Last updated: 14th Feb 2023

PLEASE READ THIS POLICY CAREFULLY BEFORE USING THE APP/ WEBSITE

We, at Onclave Systems Private Limited (“Zet Loan” or “We”) understand Privacy and its value. Therefore, it is all the more important for us to make YOU (“You” or “Customer” or “User”), the User of the website www.zetloan.com (the “Website”) and its associated mobile applications, zet Loan (“Application”) (collectively, the “Platform”) understand the reason behind collection of your information and its usage and the manner in which we collect, use, store and share information about you (“Privacy Policy”). This Privacy Policy has been prepared in compliance with:

  • Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011;

  • Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021

  • Guidelines on Digital Lending issued by the Reserve Bank of India (RBI), 2022;

  • Other applicable acts, regulations and rules which requires the publishing of a privacy policy for handling of or dealing in personal information including sensitive personal data or information and all applicable laws, regulations, guidelines provided by applicable regulatory authorities including but not limited to the RBI.

This Privacy Policy is incorporated into and at all times is subject to and is to be read in conjunction with the Terms of Use of the Platform.

You hereby expressly consent to provide the information that may be required in relation to the Services (as defined below) being rendered on the Platform by us. You acknowledge that we shall collect the information detailed under this Privacy Policy to facilitate lending & non-lending services by partnering with various financial lenders, third parties, service providers, etc based on your requirement to avail such Services (“Services”).

In order to avail any Services being provided by Zet Loan by itself or in partnership with the lenders or other third parties it is important that

YOU READ, UNDERSTAND, ACKNOWLEDGE AND UNCONDITIONALLY AGREE TO BE BOUND BY THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY

Whereas the Lending partner or finance partner is Decimus Financial Limited which is registered under RBI.

COLLECTION OF INFORMATION

The collection of information under this Privacy Policy are conducted for the following categories of services:

Part A: Information for Digital Lending Services: Information collected by Platform for facilitation of Loans being disbursed by the financial lending partners whose details are available on the Website and the Application and who are registered with the Reserve Bank of India (“Lending Partners”).

Part B: Information for Non-Lending Services: Information collected by Platform while registering a User on the Platform or while providing Value Added Services (i.e. all services other than facilitation of loans).

In order to facilitate and provide you (and co-applicants, members, nominees, if any) with the Services through the Zet Loan App/Website, we (i.e. the Company), need to collect various data and information from you. The manner in which this data and information is collected, retained, shared, stored, and processed by us (i.e., the Company), addressed in this Zet Loan Privacy Policy ("Policy"). By setting up an account on this App/Website, you agree to the processing, storage, usage and sharing of the data provided by you pursuant to this Policy.

We may revise this Policy as well as update the Services and the App from time to time, so please keep visiting this page regularly to take notice of any changes we make. If you do not agree with any part of this Policy, please stop using our Services immediately. Please also read our Terms of Use ("Terms"), which describe the terms under which we provide our and our Affiliates Services and the terms under which you can use our and our Affiliates Services.

We are a part of the Onclave Systems Private Limited . You can learn more further below in this Privacy Policy about the ways in which we share information across this company. This Policy applies to all our Services unless specified otherwise.

This Policy, incorporates, and includes our Terms and the Agreement(s) executed by you (and co-applicants, members, nominees, if any) for availing our Services and our Affiliates Services. Words and phrases not defined in this Policy shall mean the same as provided in the Terms. All references to you (as a user / visitor) shall include references to all co-applicants, covered members or nominees, joint investors, if any.

1. WHAT DATA IS COLLECTED?

By using the App, you consent to providing us, data in the ways listed below. We collect the data you provide to ensure that we can provide you services in the best manner possible. We use this data to underwrite (i.e. assess the risk it will be taking) any loan it might offer you and to determine the rates for such loans. The data being asked from you helps us and our partner to provide services to you in a robust and user-friendly manner. We have detailed the manner in which we and our partner collect data below:

a) Data you input in the course of signing up and using our Services

Zet Loan Account Data: We and our App/Website collect the data you provide to us when you create or update your Zet Loan Account. This includes your name, phone number, email ID, PAN, date of birth, pin code, nature of employment, official employment email address and name of employer, monthly income, marital status and relationship with the co-applicant (in case the loan is being sought by more than a single applicant). We may require you to share further information on a later date to confirm the veracity of your information or pursuant to any additional features added to the App.

How we use this data: For Enabling the App/Website and its Services; For Loan Processing and KYC Authentication; For Enabling Customer Support; For Research and Development; For Enabling Communications Between You and Us; For enabling Marketing and Outreach; For Automated Decisions; For Legal Compliance and Requirements.

Financial and KYC Information: We collect the data through our App/Website you provide to us when you accept the tentative terms of the loans. This includes your photograph, Aadhaar Number, PAN, parents names, bank account number, IFSC, proof of address (which can be your electricity bill, rental/lease agreement, gas bill, passport or driver's license, or any other document our App may be able to record).

How we use this data: For Enabling the App and its Services; For Loan Processing and KYC Authentication; For Legal Compliance and Requirements.

Other Data Solicited: You may be required to provide further information to the Lending Partner for the purposes of processing your loan application. Such additional information may include (without limitation) bank statements, goods and services tax returns, salary and income statements and title documents for the property being financed. This data shall be supplied to the Finance Partner through us. You may also be required to provide this information to us via physical documents, e-mail or other digital and offline methods.

How we use this data: For Enabling the App and its Services; For Loan Processing and KYC Authentication; For assessing the quantum and interest rate of loan to be extended; For Legal Compliance and Requirements.

Feedback Data and Other Data:

This includes the following:

  • If you call our call centres, we may record information provided by you to service you or record the calls for quality and training purposes.

  • Data you input when you participate in our referral programs or use any discount codes offered by us.

  • If you provide any feedback or comments to us on the App.

How we use this data: For Enabling the App and its Services; For Loan Processing and KYC Authentication; For Legal Compliance and Requirements.

b) Data we collect from your usage of our Services

Geolocation data: We and our Finance Partner collect the location data from you in two ways: (i) when you add the pin code as part of your Zet Loan Account data; and (ii) from your mobile device when enabled by you to do so. We collect this data when our App is running in the background of your mobile device. You will not be able to use the App if you disable the location services.

How we use this data: See, For Enabling the App and its Services; For Loan Processing and KYC Authentication; For Enabling Customer Support; For Enabling Marketing and Outreach; For Automated Decisions; For Legal Compliance and Requirements.

User Personal Information: Our app collects user account data which includes email address, name to log in to the app. This information is required as part of the registration process to access our service and it is also used to auto populate relevant fields in the course of the interface of our app. Our app also collects mobile numbers for verification to check the active SIM status on the device, uniquely identify you and prevent fraud and unauthorized access.

Phone Book Contacts: When you grant us access to the address book on your mobile device, then we and our Finance Partner access and store the names and contact information from your address book to facilitate invitations, assess your phone usage and habits, and to facilitate recovery of delayed EMI payments. You will not be able to use the App if you disable this access. As part of the loan journey, we collect all of your phonebook contacts which includes their contact names, phone numbers, account types, favourites (starred) and contact labels to enrich your financial profile. We use this data to determine your social network from your phonebook contacts and identify fraudulent contacts in your network and for enabling recovery of delayed EMI payments. This helps us in detecting fraud loan applications and reducing credit risk.

How we use this data: For Enabling the App and its Services; For Loan Processing and KYC Authentication.

App Data: We and our Finance Partner collect the data about your installed applications, including the applications that you have installed on and from the date you create your Zet Loan Account and the manner in which you use them. This also includes having access and permission to send you messages and notifications via your social media and instant messaging applications. You will not be able to use the App if you disable this access.

How we use this data: For Enabling the App and its Services; For Loan Processing and KYC Authentication; For Enabling Customer Support; For Research and Development; For Enabling Communications Between You and Us; For enabling Marketing and Outreach.

Usage data: We collect data about how you interact with our Services. This includes data such as access dates and times, App features or pages viewed, App crashes and other system activity, type of browser, and third-party sites or services used before or in the course of interacting with our Services.

How we use this data: For Enabling the App and its Services; For Enabling Customer Support; For Research and Development; For Enabling Communications Between You and Us; For enabling Marketing and Outreach; For Automated Decisions; For Legal Compliance and Requirements.

Transaction information: We collect transaction information related to the use of our Services, including the type of Services requested, date and time the Service was provided, loan availed, interest payable, EMI selected, and payment method. Additionally, if someone uses your promotion code, we may associate your name with that person and their usage of the App.

How we use this data: For Enabling Customer Support; For Research and Development; For Enabling Communications Between You and Us; For Enabling Marketing and Outreach; For Automated Decisions; For Legal Compliance and Requirements.

Device data: We collect data about the devices used to access our Services, including the hardware models, device IP address, operating systems and versions, software, preferred languages, unique device identifiers, advertising identifiers, serial numbers, device motion data, and mobile network data.

How we use this data: For Enabling the App and its Services; For Enabling Customer Support; For Research and Development; For Enabling Communications Between You and Us; For enabling Marketing and Outreach.

Storage: This permission is required so that users' documents can be securely downloaded and saved on users' phones and upload the right documents for a faster approval and disbursal of the loan. This helps provide a very smooth and seamless experience while using the app.

We may also be working closely with third parties (including, for example, credit information bureaus, business partners, technical sub-contractors, analytics providers, search information providers, title deeds, property verification service providers and valuers) and may lawfully receive information about you and your co-applicant from such sources. Such data may be shared internally and combined with data collected on the App.

How we use this data: For Enabling the App and its Services; For Loan Processing and KYC Authentication; For Enabling Customer Support; For Research and Development; For Enabling Communications Between You and Us; For enabling Marketing and Outreach; For Automated Decisions; For Legal Compliance and Requirements.

2.HOW AND WHY IS THE COLLECTED DATA USED?

a) For Enabling the App and its Services

We use the data collected to personalize, maintain and improve our Services. This includes using the data to:

  • Create and update the Zet Loan Account.

  • Analyze your loan eligibility and estimate your loan terms.

  • Track the disbursement and repayment of the loan.

  • Enable features that allow you to add and remove bank accounts for your loan repayment and disbursements from time to time.

  • Enable features that help you check your loan history, credit scores (as provide on government databases), and other such App features as may be added from time to time.

Perform internal operations necessary to provide our Services, including to troubleshoot software bugs and operational problems; to conduct data analysis, testing, and research; and to monitor and analyze usage and activity trends.

b) For Loan Processing and KYC Authentication

Our Lending Partner uses the data to analyze your creditworthiness, loan eligibility, KYC documents, current employment verification and, and the terms of your loans. While we collect the Financial and KYC Information, the Lending Partner is required to individually process the loan requests and verify the KYC documentation received. Failing to process such data means that you cannot be provided any loans. You hereby grant us explicit consent to fetch your KYC (Know Your Customer) details from the Central KYC Records Registry using the details provided by you.

Our Finance Partner also uses the data to track disbursement and repayment of your loan.

c) For Enabling Customer Support

We use the information to provide customer support, including to resolve your concerns from the use of the Services, and train our customer service executives.

d) For Research and Development

We may use the data so collected for research, analysis, and product development to improve the UI/UX experience – all of which will ultimately improve how you experience the App. This also helps us develop automated actions to be triggered in certain events, such as when we need to identify if photographs uploaded are not clear, fraud takes place, IFSC is incorrect etc.

e) For Enabling Communications Between You and Us

We may add features that allow you to call us (through the App or otherwise), similarly, we may also need to contact you (through the App or any other channels that you give us access to, such as WhatsApp or Facebook).

f) For Marketing and Outreach

We may use the data we collect to market the App and our Services. This includes sharing your feedback, ratings and screen names for purely promotion and marketing purposes. Such promotion and marketing may be done via hoardings, banners, pamphlets etc.

g) For Automated Decisions

The App may provide automated features for customer responses, reimbursement tracking, etc. As our App grows, we will keep adding more automated features to the App.

h) For Legal Compliance and Requirements

We may use the data we collect to investigate or address claims or disputes relating to use of our Services, or as otherwise allowed by applicable law, or as requested by regulators, government entities, and official inquiries.

i) For Product Innovation

We may use the data we collect to offer new products and services for your use.

3. HOW DO WE SHARE THE COLLECTED INFORMATION?

a) Sharing with third parties

Service Providers: We work with third party service providers to execute various functionalities of the App and we may share your information with such service providers to help us provide the App. Some of these functionalities may include:

  • Analyzing transaction behaviour and cashflows via your SMSs, bank statements, goods and services tax returns, salary and income statements, income tax returns, basis which your loan offer is generated.

  • Validating and authenticating the official verification documents provided by you.

  • Validating your preferred bank account, as well as transferring the loan amounts to you.

  • E-signing of the loan agreement or sanction letter, populating the loan agreement or the sanction letter. The information shared with these service providers is retained for auditing of the agreements.

  • Analyzing customer behaviour and to automate our marketing and outreach efforts.

  • Detection and flagging of fraud.

  • Cloud services.

  • Gathering of additional information regarding your bank account and statement details, in case adequate information has not been provided by you or through the other service providers we work with.

  • For manually collecting any sums owed by you to our Lending Partner.

  • Validating and authenticating your employment status, employment information and employment duration.

Third Party Services: The App may allow you to connect with other websites, products, or services that we don’t have control over (for example, if we allow you to pay through an external wallet facility then we will have to share your usage information with the facility provider). However, usage of such third-party services is subject to their privacy policies and not within our control. We recommend that you have a look at their privacy policies before agreeing to use their services.

LINK TO THIRD-PARTY SDK

Our application has a link to a registered third-party SDK which collects data on our behalf and data is stored to a secured server to perform a credit risk assessment. We ensure that our third-party service provider takes security measures in order to protect your personal information against loss, misuse or alteration of the data.

Our third-party service provider(s) employ separation of environments and segregation of duties and has strict role-based access control on a documented, authorized, need-to-use basis. The stored data is protected and stored by application-level encryption. They enforce key management services to limit access to data.

Furthermore, our registered third-party service provider(s) provide hosting security, they use industry-leading anti-virus, anti-malware, intrusion prevention systems, intrusion detection systems, file integrity monitoring, and application control solutions.

Change in Control: While negotiating or in relation to a change of corporate control such as a restructuring, merger or sale of our assets, we may have to disclose our databases and information we have stored in the course of our operations.

b) Sharing with law enforcement when needed

Notwithstanding any other provision of this Policy, we may share information if we have to in order to comply with the law. If any governmental authority or law enforcement officers request or require any information and we think disclosure is required or appropriate in order to comply with laws, regulations, or a legal process.

4. WHAT ARE YOUR RIGHTS REGARDING THE DATA?

1. Right to rectification: In the event that any personal data provided by you is inaccurate, incomplete or outdated then you shall have the right to provide us with the accurate, complete and up to date data and have us rectify such data. It may take up to 10 days to process your request. We urge you to ensure that you always provide us with accurate and correct information/data to ensure your use of our Services is uninterrupted.

2. Right to withdraw consent: You have the right to withdraw your consent to this Policy by uninstalling the App. However, if you have availed any services from our Affiliates, we shall have the right to continue processing your information while you are availing such services.

However, we shall not retain your data and information if it is no longer required by us and there is no legal requirement to retain the same. Do note that multiple legal bases may exist in parallel, and we may still have to retain certain data and information at any time.

3. Right to opt-out: Push Notifications: You can opt out of receiving push notifications through your device settings. Please note that opting out of receiving push notifications may impact your use of the App.

5. CONSENT MECHANISM

By setting up a Zet Loan Account, you agree to our and the Lending Partner's processing, storage, usage, and sharing of the data provided by you pursuant to this Policy. If you do not agree with any of the terms of this Policy or the Terms or wish to revoke any consent you have provided to us and/or the Lending Partner, please write to us at help@zetloan.co.in. However, please note that if you revoke any mandatory permissions or revoke the consent to process and store information such as your Zet Loan Account data, Financial and KYC Information and/or any other information needed to facilitate your loan amounts, then we may have to cease the provision of Services to you. You cannot withdraw your consent once you have availed services using the App till you have closed all services with us and our Affiliates.

6. DATA RETENTION

We shall retain the information you provide to facilitate your smooth and uninterrupted use of the App, and (i) to provide, improve and personalize our Services; (ii) to contact you about your account and give customer service; (iii) to personalize our advertising and marketing communications; and (iv) to prevent, detect, mitigate, and investigate fraudulent or illegal activities. We do not retain your personal data for longer than required for the purpose for which the information may be lawfully used. For any other information, we may entertain your request for deletion, however, you may not be able to use our Services at all after such deletion.

7. CHILDREN'S PRIVACY

Our Services are not directed to children, and we do not knowingly solicit or collect personal information from persons under the age of 18 (eighteen). If we find out that a child has given us personal information, we will take steps to delete that information and terminate the relevant Zet Loan Account.

8. COMMUNICATIONS FROM US

We may from time to time contact you via calls, SMS, emails, and other communication channels to provide you with information pertaining to our Services, notifications on updates vis-Ã -vis our Services (when we consider it necessary to do so), educational information and promotions. We may also notify you if we need to temporarily suspend the App for maintenance, and keep you informed on security, privacy, or administrative-related communications. By setting up an account on Zet Loan, you consent to us contacting you via call, SMS, push notifications, or through any other communication channel, as we may deem fit.

9. UPDATES TO THIS NOTICE

We may occasionally update this Policy. Use of our Services after an update constitutes consent to the updated notice to the extent permitted by law. Please take the time to periodically review this Policy for the latest information on our privacy practices.

Our data grievance officer is: Mr.Saurav Pandey. You may contact us on any aspect of this policy or for any discrepancies/grievances with respect to your personal data, by writing to our data grievance officer at Onclave Systems Private Limited at grievance@zetloan.com