PRIVACY POLICY

This is the Privacy Policy (“Policy”) of Entitled Solutions Pvt. Ltd., a company incorporated under the laws of India and having its registered office at 9th Floor, Saigal Apartments, Union Park, Chembur, Mumbai, Maharashtra – 400071 (“Company”).

THIS PRIVACY POLICY DOES NOT APPLY TO INFORMATION COLLECTED BY THE COMPANY IN OTHER WAYS, INCLUDING INFORMATION COLLECTED OFFLINE. PLEASE READ THIS PRIVACY POLICY CAREFULLY. BY CONTINUING TO USE THE SERVICES, OR ACCESS THE PLATFORM YOU AGREE TO THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, YOU MAY NOT AVAIL THE SERVICES.

INTRODUCTION

We, Entitled Solutions Private Limited (“Company”; “We”; “us”; “our”), a company registered under the Companies Act 2013, have developed a mobile application brand named as “Entitled” (“Entitled” / “Application”/ “App”) through which you may apply for a short term loan (“Loan”) to be granted by various non-banking financial company OR `B (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 Lender to sanction the Loan. The Personal Information shall be collected through the mobile application form (“Mobile Application Form”) available on the Application.

Downloading and installing the App shall be deemed to constitute sufficient proof that Clients have read, understood and accepted this Policy.

PERSONAL INFORMATION 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, your name, e-mail address, gender, date of birth, mobile number, passwords, photograph, mobile phone information including contact numbers, SMS, call logs and browsing history, 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.

INFORMATION WE COLLECT FROM OTHER SOURCES

We also collect information about you from third parties, including third-party verification services, credit bureaus and publicly available sources. In some circumstances, where lawful, this information may include your government-issued identification number. This includes, without limitation, the receipt and exchange of account or credit-related information with any credit reporting agency or credit bureau, where lawful, and any person or corporation with whom you have had, currently have, or may have a financial relationship, including without limitation past, present, and future places of employment and personal reporting agencies.

USE OF PERSONAL INFORMATION

We shall use the Personal Information in the following cases:

(i)            to provide you with suitable Services and to assist you in the event you need additional support

(ii)           access your credit worthiness

(iii)          to manage our relationship with you

(iv)          for internal analytics purpose

(v)           to comply with our legal or statutory obligations

(vi)          to contact you about important announcements and other important information about your User Account, the Platform and the Services.

In addition, some other uses of your personal information are as per below:

1.            detect and prevent fraud;

2.            develop and test new products and features;

3.            verify information that you have provided;

4.            to form a view of you as an individual and to identify, develop or improve products, that may be of interest to you;

5.            delivering the information and support you request, including technical notices, security alerts, and support and administrative messages;

6.            diagnose or fix technology problems

7.            to get in touch with you when necessary and contact you by email, SMS, letter, telephone or in any other way about our products and services;

8.            to find adequate references for your loan application;

9.            to give you customized offers as per your location;

10.          to maintain records under applicable law or a may apply to pursuant to agreements executed by our clients and partners

COOKIES

We may set “cookies” to track your use of the Platform. Cookies are small encrypted files, that a site or its service provider transfers to your device’s hard drive that enables the sites or service provider’s systems to recognize your device and capture and remember certain information. By using the Application, you signify your consent to our use of cookies.

DISCLOSURES

We do not sell, rent, lease your Personal Information to anybody and will never do so. Keeping this in mind, We may share Your information with third parties under a confidentiality agreement for provision of Services which inter alia restricts such third parties from further disclosing the information unless such disclosure is for the purpose as detailed under that confidentiality agreement.

We will share Your information with third parties only in such manner as described below:

·         We may disclose Your information to the financial service providers, banks or NBFCs and Our third-party partners for providing suitable Services.

·         We may share Your information with our third-party partners in order to conduct data analysis in order to serve You better and provide Services on our Platform.

·         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. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

DATA RETENTION

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, we will try to delete your Personal Information upon reasonable written request for the same.

DATA PROTECTION & SECURITY

Company shall take all reasonable precautions by way of using current industry standard encryption technologies to protect Personal Information from loss, misuse and unauthorized access, disclosure, alteration and destruction.

We have up-to-date physical security, such as secure areas in offices; electronic safeguards, such as passwords, firewalls, and encryption; and procedural safeguards to prevent ID theft. We may use cloud services such as AWS or GCP to store your personal data.

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.

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 admin@entitled.co.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 regard to issues relating to their User Account, we reply via email, WhatsApp 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

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

CHANGES TO THIS POLICY

Company may modify this Policy in its sole discretion at any time. While Company shall make best efforts to notify Clients of any such modification, it shall be Clients’ responsibility to read and understand the Policy as prevalent from time to time. Installation of the App shall be deemed to constitute acceptance of the Policy as amended.

CONTACT US

If you have questions, concerns or grievances regarding this Privacy Policy, you can email us at our grievance email-address: admin@entitled.co.in