- Section 43A of the Information Technology Act, 2000; and
- Regulation 4 of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information) Rules, 2011
Collection of Information
In order to provide Our Services, we may collect the following types of information:
1. COLLECTION OF USER PERSONAL INFORMATION
When you use our Platform, we collect and store your information which is provided by you from time to time by explicitly seeking permissions from YOU to get the required information. Our primary goal in doing so is to provide you a safe, efficient, smooth and customised experience and Services. This allows us to provide services and features that meets your needs, and to customise our Platform to make your experience safer and easier and to improve the Services provided by us. More importantly, we collect personal information from you that we consider necessary for achieving the aforementioned purpose.
In general, you can browse the Website or App without telling us who you are or revealing any information about yourself. However, to create an account on the Platform, you must provide us with certain basic information required to provide customised services. The information we collect from you, inter alia, includes:
your full name;
Permanent Account Number (PAN);
Academic records and certificates.
Wherever possible, we indicate the mandatory and the optional fields. You always have the option to not provide any information by choosing not to use a particular service or feature on thePlatform. We also collect user account data which includes email address and user public profile information like name, photo, ASID depending on the social media or networking platform used by You like Google or Facebook to log-into an app. This information is required as a part of registration process to access our Service and it is also used to auto-populate relevant fields in the course of the interface of the App. We further collect other identifiable information such as your transactions history on the Platform when you set up a free account with us as further detailed below. While you can browse some sections of our Platform without being a registered member as mentioned above, certain activities (such as availing of loan through distributors from the third party lenders on the Platform) require registration and for you to provide the above details. The Platform will clearly display the personal information it is collecting from you, and you have the option to not provide such personal information. However, this will limit the services provided to you on the Platform.
Our app also collects mobile number for verification to check the active SIM status on the device, uniquely identify you and prevent frauds and unauthorised access.
2. COLLECTION OF DEVICE LOCATION AND DEVICE INFORMATION
Information the App collects, and its usage, depends on how you manage your privacy controls on your device. When you install the App, we store the information we collect with unique identifiers tied to the device you are using. We collect information from the device when you download and install the App and explicitly seek permissions from You to get the required information from the device.
The information we collect from your device includes the hardware model, build model, RAM, storage; unique device identifiers like IMEI, serial number, SSAID; SIM information that includes network operator, roaming state, MNC and MCC codes, WIFI information that includes MAC address and mobile network information to uniquely identify the devices and ensure that no unauthorised device acts on your behalf to prevent frauds.
We collect information about your device to provide automatic updates and additional security so that your account is not used in other people’s devices. In addition, the information provides us valuable feedback on your identity as a device holder as well as your device behaviour, thereby allowing us to improve our services and provide an enhanced customised user experience to you.
3. COLLECTION OF CONTACT INFORMATION
As a part of our loan through distributor journey, we require references from the Loan through distributor applicant. In this regard, during filing the form on our App, we collect and monitor your contact information which includes name, phone number, account type, contact last modified, favourites and other optional data like relationship and structural address to enable you to autofill the data during the loan through distributor application process. This information is required for the purposes of risk analysis, enable us to detect credible references assess your risk profile and to determine your loan through distributor eligibility.
Collect contact information like names, phone numbers, email address and recently contacted times to automatically detect references information and understand relationships for your customised credit scoring.
4. COLLECTION OF INSTALLED APPLICATIONS
We collect a list of the installed applications’ metadata information which includes the application name, package name, installed time, updated time, version name and version code of each installed application on your device to assess your credit worthiness and enrich your profile with pre-approved customised loan through distributor offers.
We require storage permission so that your KYC and other relevant documents can be securely downloaded and saved on your phone. You can then easily upload the correct KYC related documents for faster loan through distributor application details filling and disbursal process. This ensures that you are provided with a seamless experience while using the application.
We require the camera information permission to provide you an easy/smooth experience and to enable you to click photos of your KYC documents along with other requisite documents and upload the same on the App during your loan through distributor application journey.
7. COLLECTION OF OTHER NON-PERSONAL INFORMATION
We automatically track certain information about you based upon your behaviour on our Platform. We use this information to do internal research on our users’ demographics, interests, and behaviour to better understand, protect and serve our users and improve our services. This information is compiled and analysed on an aggregated basis. We also collect your Internet Protocol (IP) address and the URL used by you to connect your computer to the internet, etc. This information may include the URL that you just came from (whether this URL is on our Website or not), which URL you next go to (whether this URL is on our Website or not), your computer browser information, and your IP address.
If you choose to make a purchase through the Platform, we collect information about your buying behaviour.
We retain this information as necessary to resolve disputes, provide customer support and troubleshoot problems as permitted by law.
If you send us personal correspondence, such as emails or letters, or if other users or third parties send us correspondence about your activities or postings on the Website, we collect suchinformation into a file specific to you.
Play store description sample
Get loan through distributors ranging from [INR 15,000 to INR 30,000]
100% online loan through distributor application process - Only few documents to be uploaded on the application
Disbursal within 24 hours
Annual interest rates range from 12% -- 24% depending on your risk profile and tenure.
Tenure ranges from [4 to 6 months]
Get a higher loan through distributor on successful repayment
Automatic EMI payments from salary
Use of Information
The Personal Information We collect allows Us to keep You posted on Our latest announcements, upcoming events, including confirmations, security alerts and support and administrative messages. It also helps Us to improve Our Services. If You do not want to be on Our mailing list, you can opt out at any time by updating Your preferences on the Website.
From time to time, we may use Your Personal Information to send important notices, such as communications and changes to Our terms, conditions and policies. Since, this information is important to Your interaction with Us, you cannot opt out of receiving these communications.
We may also use Personal Information for internal purposes such as data analysis and research to improve Our Services, products and customer communication.
We collect Non-Personally Identifiable Information about Our users generally to improve features and functionality of the Website. We may analyze trends through aggregated demographic and psychographic offers to users. We may also share this Non-Personally Identifiable Information with Our partners to allow them to assist Us in delivering tailored advertisements, promotions, deals, discounts, and other offers to You when You use the Services. We collect information from You when You participate in sweepstakes, games or other promotions offered on Our Website.
We may also collect information about You through other methods, including research surveys or information We obtain from third parties, including verification services, data services, as well as public sources.
Sharing of Personal Information
We only share personal information with other companies or individuals in the following limited circumstances:
We may share with third parties the location of Your device in order to improve and personalize Your experience of the Services.
We may share with third party certain pieces of non-personal information, such as the number of Users who used a particular service, users who clicked on a particular advertisement or who skipped a particular advertisement, as well as similar aggregated information. Such information does not identify You individually.
We may share with third parties’ Unique Device ID. While such information does not by itself identify You to us, it may be unique or consist of or contain information that You consider personal, however such information does not identify You individually.
Advertisers: We allow advertisers and/or merchant partners (“Advertisers”) to choose the demographic information of users who will see their advertisements and/or promotional offers and You agree that We may provide any of the information We have collected from You in non-personally identifiable form to an Advertiser, in order for that Advertiser to select the appropriate audience for those advertisements and/or offers.
If You sign through a third-party social networking site or service, your list of “friends” from that site or service may be automatically imported to the website and or service. Again, we do not control the policies and practices of any other third-party site or service.
The security of Your personal information is important to Us. We take precautions, including administrative, technical and physical measures, to safeguard Your personal information against loss, theft and misuse, as well as against unauthorized access, disclosure, alteration and destruction. When You enter sensitive information on Our registration, we encrypt that information.
This Website has various electronic, procedural and physical security measures in place to protect the loss, misuse and alteration of information, or any accidental loss, destruction or damage to data. When You submit Your information via the Website, your information is protected through Our security systems.
Accessing Third Party Websites
Protection of Children
Compliance with Laws and Law Enforcement
We will cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We reserve the right to track IP addresses for the purposes of fraud prevention, and to release IP addresses to legal authorities. We will disclose information about You to government or law enforcement officials or private parties when We believe reasonably necessary to comply with law, to protect the property and rights of Zaadu or a third party, to protect the safety of the public or any person, or to prevent or stop activity We may consider to be, or to pose a risk of being, any illegal, unethical or legally actionable activity.
You may be contacted, by email or other means; for example, we may send You promotional offer on behalf of other businesses, or communicate with You about Your use of the service. Also, we may receive a confirmation when You open an email from us. This confirmation helps us improve Our service. If You do not want to receive email or other mail from us, please indicate Your preference by clicking on the “Unsubscribe” link at the bottom of the email or changing Your email settings on Your account settings page. Please note that if You do not want to receive legal notices from us, those legal notices will still govern Your use of the service, and You are responsible for reviewing such legal notices for changes.