Privacy Policy
Loanify Fintech Private Limited (hereinafter referred to as “Loanify” or “our” or “we” or “us”) values and
respects your right to privacy. This Privacy Policy (“Policy”) aims to set out the details of the nature of
information we collect and how we use, share or otherwise process such information in relation to our
services. This Policy complies with inter alia the provisions of Information Technology (Reasonable Security
Practices & Procedures & Sensitive Personal Data or Information) Rules, 2011 under the Information
Technology Act, 2000, the RBI Guidelines on Digital Lending, and other applicable laws that require
publishing of privacy policies for collection, usage, storage, disclosure and transfer of information.
By clicking ”Accept” on the relevant Loanify App screen, you expressly agree and provide explicit consent to
be bound by the terms of this Policy. If you do not agree with the terms of this Policy, you must
immediately discontinue the use of and cease to access this App and any other services provided by Loanify
(collectively, the “Services”). This Privacy Policy does not apply to your use of Loanify’s website,
Loanify.co.in (“Website”). Please click here for the privacy policy applicable to your use of the Website.
You must be 18 years of age or above to use our App and, or, the Services.
1. SCOPE OF POLICY
This Privacy Policy applies to the App, the Services and any other online or mobile application that refers
to or links to this Policy. This Policy applies regardless of whether you have downloaded or accessed the
App onto your mobile telephone, handheld device or any other computer resource (each referred to herein as a
“Device”).
This Policy applies to all concerned Users (a “User” is any person who downloads and/or accesses the App on
any Device) whose information is collected, possessed, stored, received or otherwise dealt with by us in the
course of providing the Services.
2. INFORMATION WE COLLECT
We collect and process various types of information within the App and as part of offering our Services. The
information that we collect or process may fall within the category of “Personal Information” as we define
that term below. We limit the collection and processing of Personal Information only to what is necessary
for achieving the purposes as identified in this Policy.
Personal Information means any information pertaining to an individual natural person which, either directly
or indirectly, in combination with other information, is capable of identifying such an individual.
You provide us with information, including Personal Information, by accessing our App or otherwise using our
Services, including by corresponding or otherwise communicating with us. You may also provide us with
information indirectly via your social media accounts. Information we collect from you with your explicit
consent, or from your device in connection with your usage of the App, includes:
- Identity details, including name, date of birth, and government identification information (such as
Permanent Account Number and Aadhaar);
- Mobile number, email address, home address, and other contact details;
- Financial information, which may include account and transactional information and history,
responses submitted within the App, proof of income, and credit and borrowing history;
- Photograph/image and personal appearance;
- SMS logs and contents;
- Location information;
- Technical information, including the Internet Protocol (“IP”) address, the type of Device you use,
unique device identifiers (for example, your Device’s “IMEI” or serial number), information about
the mobile network provider and SIM card used by the Device, mobile network information, your
Device’s operating system, the type of browser you use, the mobile applications installed on your
Device, your Device’s technical specifications and settings;
- Details of your use of the App, such as page interactions and navigation;
- Communications with Loanify or Loanif's service providers, including call recordings, inquiries, and
service requests and tickets.
In accordance with the RBI Guidelines on Digital Lending, a one-time access may be taken for camera,
location, or other facilities necessary for the purpose of onboarding and KYC requirements, with your
explicit consent. If you do not wish to provide consent for the collection and processing of such data,
click “Deny” on the relevant screen or window in the App.
We may also collect information about you from a limited number of third parties that we may work with from
time to time to provide the Services, including but not limited to:
- Credit information from credit reference agencies or the lender of record, among others, in our
capacity as your authorized representative;
- Transaction information from money service businesses, mobile network providers, payment and
delivery service providers, collection agencies and analytics partners, to ensure that we
effectively meet our obligations to you.
Loanify does not collect or store biometric information.
3. WHY WE COLLECT INFORMATION
Personal Data Processed |
Purposes for Data Processing |
Identity details, including name, date of birth, and government identification information (such
as Permanent Account Number and Aadhaar) |
- Identity verification
- Fraud and crime prevention
- KYC and account monitoring obligations under anti-money laundering regulations
- Credit scoring and development or improvement of decisioning models
- Transaction and funds processing
- Contract fulfilment and collections
- Administration of the App or your account
- Ensuring network and information security
|
Mobile number, email address, home address, and other contact details |
- Identity verification
- Fraud and crime prevention
- KYC and account monitoring obligations under anti-money laundering regulations
- Credit scoring and development or improvement of decisioning models
- Transaction and funds processing
- Contract fulfilment and collections
- Administration of the App or your account
- Ensuring network and information security
|
Financial information, which may include account and transactional information and history,
responses submitted within the App, proof of income, and credit and borrowing history |
- Identity verification
- Fraud and crime prevention
- KYC and account monitoring obligations under anti-money laundering regulations
- Credit scoring and development or improvement of decisioning models
- Transaction and funds processing
- Contract fulfilment and collections
- Administration of the App or your account
- Ensuring network and information security
-
- Identity verification
- Fraud and crime prevention
- KYC and account monitoring obligations under anti-money laundering regulations
- Credit scoring and development or improvement of decisioning models
- Transaction and funds processing
- Contract fulfilment and collections
- Administration of the App or your account
- Ensuring network and information security
|
Photograph / image and personal appearance |
- Identity verification
- KYC obligations under anti-money laundering regulations
|
SMS logs and contents |
- Fraud and crime prevention
- Credit scoring and development or improvement of decisioning models
|
Location information |
- Fraud and crime prevention
- KYC and account monitoring obligations under anti-money laundering regulations
- Credit scoring and development or improvement of decisioning models
- Ensuring network and information security
|
Technical information, including the Internet Protocol (“IP”) address, the type of Device you
use, unique device identifiers (for example, your Device’s “IMEI” or serial number), information
about the mobile network provider and SIM card used by the Device, mobile network information,
your Device’s operating system, the type of browser you use, the mobile applications installed
on your Device, your Device’s technical specifications and settings |
- Identity verification
- Fraud and crime prevention
- Credit scoring and development or improvement of decisioning models
- Service improvement, training, research, analysis, and troubleshooting
- Administration of the App or your account
- Ensuring network and information security
|
Details of your use of the App, such as page interactions and navigation |
- Identity verification
- Fraud and crime prevention
- Credit scoring and development or improvement of decisioning models
- Service improvement, training, research, analysis, and troubleshooting
- Administration of the App or your account
- Ensuring network and information security
|
Communications with Loanify or Loanify’s service providers, including call recordings,
inquiries, and service requests and tickets. |
- Transaction and funds processing
- Contract fulfilment and collections
- Service improvement, training, research, analysis, and troubleshooting
- Administration of the App or your account
- Marketing and promotional offers
|
Credit information from credit reference agencies or the lender of record |
- Identity verification
- Fraud and crime prevention
- KYC and account monitoring obligations under anti-money laundering regulations
- Credit scoring and development or improvement of decisioning models
- Service improvement, training, research, analysis, and troubleshooting
|
Transaction information from money service businesses, mobile network providers, payment and
delivery service providers, collection agencies and analytics partners |
- Identity verification
- Fraud and crime prevention
- KYC and account monitoring obligations under anti-money laundering regulations
- Credit scoring and development or improvement of decisioning models
- Service improvement, training, research, analysis, and troubleshooting
|
4. DISCLOSURE OF INFORMATION
Loanify will not disclose any Personal Information to third parties unless it is necessary and/or
appropriate in order to provide Loanify’s products or services (provided, that, we may share de-identified
data with select partners for research and development). Whenever practically feasible, Loanify will only
share your personal data with third parties in an anonymized or de-identified format.
Subject to Loanify’s compliance with data storage localization requirements, we may provide read-only access
to your information, including your Personal Information, where such access is necessary and customary to
our business practices with certain third parties, including but not limited to any of Loanify’s
subsidiaries, affiliates, subcontractors, agents, service providers, or financing sources (including their
or our employees, directors and officers) for the performance of any contractual obligation we may enter
into with such parties or with you.
You understand and agree that Loanify may, as necessary and/or appropriate for the purposes provided above,
and likewise subject to Loanify’s compliance with data storage localization requirements, transfer and
disclose your Personal Information in identifiable form with:
- partner banks, non-banks, money service businesses, clearing houses, clearing or settlement systems,
withholding agents, or other regulated entities and financial institutions (for purposes of KYC,
account administration, credit disbursement, funds transfer, and loan repayment);
- credit reference agencies or credit bureaus (to obtain credit references and to comply with
reporting requirements as applicable);
- external collection agencies (to assist in the collection of any unpaid obligations);
- service providers with contractual or fiduciary relationships with Loanify (e.g., to facilitate
transaction processing, debt collection, cloud data storage, business analytics);
- external counsel, external auditors, and consultants, when necessary to resolve disputes or
complaints;
- a party in connection with any merger, acquisition or sale of all or substantially all of the assets
of Loanify and/or any company within the Loanify Group;
- a party in connection with any assignment of credit or the creation of a security interest involving
outstanding balances owned to Loanify.
Further, Loanify may also share your personal data with law enforcement or other government agencies in
connection with a formal request, subpoena, court order, or similar legal procedure, or when we believe in
good faith that disclosure is necessary to comply with the law, statutory or regulatory requirement; to
prevent physical harm or financial loss; to report suspected illegal activity, or to investigate violations
of our agreements with you.
5. STORING YOUR INFORMATION
In compliance with data localization requirements under applicable regulatory guidelines, Loanify commits to
store Users’ Personal Information only in servers located within India. All data is encrypted in transit and
is securely stored.
6. DATA RETENTION AND DISPOSAL
Loanify will retain your information for as long as it is required to provide you with the Services, or
while you are using our App. Retention periods for records are based on the type of information, the nature
of the activity, and the product or service to which the same is associated.
The periods for retention of your information, including Personal Information, vary depending on specific
legal business and statutory compliance. For example, in compliance with global anti-money laundering and
counter financing of terrorism standards, Loanify retains transaction data for a minimum period of seven (7)
years from the transaction date.
We may be required to retain your information post termination of our business relationship with you for
fraud prevention purposes and for the exercises/defense of a legal claim or for providing evidence in legal
proceedings.
Personal Information that is beyond the retention period shall be deleted or anonymized through globally
recognized privacy measurement models, in accordance with Loanify’s data retention and disposal policies.
The method of deletion or anonymization ensures that disposal is done in a secure manner that would prevent
re-identification or any further processing, unauthorized access, or disclosure.
7. RIGHTS OF USERS
You have certain rights related to the information we maintain about you and have the right to access the
data records we maintain about you, including the right to obtain the details of how we process it.
You have the right to deny or revoke your consent from letting us access or process your Personal
Information at any time, but this may render us unable to provide you with the Services. You may revoke your
consent or request the deletion of your Personal Information, subject to Loanify’s data retention
obligations under applicable laws, by emailing us at dpo@Loanify.in. Loanify reserves the right to require
the settlement of loan balances prior to the fulfilment of such requests.
You have the right to correct or modify any information that has been provided to us or has been made
available to us, subject to the presentation of relevant supporting documentation.
8. SECURITY OF INFORMATION
The transmission of information via the internet or mobile service is not completely secure. Loanify cannot
guarantee the security of your information transmitted by you or a third party in connection with the
Services, and any such transmission is at your own risk. Once Loanify has received your information,
including Personal Information, we use and employ reasonable technical, organizational, logistical, physical
and administrative measures to protect your information, against any unauthorized access, modification or
use.
Loanify implements an Information Security Management System to maintain the confidentiality, integrity, and
availability of Loanify’s information resources, in keeping with industry standard and global best
practices. We have put in place procedures to deal with any suspected personal data breach and will notify
you and any applicable regulator when we are legally required to do so.
Where Loanify provides a password or PIN that enables you to access certain parts of the App or the
Services, you are responsible for keeping this password or PIN confidential. In case of any failure to keep
such password secure from your end, we shall not be held responsible.
In the event of a security breach involving a compromise to the availability, integrity and confidentiality
of Personal Data, Loanify implements an incident management policy to immediately ascertain the nature and
extent of the incident, and to execute measures to mitigate the adverse effects of the incident
9. CHANGES & QUERIES
We retain the right to make changes to this Policy in future. We understand that it is our duty to keep you
informed of any such changes, therefore the Policy with any such changes to it shall be posted on the App,
and if required you will be notified via email or a notification on the App.
We advise you to go through our Policy diligently and periodically and accept any modifications prior to any
continued use of the App or subsequent availing of our Services.
In case of any query or grievance pertaining to this Policy, you may contact us via mail for its redressal
at dpo@Loanify.in. However, if you are not satisfied with the resolution of your concern, you may raise an
escalation to the appointed Nodal Grievance Redressal Officer.
Loanify – Nodal Grievance Redressal Officer:
Name: Mr. Ajay Kumar Shukla
Email: grievance@loanify.in
Number: 07054007001
The Nodal Grievance Redressal Officer will acknowledge all grievances within 48 hours of receipt and shall
address them within a period of 30 days.
EFFECTIVE DATE: DECEMBER 30, 2022