Privacy Policy – Dhani Finance Services

Privacy Policy

Privacy Policy

1. WHAT DATA IS COLLECTED?

By using the App, you consent to providing us and our Lending Partner, data in the ways listed below. We collect the data you provide to ensure that we can provide you Services in the best manner possible. Our Lending Partner uses this data to underwrite (i.e. assess the risk it will be taking) any loan it might offer you and to determine the rates for such loans. The data being asked from you helps us and our Lending Partner to provide services to you in a robust and user-friendly manner. We have detailed the manner in which we and our Lending Partner collect data below:

Dhani finance Account Data: We and our Lending Partner collect the data you provide to us when you create or update your Dhani finance Account. This includes your name, phone number, email ID, PAN, date of birth, pin code, nature of employment, official employment email address and name of employer, monthly income, marital status and relationship with the co-applicant (in case the loan is being sought by more than a single applicant). We or our Lending Partner may require you to share further information on a later date to confirm the veracity of your information or pursuant to any additional features added to the App.

How we use this data: See, For Enabling the App and its Services; For Loan Processing and KYC Authentication; For Enabling Customer Support; For Research and Development; For Enabling Communications Between You and Us; For enabling Marketing and Outreach; For Automated Decisions; For Legal Compliance and Requirements.

Dhani finance Account Data: We and our Lending Partner collect the data you provide to us when you create or update your Dhani finance Account. This includes your name, phone number, email ID, PAN, date of birth, pin code, nature of employment, official employment email address and name of employer, monthly income, marital status and relationship with the co-applicant (in case the loan is being sought by more than a single applicant). We or our Lending Partner may require you to share further information on a later date to confirm the veracity of your information or pursuant to any additional features added to the App.

How we use this data: See, For Enabling the App and its Services; For Loan Processing and KYC Authentication; For Enabling Customer Support; For Research and Development; For Enabling Communications Between You and Us; For enabling Marketing and Outreach; For Automated Decisions; For Legal Compliance and Requirements.

Financial and KYC Information: We and our Lending Partner collect the data you provide to us when you accept the tentative terms of the loans. This includes your photograph, Aadhaar Number, PAN, parents names, bank account number, IFSC, proof of address (which can be your electricity bill, rental/lease agreement, gas bill, passport or drivers license, or any other document our App may be able to record).

How we use this data: See, For Enabling the App and its Services; For Loan Processing and KYC Authentication; For Legal Compliance and Requirements.

Other Data Solicited: You may be required to provide further information to the Lending Partner for the purposes of processing your loan application. Such additional information may include (without limitation) bank statements, goods and services tax returns, salary and income statements and title documents for the property being financed. This data shall be supplied to the Lending Partner through us. You may also be required to provide this information to us and the Lending Partner via physical documents, e-mail or other digital and offline methods.

How we use this data: See, For Enabling the App and its Services; For Loan Processing and KYC Authentication; for assessing the quantum and interest rate of loan to be extended; For Legal Compliance and Requirements.

Feedback Data and Other Data: This includes the following:

If you call our call centers, we may record information provided by you to service you or record the calls for quality and training purposes.
Data you input when you participate in our referral programs or use any discount codes offered by us.
If you provide any feedback or comments to us on the App or as part of our research programs for improving the App.
How we use this data: See, For Enabling the App and its Services; For Loan Processing and KYC Authentication; for Legal.

Geolocation data: We and our Lending Partner collect the location data from you in two ways: (i) when you add the pin code as part of your Dhani finance Account data; and (ii) from your mobile device when enabled by you to do so. We collect this data when our App is running in the background of your mobile device. You will not be able to use the App if you disable the location services.

How we use this data: See, For Enabling the App and its Services; For Loan Processing and KYC Authentication; For Enabling Customer Support; For Enabling Marketing and Outreach; For Automated Decisions; For Legal Compliance and Requirements.

User Personal Information: Our app collects user account data which includes email address, name to log in to the app. This information is required as part of the registration process to access our service and it is also used to auto populate relevant fields in the course of the interface of our app. Our app also collects mobile numbers for verification to check the active SIM status on the device, uniquely identify you and prevent fraud and unauthorized access.

Phone Book Contacts: When you grant us access to the address book on your mobile device, then we and our Lending Partner access and store the names and contact information from your address book to facilitate invitations, assess your phone usage and habits, and to facilitate recovery of delayed EMI payments. You will not be able to use the App if you disable this access. As part of the loan journey, we collect all of your phonebook contacts which includes their contact names, phone numbers, account types, favorites (starred) and contact labels to enrich your financial profile. We use this data to determine your social network from your phonebook contacts and identify fraudulent contacts in your network and for enabling recovery of delayed EMI payments and for promotional and marketing purposes. This helps us in detecting fraud loan applications and reducing credit risk.

How we use this data: See, For Enabling the App and its Services; For Loan Processing and KYC Authentication; Marketing and Outreach.

Financial SMS Data: When you grant us access to the SMSs on your mobile device, then we and our Lending Partner collect SMS data stored on your mobile device. You will not be able to use the App if you disable this access.

How we use this data: See, For Enabling the App and its Services; For Loan Processing and KYC Authentication

App Data: We and our Lending Partner collect the data about your installed applications, including the applications that you have installed on and from the date you create your Dhani finance Account and the manner in which you use them. This also includes having access and permission to send you messages and notifications via your social media and instant messaging applications. You will not be able to use the App if you disable this access.

How we use this data: See, For Enabling the App and its Services; For Loan Processing and KYC Authentication; For Enabling Customer Support; For Research and Development; For Enabling Communications Between You and Us; For enabling Marketing and Outreach.

Usage data: We collect data about how you interact with our Services. This includes data such as access dates and times, App features or pages viewed, App crashes and other system activity, type of browser, and third-party sites or services used before or in the course of interacting with our Services.


How we use this data: See, For Enabling the App and its Services; For Enabling Customer Support; For Research and Development; For Enabling Communications between You and Us; For enabling Marketing and Outreach; For Automated Decisions; For Legal Compliance and Requirements.

2. HOW AND WHY IS THE COLLECTED DATA USED?

The data that is collected in accordance with Section 1 of this Policy will be used in the manner detailed below:

We use the data collected to personalize, maintain and improve our Services. This includes using the data to:

Create and update the Dhani finance Account.
Analyze your loan eligibility and estimate your loan terms.
Track the disbursement and repayment of the loan.
Enable features that allow you to add and remove bank accounts for your loan repayment and disbursements from time to time.
Our Lending Partner uses the data to analyze your creditworthiness, loan eligibility, KYC documents, current employment verification and, and the terms of your loans. While we collect the Financial and KYC Information, the Lending Partner is required to individually process the loan requests and verify the KYC documentation received. Failing to process such data means that you cannot be provided any loans. You hereby grant us explicit consent to fetch your KYC (Know Your Customer) details from the Central KYC Records Registry using the details provided by you.

Our Lending Partner also uses the data to track disbursement and repayment of your loan.

We use the information to provide customer support, including to resolve your concerns from the use of the Services, and train our customer service executives.

We may use the data so collected for research, analysis, and product development to improve the UI/UX experience – all of which will ultimately improve how you experience the App. This also helps us develop automated actions to be triggered in certain events, such as when we need to identify if photographs uploaded are not clear, fraud takes place, IFSC is incorrect etc.

We may add features that allow you to call us (through the App or otherwise), similarly, we may also need to contact you (through the App or any other channels that you give us access to, such as WhatsApp or Facebook).

We may use the data we collect to market the App and our Services. This includes sharing your feedback, ratings and screen names for purely promotion and marketing purposes. Such promotion and marketing may be done, inter alia, via hoardings, banners, pamphlets, calls, SMSes, emails and other means.

The App may provide automated features for customer responses, reimbursement tracking, etc. As our App grows, we will keep adding more automated features to the App.

We may use the data we collect to investigate or address claims or disputes relating to use of our Services, or as otherwise allowed by applicable law, or as requested by regulators, government entities, and official inquiries.


We may use the data we collect to offer new products and services for your use.

3. HOW DO WE SHARE THE COLLECTED INFORMATION?

We are very protective about your data. We may enter into data-sharing agreements or disclose the collected data in order to provide the Services and new product offerings to you. We have detailed the manner in which we and the Lending Partner share the collected data below:

Service Providers: We work with third party service providers to execute various functionalities of the App and we may share your information with such service providers to help us provide the App. Some of these functionalities may include:

Analyzing transaction behavior and cashflows via your SMSs, bank statements, goods and services tax returns, salary and income statements, income tax returns, basis which your loan offer is generated.
Validating and authenticating the official verification documents provided by you.
Validating your preferred bank account, as well as transferring the loan amounts to you.
E-signing of the loan agreement or sanction letter, populating the loan agreement or the sanction letter. The information shared with these service providers is retained for auditing of the agreements.
eNACH set-up to enable autopay.
Analyzing customer behaviour, conducting research into customer behaviour and contacting the customers for the said purpose, and to automate our marketing and outreach efforts.
Detection and flagging of fraud.
Cloud services.
Gathering of additional information regarding your bank account and statement details, in case adequate information has not been provided by you or through the other service providers we work with.
For manually collecting any sums owed by you to our Lending Partner.
Validating and authenticating your employment status, employment information and employment duration.
Third Party Services: The App may allow you to connect with other websites, products, or services that we don’t have control over (for example, if we allow you to pay through an external wallet facility then we will have to share your usage information with the facility provider). However, usage of such third-party services is subject to their privacy policies and not within our control. We recommend that you have a look at their privacy policies before agreeing to use their services.

LINK TO THIRD-PARTY SDK

Our application has a link to a registered third party SDK which collects data on our behalf and data is stored to a secured server to perform a credit risk assessment. We ensure that our third party service provider takes security measures in order to protect your personal information against loss, misuse or alteration of the data.

Our third-party service provider(s) employ separation of environments and segregation of duties and has strict role-based access control on a documented, authorized, need-to-use basis. The stored data is protected and stored by application-level encryption. They enforce key management services to limit access to data.

Furthermore, our registered third party service provider(s) provide hosting security – they use industry-leading anti-virus, anti-malware, intrusion prevention systems, intrusion detection systems, file integrity monitoring, and application control solutions.

Change in Control: While negotiating or in relation to a change of corporate control such as a restructuring, merger or sale of our assets, we may have to disclose our databases and information we have stored in the course of our operations.

If any governmental authority or law enforcement officers request or require any information and we think disclosure is required or appropriate in order to comply with laws, regulations, or a legal process.

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