Privacy Policy for Loans

Privacy Policy

(Last updated – Feb 16th, 2024)

In this policy,

• “We,” “Us,” and “Our” means Billionbrains Garage Ventures Private Limited (“BGV”), its Group Companies, Affiliates and Subsidiary Companies;
• The “Site” and/or “Platform” means any web site, mobile site, and/or Digital lending application (DLA) We provide that includes a link to this online Privacy Policy;
• The “Service” means any information, documents, assistance, or services that the Lending Service Provider (LSP) may provide to you through Our Site and/or Platform; and
• “You” and “Your” mean anyone who visits, accesses, or uses our Site (groww.in) or obtains Services from us through our Site and/or Platform.

Your privacy is of utmost importance to Us and protection of Your Personal Data as disclosed by You to Us is a key commitment for Us. During Your usage of our Site/Platform, We may collect and generate various data points about You as specified below. In this, We are governed by the provisions of applicable law in India including the Information Technology Act 2000, the 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 to maintain the privacy of Your Personal Data. We collect and process Your Personal Data only to the extent necessary and need-based by Us to process Your requirement(s) and in the manner as detailed hereinafter below in section III and IV, and in accordance with such applicable law.

“Personal Data” means data relating to You that is directly or indirectly identifiable, having regard to any characteristic, trait, attribute or any other elements of Your identity or any combination of such element with any other information. Personal Data does not mean information that is freely available or accessible in public domain or furnished under the Right to Information Act, 2005 or any other law for the time being in force. Personal Data includes Sensitive Personal Data, which relates to password, financial information such as bank account or credit card or debit card or other payment instrument details, physical, physiological and mental health condition, sexual orientation, medical records and history, biometrics or any other data categorised as sensitive under applicable law in India.

I. Types of Information We collect

We may collect following information from You, as You have disclosed to Us:

• Personal Data (e.g. name, contact details including, residential address, correspondence address, date of birth, documents such as identity card / passport details / Aadhaar details / PAN / Voter ID / driving license, and/or education details) provided by You to Us to avail various products/Services from Us.
• Your financial details (e.g. income, expenses, and/or credit history), including transaction history, balances, payment details, for effecting transfer of monies through various payment channels needed as part of request for some of Our products/Services.
• voice recordings of Our conversations with the customer care agent to address Your queries/grievances;
• opinions provided by You to Us by way of feedback or responses to surveys;
• information obtained from Your mobile device, for the purpose of on-boarding/ KYC requirements only, duly agreed and consented by You by way of using the Site/Platform like device location, camera and microphone access, or such other information that may have been voluntarily provide by you in connection with availing the Services on the Platform. Necessary permission/consent shall be sought for the same at appropriate stage during the Platform usage at all times.
• employment details (e.g. occupation, positions held, employment history, salary and/or benefits) as part of Our record retention for credit/various product evaluations or required under applicable law including Prevention of Money Laundering (Maintenance of Records) Rules, 2005
• specimen signature(s) for processing of Your instructions received by Us through Our various payment and delivery channels;
• access to your mobile camera device for the purpose of on-boarding/ KYC requirements only and for the functioning of many Platform functionalities including, but not limited to scan and pay etc. access to device camera is required. Permission is sought for the same at appropriate stage during the Platform usage.

In general, You can browse Our Platform without telling Us who You are or revealing any Personal Data about yourself. However, to create an account on Platform, You must provide Us with the aforementioned basic information required to provide customized services.

You may, in your sole and absolute discretion, choose either: (i) not to provide the information, specific data requisitioned by Us from you in connection with Our Services from time to time or (ii) cancel/revoke your consent so granted to collect Your Personal Data and/or communication that you have elected to receive from Us in relation to the information you have already shared with Us. However, in the event if You do not provide Your consent or later withdraw Your consent, We request you not to access the Platform and/or use the Services and We also reserve the right to not provide You any Services through the Platform. In such a scenario, the Company may delete Your information (Personal or otherwise) or de-identify it so that it is anonymous and not attributable to You.

II. Purpose of obtaining the information:

The intended purpose of collecting information provided by You is to:

• establish identity and verify the same;
• to facilitate your KYC;
• conduct KYC for our third-party having contractual relationships with Us based on the information shared You. Necessary permission/consent is sought for the same at appropriate stage during the Platform usage; As well as post any changes/updates/modification as it deemed necessary
• monitor, improve, and administer Our Platform;
• to make improvements to our Service to provide correct transaction information to You
• design and offer customized products and Services on Our Platform from time to time;
• send communications notifications, information regarding the products or Services requested by You or process queries and applications that You have made on Our Platform;
• conduct data analysis in order to improve the Services/products provided to You;
• use Your information in order to comply with country laws and regulations;
• use Your information in other ways permitted by law (statutory and/or regulatory) to enable You to obtain financial services from third-party having contractual relationships with Us.
• Undertake recovery and collections related actions including sending communications as and when required.

We will use and retain the information for such periods as necessary to provide You the Services on the Platform, to comply with our legal obligations, to resolve disputes, and enforce the agreements entered into by You and for such other reasons as specified in Clause V below.

III. Sharing of data with third parties

Any Personal Data that We have access to shall not share without Your consent unless as specified in below cases wherein we are obliged to share.

In various processes / submission of applications / availing of product / service offerings, We shall seek Your explicit consent to use / share Your Personal Data.

In our business and operational processes, We only share the data on a “need-to-know” basis to designated personnel or partners or service providers.

We will share your data with competent / legal / statutory / regulatory agencies / authorities or partners / service providers acting on our behalf (as the case may be) in following cases:

1. We disclose and share Your information with the lending partners and our third-party partners for facilitation of a loan or facility or line of credit;
2. For enabling the provision of the products / services availed by You, strictly on a “need to know” basis and subject to applicable laws.
3. We will disclose the information to our third-party technology and credit partners to perform credit checks and credit analysis like Credit Bureaus or third party data source providers;
4. 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.
5. We may disclose Your information, without prior notice, if We are under a duty to do so in order to comply with any legal obligation or an order from the government and/or a statutory authority, or 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 and this may include exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
6. Where it is directed or required by legal / regulatory / statutory / governmental authorities / judiciary under any applicable laws / regulations or judicial pronouncement though a legally obligated request.
7. Where it is required to verify, mitigate or prevent fraud or to manage risk or recover funds in accordance with applicable laws / regulations.
8. When You make purchases through our services, we may collect and store information about You to process your requests and automatically complete forms for future transactions, including (but not limited to) your phone number, address, email, billing information and payment preferences. This information may be shared with third-parties which assist in processing and fulfilling Your requests, including payment gateway processors, and for providing You with products / services to better serve Your needs and interests. Such sharing shall be in accordance with Your instructions and subject to appropriate confidentiality and security requirements.
9. We may share Your Personal Data with our group/associate/affiliate companies to comply with regulatory requirement or restriction applicable to Us and/or to our group/associate/affiliate companies.
10. We may share your data with third parties/group companies/ affiliates for the purpose of undertaking recovery and collection activities. We may also share your information with the below-mentioned entities for them to communicate with you for the indicated purposes.

IV. Storage of your Personal Data
When You use Our Platform, We collect and store your information which is provided by You from time to time by explicitly seeking permissions from You to get the required information. Our primary goal in doing so is to provide You a safe, efficient, smooth and customized experience and Services. This allows Us to provide Services and features that meets Your needs, and to customize Our Platform to make Your experience safer and easier and to improve the Services provided by Us.

We may process, store and retain Your Personal Data on Our servers where the data centres are located, and/or on the servers of third parties having contractual relationships with Us. All data is stored in India only. We will retain your data for the period that you continue to be our customer and for such period as required to comply with any obligation under any law for the time being in force.

The information that is collected from you may be transferred to, stored and processed at any destination as permitted under applicable law. By submitting information to Us, You agree to this transfer, storing and / or processing. We will take such steps as We consider reasonably necessary to ensure that Your information is treated securely and in accordance with this Privacy Policy.

V. Usage of Your Personal Data

We use Your Personal Data in our business activities for providing and performing, among other actions, the following:

• To facilitate the transactions or report on these transactions;
• To undertake research and analytics for offering or improving our products / services and their security and service quality;
• To check and process Your requirements submitted to Us for products / services and / or instructions or requests received from You in respect of these products / services;
• To share with You, updates on changes to the products / services and their terms and conditions including Site/Platform’s terms and conditions;
• To take up or investigate any complaints / claims / disputes;
• To respond to your queries or feedback submitted by You;
• To verify your identity for us to provide products / services to You;
• To carry credit checks, screenings or due diligence checks as lawfully required by Us and/or Bureaus;
• To undertake financial / regulatory / management reporting, and create and maintain various risk management models;
• To conduct audits and for record keeping purposes;
• To enable us to provide You with selective offers and promotions, search results, location-based services;
• To auto populate such third party pages basis Your click on advertisement instances on our website and Your proceeding to such pages;
• To comply with the requirements of applicable laws / regulations and / or court orders / regulatory directives received by Us;

VI. Purging of your Personal Data

You may choose to close and/or delete Your account at any point of time by making such choice through Site/Platform. With this We will no longer provide Your data for external processing as mentioned above. However, We may retain Your Personal Data as long as the purpose for its usage exists, after which the same shall be disposed off by Us except for any record retention required as per applicable law. The provisions of various laws require Your transaction logs to be stored for longer periods post the deletion of an account. Further, in the event of the pendency of any legal, regulatory and/or statutory proceeding or receipt of any legal and / or regulatory direction to that effect, We may be required by the law of the land to retain your Personal Data for longer periods.

VII. Cookie Policy

Please note that a “cookie” is a small piece of information stored by a web server on a web browser so it can be later read back from that browser. We may use cookie and tracking technology depending on the features offered. No Personal Data will be collected via cookies and other tracking technology; however, if you previously provided Personal Data, cookies may be tied to such information.

VIII. Links to other websites

Our website may contain links to other websites which are not maintained by Us. This privacy policy only applies to Us. You are requested to read the other websites’ privacy policies when visiting these websites.

IX. Reasonable Security Practices and Procedures

We take the security of Your information very seriously. To this end, We use several security techniques including secure servers, firewalls and encryptions. We have in place appropriate administrative, technical, physical safeguards and security measures to protect the Personal Data You provide to us against accidental, unauthorized or unlawful loss, destruction, damage, alteration, access, disclosure or use and any other unlawful forms of processing. When We collect data, we collect your personal details on a secure server. We use firewalls on our servers. We take various steps and measures to protect the security of your Personal Data from misuse, loss, unauthorised access, modification or disclosure. We use latest secure server layers encryption and access control on our systems. We request You to please do not share your Account’s login, password and OTP details with anybody.

While We observe reasonable security measures to protect Your Personal Data on all our digital platforms, security risks may still arise for reasons outside of our control such as hacking, virus dissemination, force majeure events, breach of firewall etc. Please note that the above mentioned measures do not guarantee absolute protection to the Personal Data.

We wish to mention that in case of non-compliance and/or breach with the privacy policy pertaining to access or usage of the computer resource, We shall have the right to terminate the access or usage rights of the Yours to the computer resource immediately or remove non-compliant information or both, as the case may be

X. Contact us

XI. Policy Review & Updates

This policy will be reviewed by Us as and when required and the same may be subject to change at any point in time. While We will make reasonable efforts to keep you posted on any updates to this privacy policy, to make sure that you are aware of any changes, we recommend that you review this policy periodically.

This Privacy Policy shall apply uniformly to Our desktop website, mobile site & mobile applications.

We reserve the right to change/modify the information provided on or via this Site, including the terms of this disclaimer, at any time and without notice. You can determine when the Terms were last modified by referring to the “Last Updated” legend above. However, We shall not undertake to update You with the content contained on this Site/Platform from time to time. You are obliged to exercise your independent diligence on the information provided on or via this Site before arriving at any decision and you will be solely responsible for your actions. We shall not be held responsible for all or any actions that may subsequently result in any loss, damage and or liability on account of such change in the information on this Site. Your continuous use of the website/mobile application following the posting of changes shall mean that You accept and agree to the changes and shall be legally bound by the same.

XII. Governing Law & Jurisdiction

This policy will be governed by and construed in accordance with the laws of India and subjected to the exclusive jurisdiction of the Courts of Bangalore.

XIII. Details of associated third parties