This Privacy Policy seeks to comply with the provisions of the Information Technology
Act, 2000 (“Act”) and the Information Technology (Reasonable security practices,
procedures and sensitive personal data or information) Rules, 2011 ("Rules") and
guidelines on digital lending issued by RBI to the extant its applicable (Including any
amendments thereto) that require publishing of the Policy for collection, use, storage
and transfer of sensitive personal data or information.
CODEMODULU FINANCIAL INVESTMENT SERVICES PRIVATE LIMITED, a private limited company,
referred to as “Company”, “We”, “Us” or “Our” which owns and operates the website
www.Moneyase.in and/or the mobile application and SDKs, ‘Moneyase’, and ‘Moneyase ’,
(collectively referred to as the “Platform”).
“You” and “Your” shall mean anyone who visits, accesses, or uses our Platform or obtains
Services from Us through our Platform.
We are committed to protecting Your privacy and the information that You share while
using and operating the Platform. We value the trust You place in Us and thus We
maintain the highest security standards for securing the transactions and Your
information.
We may also allow Our group companies, affiliates and subsidiary companies to use Our
Platform to offer their products and services to You, under applicable terms and
conditions specified on Our Platform from time to time.
This Privacy Policy specifies the manner in which personal data and other information
are collected, received, stored, processed, disclosed, transferred, dealt with or
otherwise handled by the Company. The information received from You while accessing the
Services through website, mobile app, customer service will be utilised in a manner as
set out in this Policy.
Please read the Privacy Policy carefully prior to using or registering on the Platform
or accessing/availing the services made available on the Platform.
By visiting the Platform, You (“You” or “Your”), accept and agree to be bound by the
terms and conditions of this privacy policy (“Privacy Policy”). This Privacy Policy is
incorporated into and subject to the Term of use of the Platform (“Terms”) and shall be
read harmoniously and in conjunction with the Terms. We reserve the right to update or
modify this Privacy Policy at any time without prior notice and such changes shall be
effective immediately
We wish to mention that in case of non-compliance with the privacy policy pertaining to
access or usage of the computer resource, We shall have the right to terminate Your
access or Your usage rights to the computer resource immediately or remove non-compliant
information or both, as the case may be.
2. DATA WE COLLECT ABOUT YOU
We collect, transmit, and store personal data about you on our secured servers after
obtaining your consent, to provide you with, or in connection with, the Services. Please
note that we only collect and process a minimal amount of your personal data to provide
you with the Services.
The information collected on the platform includes:
Identity and profile-related data: This includes your first and last name, parent’s
name, husband’s name, date of birth, gender, educational qualifications, purpose of
loan, address, employment status, company name, contact information (including
addresses, email IDs and phone numbers) and marital status.
KYC/KRA data: This includes identification details such as last 4 digits of Aadhaar,
PAN number, signature & documents for identity/address proofs such as Aadhaar, PAN,
passport details, Voter ID, driving license, and/or education details.
Financial savings data: This includes your investment in financial assets, shares,
mutual funds, bonds, insurance, GST, ITR.
Financial data: This includes your past credit history, income details, details of
loans issued or otherwise applied for through the Platform, payments, and repayments
thereof, bank account details, and bank account statements.
Device data: This includes your IP addresses, browser types and versions, cookie,
time zone settings, operating systems, and device information. We collect, transmit,
and store such data on our secured server.
Transaction data: This includes details of transactions that may occur through the
Platform or in connection with the Services. For example, transaction data may
include the services you have sought or availed through the Platform or
confirmations of such services.
We are required to collect your personal data to provide you with access to the Platform
and Services. In certain cases, we are required to collect personal data as required by
law, or under the Terms. If you fail to provide us that data as and when requested by
us, we will not be able to perform our obligations under the arrangement we have with
you or are trying to enter into with you (for example, to provide you with features of
the Services). In this case, we may have to cancel or limit your access to the Services
(or part thereof).
3. HOW WE COLLECT DATA ABOUT YOU
We use different methods to collect and process personal data about you. This includes:
Information you provide us: This is the information (including identity, contact,
KYC, financial, and device data) you consent to give us when you use our Services or
when you correspond with us (for example, by email or chat, or through the
Platform). It includes information you provide when you register to use the
Services, use a Platform feature, share data through the Platform, or when you
report a problem with the Platform and our Services. If you contact us, we will keep
a record of the information shared during the correspondence.
Information we collect about you and your device: Each time you visit the Platform
or use the Services, we will automatically collect personal data through the use of
tools like cookies.
Information we receive from other sources including third parties and publicly
available sources.
Information from third-parties: We or the Financing Partner may also work closely
with third parties (including, for example, Mutual Funds RTAs, Demat Depositories,
credit information bureaus, account aggregators, business partners, technical
sub-contractors, analytics providers, search information providers, etc.) and may
lawfully receive information about You from such sources. Such data may be combined
with data collected on the Portal and such other information as provided in this
Policy. Such third parties will provide equal or equal protection to the user data
as provided in this Policy.
Information from third-parties: We may also receive personal data about you from
various public sources including our third parties, Google analytics for advertising
and user analytics purposes, and other publicly available sources. Please note that
we do not have any control over personal data that you may choose to make publicly
available. We may also obtain some personal information from third parties such as
direct selling agents, intermediaries, digital loan aggregators, etc. in the nature
of leads or information about potential borrowers (e.g., name, contact details,
etc.). You hereby expressly consent to Our access and use of Your aforesaid
information, and disclosure of Your personal information in accordance with this
Policy. We 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
Portal.
4. HOW WE USE YOUR PERSONAL DATA AND FOR WHAT PURPOSES
We will only use your personal data in accordance with the applicable law. Most
commonly, we will use your personal data to provide you with the Services, or where we
need to comply with a legal obligation.
You agree and acknowledge that by using our Services and creating an account on the
Platform, you authorize us, our associate partners, and affiliates to contact you via
email, phone, or otherwise. This is to ensure that you are aware of all the features of
the Services.
In general, we use your personal data for the following purposes and activities
undertaken without direct human supervision or control:
To register you as a user of the Platform;
To provide you with the Services;
To facilitate your application to avail loan and otherwise in connection with your
obtaining of credit facilities from regulated entities including our lending
partners
To manage our relationship with you, including notifying you of changes to any
Services;
To administer and protect our business and the Platform, including troubleshooting,
data analysis, system testing, and performing internal operations;
To deliver content to you;
To send you communication, including through WhatsApp business messages, in relation
to your use of the Platform or Services;
To monitor trends so we can improve the Platform and Services;
To improve our business and delivery models;
To perform our obligations that arise out of the arrangement we are about to enter
or have entered with you;
To enforce our Terms;
To undertake marketing services, including sending you promotional messages;
To respond to court orders, establish or exercise our legal rights, or defend
ourselves against legal claims;
In compliance with the Reserve Bank of India’s norms, to contact you or locate you
in case of any default; and
To ensure compliance with applicable laws.
5. HOW WE STORE AND RETAIN DATA ABOUT YOU
We shall retain/store user’s Information in India if it is required to provide services
or as long as it is required for business purpose. Retention of information will be as
per applicable law/ regulatory requirements in India.
Data Storage Policy
Objective:
To comply with digital lending guidelines by ensuring customer data is
collected, stored, and managed securely, while adhering to the principle of
minimal data collection.
Data Collection and Storage
Permissible Customer Data:
Name
Date of Birth (DOB)
Contact Information:
Email Address
Phone Number
Residential Address
Prohibited Customer Data:
Moneyase ensures that no KYC-related documents or any income details,
whether masked or unmasked, are stored under any circumstances.
Purging Policy for Customer Basic Data
Definition of Basic Data:
Basic data refers to essential customer information, including:
Name
Date of Birth (DOB)
Contact Information: Email Address and Phone Number
Additional Data for Lead Creation:
Includes any necessary details for account creation or lead generation,
such as:
Identification details (e.g., Aadhaar, PAN, or equivalent)
Other minimal data required to process the lead
Retention Timeline:
Active Customers:
Basic Data: Retained for the entire duration of the customer
relationship (e.g., while the loan or service is active).
Additional Data: Deleted within 3 to 6 months of its purpose being
fulfilled. Aadhaar will not be stored whether masked or unmasked, under
any circumstances.
Inactive Customers or Unfulfilled Leads:
Basic Data: Retained for the duration of the customer relationship to
support potential future services.
Additional Data: Deleted within 3 to 6 months after the lead is marked
as inactive or unfulfilled. Aadhaar will not be stored whether masked or
unmasked, under any circumstances.
To enhance/ improvise the products/ services of CODEMODULU FINANCIAL INVESTMENT SERVICES
PRIVATE LIMITED
We ensure that access to user data is sufficiently restricted using access controls and
industry standard encryption algorithms. Further, we have in place a robust incident
management system along with a proactive incident response posture.
Security Breach Management :At Monyase, we are committed to
protecting your personal information. In the event of a security breach, we have a clear
and transparent process in place to handle and mitigate the situation. Below are the
details of our policy regarding security breaches:
Breach Notification: In the event of a security breach that
compromises your personal data, we will notify you promptly. The notification will
include:
Timely Notification: We will notify you as soon as possible, and
within the timeframe required by applicable laws and regulations.
Details of the Breach:
The nature of the breach.
Specific details about the personal data affected by the breach, such as name,
contact details, financial data, etc.
If any sensitive data (such as passwords, credit card details, etc.) has been
compromised, we will provide clear guidance on steps you should take to protect
yourself.
Mitigation Steps: We will inform you about the steps we have taken
to mitigate the effects of the breach and prevent further unauthorized access to
your personal information. This may include actions such as:
Suspending compromised accounts
Enhancing our security protocols
Providing guidance on securing your data
Investigation of the Breach:
We will immediately initiate an internal investigation to determine the cause and
scope of the breach.
Our security experts will work with forensic specialists if necessary to identify
how the breach occurred and what vulnerabilities were exploited.
Containment of the Breach:
We will take immediate actions to contain the breach, preventing further exposure of
your personal information.
Steps may include locking affected systems or accounts and isolating compromised
data.
Assessment of Damage:
We will assess the extent of the damage and the specific data compromised during the
breach.
We will evaluate any potential risks to your privacy and take steps to minimize
those risks.
Preventing Future Occurrences:
After addressing the breach, we will implement measures to enhance our security
infrastructure and reduce the likelihood of similar breaches occurring in the
future.
These measures may include updating encryption methods, increasing monitoring,
conducting security audits, and improving employee training on data protection.
6. HOW WE SHARE YOUR PERSONAL DATA
You agree and acknowledge that any and all information pertaining to you, whether or not
you directly provide it to us (via the Services or otherwise), including but not limited
to personal correspondence such as emails, instructions from you, etc., may be
collected, compiled, and shared by us with third parties (lending partners
(Lendingkart,Credit Saison,Olyv,Abhiloan) and Experian bureau) after obtaining your
explicit consent, solely in order to render the Services to you (that is, in connection
with loan applications and your loan journey). This may include but not be limited to
Lending Partners (as defined in the Terms), storage providers, data analytics providers,
consultants, lawyers, and auditors. We may also share this information with our group &
affiliate companies with the above mentioned purposes. If you fail to provide consent
for sharing of such data when requested by us, we may not be able to perform our
obligations under the arrangement we have with you or are trying to enter into with you.
In this case, we may not be able to provide the Services to you.
You agree and acknowledge that by using our Services and creating an account on the
Platform, you authorize us, our associate partners, and affiliates to contact you via
email, phone, or otherwise. This is to ensure that you are aware of all the features of
the Services.
You agree and acknowledge that we may share data where we are required by law, any
court, a government agency, or authority to disclose such information. Such disclosures
are made in good faith and belief that it is reasonably necessary to do so for enforcing
this Policy or the Terms, or in order to comply with any applicable laws and
regulations.
We and Our group companies, affiliates and subsidiary companies (to the extent Personal
Information is collected by them) may, with consent in compliance with applicable laws,
share/transfer/assign all of Your Personal Information and other information with any
other business entity(ies), in the event of a merger, sale, re-organization,
amalgamation, joint ventures, assignment, restructuring of business or transfer or
disposition of all or any portion of Our business.
7. ACCESS AND UPDATING YOUR PERSONAL DATA
You hereby warrant that all personal data that you provide us with is accurate,
up-to-date, and true. When you use our Services, we make best efforts to provide you
with the ability to review and correct inaccurate or deficient data, subject to any
legal requirements. We shall verify the accuracy of the new personal data you provided
to us.
8. DATA SECURITY
Our Platform has reasonable security measures and safeguards in place to protect Your
privacy and Personal Information from loss, misuse, unauthorized access, disclosure,
destruction, and alteration of the information in compliance with applicable laws.
Further, whenever You access Your account on the Platform or any information relating to
it, We offer the use of a secure server. We cannot however ensure or warrant the
security of any information You transmit to the Company or guarantee that Your Personal
Information and/or other Non-Personal Information provided for availing the Services or
accessing the Platform will not be accessed, disclosed, altered or destroyed by a breach
of any of Our security measures and safeguards . It is further clarified that You have,
so long as You access and/or use the Platform (directly or indirectly), the obligation
to ensure that You shall at all times, take adequate physical, managerial, and technical
safeguards, at Your end, to preserve the integrity and security of Your data which shall
include and not be limited to Your Personal Information.
When payment information is being transmitted on or through the Platform, it will be
protected by encryption technology. You expressly consent to the sharing of Your
information with third party service providers, including payment gateways, to process
payments and manage your payment related information. We take various steps and measures
to protect the security of your information from misuse, loss, unauthorized access,
modification or disclosure. We use the latest secure server layers encryption and access
control on our systems. Please do not share your Account’s login, password and OTP
details with anybody.
While We observe reasonable security measures to protect Your Personal Information on
all our digital platforms, security risks may still arise for reasons outside of our
control such as hacking, virus dissemination, force majeure events, breach of firewall
etc. Please note that the above mentioned measures do not guarantee absolute protection
to the Personal Information. The Company assumes no liability or responsibility for
disclosure of Your information due to errors in transmission, unauthorized third-party
access, or other causes beyond its control. You play an important role in keeping Your
personal information secure. You shall not share Your Personal Information or other
security information for Your account with anyone. The Company has undertaken reasonable
measures to protect Your rights of privacy with respect to Your usage of the Platform
controlled by Us and Our Services. However, We shall not be liable for any unauthorized
or unlawful disclosures of Your personal information made by any third parties who are
not subject to Our control.
9. THIRD–PARTY WEBSITES
Our Platform may link You to other third – party Platforms (“Third – Party Sites”) that
may collect Your Personal Information including Your IP address, browser specification,
or operating system. The Company is not in any manner responsible for the security of
such information or their privacy practices or content of those Third – Party Sites.
Additionally, You may also encounter “cookies” or other similar devices on certain pages
of the Third – Party Sites and it is hereby clarified by the Company that the Platform
does not control the use of cookies by these Third – Party Sites. These third-party
service providers and Third-Party Sites may have their own privacy policies governing
the storage and retention of Your information that You may be subject to. This Privacy
Policy does not govern any information provided to, stored on, or used by these
third-party providers and Third-Party Sites. We recommend that when You enter a
Third-Party Site, You review the Third Party Site’s privacy policy as it relates to
safeguarding of Your information.
10. COOKIES
Cookies are small data files that are stored on your device. We use cookies and other
tracking technologies to distinguish you from other users of the Services and to
remember your preferences. This helps us provide you with a good experience when you use
our Services and also allows us to improve the Services.
We receive and store Non – Personal Information, by the use of data collection devices
such as “cookies” on certain pages of the Platform, in order to help and analyze Our web
– page flow, track user trends, measure promotional effectiveness, and promote trust and
safety. We offer certain additional features on the Platform that are only available
through the use of a “cookie”. We place both permanent and temporary cookies in Your
computer’s hard drive.
We also use cookies to allow You to enter Your password less frequently during a session
on the Platform. Most cookies are “session cookies,” meaning that they are automatically
deleted from Your hard drive at the end of a session. You are always free to decline Our
cookies if Your browser permits, although in that case, You may not be able to use
certain features or Services being provided on the Platform or You may be required to
re-enter Your password each time you log – in or access the Platform during a session.
No Personal Data will be collected via cookies and other tracking technology; however,
if you previously provided Personal Data, cookies may be tied to such information.
11. ACCESSING & UPDATING YOUR INFORMATION
At any point of time You can choose to edit/modify or delete/withdraw any Personal
Information shared for use of the Platform. Please note that deleting or withdrawing
information may affect the Services we provide to you. You can edit/modify or delete
Your information by writing to service@Moneyase.in.
12. YOUR CONSENT TO PRIVACY POLICY
By visiting the Platform or setting up/creating an account on the Platform for availing
the Services on the Platform at such time, You signify Your acceptance to the provisions
of the Privacy Policy.
You may choose to withdraw Your consent provided hereunder at any point in time. Such
withdrawal of consent must be sent in writing to service@Moneyase.in. In case You do not
provide Your consent or later withdraw Your consent, We request you not to access the
Platform and/or use the Services and also reserve the right to not provide You any
Services through the Platform. In such a scenario, the Company may delete Your
information (Personal or otherwise) or de-identify it so that it is anonymous and not
attributable to You. All the data which is not require to retail as per applicable law
will be deleted from company database and backup if any
13. CHANGES TO PRIVACY POLICY
We reserve the unconditional right to change, modify, add, or remove portions of this
Privacy Policy at any time, without specifically notifying You of such changes. However,
We may, at Our sole discretion, provide You push notifications or such other form(s) of
notice as We deem necessary to keep You updated about this Privacy Policy. Any changes
or updates will be effective immediately. You should review this Privacy Policy
regularly for changes. Your continued usage of the Platform shall signify Your consent
to such changes and agreement to be legally bound by the same.
14. GOVERNING LAW & JURISDICTION
This policy will be governed by and construed in accordance with the laws of India and
subjected to the exclusive jurisdiction of Courts of Bangalore.
15. GRIEVANCE OFFICER
MONEYASE aims to provide the best customer service through its Platform. We value
customer-relationship and strive to offer an efficient and robust grievance redressal
mechanism.
If you have any questions or concerns regarding the Platform, please feel free to
contact us.
Customer Service Team (Level 1): You can reach us for any query/complaint by writing to
us at service@Moneyase.in.
Grievance Team (Level 2): If the Complaint/Grievance is not redressed by the Customer
Service Centre within 7 working days, the customer shall approach the Digital Lending
Grievance Redressal Officer (GRO) of the Company at below details: