(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.
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.
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.
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.
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.
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.
Terms & Conditions
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.
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 New No. 249, Ambujammal Street, Off TTK Road, Alwarpet, Chennai 600018 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.
“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.
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.
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.
While registering with the Website to avail the Services, the Borrower shall not:
(a) create any Account for anyone other than the Borrower, unless such person’s prior written permission has been obtained;
(b) use an Account that is the name of another person with the intent to impersonate that person;
(c) use a name for the Account that is a name that is otherwise offensive, vulgar or obscene or otherwise unlawful; or
(d) create more than one Account on the Website.
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.
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.
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.
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.
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.
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
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.
HOW TO CONTACT US:
If you have questions or concerns about this Policy, please contact us at email@example.com or call us on 022-62603800.
Fair Practices Code
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.
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. 249 A, Ambujammal Street, Off TTK Road, Alwarpet, Chennai-600018 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.
- 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
- 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.
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
- 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
- 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.
Grievance Redressal Mechanism
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.
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.
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.
The policy intends to manage/mitigate Legal, Compliance and Operational Risk.
The policy stipulates the requirements related to registration of complaints, escalation of complaints, resolution of complaints and periodic review to grievances redressal.
The Board shall review grievance redressal policy on annual basis or at earlier intervals, in case of any regulatory changes necessitating such interim reviews.
GRIEVANCE REDRESSAL POLICY
- 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:
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: firstname.lastname@example.org
Address: 7th Floor, South Annexe, Tower 2, One World Centre 841, Senapati Bapat Marg, Saidham Nagar, Lower Parel, Mumbai – 400013.
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: email@example.com
If the complaint / dispute is not redressed within a period of one month 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
This policy is subject to revision based on the extant RBI guideline from time to time.
Interest Rate Model Policy
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.
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.
Following the NACH Circular (vide cir. no: NPCI/2020-21/NACH/Circular No. 013 & NPCI/2020-21/NACH/Circular No. 044 and 025) issued by NPCI, all customers are requested that for any requests related to initiating any stop/cancel the NACH mandate, please write to us at firstname.lastname@example.org.
Emergency Credit Line Guarantee Scheme (ECLGS)
Epimoney Private limited is a Member Lending Institution (MLI) which in compliance to ECLGS scheme proposed by NCGTC to aid Micro, Small and Medium Enterprises (MSMEs) sector has updated the product offerings to existing customers as per the eligibility norms of the scheme.
Scheme has been proposed in 3 different Tranches:
ECLGS 1.0 , ECLGS 2.0 , ECLGS 3.0
For eligibility and latest update from the trust please refer to:
To understand the latest Operating Guidelines of the Scheme please refer to:
For other FAQs:
FAQS on restructuring 2.0 scheme of RBI
1. What is the restructuring 2.0 scheme approved by RBI?
The Reserve Bank of India (‘RBI’) had provided a framework dated August 6, 2020 to banks & lending institutions for implementation of resolution plans for addressing the economic fallout due to the COVID-19 pandemic which has led to significant financial stress for customers. The RBI has further issued two notifications to extend the above facility under the Resolutions Framework 2.0:
- Notification RBI/2021-22/31/DOR.STR.REC.11/21.04.048/2021-22 dealing with Resolution framework for Advances to Individuals and other Businesses.
- Notification RBI/2021-22/32/DOR.STR.REC.12/21.04.048/2021-22 dealing with Restructuring of Advances to MSMEs
Basis the framework and regulatory guidelines, Epimoney Private Limited (‘the Company’) has framed and adopted this policy named as “Restructuring of the loan/s 2.0” (‘Policy’) of individuals and entities that have been impacted due to the COVID-19 pandemic.2. Who is eligible for restructuring?
Customers meeting below mentioned criteria will be eligible for restructuring as per RBI circular under Resolution Framework 2.0
I. Individuals and Small Businesses –
- Individuals who have availed loans for personal purposes.
- Individuals who have availed of loans and advances for business purposes and to whom the lending institutions have aggregate exposure of not more than INR 25 Crores as on March 31, 2021.
- Small businesses, including those engaged in retail and wholesale trade, other than those classified as micro, small and medium enterprises as on March 31, 2021, and to whom the lending institutions have aggregate exposure of not more than INR 25 Crores as on March 31, 2021.
- Credit facilities / investment exposure to the borrower was classified as Standard by the lending institution as on March 31, 2021.
II. Entities (MSME segment) –
Should have been classified as Standard as on March 31, 2021 and should also fulfill the following criteria –
- Self Employed customer segment who qualifies the below mentioned MSME norms.
- The borrower should be classified as a micro, small or medium enterprise as on March 31, 2021 in terms of the Gazette Notification S.O. 2119 (E) dated June 26, 2020
- Udyam registration document will be required for MSME classification
- The aggregate exposure, including non-fund based facilities, of banks and NBFCs to the borrower does not exceed INR 25 Crores as on March 31, 2021.
- The borrower’s account was a ‘standard asset’ as on March 31, 2021.
- The borrowing entity is GST-registered on the date of implementation of the restructuring. However, this condition will not apply to MSMEs that are exempt from GST-registration. This shall be determined on the basis of exemption limit obtaining as on March 31, 2021.
- The borrower’s account was not restructured under previous MSME restructuring circulars.
3. What loans will qualify under the definition of “Personal purpose”?
- Personal loans refer to loans given to individuals and consist of:
- Consumer Credit - personal loans to professionals (excluding loans for business purposes)
- Education Loan
- Loans given for creation/ enhancement of immovable assets (e.g., housing, etc.)
- Loans given for investment in financial assets (shares, debentures, etc.)
- MSME loans with Udyam certificate (The borrower should be classified as a MSME on March 31, 2021 in terms of Gazette Notification S.O. 2119 (E) dated June 26, 2020).
4. Am I eligible for restructuring if I have take loan after March 31, 2021 and affected by pandemic?
No, only those loans which were availed on or before March 31, 2021 and affected by pandemic will be eligible for restructuring.
5. How do I avail the restructuring benefit on my loan?
You may visit our Company website for the application link, fill the application form and submit the relevant details.
6. Can I apply multiple times for restructuring?
No, you can apply for restructuring only once.
7. What are the restructuring options that are available to me?
The balance tenure of the loan can be extended by a further period of maximum 24 months, including the moratorium period at the Company’s discretion to ease your monthly EMI repayment burden.
8. Do I need to submit any documents to avail the restructuring benefit?
The Company will require you to submit documents giving details about the current status of your employment or business:
- Latest 6 months bank statements till date ( from Jan’ 21 onwards till date of application)
- Udyam certificate for MSME customers
- Declaration by self-employed non-professionals/ businessmen declaring that their business is affected by Covid-19
9. Will opting for the restructuring package have an impact on my credit bureau report?
As per regulatory guidelines, your loan/credit facility will be reported to the credit bureau as “Restructured”.
10. I hold multiple loans/credit facilities with the bank/lending institution. Do I have to apply separately for each of these loans?
The restructuring application form shall have the option to apply for one or all the loans by a single application on the Company’s website. The Company shall assess the application on regulatory guidelines, on the COVID-19 impact and the viability of the repayment plan before decisioning the same.
11. Can I apply for restructuring now as I was not able to apply for moratorium before?
The scheme for restructuring is open to all customers of the Company irrespective of the moratorium applied status subject to the borrower meeting the regulatory guidelines of restructuring.
12. I have already availed of restructuring. Can I avail this once again?
If you have already availed restructuring, you are not eligible for restructuring under this scheme. However, if you have not availed of the full benefit of 24 months tenor extension in the earlier scheme which ended on December 31, 2020, the Company can evaluate and provide relief to the extent of overall tenor extension subject to eligibility conditions being met.
13. My loan was taken along with a co-borrower/s. Will all the co-borrowers of the original Loan agreement be required to sign the revised restructuring agreement?
As per regulatory and legal requirements, all borrowers/co-borrowers of the original loan need to agree and sign on any changes in the loan structure including the restructuring agreement.
14. What is the last date of making applications through the portal?
The link on the portal will be live till September 10, 2021 for customers.
Name of Co-Lenders
Vivriti Capital Private Limited
Fullerton India Credit Company Limited
MAS Financial (Lead Sharing) Services Limited
Profectus Capital Private Limited
Growth Source Financial Technologies Private Limited
Muthoot Finance Limited
Resolution Framework COVID 2.0
Whistle Blower Policy
SMA/NPA Classification: Customer Education
The circular DBR.No.BP.BC.45/21.04.048/2018-19 dated June 7, 2019, on ‘Prudential Framework for Resolution of Stressed Assets’ requires the lenders to recognize incipient stress in borrower accounts, immediately on default, by classifying them as special mention accounts (SMA). Illustration with respect to SMA/NPA Classification: (i) If the Repayment Date with respect to the Facility falls on March 31st, and the relevant outstanding amounts payable on such date is not received in full on such Repayment Date, before the Lender runs the day-end process with respect to the classification of their borrower accounts for the Repayment Date, the date of overdue shall be March 31st. (ii) In the event of the Facility continues to remain overdue, then the loan account shall be tagged as SMA-1 upon running day-end process on the 30th day from March 31st i.e. upon completion of 30 days of the Facility being continuously overdue. Accordingly, the date of SMA-1 classification for that account shall be 30th April. (iii) Similarly, if the Facility continues to remain overdue after it being classified as SMA-1, it shall be tagged as SMA-2 upon running day-end process on the 60th day from March 31st i.e. on 30th May. (iv) In the event of the Facility continuing to remain overdue further, it shall become classified as NPA upon running day-end process on the 90th day from March 31st i.e. on 29th June.
- Disclosure on Liquidity Risk December 2019
- Disclosure on Liquidity Risk March 2020
- Disclosure on Liquidity Risk June 2020
- Disclosure on Liquidity Risk September 2020
- Disclosure on Liquidity Risk December 2020
- Disclosure on Liquidity Risk March 2021
- Disclosure on Liquidity Risk June 2021
- Disclosure on Liquidity Risk September 2021
- Disclosure on Liquidity Risk December 2021
- Disclosure on Liquidity Risk March 2022
- Disclosure on Liquidity Risk June 2022