We, at Sai Roshni Capital Private Limited (“Ezfinanz” 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.ezfinanz.com (the “Website”) and its associated mobile applications, (“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:

1. Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011;
2. Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021

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 services based on your requirement to avail such Services (“Services”).

Ezfinanz will only be using the information for providing the Services to you.

In order to avail any Services being provided by Ezfinanz by itself it is important that YOU READ, UNDERSTAND, ACKNOWLEDGE AND UNCONDITIONALLY AGREE TO BE BOUND BY THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY.

IF YOU DO NOT AGREE TO THIS POLICY OR ANY PART THEREOF, PLEASE DO NOT USE/ ACCESS/ DOWNLOAD/ INSTALL THE PLATFORM OR ANY PART THEREOF.

For the users consenting to continue accessing the Platform and avail the Services, this Privacy Policy explains our policies and practices regarding the collection, use, and disclosure of Your information.

1. User Personal Information: The data points we collect from You for lending services include, inter alia, your full name, email id, PAN, GST Network user id & password, address, mobile number, postal code.

2. Social Account Information: Ezfinanz may provide you with the option to register using social accounts (Google or Facebook) to access the app and shall collect only such registered email id and user public profile information like name, email, ASID depending on the platform used by You to log-into the Application during registration/ sign in process in the Platform.

How we use this information: We may collect and store email id, name and address associated with that account for the purpose of verification and to pre-populate relevant fields in the course of Platform interface. However, we shall not collect / store account passwords.

Device Information and Installed Apps data: We additionally collect certain device information provided herein for our lending services. Information which the Application collects, and its usage, depends on how you manage your privacy controls on your device.

(i) Device Information: When you install the Application, we store the information we collect with unique identifiers tied to the device you are using. We collect information from the device when you download and install the Application and explicitly seek permissions from You to get the required information from the device. Additionally, we also collect your Log information (via the domain server through which the User accesses the App Search queries, IP address, crashes, date etc for the purpose of improvising the Application functionality. In addition to the above, we also track and collect the data related to the performance of the Application and other diagnostic data for identifying and resolving any technical glitches that may be identified from such data and also for improving the overall functionality of the Application.

How we use the information: We collect information about your device to provide automatic updates and additional security so that your account is not used in other people’s devices. In addition, the information provides us valuable feedback on your identity as a device holder as well as your device behaviour, thereby allowing us to improve our products interaction, quality of services and provide an enhanced customized user experience to you. We further collect other identifiable information such as your transactions history on the Platform when you set up a free account with us.

(ii) Installed Application Data: We collect and transmit a list of specific installed applications’ metadata information which includes the application name, package name, installed time, updated time, version name and version code of each installed application on your device. This data may be collected even when the app is closed or not in use

How we use this information: We use this information for your onboarding and Know Your Customer (KYC) purpose with your explicit consent.

Location, Camera, Microphone Access: We will collect your device location and request camera and microphone access for facilitating lending services in accordance with applicable laws.

How we use this information: We shall collect your device location information for verifying your address, for the KYC and onboarding process for the Services. We may request camera access to scan and capture the required KYC documents in accordance with applicable laws. We shall store such data. We require microphone permissions to enable a two-way communication between our authorised agents and you for the purpose of performing and completing your Video KYC for the Lending Services. Your audio shall be recorded for regulatory purposes.

For making the Services available to you, we may collect credit information by obtaining specific authorisations from you (if required under applicable laws), from certain third parties such as credit bureaus or credit rating companies as your ‘authorised representative’ from time to time in accordance with applicable laws
In order to facilitate credit products to you, we may receive certain information pertaining to document verification, repayment status etc from certain third parties including NSDL, payment gateway providers.

We may further collect your GST details from the Official GSTIN API stack or other relevant websites using the GST Network user id and password details or OTP as provided by you.

We may further collect your bank account numbers or UPI payment information to facilitate collection and repayment of loan payments.

We shall only collect this information on a need basis strictly for the purpose of providing you with the Services. The information collected from such third parties will be retained by us.

In due course of using our Services, you are required to submit data to enable our Services. We use this data to create your profile and provide you with the best available services. Mentioned below is some of the data we collect from you:

i. Data provided by you by filling in forms in the Application or on the Website.
ii. Data provided by corresponding with us (for example, by e-mail or chat).
iii. Data and information, you provide when you register to use the Website, download or register on our App, subscribe to any of our Services (such as applying for a loan), search for a Service, and when you report a problem with our App, our Services, or any of our Sites.
iv. Data including your name, address, gender, date of birth, e-mail address, phone number, username, password and other registration information.
v. PAN Card, Aadhaar Card, financial information such as employer name, monthly salary, bank account no., bank statements, credit information, GST information, copies of identification documents for the onboarding of your application to avail the services.
vi. Data generated by your usage of our Platform.
vii. Contact details (i.e. the phone number) of the third party individuals (including your relatives and friends) that are voluntarily added by you at the time of loan application.

This data helps us create your profiles, complete mandatory KYC as per the requirements of the Services, and approve loans and provide you with customized support in case of issues.

We under no circumstances and at no point take any biometric data from you for any of our services or operations. In case, if any of our representatives ask for the same from you, we request you to kindly refrain from doing the same and address this concern to our Grievance Officer (the details of the same have been provided on our website).

For the provision of lending Services, we shall only store basic personal information such as your name, your address, your contact information which are required to be stored for carrying out our lending services. We ensure that every data or information that we collect from you is stored in servers located in India and the same is compliance with all the statutory/regulatory obligations

We automatically track certain information about you based upon your behaviour on our Platform. We use this information to do internal research on our users’ demographics, interests, and behaviour to better understand, protect and serve our users and improve our services. This information is compiled and analysed on an aggregated basis.

Cookies: Cookies are small data files that a Website stores on Your computer. We will use cookies on our Website similar to other lending websites / apps and online marketplace websites / apps. Use of this information helps Us identify You in order to make our Website more user friendly. Most browsers will permit You to decline cookies but if You choose to do this it might affect service on some parts of Our Website.

We shall use the information collected from you for facilitating the lending Services for the following purposes as detailed below. We understand the importance of your information and ensure that it is used for the following intended purposes only.

1. Establish identity and verify the same;
2. Troubleshoot problems, monitor, improve and administer our Platform;
3. Provide our service i.e. facilitating loans to You or providing our value-added services;
4. Analyze how the Platform is used, diagnose service or technical problems and maintain security;
5. Send communications notifications, information regarding the products or services requested by You or process queries and applications that You have made on the Platform;
6. Measure consumer interest and satisfaction in our products and services and manage Our relationship with You;
7. Marketing and promotional purposes including sending you promotional SMS, Email and WhatsApp and informing you about online and offline offers, products, services, and updates;
8. Conduct data analysis in order to improve the Services / Products provided to the User;
9. Use the User information in order to comply with country laws and regulations;
10. Use the User information in other ways permitted by law to enable You to avail financial services;
11. Resolve disputes and detect and protect us against suspicious or illegal activity, fraud, and other criminal activity;
12. Customize your experience and enforce our terms and conditions;
13. The contact details (i.e. the phone number) of the third party individuals (including your relatives and friends) that are voluntarily added by you at the time of loan application may be used for the purpose of establishing contact in case we are unable to contact you, including at the time of collection of installments;
14. We will use and retain only such basic personal information such as your name, contact information, address details and such other information which are necessary for the provision of Services and for such periods as necessary to provide You the Services on the Platform, to comply with our legal obligations, to resolve disputes, and enforce our agreements.

We may disclose Your information, in order to enforce or apply our terms of use or assign such information in the course of corporate divestitures, mergers, or to protect the rights, property, or safety of us, our users, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

We and our affiliates may share Your information with another business entity should we (or our assets) merge with, or be acquired by that business entity, or reorganization, amalgamation, restructuring of business for continuity of business. Should such a transaction occur then any business entity (or the new combined entity) receiving any such information from us shall be bound by this Policy with respect to your information.

We will disclose the information to our third-party technology or third-party data source providers;

We will share Your information under a confidentiality agreement with the third parties and restrict use of the said information by third parties only for the purposes detailed herein. We warrant that there will be no unauthorized disclosure of your information shared with third parties.

We shall disclose your KYC journey or any data with respect to the same to the relevant regulatory authorities as a part of our statutory audit process. Please note that your Aadhaar number shall never be disclosed.

We may share your personal information with the governmental authorities, quasi-governmental authorities, judicial authorities and quasi-judicial authorities if we are acting under any duty, request or order as part of our legal obligations and in accordance to the applicable laws. By accepting this Privacy Policy, you hereby provide your consent to disclose your personal information for such regulatory disclosure.

Any disclosure to third parties is subject to the following:

If we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request, we shall not seek your explicit consent however we shall reasonably endeavour to notify the same to you accordingly as the case may be;

We shall take your express consent in the event we share your personal data with third parties;

We shall share your information with third-party only on a need basis and only for the purpose stated hereunder, as per the applicable laws.

We shall additionally seek express consent through a separate consent for at appropriate stages of data collection, if so required under applicable laws.

Usage of your information by such third parties is subject to their privacy policies. We share limited information with them, strictly to the extent required. We recommend you to have a look at the privacy policies of such third parties.

We at Ezfinanz promise to protect your personal data from unauthorized access, misuse, and disclosure using the right security measures based on the type of data and how we are processing the same. We retain information about you to provide a seamless experience, to contact you in case of support required and about your account, to detect, mitigate, prevent, and investigate fraudulent or illegal activities during the course of the Services. We retain your data for as long as necessary to provide you with our services. We may also retain and use your basic personal information inter alia as name, contact number, transactional details and address details as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements which shall always be in accordance with applicable laws. Subject to this section, we may delete your data upon reasonable written request for the same at any stage. However, you may not be able to use our services after deletion.

We reserve the right to change, modify, add, or remove portions of this Privacy Policy at any time for any reason. In case, any changes are made in the Privacy Policy, we shall update the same on the Platform. Once posted, those changes are effective immediately, unless stated otherwise. We encourage you to periodically review this page for the latest information on our privacy practices. Continued access or use of the Services constitute Your acceptance of the changes and the amended Privacy Policy.

The Platform intends to protect your information and to maintain its accuracy as confirmed by you. We implement reasonable physical, administrative and technical safeguards to help us protect your information from unauthorized access, use and disclosure.

Our Platform has stringent security measures in place to protect the loss, misuse and alteration of information under control. We endeavour to safeguard and ensure the security of the information provided by you. We use Secure Sockets Layers (SSL) based encryption, for the transmission of the information, which is currently the required level of encryption in India as per applicable law.

We blend security at multiple steps within our products with the state-of-the-art technology to ensure our systems maintain strong security measures and the overall data and privacy security design allow us to defend our systems ranging from low hanging issues up to sophisticated attacks.

We aim to protect from unauthorized access, alteration, disclosure or destruction of information we hold, including:

1. We use encryption to keep your data private while in transit;
2. We offer security features like OTP verification to help you protect your account;
3. We review our information collection, storage, and processing practices, including physical security measures, to prevent unauthorized access to our systems;
4. We restrict access to personal information to our employees, contractors, and agents who need that information in order to process it. Anyone with this access is subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations;
5. Compliance & Cooperation with Regulations and applicable laws;
6. We regularly review this Privacy Policy and make sure that we process your information in ways that comply with it.

We ensure that the Aadhaar number is not disclosed in any manner.

Data protection laws vary among countries, with some providing more protection than others. We also comply with certain legal frameworks relating to the transfer of data as mentioned and required under the Information Technology Act, 2000, rules and the amendments made thereunder.

When we receive formal written complaints, we respond by contacting the person who made the complaint. We work with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of your data that we cannot resolve with you directly.

For any privacy-related concerns or complaints, please contact our Grievance Officer We aim to respond to all queries within 7 working days.

Modifying or rectifying your information: In the event that any Personal Information 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 at Our end immediately. 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. In case of modification of Personal Information, Users will be required to furnish supporting documents relating to change in Personal Information for the purpose of verification by the Company.

Your Privacy Controls: You have certain choices regarding the information we collect and how it is used:

Report an issue: You have a right to report a security incident to the Grievance Redressal officer. You are entitled to prevent unauthorized usage of your information by our personnel/agents by informing us, within 10 days of being informed of the proposed use, that you do not wish to disclose such information.