Privacy Policy for Digital Lending Products / Money Lending Services

I. Types of Information We collect

• Subject to You accepting this Digital Lending Privacy Policy, We may collect Your Personal Data and Personally Identifiable Information (PII) for the purpose of providing Services on the Platform which includes but is not limited to the following:
• Name
• Contact information (phone numbers, email addresses)
• Residential address
• Financial information
• Employment details
• Credit history and records
• Identity Documents and/or any details provided by You to Us to avail various products/Services from Us.
• 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;
• All information that may have been voluntarily provided by You in connection with availing the Services on the Platform. Necessary permission/consent shall be sought for the same at an appropriate stage during the Platform usage at all times.
• One time access to Your camera, microphone, location and mobile device for the purpose of onboarding or KYC requirements of us or our Partner with Your explicit consent in accordance with the Digital Lending guidelines issued by RBI and as amended from time to time. Unless required for compliance with applicable laws or specifically consented to by You, We shall desist from accessing mobile phone resources like file and media, contact list, call logs, telephony functions, etc.
• Except as required under applicable laws or as may be consented by You in compliance with applicable laws, We shall not collect or store Your bio-metric data. 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.
• In general, You can browse Our Platform (limited web pages from our website) 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. Mobile application can be browsed only after creating an account with us as aforesaid.

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. We shall delete Your Personal Data upon Your request, provided there is no active loan or service being availed by You or if Your Personal Data is required to be retained due to applicable laws or any regulatory requirement. You may send an email to lendingsupport@angelbroking.com for any such request. The email should mention Your mobile number, lender name, and type of modification required along with request for data deletion. The data deletion will happen within 45 days of Your request.

II. Purpose of obtaining the information:

• Establish identity and verify the same;
• To facilitate Your KYC with Our lending Partners;
• Post any changes/updates/modifications as 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.

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 be shared without Your consent unless as specified in the below cases wherein we are obliged to share. You hereby agree and consent to us collecting, transferring, and sharing Personal Data to our lending partners, service providers, subsidiaries and group companies or such other third-parties as may be listed out in Clause XIV below.

In various processes / submission of applications / availing of product / service offerings, We shall seek Your explicit consent to use / share Your Personal Data.Please note that data sharing for statutory / regulatory agencies would not require explicit consent
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 may disclose and share Your information with the lending partners and our third-party partners for the purpose of reviewing credit records, facilitation of a loan provision or facility or line of credit, suggesting loan eligibility, and the shared information is used by these vendors/partners in accordance with their own privacy policies and applicable laws;
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 service providers and credit partners to perform credit checks and credit analysis like Credit Information Companies (Credit Bureaus) or third party data source providers;
4. We will share Your information under confidentiality obligations with the third parties and restrict the use of the said information by third parties only for the purposes detailed herein.
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.

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. This allows Us to provide Services and features that meet Your needs, and to customize Our Platform to make Your experience safer and easier and to improve the Services provided by Us.

We may store, process, and retain Your Personal Data on Our servers located in India, and/or on the servers of third parties having contractual relationships with Us. 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. We will comply with the following procedure for destruction and disposal of Your Personal Data:

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.

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 (vide the Services) and to report on these transactions to our lending partners;
• 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 out credit checks, screenings, or due diligence checks as lawfully required by Us and/or credit 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 etc.;
• To comply with the requirements of applicable laws/regulations and/or court orders/regulatory directives received by Us; 
• To create Your login credentials or for creating Your profile on the Platform;
• To help promote a safe service on the Platform and protect the security and integrity of the Platform, the Services and the users; 
• To share marketing materials with You;
• To detect, prevent and protect us from any errors, fraud and other criminal or prohibited activity on the Platform; 
• To enforce and inform about our terms and conditions; 
• To contact You; 
• for any other purpose after obtaining Your explicit and unambiguous consent at the time of collection;

Commission/Brokerage: You understand that Angel One may earn commission / brokerage for facilitating loan transactions. This commission is earned for connecting You with Our partners as an agent of such partnerships.

VI. Cookie Policy

We may also collect certain non-personal information, such as system generated user ID and access tokens (“Non - Personal Information”) while You browse, access or use the Platform or if You have Our mobile application on Your device. We receive Non–Personal Information by the use of data collection devices such as “cookies” on certain pages of the Platform, in order to help and analyse our web - page flow, track user trends, and promote trust and safety. 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. We may place both permanent and temporary cookies on Your device. We also use cookies to allow You to enter Your password less frequently during a session on the Platform. Most cookies are “session cookies,” meaning that they are automatically deleted from Your hard drive at the end of a session. You are always free to decline our cookies if Your browser permits, although in that case, You may not be able to use certain features or Services being provided on the Platform or You may be required to re-enter Your password each time You log – in or access the Platform during a session. 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.

VII. Links to other websites

Our Platform may provide links to other third - party platforms including those of third-party Partners (“Third – Party Sites”) that may collect Your Personal Data such as Your IP address, browser specification, or operating system, etc. We are not in any manner responsible for the security of such information or their privacy practices or content of those Third – Party Sites. Additionally, You may also encounter “cookies” or other similar devices on certain pages of the Third – Party Sites and it is hereby clarified by the Company and its Affiliates that they do not control the use of cookies by these Third-Party Sites. These third-party service providers and Third-Party Sites may have their own privacy policies governing the storage and retention of Your information that You may be subject to. We recommend we are not liable for the information published in search results or by any Third-Party Sites.

VIII. 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. We cannot however ensure or warrant the security of any information You transmit to Us or guarantee that Your Personal Data may not be accessed, disclosed, altered, or destroyed by a breach of any of our security measures and safeguards. In the event of any actual or suspected security incident, including data breach, we will take all measures required to be undertaken under applicable laws. It is further clarified that You have and so long as You access and/or use the Platform (directly or indirectly) the obligation to ensure that you take adequate physical, managerial, and technical safeguards at your end to preserve the integrity and security of your information including Your Personal Data.

Additionally, We shall also ensure compliance with various technology standards/requirements on cybersecurity stipulated under applicable laws in provision of Our Services to You.

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

IX. Compliance with Laws and Applicable Regulations

We comply with all applicable laws and regulations concerning data privacy and security, including but not limited to 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, The Digital Personal Data Protection Act, 2023 (upon it being enforced).

X. Contact us

If You have any queries, feedback, questions, or concerns regarding the collection, processing, usage, disclosure, and security of Your information/data, or any aspect of this Digital Lending Privacy Policy, please address them to lendingsupport@angelbroking.com.

XI. Policy Review & Updates

This Digital Lending Privacy 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 Digital Lending Privacy Policy, to make sure that You are aware of any changes, we recommend that You review this Digital Lending Privacy Policy periodically.

This Digital Lending 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/Platform, 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/Platform 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/Platform. 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. Grievance Redressal

For grievances related to Our Platform , You can reach out to Our nodal officer(s) at:

Name: Gable Fernandes

Email id:lendingsupport@angelbroking.com

Phone No: 1800 1020

Designation: Nodal Grievance Redressal Officer

Address:601 6th Floor, Ackruti Star, Central Road - MIDC, Andheri (E), Mumbai - 400 093 

You may also reach out to Our lending partners for any grievances related to Your loans. The details of the grievance officers of our lending partners can be found below: 

Lender Name: KSF

Name: Ms. Preethi Nair

Email Id:preethi.nair@creditsaison-in.com

Grievance Redressal mechanism of Kisetsu Saison Finance India Private Limited (Credit Saison)

Lender Name: SMFG

Name: Ritesh Saxena

Email Id - GRO@smfgindia.com

Number - 022-69581104

Designation: Grievance Redressal Officer

Grievance Redressal mechanism of SMFG India Credit Co. Ltd.

Lender Name: ABFL

Name: Mr. Arijit Sen

Designation: Grievance Redressal Office

Email: grievance.finance@adityabirlacapital.com

Number: 080 – 45860196

Grievance Redressal mechanism of Aditya Birla Finance Ltd.

If the complaint has not been addressed by the respective lending partner within 30 days from the date of raising the complaint or the provided response is not satisfactory, the customer can lodge a complaint over the Complaint Management System (CMS) portal (https://cms.rbi.org.in/cms/indexpage.html#eng) under the Reserve Bank-Integrated Ombudsman Scheme (RB-IOS). For banks / lending partners currently not covered under RB-IOS, complaint may be lodged as per the grievance redressal mechanism prescribed by RBI.

XIII. Governing Law & Jurisdiction

XIV. Details of associated third parties

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

Name	Services Provided
Kisetsu Saison Finance (India) Private Limited	Lending Partner
Acko General Insurance Limited	Insurance Partner
Digiotech Solutions Private Limited	Nach Mandate
Hyperverge Technologies Private Limited	Support Services
Moshpit Technologies Private Limited (Finbox)	Support Services
Experian Credit Information Company of India Private Limited	Credit Information Partner
SMFG India Credit Co. Ltd. (Formerly Fullerton India Credit Co. Ltd.)	Lending Partner
Aditya Birla Finance Limited	Lending Partner