Vaidhudyam Chamber of Commerce and Industry (VCCI), a company incorporated as
Section-8
Microfinance Company under the provisions of the Companies Act, 2013, engaged to render certain
services on the App or Website, (“VCCI”/ “We”/
“Us”/”Our”) are committed to upholding the privacy and security of the
information supplied by every person (“User”/“You”/”Your”)
accessing and using any version of the VCCI application (“App”) on a compatible
device. This privacy policy (“Privacy Policy”) briefly provides the way we collect
and use user information.
The Company shall strive to seek only relevant personal information about You that
are required
for Us to provide You with the appropriate credit analysis and credit advice and other services
more particularly stated in the Terms and Conditions. By accessing or using the Website, you
signify that you have read, understood, and agree to be bound by this Privacy Policy. We may
make changes to the Privacy Policy from time to time. We will notify you of any material changes
by sending you an email, posting a notice on the homepage of the Website, or posting a notice in
your account when you first login after we have made changes. If you receive notification or a
change in our Privacy Policy, you must review the new Privacy Policy carefully to make sure you
understand our practices and procedures and such changes shall be effective immediately upon
posting the updated or modified Privacy Policy on the VCCI website.
The security of personal information about You is our priority. We protect this
information by
maintaining physical, electronic, and procedural safeguards that meet applicable law. We train
our employees in the proper handling of personal and sensitive information. When We use other
companies to provide services for us, we require them to protect the confidentiality of personal
and sensitive information they receive. The Company does not sell or forward or rent your
personal information you share with any third party for any purposes like marketing etc. without
your explicit consent.
Your access and use of the Website 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 Website and any disputes arising therefrom, is subject to this Privacy Policy as well as the
terms and conditions, as set out below (“T&C”).
- Information Collected :
- We collect personal information of the user. While some user information must
be
mandatorily provided, others are optional and certain portions of the information
will
remain private and some will be displayed to other users. Additional information may
be
gathered during subsequent use of the Website by the user, whenever the user chooses
to
provide it.
- Certain mandatory information will be collected at the time of registration on the
Website
which is required to enable the user to login to the Website 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.
- We collect personal information, that includes any information concerning the
personal
or material circumstances of an identified or identifiable User, e.g. name, e- mail
address,
gender, date of birth, postal address, phone number, a unique login name, password,
password
validation, marital status, family details, business information and other details
shared
via application form or via email or via any other medium. It can also include
information
such as username, account number, password and any other personally identifiable
information. While you can browse some sections of our website without being a
registered
member as mentioned above, most activities (such as availing of loans and other
financial
services on the Website and the App) require registration and for you to provide the
above
details. We will indicate the mandatory and the optional fields against the
information
requested from you. You always have the option to not provide your personal
information by
choosing not to use a particular service or feature on the Platform.
- To use the facilities and services available on the Website, the user may be
required,
from time to time, to provide certain additional personal information after
registration on
the Website, which information shall be collected only upon receiving the
user’s
consent
- 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 Website, including mobile
network
information, standard web log information, traffic to and from our Website, tracking
inside
the Website 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 Website and the functions and
features
therein; and
- the type of device used by the User (“Device”).
- 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, and use such information in accordance with this Privacy Policy.
- After obtaining the user’s specific consent to allow the App to access the
user’s SMS, location and other relevant information from the hand-held device,
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
- 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.
- We collect a list of the installed applications’ information which includes
the
application name, package name, installed time, updated time, version name and
version code
of each installed application on your device to assess your creditworthiness and
enrich your
profile with pre-approved customized loan offers.
We will access the camera function of the device to capture selfies for identity
verification and collection of scanned documents during the KYC process.
- We only access the data from the device one time. Explicit consent is also recorded
from the
user in that effect. This is in accordance with the Digital Lending guidelines
defined by
RBI
- Method and manner of use of user information
- When the user registers with the Website, we will use the information supplied by
the user
to pull a credit report from 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.
- 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 Website;
- 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 Website from time to time to cater to the user’s
interests;
- Providing the Website and the functions and features therein, efficiently;
- Preserve social history as governed by existing law or policy;
- You acknowledge that you are licensing us to use, modify, display, distribute and
create new
material from the information you provide through the Website 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 Website and you hereby provide consent for the same.
- Sharing of Information
We will not use user information for any purpose other than regarding the
Website. VCCI
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 regarding the services being rendered through the Website;
- it is to help investigate, prevent or act regarding unlawful and illegal activities;
suspected fraud, potential threat to the safety or security of any person,
violations of
VCCI’s Terms & Conditions, or as a defence against legal claims;
- it is a case of special circumstances such as compliance with court orders,
requests/orders,
notices from legal authorities or law enforcement agencies compel us to make such
disclosure; and
- it forms part of the information VCCI shares with advertisers on an aggregate basis.
- Information security
- User Information transmitted over the internet is protected with encryption, using
the
Secure Socket Layer (SSL) or equivalent protocols.
- 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 must 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.
- 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 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 Website 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.
- The collection, usage, and sharing of User information by VCCI shall be in
compliance with
the Information Technology (Reasonable Security Practices and Procedures and
Sensitive
Personal Data or Information) Rules, 2011, RBI regulations and other applicable
laws.
- Data Storage/Deletion Policy
- The user acknowledges that the Platform has duly collected the information with the
users
consent and the user has the option to not provide such information or deny consent
for use
of specific information or revoke the consent already given. However, any withdrawal
of such
personal information will not be permitted in case any Service availed by the user
is
active. Where a consent has been withdrawn the Platform does not guarantee or be
liable for
providing such Service. The user shall have the following rights pertaining to the
information collected by us.
- Deny Consent: The user shall have the right to deny consent for use of specific
data,
restrict disclosure to third parties, data retention, revoke consent already granted
to
collect personal data and if required, make the App delete/ forget the data.
However, any
such denial will not prejudice the right of the Lending Partners to retain any data
in
relation to the loans availed by you or by the non-lending service providers in
relation to
the non-lending services provided. Further, in case of a denial of a consent, the
Platform
does not provide a guarantee or will not be liable towards the continued
facilitation of the
Services if any such controls are exercised.
- Withdraw Consent: The user may withdraw consent to contact the user, for the
continued
collection, use or disclosure of user information, at any time, or request for
deletion of
login account by raising a request on the App or by mailing Us at vccimf@gmail.com. However, Platform does
not
provide a guarantee of Services if any such controls are exercised. Further, if the
user has
availed any loan facilities from our lending partner, the lending partner shall have
the
right to continue processing the information till such credit facility has been
repaid in
full, along with any interest and dues payable and/or for such period as may be
allowed
under applicable law.
- However, we shall not retain user 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.
Also, the information may still be used for the execution of any outstanding or
termination
activity of any Lending or Non-lending Services. Unless there is a
regulatory/operational
need to retain any user information, it will be wiped from the system within 5 years
from
the cessation of the relationship.
- If the user no longer wishes to receive notifications about VCCI services, the user
may
change his/her notification preferences by contacting VCCI at vccimf@gmail.com. VCCI reserves the
right to
close the user account if the user opts out of receiving certain crucial notices
that are
required to perform the VCCI services through its website. The user may not opt out
of
receiving notifications about due or past due amounts that the user owes VCCI or any
other
collections efforts.
-
Procedure for correcting inaccuracies in the information
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: vccimf@gmail.com.
-
7. Child protection policy
VCCI’s Services are intended for users who are 18 years and older only.
Accordingly, we
will not knowingly collect or use any Personal Information from individuals that we know
to be
under the age of 18. In addition, we will delete any information from our database that
we know
originates from an individual under the age of 18.
-
8. Data sharing with Third party
VCCI may share personal information of a user with Credit Rating Agencies and such
information shall
be shared with Credit Rating Agencies in the event the Reserve Bank of India issues
guidelines or
direction in this regard.
- 9.Security Precautions
-
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. For
example,
we
encrypt all information when we transmit over the internet.
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 users from unauthorized access, alteration, disclosure or
destruction of information we hold, including:
- We use encryption to keep your data private while in transit;
- We offer security feature like an OTP verification to help you protect your
account;
- We review our information collection, storage, and processing practices,
including
physical security measures, to prevent unauthorized access to our systems;
- 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;
- Compliance & Cooperation with Regulations and applicable laws;
- We regularly review this Privacy Policy and make sure that we process your
information
in ways that comply with it.
- Data transfers;
- We ensure that the Aadhaar number is not disclosed in any manner.
- We or our affiliates maintain your information on servers located in India.
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 and rules
made
thereunder.