of the prospective borrowers are appropriately informed to the borrower. Terms and conditions pertaining to the facility will be conveyed to prospective borrowers. We commit that disputes arising out of the lending decisions will be appropriately resolved by a grievance redressal mechanism set up by us. 

This Fair Practice Code is applicable to all facilities and services provided by the Company whether the same is provided over the phone, by post, through interactive electronic devices, on the internet or by any other method we maybe currently using or may introduce at a future date.

• Key Commitments

The Company’s key commitments to customers:

• Act fairly and reasonably in all their dealings with customers by:
  • Meeting the commitments and standards in this Code, for the products and services the Company offers and, in the procedures and practices its staff follows.
  • Making sure that Company’s products and services meet relevant laws and regulations. Company’s dealings with customers will rest on ethical principles of integrity and transparency.
• Help customers understand how Company’s products work by:
  • Explaining their financial implications.
  • Providing information about them in simple Hindi and/ or English and/or the local language. 
  • Help the customer choose the one that meets his/her needs the best.
• Deal quickly and sympathetically with things that go wrong by:
  • Correcting mistakes quickly by acting in a timely manner and handling the customer’s complaints effectively in a time bound manner
  • Telling customers’ how to take their complaint forward if they are still not satisfied.
• Publicize this Code, put it on Company’s website and have copies available for customer on request.
• Information
  • Helping customer choose products and services, which meet their needs and give them clear information explaining the key features of the services and products they are interested in.
  • Inform customers about the documentary information the Company needs from them to establish customer’s true identity and address and, other documents to comply with legal and regulatory requirements.
• Applications for loans and their processing

1. • All communications to the borrower shall be in the vernacular language/ Hindi/ English or a language as understood by the borrower.

• • The Loan application forms of the Company will include necessary information which affects the interest of the borrower, so that a meaningful comparison with the terms and conditions offered by other NBFCs can be made and informed decision can be taken by the borrower. The loan application form will indicate the documents required to be submitted with the application form.
  • The Company will have a system of giving acknowledgement for receipt of all loan applications. The time frame /within which loan applications will be disposed of will be indicated in the acknowledgement.
• Loan appraisal and terms/conditions

The Company will convey in writing to the borrower in the vernacular language/ Hindi/ English or a language as understood by the borrower by means of sanction letter or otherwise, the amount of loan sanctioned along with the terms and conditions including annualised rate of interest and method of application thereof and keep the acceptance of these terms and conditions by the borrower on its record. The Company will mention the penal interest charged for late repayment in bold in the loan agreement.

The Company will furnish a copy of the loan agreement preferably in the language as understood by the borrower along with a copy each of all enclosures quoted in the loan agreement to all the borrowers at the time of sanction / disbursement of loans based on declaration obtained from the customer on his/her preferred language of communication

• • Disbursement of loans including changes in terms and conditions
  • The Company will give notice to the borrower in the vernacular language/ Hindi/ English or a language as understood by the borrower of any change in the terms and conditions including disbursement schedule, interest rates, service charges, prepayment charges etc. The Company may communicate via writing or updating on Company’s website, of any change in the terms and conditions. The Company should also ensure that changes in interest rates and charges are effected only prospectively. A suitable condition in this regard should be incorporated in the loan agreement.
  • Decision to recall / accelerate payment or performance under the agreement will be in consonance with the loan agreement.
  • The Company will release all securities on repayment of all dues or on realization of the outstanding amount of loan subject to any legitimate right or lien for any other claim the Company may have against borrower. If such right of set off is to be exercised, the borrower will be given notice about the same with full particulars about the remaining claims and the conditions under which the Company is entitled to retain the securities till the relevant claim is settled / paid.
• Confidentiality

The Company shall treat all information of the borrower as private and confidential, this shall even apply after the repayment of all money due to us from the borrower. 

The Company shall not reveal transaction details to any other person other than the following exceptional cases:

• • • • ​ If required to provide the information relating to a borrower by law or under an order of government, statutory, regulatory authority.  
      • Associate / entities or companies for providing other services or products

• General
  • The Company will refrain from interference in the affairs of the borrower except for the purposes provided in the terms and conditions of the loan agreement (unless new information, not earlier disclosed by the borrower, has come to the notice of the Company).
  • In the matter of recovery of loans, the Company will not resort to undue harassment viz. persistently bothering the borrowers at odd hours, use of muscle power for recovery of loans, etc. To avoid rude behavior from the staff of the Company, the Company shall ensure that the staff are adequately trained to deal with the customers in an appropriate manner to follow the Board approved policy that is in place in the form of Code of Conduct for the field staff to deal with the customers and avoid non-coercive methods of recovery.
  • In case of receipt of request from the borrower for transfer of borrowal account, the consent or otherwise – i.e., objection of the Company, if any – shall be conveyed to the borrower within 21 days from the date of receipt of any request. Such transfer shall be as per transparent contractual terms in consonance with law. 
• Further Assistance
  • A grievance redressal mechanism within the organization comprising Business Heads, Grievance Redressal Officer and Customer Service has been set up to resolve disputes arising in this regard. This Forum will ensure that all the disputes arising out of the decisions the Company’s functionaries are heard and disposed of at least at the next higher level.
  • There will be a periodical review of the compliance of the Code and the functioning of the grievances redressal mechanism at various levels of management. A consolidated report of such reviews will be submitted to the Board at regular intervals. Any change in the Fair Practice code shall be updated on the Company’s website.
  • The following information shall be displayed prominently, for the benefit of the customers, at all branches / places of the Company where business is transacted:
  • the contact details of the Grievance Redressal Officer who can be approached for resolution of complaints and for grievances in relation to Cyber Security/Cyber threats incidents faced by the customers against the Company is as set out below:

Name: Mr. Manish Lunia

Address: 7th Floor, South Annexe, Tower 2, One World Centre 841, Senapati Bapat Marg, Saidham Nagar, Lower Parel, Mumbai – 400013

Phone: 022-62603800

E-mail: nodal.grievance@epimoney.com

• • If the complaint / dispute is not redressed within a period of one month, the customer may appeal to the Officer-in Charge of the Regional Office of DNBS of RBI (complete contact details are set out below), under whose jurisdiction the registered office of the Company falls as displayed at all the operating offices of the company.

[The public notice should serve the purpose of highlighting to the customers, the grievance redressal mechanism followed by the Company, together with details of the Grievance Redressal Officer.]

• Posting on Website
  • Fair Practices Code, preferably in the vernacular language or a language as understood by the borrower should be put up on the web-site of the Company for the information of various stakeholders.
• Regulation of rate of interest
  • The Company has laid down appropriate internal principles and procedure in determining interest rates, processing fees and other charges. The Company has adopted an interest rate model taking into account relevant factors such as, cost of funds, margin and risk premium, etc. and determine the rate of interest to be charged for loans and advances. The rate of interest and the approach for gradations of risk and rationale for charging different rate of interest to different categories of customers shall be communicated explicitly in the sanction letter. The rates of interest and the approach for gradation of risks shall also be made available on the web -site of the Company. The information published on the website or otherwise published should be updated whenever there is a change in the rates of interest.
  • The rate of interest should be annualised rates so that the borrower is aware of the exact rates that would be charged to him.
  • The Company shall not charge foreclosure charges/ pre-payment penalties on floating rate term loans sanctioned, if any, to individual borrowers. 
• Review of the Policy

There will be an Annual review of the compliance of the Fair Practices Code and the functioning of the grievances redressal mechanism at various levels of management.
A consolidated report of such reviews will be submitted to the Board at regular intervals. 

Introduction:

The Domain name flexiloans.com (“website”) is owned by Epimoney Private Limited,
(“the Company”). The Company is a Non-Deposit taking Non-Banking Financial Company (NBFC) registered with the Reserve Bank of India (RBI) and is engaged in the business of providing financial assistance. As per extant guidelines of RBI, all NBFCs should ensure that a suitable mechanism exists for receiving and addressing complaints from its customers / constituents with specific emphasis on resolving such complaints fairly and expeditiously regardless of source of the complaints.

The Company is inter alia engaged in the business of providing financial assistance to various business entities including small and medium enterprises in the form of facilitating access to various loan products from time to time. In order to address the customer grievances while servicing the customers, the Company formulates the suitable mechanism to address such requirements. 

Objective:

The Grievance Redressal Mechanism is framed to provide best customer services and to comply with the Guidelines of Fair Practices Code prescribed by the Reserve Bank of India and the Fair Practices Code of the Company which inter-alia set out broad parameters for dealing with customers.

Brief description of the Policy:

The policy framework lays down requirements related to aspects of principal of grievances redressal, registration of complaints, escalation of complaints, resolution of complaints, periodic review of records.

Regulatory Requirements:

The Reserve Bank vide its Master Direction dated September 01, 2016 as amended from time to time, issued guidelines on Fair Practices Code (FPC) to be adopted by all NBFCs while doing lending business and to formulate the Customer Grievance Redressal Policy as duly approved by the Board and have to display details relating to Grievance Redressal Officer at their branches / places where business is transacted.

Risk type:

The policy intends to manage/mitigate Legal, Compliance and Operational Risk.

Grievance Assessment:

The policy stipulates the requirements related to registration of complaints, escalation of complaints, resolution of complaints and periodic review to grievances redressal.

Policy Review:

The Board shall review grievance redressal policy on annual basis or at earlier intervals, in case of any regulatory changes necessitating such interim reviews.

ANNEXURE A

GRIEVANCE REDRESSAL POLICY

Objective:

• The objective of the Grievance Redressal policy of the Company is to ensure the fair and equal treatment to all its customers without any bias -irrespective of caste, creed, race, gender, special abilities – on all occasions 
• The resolution of grievances is within defined Turn Around Time (TAT) 
• The resolution process is accelerated with proactive interventions by the Grievance Redressal Committee to cause nil distress to the customers 

Principles of grievance Redressal: 

• Our customers will be provided with information on how to raise their grievances or concerns at all offices and on website.
• The process to raise a complaint / escalation / grievance would involve only relevant investigative questions without any kind of hassle to the customer. 
• Resolutions would follow the simple principle of ensuring an efficient resolution. The responses would be in consistent with the RBI guidelines at all times as applicable to reduce customer grievances.  
• We shall always remain quick and consistent in providing necessary information or process requested by the customer.

Registration of complaints: 

The Company enables its customer’s to register complaints through multiple channels. The various channels available to customers are as follows: – 

• E-mail: Customers can send an email for redressal of issues. Respective Contact Numbers for Business Lines and their email ids are available on the website.
• Registered / Corporate / Administrative Offices: Customers can speak to the officials-in-charge at the Company’s offices for resolution of their issues or register their grievances at the Office Complaints Register available at reception. 
• Grievance Redressal Unit: Customers can reach out to a dedicated Number of Grievance Redressal Unit over phone and email which is updated on our website under section => Grievance Redressal.
• A Report containing number of complaints received, resolved, unattended during Financial Year, timeline for resolution and summary of such grievance is provided to the Board for their review of GR mechanism in order to streamline the process. well for reduction of complaints.

• Escalation of complaints:

Level 1: 

The customer may register his/her query/ complaint to the Company which shall be addressed to the Grievance Redressal Officer (GRO) in connection with any matter pertaining to business practices, lending decisions, credit management, recovery and complaints relating to updation / alteration of credit information. The details of the Grievance Redressal Officer are given as follows: 

Name of the Grievance Redressal Officer: Mr. Manish Lunia

Email id: nodal.grievance@epimoney.com  

Address: 7th Floor, South Annexe, Tower 2, One World Centre 841, Senapati Bapat Marg, Saidham Nagar, Lower Parel, Mumbai – 400013.

Tel: 022-62603800

Level 2: 

If the complaint is not resolved within 15 days, the customer shall complaint to the Compliance Head of the Company at his following email id: compliance@epimoney.com 

Level 3: 

If the complaint / dispute is not redressed within a period of 30 days from date of its receipt, the customer may appeal to: 

Deputy General Manager, 

Department of Non-Banking Supervision, 

Reserve Bank of India, 

Post Box No. 40, Chennai Post Office, Chennai

Policy Revision:

This policy is subject to revision based on the extant RBI guideline from time to time.

For FinTech/ Digital Lending related complaints:
For any complaints related to Fintech/ digital lending, contact us/ write to us at:
Grievance Redressal Officer: Mr. Manish Lunia
Contact Number: 022-62603800 – 10.30 am to 6.00 pm (Monday to Friday except National Holidays)
Email ID: nodal.grievance@epimoney.com

Epimoney Private Limited is RBI registered Non-Deposit taking Non-Banking Financial Company (NBFC) and it proposes to put its Base Rate of lending on its website. In order to ensure its standards of transparency, in conformity with the stipulations of the RBI’s directives, such interest rate policy is adopted by the Board. The policy is enumerated as under:-

 Interest Rate Policy:

Reserve Bank of India Vide its Master Direction – Non-Banking Financial Company – Non-Systemically Important Non-Deposit taking Company (Reserve Bank) Directions, 2016 as amended from time to time, has directed that the Board of each NBFC shall approve an Interest rate model for the Company, taking in to account relevant factors such as cost of funds, margin and risk premium, etc. and determine the rate of interest to be charged for loans and advances.

The Company intimates the Borrower: The loan amount, annualized rate of interest, tenure, amount of equated monthly installment at the time of sanction of the loan. 

Principles for determining interest rate for loans:

•  Epimoney Private Limited (herein after referred to as “the Company”) has its own model for arriving at interest rates taking into consideration among other things, the Company’s weighted average cost of funds, un-allocable overheads and other administrative costs which is further adjusted for ALM mismatch. The weighted average cost of funds is computed considering the cost of the Company’s aggregate borrowings at month end time from various sources such as bank, NBFC lines, non-convertible debentures, etc.

• The rate of interest for loans for various business segments and various schemes thereunder is arrived at through Company’s interest rate model, cost on account of risk and tenor premium for the concerned business segment, business specific operating cost and margin is added to arrive at the lending rate.

• The final lending rate for various products offered by the Company will be arrived at, after taking into account market reputation, interest, credit and default risk in the related business segment, historical performance of similar homogeneous clients, profile of the borrower, tenure of relationship with the borrower, repayment track record of the borrower in case of existing customer, subventions available, deviations permitted, future potential, group strength, overall customer yield, nature and value of primary and collateral security, etc. Such information is gathered based on information provided by the borrower, credit reports, market intelligence and information gathered by field inspection of the borrower’s premises.

The rate of interest for the same product and tenor availed during same period by different customers need not to be standardized. It could vary for different customers depending upon consideration of any or combination of above factors. 

• The interest rates could be offered on fixed or variable basis and charged on flat or reducing balance method.

• The interest could be charged on daily/fortnightly/monthly or quarterly basis or such other periodicity (based on type of product) as may be approved by the designated authority. Specific terms in this regard would be addressed through the relevant product policy. Rests for different products / segments.

• Interest rates / interest type would be intimated to the customers at the time of sanction/ availing of the loan and EMI apportionment towards interest and principal dues would be made available to the customer.

• The interest shall be deemed payable immediately on the due date as communicated and no grace period for payment of interest is allowed.

• Besides normal interest, the company may levy additional / penal interest for delay or default in making payments of any dues. These additional or penal interests for different products or facilities would be decided by the respective business / product heads

• Changes in the interest rates and charges would be prospective in effect and intimation of change of interest or other charges would be communicated to customers in a mode and the manner deemed fit and transparent.

• Besides interest, other financial charges like processing fees, origination fees, cheque bouncing charges, late payment charges, re-scheduling charges, pre-payment / foreclosure charges, part disbursement charges, cheque swap charges, security swap charges, charges for issue of statement account etc., would be levied by the company wherever considered necessary. Besides these charges, stamp duty, GST and other cess would be collected at applicable rates from time to time as communicated in the documentation provided.
  Any revision in these charges would be have a prospective effect and will be communicated with the borrower.

• While deciding the charges, the practices followed by the competitors in the market would also be taken into consideration.

• Claims for refund or waiver of charges / penal interest / additional interest would normally not be entertained by the company and it is at the sole discretion of the company to deal with such requests.

• Any revision in the Company’s interest rates applicable to business would be reviewed by the Board of Directors.

• Review:

The rates of interest shall be reviewed periodically and any revisions in this policy shall be decided by ALCO and shall, subsequently, be presented to the Board of Directors of the Company for its approval.