This Privacy Policy (“Privacy Policy”) describes what information Cronywits Consulting (“Company”), as the owner and operator of the Platform may collect from a user (“You”, “Your” or “User”), on or through our website, https://www.finkartz.com/ (that includes website, mobile applications and related platforms). We recognize that many visitors and users of www.finkartz.com / are concerned about the information they provide to us and how we use that information. This Privacy Policy has been developed to address those concerns. At www.finkartz.com / we respect your privacy and take reasonable measures to protect your personal information and other details that you share with us. Sensitive Personal Data collected and retained (either internally or third-party servers) is necessary for the purposes identified in this Privacy Policy and for providing the services. No unnecessary or additional information is asked for by www.finkartz.com /

This Privacy Policy is published in compliance with the terms and rules of the Information Technology Act, 2000 including the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011.

This Privacy Policy may be subject to further changes including as may be warranted by change in law. Upon updating the Policy, we may revise the “Updated” date at the bottom of this Policy. We therefore request you to go through our Privacy Policy frequently to be updated with changes incorporated from time to time. Your continued engagement with us will imply your acceptance of such updates to this Policy.

By visiting/ accessing the website and voluntarily providing us with information (personal and/ or non- personal), you are consenting to our use of it in accordance with this policy. This policy does not apply to third-party websites/ applications that are connected via links to the website.

If you do not agree to the terms of this Privacy Policy, please do not (i) access or use our website, (ii) avail of services from us, and do not disclose your information to us.

Collection of Information

During your use of the Website, we will collect such information from you, including but not limited to:

1. Your name, address, date of birth, contact information, marital status, Permanent Account Number (PAN), Employee Provident Fund Details, name of the bank where You have a primary account, bank statements, pay slips, GST, income tax returns and employment details, information relating to income and expenses obtained through bank SMS scraping and through integration with our service provider, other Know Your Customer documents etc.;
2. Details regarding your employment, comprising of years of experience, details of income, name of the current and previous employers, details of the office address, details regarding the years/months completed with the current employer;
3. Information with respect to your income tax returns;
4. Credit related information that is collected from other sources like the credit bureau;
5. Information about your transaction history like spend data, call history, contact list and other related information through our mobile application;
6. Your unique identifiers such as username and password, preferences information and transaction history;
7. Information collected through Facebook, Twitter, LinkedIn or other social media accounts of the Users which have been linked to the account on the Website. We may receive Your Personal Information from such social media websites/ applications, in accordance with the privacy policy of such sites/applications. Such information received from the other websites/platforms/applications at the time of accessing the website may include, and not be limited to, the user’s name, profile picture, e-mail address associated with that particular website/ application, any information that has been made public in connection with that website/ application belonging to you and/ or any information or content the social media website/ application has the right to share with Us. By accessing or connecting to the Website through a social media website/ application, you authorize Us to collect, store, use and retain such information and content in accordance with this Policy.
8. Information that you provide when You write directly to Us (including by e-mail) or provide us over telephone;
9. Recordings of telephonic conversations between you and our call centre executives for any query or assistance;
10. Information with respect to IMEI code, details on whether your phone supports dual sim cards, mobile network, name of the device, device operating systems and IP address;
11. Information relating to other mobile applications installed on your device;
12. Any other information that Finkartz is required to collect as per specific mandate from any bank or as a requirement under applicable law;
13. Clickstream data, including but not limited to the products browsed on Our Website, the pages viewed, how you navigate through the Website and interact with webpages, etc.

The information We collect about you will depend on the products and services We offer, on an ongoing basis. The information collected from you will be used in order to effectively provide services to you. If you do not allow us to collect all the information we request, we may not be able to deliver all of these services effectively.

Consent

Usage of the services provided by us may require you to provide consent for uploading personal information as enumerated above in the collection of information Clause.

You expressly consent us to share your requisite information with third parties to do an aggregate check of your credit profile to streamline your experience of using the services provided by us.

You, while providing your details/documents as enumerated above in the collection of information Clause to us, including but not limited to personal information, expressly consent to us (including its marketing channels and business partners) to contact you through SMS, call and/ or e-mail and to follow up calls in relation to the services provided through Finkartz, for imparting product knowledge, offering promotional offers running on Finkartz & various other offers offered by Our business partners. If, at any point during your engagement with our services, wish to withdraw consent with respect to sharing personal information by you, please e-mail info@Finkartz.com.

Use of Information

We may use the information provided by you in the following ways, viz:

1. To establish identity and assess applications;
2. Monitor, improve and administer our website;
3. Design and offer customized products and services offered by our third-party partners, manage our risks including the risk of fraud that may be committed against us or our partners;
4. Analyse how the Website is used, diagnose service or technical problems and maintain security;
5. Send communications notifications, information regarding the products or services requested by you or process queries and applications that you have made on the Website;
6. Manage Our relationship with you and provide you with or inform you about other products or services we think you might find of some use;
7. Conduct data analysis in order to improve the Services provided to the User;
8. Use the User information in order to comply with country laws and regulations;
9. To conduct KYC for our third-party partners based on the information shared by the User for the provision of Services. This would include conducting analysis of Your bank statements and eKYC. Finkartz, may directly or through third parties, conduct the KYC on its customers. In the event the KYC as detailed under this clause is being conducted by its third-party service providers, Finkartz shares your relevant information with such third party service providers for availing the said services;
10. To authenticate EPF details from your previous records, check your previous employment details, and check PAN status, using the required details;
11. Use the User information in other ways permitted by law.

We will use and retain your information for such periods as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Cookies

Cookies are small data files that a website stores on your computer. We will use cookies on our website similar to other lending websites and online marketplace websites. Use of this information helps us identify you, the User behaviour, the products that the User browses, in order to make our website more user friendly and to be able to provide you with information relating to Products that may be of interest to you. We might also use this information to display advertising from third party companies. Most browsers will permit you to decline cookies but if you choose to do this it might affect service on some parts of our website.

We might also use other technology to track how you interact with website and employ some third party agencies to use the data on our behalf for data analysis to determine your use and journey on the website.

Storage and Security of Information

We store and process your personal information on our secured servers and other cloud service providers. Some of the safeguards we use are firewalls and data encryption using SSL, and information access authorization controls. We use reasonable safeguards to preserve the integrity and security of your information against loss, theft, unauthorised access, disclosure, reproduction, use or amendment. To achieve the same, we use reasonable security practices and procedures as mandated under applicable laws for the protection of your information.

However, you understand and accept that there’s no guarantee that data transmission over the Internet will be completely secure and that any information that you transmit to us is at your own risk. We assume no liability for any disclosure of information due to errors in transmission, unauthorized third party access to our website and data bases or other acts of third parties, or acts or omissions beyond our reasonable control and you shall not be entitled to hold Finkartz responsible for any breach of security. However, Finkartz shall duly inform you if there has been any breach or unauthorised disclosure of the information as provided by you.

Sharing of Information

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. However, we are not responsible for any breach of security or for any actions of any third parties that receive your personal information. Please note that by agreeing with the terms as laid out in this Privacy Policy, you also provide your consent for your information to be shared with third parties in the manner as described below:

1. We may disclose Your information to the financial service providers, banks or NBFCs and our third party partners for providing the Services as detailed under the Terms of Use;
2. 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;
3. 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.

Third Party Websites

With this policy we are only addressing the disclosure and use of data collected by us. If you visit any websites through the links on the Finkartz Website, please ensure you go through the privacy policies of each of those websites. Their data collection practices and their policies might be different from this policy and Finkartz does not have control over any of their policies.

We might publish your data, excluding personally identifiable information as determined by us, on various pages of our website that will be visible to people other than registered users.

Exclusion

We have taken every effort to ensure that this Policy adheres with the applicable laws. The invalidity or unenforceability of any part of this Policy shall not prejudice or affect the validity or enforceability of the remainder of this Policy. This Policy does not apply to any information other than the information collected by Finkartz through the website. This Policy shall be inapplicable to any unsolicited information you provide us through this website or through any other means. This includes, but is not limited to, information posted in any public areas of the website. All unsolicited information shall be deemed to be non-confidential and the Company shall be free to use and/ or disclose such unsolicited information without any limitations.

Governing Law and Jurisdiction

This Privacy Policy, our services and the use of it is governed by and construed in accordance with the laws of India and any legal proceeding or any disputes arising out of or in connection with this policy will occur exclusively in the courts located in Jaipur, Rajasthan, India. and You hereby accede to and accept the jurisdiction of such courts.

Please proceed only if you accept all the conditions enumerated herein above, out of your free will and consent.

This document was last updated on April 30, 2022