PRIVACY POLICY – 18th June 2022

FINSARA is a trademark of Resilient Artificial Intelligence Solutions Private Limited, a company incorporated under the provisions of the Companies Act, 2013, and has its corporate office at 2nd Floor 108, Udyog Vihar Phase 1, Sector 20, Gurugram, Haryana 122016 (“we” or “our” or “us”). We are engaged in the business of providing services to you for receiving financial products and services from other partners.

This Privacy Policy (“Policy”) outlines our practices in relation to the collection, storage, use, processing, and disclosure of information that its customers (“you” or “your”) have chosen to share upon visiting, downloading and using our mobile application “FINSARA” or FINSARA website available at https://www.finsara.app (collectively, “App”)

The services offered to you on or through App are referred to as “Services”. Please note that unless specifically defined in this Policy, capitalised terms shall have the same meaning ascribed to them in our Terms and Conditions, available at https://finsara.app/terms.html (“Terms”). Please read this Policy in consonance with the Terms.

By visiting, downloading, accessing the App or by using all or any part of the Services, you agree to the terms of this Policy.

1. INFORMATION COLLECTION

A. COLLECTION OF PERSONALLY IDENTIFIABLE INFORMATION

When you use our Platform, whether our Website or our App, we collect and store your information (personal information) which is provided by you from time to time by explicitly seeking permission from YOU to get the required information. Our primary goal in doing so is to provide you with a safe, efficient, smooth, and customized experience and services. This allows us to provide services and features that meet your needs, and customize our Platform to make your experience safer and easier and improve the services provided by us. More importantly, we collect personal information from you that we consider necessary for achieving the aforementioned purpose.

In general, you can browse the Website or App without telling us who you are or revealing any personal information about yourself. However, to create an account on the Website or App, you must provide us with the certain basic information required to provide customized services. The information we collect from you, inter alia, includes:

  • your full name;
  • email;
  • mailing address;
  • postal code;
  • family details;
  • university/college details;
  • phone number;
  • Permanent Account Number (PAN);
  • Aadhaar Number;
  • Academic records and certificates.

Where possible, we indicate the mandatory and the optional fields. You always have the option to not provide your personal information by choosing not to use a particular service or feature on the Platform. We also collect other identifiable information (your payment card details and transaction histories on the Platform) from you when you set up a free account with us as further detailed below. While you can browse some sections of our Platform without being a registered member as mentioned above, certain activities (such as availing of loans from the third-party lenders on the Platform) require registration and for you to provide the above details. The Platform shall clearly display the personal information it is collecting from you, and you have the option to not provide such personal information. However, this will limit the services provided to you on the Platform.

B. COLLECTION OF FINANCIAL SMS INFORMATION

We don’t collect or store your personal SMS. Our app collects and transmits only your financial SMS (sent by 6-digit alphanumeric senders) data to FINSARA servers, which helps us in identifying the various bank accounts that you may be holding and cash-flow patterns for the purpose of performing credit risk assessment, assessing your credit worthiness, and assigning a line of credit faster.

C. COLLECTION OF MOBILE NUMBER

When you sign up with us, we collect your mobile number and email address to uniquely identify you. This helps us ensure that no unauthorised device or person is acting on your behalf.

D. COLLECTION OF DEVICE INFORMATION

Our app collects information from your device that includes the IMEI number, model number, OS details, mobile network information and Wi-Fi information to provide additional security so that no unauthorized devices act on your behalf to prevent fraud.

E. COLLECTION OF LOCATION

We collect and monitor the location information from your device to provide the serviceability of your line of credit. This also helps us to verify the addresses and make a better credit risk decision.

F. COLLECTION OF CONTACT

As a part of our app journey, we require references to whom you can refer FINSARA.

G. STORAGE

We require storage information permission so that you can upload photos and/or documents to complete your onboarding journey

H. CAMERA

We require camera access so that you can easily scan any UPI QR code to initiate payment. This will also provide an easy way to scan, or capture required KYC documents.

I. COLLECTION OF OTHER NON-PERSONAL INFORMATION

We automatically track certain information about you based on 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. We also collect your Internet Protocol (IP) address and the URL used by you to connect your computer to the internet, etc. This information may include the URL that you just came from (whether this URL is on our Website or not), which URL you next go to (whether this URL is on our Website or not), your computer browser information, and your IP address.

Cookies are small data files that a Website stores on Your computer. We will use cookies on our Websites like 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.

If you choose to make a purchase through the Website, we collect information about your buying behaviour.

We retain this information as necessary to resolve disputes, provide customer support and troubleshoot problems as permitted by law.

If you send us personal correspondence, such as emails or letters, or if other users or third parties send us correspondence about your activities or postings on the Website, we collect such information into a file specific to you.

2. USE AND DISCLOSURE OF YOUR PERSONAL AND OTHER INFORMATION

We access, store and use the information we collect from to provide our Services, research and develop new ones.

We use personal information to provide the services you request, customize your user experience and improve our services. To the extent we intend to use your personal information to market any product to you, we will provide you with the ability to opt-out of such uses.

We use the information provided by You in the following ways:

  • A. to establish identity and verify the same.
  • B. monitor, improve and administer our Website / Platform.
  • C. provide our service i.e. perform credit profiling for the purpose of facilitating loans to You.
  • D. design and offer customized products and services offered by our third-party financial partners.
  • E. analyse how the Website is used, diagnose service or technical problems and maintain security.
  • F. send communications notifications, information regarding the products or services requested by You or process queries and applications that You have made on the Website.
  • G. manage Our relationship with You and inform You about other products or services We think You might find of some use.
  • H. conduct data analysis in order to improve the Services / Products provided to the User.
  • I. use the User Information in order to comply with country laws and regulations.
  • J. to conduct KYC for our third-party lending partners based on the information shared by the User.
  • K. use the User information in other ways permitted by law to enable You to take financial services from our lending partners.
  • L. detect and protect us against suspicious or illegal activity, fraud and other criminal activity.
  • M. resolve disputes or troubleshoot problems.

In our efforts to continually improve our product and service offerings, we collect and analyze demographic and profile data about our users' activity on our Website or App. We will use and retain Your information for such periods as necessary to provide You with the Services, comply with our legal obligations, resolve disputes, and enforce our agreements.

3. PURPOSES AND USAGE OF COLLECTED INFORMATION

  • A. The primary purpose of collecting your information is to provide you with the Services. In addition, the information can be used for the following purposes:
  • B. To register you as a user of the App.
  • C. To provide personalised offers.
  • D. To manage our relationship with you, including notifying you of changes to any Services.
  • E. To administer and protect our business and the App, including troubleshooting, data analysis, system testing, and performing internal operations.
  • F. To deliver content.
  • G. To send you communication, including through WhatsApp business messages, in relation to your use of the App or Services.
  • H. To monitor trends so we can improve the App and Services.
  • I. To improve our business and delivery models.
  • J. To perform our obligations that arise out of the arrangement we are about to enter or have entered with you.
  • K. To enforce our Terms and legal requirements.
  • L. To perform collection related activities.
  • M. To undertake marketing services, including sending you promotional messages.
  • N. To respond to court orders, establish or exercise our legal rights, or defend ourselves against legal claims.
  • O. We will not use User information for any purpose other than in connection with this Platform. FINSARA will not rent, sell or share User information and will not disclose to 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 the services being rendered through the Platform;
    • it is to help investigate, prevent or take action regarding unlawful and illegal activities;
    • it is to investigate suspected fraud, potential threat to the safety or security of any person, violations of FINSARA's Terms & Conditions, or as defence against legal claims;
    • if it forms part of the information FINSARA shares with advertisers on an aggregate basis.

4. SHARING OF INFORMATION

  • A. As mentioned above any and all information pertaining to you, whether or not you directly provided it to us, may be shared in order to render the Services to you. In addition, we may share your information with the following:
  • B. Our affiliate or subsidiaries or any company that we intend to merge with or acquire.
  • C. Banks and other financial institutions to provide you Services or develop new products.
  • D. Credit Bureau and other third parties (including collection agencies) are involved – directly or indirectly – in providing services or in running our business operations. This may include but not be limited to lenders, storage providers, data analytics providers, consultants, lawyers, and auditors.
  • E. Where we are required by law, any court, a government agency, or authority to disclose such information. Such disclosures are made in good faith and belief that it is reasonably necessary to do so for enforcing this Policy or the Terms, or in order to comply with any applicable laws and regulations.
  • F. The acceptance of this Policy by you authorizes us, our associate partners, affiliates and subsidiaries to contact you via SMS email, phone, or otherwise regarding Services or any promotional offers.

5. ACCESS AND UPDATE YOUR INFORMATION

You hereby warrant that all information that you provide us with is accurate, up-to-date, and true. When you use our Services- we use commercially reasonable efforts to provide you with the ability to access and correct inaccurate or deficient information, subject to any legal requirements.

6. DATA SECURITY

We implement appropriate security measures to protect your information from unauthorised access, and follow standards prescribed by applicable law.

7. DATA RETENTION

You agree and acknowledge that your information will continue to be stored and retained by us for as long as necessary to fulfil our stated purpose(s) or for a reasonable period after termination of your account on the App or access to the Services, whichever is later.

8. TRANSFER OF INFORMATION

We comply with applicable laws in respect of storage and transfers of your information. Please note that your financial data is only stored on systems located in India.

9. LINKS TO THIRD PARTY WEBSITES

Our Services may, from time to time, contain services provided by or links to and from the websites of our partner networks, service providers, financial institutions, advertisers, and affiliates (“Third Party Services”). Please note that the Third-Party Services that may be accessible through our Services are governed by their own privacy policies. We do not accept any responsibility or liability for the policies or for any information that may be collected through such Third-Party Services. Please check their policies before you submit any personal data to such websites or use their services.

10. BUSINESS TRANSITIONS

You agree and acknowledge that in the event we go through a business transition, such as a merger, acquisition by another organisation, or sale of all or a portion of our assets, your personal data might be among the assets transferred.

11. WITHDRAWAL OF CONSENT

You may withdraw your consent given for collecting any Information and Personal Data under this Privacy Policy and pursuant to use of the Services, at any time by sending an email to contact@finsara.app. In such an event, we reserve the right to not allow you further usage of our App or provide/use any Services thereunder, without any obligations or liability, whatsoever, whether in contract, tort, law, equity or otherwise, in this regard.

12. CHANGE IN PRIVACY POLICY

We keep our Policy under regular review and may amend it from time to time, at our sole discretion. Any changes shall be deemed effective immediately upon publishing of the modified Policy on the App and any continuous usage of Services, following the modification will indicate acceptance of changes in Policy by you.

13. GRIEVANCE OFFICER

You may contact our Grievance Officer with any enquiry relating to this Policy or your personal data.

Name: Vishwas Trehan

Address: 2nd Floor 108, Udyog Vihar Phase 1, Sector 20, Gurugram, Haryana 122016

Email Address: Vishwas@resilient-ai.com