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
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 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 email@example.com
· 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
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.