Privacy Policy

This legal document is an electronic record in terms of Information Technology Act, 2000, and rules there under as applicable and the amended provisions pertaining to electronic records in various statutes as amended by the Information Technology Act, 2000. This electronic record is generated by a computer system and does not require any physical or digital signatures.

This legal document is published in accordance with the provisions of Rule 4 of the Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011 of Information Technology Act, 2000 amended through Information Technology Amendment Act, 2008 that require publishing the privacy policy for access or usage of MobiCred mobile app, its software products/solutions, its services and other integrated systems (“MobiCred”). By using MobiCred, you clearly agree and acknowledge to be bound by terms of this policy. References in this policy to "we" or "us" or “web” or “site” or “app” or “products/solutions” or “services” or “Company” are references to MobiCred and its integrated systems and “you” as user of MobiCred.

This privacy policy applies to all types of users of MobiCred including but not limited to visitors, customers, brokers/agents and other users.

By using/browsing MobiCred, clicking the “I accept/I agree” button or completing the registration process, you clearly agree and acknowledge that you have reviewed this privacy policy agreement, given your free and full consent and accepted this agreement.

INTRODUCING OURSELVES

We, ORICRED FINSERV PRIVATE LIMITED (Company; We; us; our) have developed a mobile application called MobiCred (Application / App) through which you may apply for a loan (Loan) to be granted by us or non-banking financial company or Banks (LENDER), based on the loan agreement executed between you and LENDER. LENDER has appointed and authorized us to collect, store, authenticate, verify and distribute the Personal Information (defined below) as may be required by the LENDER to sanction the Loan. The Personal Information shall be collected through the mobile application form (Mobile Application Form) available on the Application.

PRIVACY PREAMBLE

While providing aforesaid online services, the issue of online privacy is extremely crucial for MobiCred which is committed to safeguarding the information provided by users. MobiCred is dedicated to create a reasonably secured environment for its users.

Respecting privacy of its online users while providing top-of-the-line services have remained the core strategies for MobiCred. Our Privacy Policy gives users a view of the Privacy Practices followed by MobiCred and assures them of safe passage.

At MobiCred, data protection is a matter of trust and your privacy is very important to us. We use your personal information only in the manner set out in this Privacy Policy. Please read this privacy policy to learn more about our information gathering and dissemination practices.

The privacy practices of this statement apply to our services available under the domain and sub-domains of MobiCred, our software products/solutions, our services and apply generally to our parent, affiliates, subsidiaries or joint venture of MobiCred. By visiting MobiCred, you agree to be bound by the terms and conditions of this Privacy Policy.

This Privacy Policy explains how MobiCred gathers personal information, classified as mandatory or optional as part of the normal operation of our services; and uses, discloses and protects such information through MobiCred. This detailed privacy policy enables you to take informed decisions in dealings with us. Our parent, subsidiaries and joint ventures operate under similar privacy practices subject to the requirements of applicable law.

By registering with MobiCred, you acknowledge your acceptance of the terms of this Privacy Policy, expressly consent to our use and disclosure of your personal information in accordance with this Privacy Policy and that any personal information provided by you through MobiCred is provided under a lawful contract. This Privacy Policy is incorporated into and subject to the terms of the Terms of Service/User Agreement.

At the same time, MobiCred would like to make it clear that it may provide links to other web sites/apps/APIs that are governed by their own Privacy Policies and MobiCred does not take responsibility for the privacy/security practices provided by those sites/apps/APIs. Visitors/users of the MobiCred are urged to familiarize themselves with its Privacy Policy as well the policies of the third party that collect personally identifiable information.

When you provide us with your personal data, you are clearly agreeing to the rules and regulations stipulated under our Privacy Policy and are bound by it. If you do not agree to our Policy then please do not use MobiCred.

PERSONAL DETAILS COLLECTED

In order to avail the Services, you are required to register with the Company by logging in through Third Party Platforms (defined below) (User Account). During the application process, you shall be required to share/upload certain personal information including but not limited to your name, e-mail address, gender, date of birth, mobile/phone number, photograph, mobile phone information and login-in credentials of Third Party Platforms (defined below), financial information such as bank documents, salary slips, bank statements, PAN card, bank account no., data from Credit Information Companies, data required for Know Your Customer compliances, requirement and other relevant details (Personal Information). You undertake that you shall be solely responsible for the accuracy and truthfulness of the Personal Information you share with us.

You understand and acknowledge that the Company reserves the right to track your location (Track) during the provision of the Services, and also in the event that you stop, cease, discontinue to use or avail the Services, through the deletion or uninstallation of the Mobile App or otherwise, till the event that your obligations to pay the Outstanding Amount(s) to LENDER, exist. Deletion, uninstallation, and/or discontinuation of our Services, shall not release you from the responsibility, obligation and liability to repay the Outstanding Amount(s).

The key information collected from the device is further detailed below:

  • Location

    We collect the location data from you in two ways: (i) When you add the address as part of your filling up of MobiCred App; and (ii) from your mobile device when enabled by you to do so. This information collected and monitored about the location of your device so as to provide serviceability of your loan application, reduce risk associated with your loan application and to provide pre-approved customized loan offers.

    How we use this data : 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.

  • SMS Information

    MobiCred doesn't collect or store personal SMS from your Inbox.

  • Device Information

    Specific Information is collected and monitored by our application regarding your device including hardware model, brand, manufacturer, OS version, IMEI information.

    How we use this data : To uniquely identify the devices and to ensure that no unauthorized device acts on your behalf which will help us in preventing frauds. This will also help us in enriching your credit profile and assessing your credit worthiness, besides enabling the app and its services, for enabling customer support and for research and development. We also gather log information like search queries, Firebase Analytics for crash reporting to enhance your experience and ensure seamless functionality of our application.

  • Personal Data

    We collect your personal information data which includes your name, phone number, email address, date of birth, mailing and home address, personal identifiers like bank account number, permanent account number and unique identification number (aadhaar). We also collect your picture and photo of PAN Card, Aadhaar Card and Address Proof like Electricity Bill or LPG Related documents and Profession related document which you provide at the time of profile creation.

    How we use this data : All the mentioned information is required as part of Profile creation and KYC process and to access our service and is also used to auto-populate relevant input fields in the course of our application interface as part of application feature. Also, we use some of the above mentioned personal information like name, phone number, email address etc. to uniquely identify you and prevent frauds and unauthorized access. Your address and professional details are used for personalizing the loan products for you.

Technical Data

When you use MobiCred for information purposes only, we only collect the data that your browser transmits to our server. If you wish to view MobiCred app, we collect the following data, which is technically necessary for us to display our app to you and to ensure its stability and security: IP address, Date and time of the request, Time zone difference to Greenwich Mean Time (GMT), Content of the request (specific page), Access status/HTTP status code, Amount of data transferred in each case, Page from which the request came, Browser, Operating system and its interface, Language and version of the browser software.

How we use this data : The aforementioned data is processed by us for the following purposes: Ensuring a smooth connection setup of the app, ensuring a comfortable use of our app, evaluating system security and stability and for other IT administrative purposes.

GOVERNING STATUTE

This Privacy Policy is governed by and is compliant with the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules 2011, which is designed to protect Personal Information of the End-User(s) of the Services; and other applicable rules and regulations related to privacy.

EMAILS

You agree and acknowledge that when we receive e-mails from you, we may retain the content of any e-mail messages sent to us, as well as details of your e-mail address. You further agree and acknowledge that MobiCred shall use your email id and mobile number information for sending promotional messages using different platforms from time to time. If you send us personal correspondence, such as letters, or if other users or third parties send us correspondence about your activities or postings on MobiCred, we may collect such information into a file specific to you.

COOKIES

We use data collection devices such as "cookies" on certain pages to help analyze our online page flow, measure promotional effectiveness, and promote trust and safety.

MobiCred uses "cookies" to track usage patterns, traffic trends and user behaviour, as well as to record other information from the app. For certain services provided on MobiCred, cookies allow MobiCred to save information locally so that you will not have to re-enter it the next time you visit. Many content adjustments and customer service improvements are made based on the data derived from cookies.

The user may set the browser to refuse cookies. If the user so chooses, the user may still gain access to most of the features, but the user may not be able to conduct certain types of transactions or take advantage of some of the interactive elements offered.

You can set your browser so that you are informed about the setting of cookies, allow cookies only in individual cases, exclude the acceptance of cookies for certain cases or in general, activate the automatic deletion of cookies when closing the browser.

The cookie settings can be managed under the appropriate links for the respective browsers.

We also recommend that you regularly delete your cookies and browser history manually.

Third party Apps which are accessible from MobiCred via links, click-through or banner advertising may use Cookies. However, it is important for us to inform you that we shall have no access or control over such Cookies and therefore you agree that we shall not be held responsible for privacy/security issues relating to third parties.

API

We use certain APIs for various services and authentication related to KYC, Loan Processing and Disbursement. It is important for us to inform you that we will have limited control over aforesaid APIs and therefore you clearly agree and acknowledge that we shall not be held responsible for privacy/security issues relating to the same.

OUR USE OF YOUR INFORMATION

We use your personal information to facilitate the services you request. We do not sell, rent, trade or exchange any personally-identifying information of our Users. We may provide your collected information to our affiliates and service providers under contract (such as customer care, billing, data analytics etc.) to support the operation of MobiCred and our services. To the extent we use your personal information to market to you, we will provide you the ability to opt-out of such uses. We use your personal information to: resolve disputes; troubleshoot problems; collect payments; measure consumer interest in the services provided by us, inform you about online and offline offers, products, services, and updates; customize your experience; detect and protect us against error, fraud and other criminal activity; enforce our User Agreement(s), and in general to improve the user experience and make it comparable to other similar websites/apps; and as otherwise described to you at the time of collection. In our efforts to continually improve our product and service offerings, we may collect and analyze demographic, profile and usage data about our users' activity on our app.

We use your personal information to improve our platform, improve MobiCred's content and product offerings, prevent or detect fraud or abuses of our MobiCred and tailor it to meet your needs, so as to provide you with a smooth, efficient, safe and customized experience while using the app.

In future, we may also use your personal information to display contents and services that are targeted to your interests. By accepting the User Agreement and Privacy Policy, you expressly agree to receive this information. If you do not wish to receive these communications, we encourage you to opt out by sending a mail to wecare@mobicred.in.

DISCLOSURES

We do not sell, rent, lease your Personal Information to anybody and will never do so. Keeping this in mind, we may disclose your Personal Information in the following cases:

  • Administrators: We shall provide access to your Personal information to our authorized administrators for internal business purposes, who shall be under confidentiality obligations towards the same.
  • Affiliates: We may provide Personal Information we collect to our affiliates. For example, we may disclose Personal Information to our affiliates in order to respond to your requests for information or the Services, or to help limit your receipt of marketing materials you have requested not to receive.
  • Business Partners: We may use certain trusted third party companies and individuals to help us provide, analyse, and improve the Services including but not limited to data storage, maintenance services, database management, credit bureaus, rating agencies, web analytics, payment processing, and improvement of the Platform’s features. These third parties may have access to your information only for purposes of performing these tasks on our behalf and under obligations similar to those in this Privacy Policy. We may disclose your Personal Information to partners who perform business functions or hosting services on our behalf and who may be located outside India.
  • Service Providers: We may share your Personal Information with the service providers, including LENDER, who are working with us in connection with the operation of the Services or the Platform, so long as such service providers are subject to confidentiality restrictions consistent with this Privacy Policy.
  • Joint Marketing Arrangements: Where permitted by law, we may share your Personal Information with joint marketers with whom we have a marketing arrangement, we would require all such joint marketers to have written contracts with us that specify the appropriate use of your Personal Information, require them to safeguard your Personal Information, and prohibit them from making unauthorized or unlawful use of your Personal Information
  • Persons Who Acquire Our Assets or Business: If we sell or transfer any of our business or assets, certain Personal Information may be a part of that sale or transfer. In the event of such a sale or transfer, we will notify you.
  • Legal and Regulatory Authorities: We may be required to disclose your Personal Information due to legal or regulatory requirements. In such instances, we reserve the right to disclose your Personal Information as required in order to comply with our legal obligations, including but not limited to complying with court orders, warrants, or discovery requests. We may also disclose your Personal Information(a) to law enforcement officers or others; (b) to Credit Information Companies; (c) to comply with a judicial proceeding, court order, or legal process served on us or the Platform; (d) to enforce or apply this Privacy Policy or the Terms of Service or our other policies or Agreements; (e) for an insolvency proceeding involving all or part of the business or asset to which the information pertains; (f) respond to claims that any Personal Information violates the rights of third-parties; (g) or protect the rights, property, or personal safety of the Company, or the general public. You agree and acknowledge that we may not inform you prior to or after disclosures made according to this section.

Notwithstanding anything mentioned hereinabove, the Company shall not be responsible for the actions or omissions of the service providers or parties with whom the Personal Information is shared, nor shall the Company be responsible and/or liable for any additional information you may choose to provide directly to any service provider or any third party.

OPT OUT, DATA RETENTION AND DATA DELETION

As per Rule 5(7) of the Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011 of Information Technology Act, 2000 amended through Information Technology Amendment Act, 2008, you have an option to withdraw your consent for use of your sensitive personal data given earlier to us. Such withdrawal of consent shall be sent in writing to our registered address or mail us at wecare@mobicred.in.

However, we will retain your Personal Information for as long as your registration with us is valid and the Outstanding Amount(s) is due and payable to LENDER. We may also retain and use your Personal Information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Subject to this section and approval from the LENDER, we will try to delete your Personal Information upon reasonable written request for the same as per above Rule 5(7) of the Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011. Please note, however, that there might be latency in deleting Personal Information from our servers and backed-up versions might exist even after deletion.

REASONABLE SECURITY PRACTICES AS PER I. T. ACT, 2000 AND ITS RULES

We value your trust in providing us your Personal Information, hence we continuously strive to use commercially acceptable means of protecting it. We request you to note that no method of transmission, whether in physical form or over the internet, or method of electronic storage is 100% secure and may be subjected to unintentional risks, due to reasons beyond our control. Data pilferage due to unauthorized hacking, virus attacks, technical issues is possible and we take no liabilities or responsibilities for it.

You are responsible for all actions that take place under your User Account. If you choose to share your User Account details and password or any Personal Information with third parties, you are solely responsible for the same. If you lose control of your User Account, you may lose substantial control over your Personal Information and may be subject to legally binding actions.

We have implemented reasonable security practices as per Rule 8 of the Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011 of Information Technology Act, 2000 amended through Information Technology Amendment Act, 2008.

Access to your Loan Account is through the APP and the same is accessed through your registered mobile number by providing OTP received in your registered mobile number for authentication.

MobiCred has implemented reasonably stringent, internationally acceptable standards of technology, managerial security, technical security, operational security and physical security in order to protect personally identifiable information from loss, misuse, disclosure, alteration or destruction. The data resides behind a firewall and other standard security tools, with access restricted to authorized personnel of MobiCred.

MobiCred has implemented “Reasonable Security Practices & Procedures” as required by the Information Technology Act, 2000 rules including any amendment in the said Act and its rules. By complying with such provisions, MobiCred assures you proper care and control over its I.T. and Security operations under sections 43, 43A, 45, 66,72A & 85 of I. T. Act, 2000 and I.T.A.A, 2008 including related rules and therefore you agree that MobiCred shall not be held responsible for any activity in your account which results from your failure to keep your own password/device secured.

By using this app, you agree that MobiCred shall not be held responsible for any uncontrollable security attacks and in such cases you agree that MobiCred shall not be held responsible for any type of financial losses, loss of opportunity, legal cost, business losses, reputation loss, direct and indirect losses that may occur to you as per the Provisions of Section 43, 43A and 45 of Information Technology Act, 2000 including any amendments in the said Act and any other laws of India for the time being in force.

You further agree that MobiCred's management shall not be held responsible directly or indirectly for any cyber-crime related criminal liabilities under I. T. Act, 2000 relating to your information as you have verified, agreed and acknowledged that management of MobiCred complies with due diligence (care & controls) requirements of I.T.Act,2000 including its rules and amendments.

You clearly agree and acknowledge that our reasonable security practices & procedures shall mean and include but are not limited to following:

Strong password, OTP and other general security controls

SSL certificate

256 Bit Encryption Standards

Firewall

Built with the high Standards for Privacy and Data Security on AWS Cloud Server having its link https://aws.amazon.com/products/security, which provides complete information of security controls of server on which MobiCred is hosted.

Further, you also agree and acknowledge that MobiCred management shall never be held responsible regarding privacy of your sensitive personal data in case of sharing your sensitive personal data to any authorized cyber investigation agency of appropriate government authorities under sections 67C, 69, 69A, 69B, 70B, 79 and 80 of I.T. Act, 2000 including its amendments, rules and every other applicable laws.

ACCESSING AND MODIFYING PERSONAL INFORMATION

In case you need to access, review, and/or make changes to the Personal Information, you will be required to furnish supporting documents relating to change in Personal Information for the purpose of verification by the Company. You shall keep your Personal Information updated to help us to serve you better.

CHILDRENS PRIVACY

Our services are not meant for children and we do not knowingly solicit or collect personal information from persons under the age of 18 (Eighteen). If we find out that a child has given us personal information, we will take steps to delete that information and terminate the relevant MobiCred account.

ANCILLIARY SERVICES

We may provide you with certain ancillary services such as chat rooms, blogs and reviews for the Services. Subject to any applicable laws, any communication shared by you via the Platform or through the blogs, reviews or otherwise to us (including without limitation contents, images, audio, financial information, feedback etc. collectively Feedback) is on a non-confidential basis, and we are under no obligation to refrain from reproducing, publishing or otherwise using it in any way or for any purpose. You shall be responsible for the content and information contained in any Feedback shared by you through the Platform or otherwise to us, including without limitation for its truthfulness and accuracy. Sharing your Feedback with us, constitutes an assignment to us of all worldwide rights, titles and interests in all copyrights and other intellectual property rights in the Feedback and you authorize us to use the Feedback for any purpose, which we may deem fit.

COMMUNICATIONS FROM THE PLATFORM

  • Special Offers and Updates:We may send you information on products, services, special deals, and a newsletter of the Company. Out of respect for your privacy, we present you with the option of not receiving these types of communications. You may unsubscribe via the unsubscribe mechanism provided in each such communication or by emailing us at wecare@mobicred.in
  • Service Announcements: On certain occasions or under law, we are required to send out Service or Platform related announcements. We respect your privacy, however you may not opt-out of these communications. These communications would not be promotional in nature.
  • Customer Service:We communicate with Customer(s) on a regular basis to provide requested services and in regards to issues relating to their User Account, we reply via email or phone, based on Customer(s) requirements and convenience.

INDEMNIFICATION

You agree to indemnify us, our subsidiaries, affiliates, officers, agents, co-branders or other partners, and employees and hold us harmless from and against any claims and demand, including reasonable attorneys fees, made by any third party arising out of or relating to: (i) Personal Information and contents that you submit or share through the Platform; (ii) your violation of this Privacy Policy, (iii) or your violation of rights of another Customer(s).

LIMITATIONS OF LIABILITY

You expressly understand and agree that the Company shall not be liable for any direct, indirect, incidental, special, consequential or exemplary damages, including but not limited to, damages for loss of profits, goodwill, use, data, information, details or other intangible losses (even if the Company has been advised of the possibility of such damages), resulting from: (i) the use or the inability to use the Services; (ii) unauthorized access to or alteration of your Personal Information.

GOVERNING LAWS AND DUTIES

You expressly understand and agree that the Company, including its directors, officers, employees, representatives or the service provider, shall not be liable for any direct, indirect, incidental, special, consequential or exemplary damages, including but not limited to, damages for loss of profits, goodwill, use, data or other intangible losses (even if the Company has been advised of the possibility of such damages), resulting from; (a) use or the inability to avail the Services (b) inability to use the Platform (c) failure or delay in providing the Services or access to the Platform (d) any performance or non-performance by the Company (e) any damages to or viruses that may infect your electronic devices or other property as the result of your access to the Platform or your downloading of any content from the Platform and (f) server failure or otherwise or in any way relating to the Services.

JURISDICTION

This Agreement shall be construed and governed by the laws of India and courts of law at Bhubaneswar shall have exclusive jurisdiction over such disputes without regard to principles of conflict of laws.

CHANGES TO THIS POLICY

Our privacy policy is subject to change at any time without notice. To make sure you are aware of any changes, please review this policy periodically. Continued use of the Services and access to the platform shall be deemed to be your acceptance of this Privacy Policy.

CONTACT US FOR GRIEVANCE REDRESSAL

Grievance Officer

If you have any questions or grievances regarding the privacy statement, practices of the app, or any other transaction issue, please contact our Grievance Officer on grievance@mobicred.in. We have appointed our Grievance Officer as per Rule 5 (9) of the Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011 of Information Technology Act, 2000 amended through Information Technology Amendment Act, 2008 and you can contact him, the name and contact details of the Grievance Officer are provided below for your reference:

Name: Mr. Ajay Sakti Das
Address: Oricred Finserv Pvt Ltd, N6/152, IRC Village, Bhubaneswar, Odisha, India.
Email: grievance@mobicred.in
Contact: +91 7609083241
Time: Mon - Sat (09:30am - 06:00pm)