PRIVACY POLICY
(A) FINTECH ONLINE MOBILE APPS – ONLY FOR PERSONAL LOAN PRODUCT DEEESHA FIN AND EDU TECHNOLOGIES (hereinafter “DEEESHA”) and its third-party service providers engaged to render certain services on the App / Website (if applicable) (“DEEESHA”/“We”/ “Us”) are committed to upholding the privacy and security of the information supplied by every person (“User”/“You”) accessing and using any version of the DEEESHA application / Website (“App”) on a compatible device. This privacy policy (“Privacy Policy”) briefly provides the manner in which We collect and use User information. By accessing or using the App, You signify that You have read, understood and agree to be bound by this Privacy Policy. We reserve the right to update or modify this Privacy Policy at any time without prior notice and such changes shall be effective immediately upon posting the updated or modified Privacy Policy on the DEEESHA website (i.e. DEEESHA and we shall not be bound to inform you of any modifications hereof. Your access and use of the App following any such change constitutes your agreement to follow and be bound by this Privacy Policy, as updated or modified. For this reason, We encourage You to review this Privacy Policy each time You access and use the App. Your use of the App and any disputes arising therefrom, is subject to this Privacy Policy as well as the terms and conditions, as set out below (“T&C”).
Please read the T&C ( Term&Conditions) in order to obtain information on the terms governing the use of our App and our services.
1. The App / Website and Clients
Company has developed and solely owns a mobile personal finance software App / Website called “ Deeesha Loan Referral App” (“App / Website)”, which expression shall include future releases of the App / Website. Company makes the App / Website available for browsing on the website and also for download and use on mobile phones to clients (“Clients”). Browsing / downloading and installing the App / Website shall be deemed to constitute sufficient proof that Clients have read, understood and accepted this Policy.
Personal Information
2.1 “Personal Information” means the Transaction Information as defined in the Terms of Service and includes information that is contained in text messages (that is, SMS) sent by providers of services and/or products (including but not limited to financial institutions, mobile carriers and utility companies) to Clients’ mobile telephone number(s) in connection with one or more transactions across multiple financial accounts (including purchase, payments, billing information and service notifications related thereto). Without limitation, Transaction Information includes:
2.1.1
Mobile phone numbers of Clients
2.1.2
Email addresses of Clients
2.1.3
Partial payment card data only to the extent such card data is disclosed in the said messages
2.1.4
Information related to the transaction in question including identity of the service or product and the price or fee paid or payable in respect thereof.
Purpose of Collection and Use of Personal Information
DEEESHA may collect, store, access and use Personal Information solely to the extent required for DEEESHA to enable Clients to utilize the features of the App / Website and to provide better user experience to Clients. Such use shall expressly include sharing the Personal Information with Affiliates and Lenders.
Information Collected
We will collect personal information of the User. While some User information has to be mandatorily provided, others are optional and certain portions of the information will remain private and some will be displayed to other users; We shall always let the User know which is which. Additional information may be gathered during subsequent use of the App by the User, whenever the User chooses to provide it.
A Certain mandatory information will be collected at the time of registration on the App which is required to enable the User to login to the App and for Us to: (i) verify the User’s identity; (ii) determine the User’s eligibility for taking loans using, inter alia, our proprietary technology and such additional rules that may be determined by: (a) Us; (b) our banking partners; or (c) both (a) and (b); and (iii) safeguard against illegal activities like fraud, cheating, misappropriation, etc.
B In order to use the facilities and services available on the App, the User may be required, from time to time, to provide certain additional personal information after registration on the App, which information shall be collected only upon receiving the User’s express consent
C We may also automatically receive and collect certain anonymous information in standard usage logs through the web server, including mobile-identification information obtained from the equivalent of “cookies” sent to the App, including mobile network information, standard web log information, traffic to and from our App, tracking inside the App and any other available information, from:
♦ An IP address, assigned to the device used by the User;
♦ The domain server through which the User accesses the App and the functions and features therein; and
♦ The type of device used by the User (“Device”).
D The User may choose to provide Us with access to certain personal information stored by third parties like social networking sites (e.g. Facebook and Twitter). We will have access to such information to the extent allowed by the User’s privacy settings on that site and the User’s specific authorization. In the event the User associates a User account managed by Us with an account maintained with any third party to enable Us to access certain information maintained in such third party managed accounts, the User agrees that We may collect, store and use such information in accordance with this Privacy Policy.
E After obtaining the User’s specific consent to allow the App to access the User’s SMS inbox, we may collect relevant information from text messages (SMS) received by the Users from providers of services and/or products (including but not limited to retail outlets, financial institutions, mobile carriers and utility companies), that will enable us to provide better access to financial services and products to the Users. We will only access business messages that originate from alphanumeric senders.
F In order to enhance our ability to provide valuable services and experiences to the User, We may: (i) automatically receive, collect and analyse your location information which may be accessed through a variety of methods including, inter alia, GPS, IP address, and cell tower location; and (ii) collect information pertaining to your Device and your usage thereof, including, inter alia, the names of the other applications on your mobile Device and how you use them, information about your Device, and information about your use of features or functions on your Device.
G DEEESHA may collect information with your consent from your mobile device like device location, device information (including storage, model, installed apps, WiFi, mobile network) transactional and promotional SMS, communication information including contacts to provide customized offerings.
II Method and manner of use of User information
A When the User registers with the App, We will use the information supplied by the User to pull a credit report from a credit bureaus and identity verification services to facilitate banks and other financial institutions to evaluate the User’s loan request in the context of the User’s complete financial situation.
B We will also use the User information to enable activities and transactions that need to occur during the process of lending, such as:
♦ Generating and maintaining User profiles on the App;
♦ Provide personalized features;
♦ Aiding financial services organizations to provide better services;
♦ Facilitating collection activities as needed;
♦ Maintaining regular communications with the User concerning transactions the User initiates, such as requesting information or assistance, submitting a loan request, making payments, transferring funds, etc.
♦ Modifying the App from time to time to cater to the User’s interests;
♦ Providing the App and the functions and features therein, efficiently ;
♦ Preserve social history as governed by existing law or policy;
C You acknowledge that you are licensing Us to use, modify, display, distribute and create new material from the information you provide through the App to render certain services on the App. By providing such information, you automatically agree, or promise that the owner of such information has expressly agreed to allow or license, as the case may be, Us to use the information in the manner set out in this Privacy Policy, without the payment of any fees. We may, to the extent permitted by law, also use, license, reproduce, distribute disclose, and aggregate, non-personally identifiable information that is derived through your use of the App and you hereby provide consent for the same.
4. Usage of Google Advertising ID
As per the terms of Google Play Services, Deeesha shall use the Google advertising ID when available on a device, only for advertising and user analytics purposes. Deeesha may share this ID with advertising partners only for the purpose of advertising. Deeesha shall not connect the advertising ID to any personally-identifiable information without the explicit consent of Clients. Deeesha shall abide by reset and “Opt out of Interest-based Advertising” settings of Clients.
5. Sharing of Personal Information with Third Parties
Deeesha shall not publish, sell, give on rent, trade or otherwise transfer Personal Information to third parties, except as may be required by law, or pursuant to the order of a court or regulatory authority, or in order for Deeesha to enforce its rights, or as expressly stated by this Policy. In the event Deeesha needs to share Personal Information with third parties, Deeesha shall enter into non-disclosure agreements or equivalent covenants that are, at the least, as protective as the provisions of this Policy.
We will not use User information for any purpose other than in connection with the App. DEEESHA will not rent, sell or share User information and will not disclose any of the User’s personally identifiable information to third parties, unless:
♦ it is pursuant to obtaining the User’s permission;
♦ it is in connection with disclosure to financial institutions and banks, in which case, the User hereby gives his express permission;
♦ it is in connection with the services being rendered through the App;
♦ it is to help investigate, prevent or take action regarding unlawful and illegal activities; suspected fraud, potential threat to the safety or security of any person, violations of DEEESHA’s Terms& Conditions, or as defence against legal claims;
♦ it is a case of special circumstances such as compliance with court orders, requests/order, notices from legal authorities or law enforcement agencies compel us to make such disclosure;
♦ it forms part of the information DEEESHA shares with advertisers on an aggregate basis.
6. Choice
Deeesha reasonably presumes that Clients who make available Personal Information to Deeesha are doing so out of their own volition. Deeesha does not compel Clients to disclose Personal Information. At any time, Deeesha may opt not to provide Personal Information by uninstalling the App / Website.
Procedure For Removing User Name from the Records
A If and when a User is desirous of having his/her name and other details removed from the records of DEEESHA, immediately upon receiving the User’s written request to that effect DEEESHA shall, subject to the terms hereof, remove and/delete all such information.
B If the User no longer wishes to receive notifications about DEEESHA services, The User may change his/her notification preferences by contacting DEEESHA at support@DEEESHA.com. DEEESHA reserves the right to close the User account if the User opts out of receiving certain crucial notices that are required to perform the DEEESHA services through its App. The User may not opt-out of receiving notifications about due or past due amounts that the User owes DEEESHA or any other collections efforts.
7 Correctness and Integrity of Personal Information Deeesha accesses Personal Information as aforesaid from SMS messages on an ‘as is’ basis. Therefore, Deeesha shall not be responsible in any way for the correctness, completeness and integrity of any Personal Information collected hereunder. The User may correct or update any information online. In the event of loss of access details the User may retrieve the same or receive new access details by sending an e-mail to: support@DEEESHA.com.
8. Security Deeesha shall take all reasonable precautions by way of using current industry standard encryption technologies to protect Personal Information from loss, misuse and unauthorized access, disclosure, alteration and destruction.
A. The information provided by the User is stored in access controlled facilities with restricted access. User Information transmitted over the internet is protected through the use of encryption, using the Secure Socket Layer (SSL) or equivalent protocols.
B. If a password is used to help protect User accounts and account information, it is the responsibility of the User to keep the password confidential. You have to ensure that You always log out, before sharing the device with a third party and it is advised that the User utilize a service to protect access to the User’s Device.
C. We shall use generally accepted industry standards to protect the User information submitted to Us, both during transmission and upon receipt. However, please be advised that, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, even though We strive to use commercially acceptable means to protect User information, We cannot guarantee its absolute security and your use of the App is at your sole risk and discretion. We also cannot warrant that such User information may not be misused in the event our safeguards and protocols are breached by a malicious third-party. Further, We are not liable to nor can we fully control the actions of other users with whom you may choose to share your information.
D. The collection, usage, and sharing of User information by DEEESHA shall be in compliance with the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 and other applicable laws.
9 Limit of Liability
Notwithstanding anything to the contrary in this Policy or any other terms of service or use appliable as between Deeesha and Clients, Deeesha’s aggregate liability hereunder shall be limited to Rs.1000/- (Rupees One Thousand Only) and shall not extend to any indirect or remote damages whatsoever, including but not limited to special, incidental, consequential, or punitive damages or loss of profits.
10 Enforcement
For any inquiries and complaints, the following email address may be used: support@deeesha.com. All inquiries and complaints shall be looked into promptly and without charging any fee to the inquirer / complainant.
Grievance Officer
For any inquiries and complaints, the following email address may be used: support@DEEESHA.com
11 Compliance
Deeesha shall always cooperate with regulatory authorities and investigating agencies in India in the matter of treatment of Personal Information.
12 Amendments
Deeesha may modify this Policy in its sole discretion at any time. While Deeesha shall make best efforts to notify Clients of any such modification, it shall be Clients’ responsibility to read and understand the Policy as prevalent from time to time. Installation / Browsing of the App / Website shall be deemed to constitute acceptance of the Policy as amended.