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Company Private Limited values your privacy. This Privacy Policy (“Policy”) describes the privacy policy and procedures on the collection, use, disclosure and protection of your information when you use our website located at www.flexypay.in, or the flexypay mobile application (collectively, “Platform”) made available by Flexypay Solutions Private Limited (“Company”, “we”, “us” and “our”), a private company established under the laws of India having its registered office at 91 Springboard, Plot No. 71, LVS Arcade, Jubilee Enclave, Hitec City, Madhapur, Hyderabad - 500081.
The terms “you” and “your” refer to the user of the Platform. The term “Services” refers to any services offered by Company whether on the Platform or otherwise.
Please read this Policy before using the Platform or submitting any personal information to Company. This Policy is a part of and incorporated within, and is to be read along with, the Terms of Use. If you have any questions or comments about the Policy, please contact us at [email protected].
This Policy does not apply to information that you provide to, or that is collected by, any third-party, such as social networks or pay through our Services and any other third party that you use in connection with its Services. We encourage you to consult directly with such third-parties about their privacy practices.
In terms of the Information Technology (Intermediaries Guidelines) Rules, 2011 and the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, any grievance or complaint may be intimated to the Grievance redressal officer, email: [email protected]. The complaint shall be redressed within a period of 21 days.
By using the Platform and the Services, you agree and consent to the collection, transfer, use, storage, disclosure and sharing of your information as described and collected by us in accordance with this Policy. If you do not agree with the Policy, please do not use or access the Platform or the Services therein.
We may occasionally update this Policy and such changes will be posted on this page. If we make any significant changes to this Policy we will endeavour to provide you with reasonable notice of such changes, such as via prominent notice on the Platform or to your email address on record and where required by applicable law, we will obtain your consent. To the extent permitted under the applicable law, your continued use of our Services after we publish or send a notice about our changes to this Policy shall constitute your consent to the updated Policy.
The App has a link to a registered third party SDK which collects data on our behalf and data is stored to a secured server to perform a credit risk assessment. We ensure that our third party service provider takes extensive security measures in order to protect your personal information against loss, misuse or alteration of the data. Our third-party service provider employs separation of environments and segregation of duties and have strict role-based access control on a documented, authorized, need-to-use basis. The stored data is protected and stored by application-level encryption. They enforce key management services to limit access to data. Furthermore, our registered third party service provider provides hosting security – they use industry-leading anti-virus, anti-malware, intrusion prevention systems, intrusion detection systems, file integrity monitoring, and application control solutions.
You may log into our Platform through your Facebook account/ Google Account/ or such option available on the Platform (“Social Account”). If you do so, you must enter the email address and password that you use for your Social account. We will ask that you grant us permission to access and collect your Social Account basic information (this includes your name, profile picture, gender, networks, user IDs, list of friends, date of birth, email address, and any other information you have set to public on your Facebook account). If you allow us to have access to this information, then we will have access to this information even if you have chosen not to make that information public.
We store the information that we receive from Social Account with other information that we collect from you or receive about you.
The respective Social Account controls the information it collects from you. For information about how Social Accounts may use and disclose your information, including any information you make public, please consult the respective Social Account`s privacy policy. We have no control over how any third party site uses or discloses the personal information it collects about you.
We and our third party service providers, which include ad networks, use cookies, web beacons, and other tracking technologies to collect information about your use of our Platform and Services, such as your browser type, your ISP or operating system, your domain name, your access time, the URL of the previous website you visited, your page views, your IP address, and the type of device that you use. We also track how frequently you visit our Platform and use our Services. We use this information (including the information collected by our third party service providers) for Platform analytics (including to determine which portions of our Platform are used most frequently, what our users like/do not like), to assist us in determining relevant advertising (both on and off our Platform), to evaluate the success of our advertising campaigns, and as otherwise described in this policy. Currently, we do not honour browser requests not to be tracked.
“Personal information” is defined to include information that whether on its own or in combination with other information may be used to readily identify or contact you such as: name, address, email address, phone number etc.
We collect personal information from you availing our products and services. This information is partially or completely accessible to all visitors using Company`s Platform or mobile application, either directly or by submitting a request for a service. Users are required to create an account to be able to access the Platform, and will be required to disclose and provide to Company information including personal contact details, bank details, personal identification details (such as PAN card, Aadhar card, phonebook, call logs etc.) and participate in polls or surveys or feedbacks etc. Such information gathered shall be utilized to ensure greater customer satisfaction and help a customer satiate their needs. The type of personal information that we collect from you varies based on your particular interaction with our Platform or mobile application.
Consumers: During the Account registration process and during your usage of Platform or application, we will collect information such as your name, postal code, telephone email address and other personal information. You also may provide us with your, mailing address, and demographic information, PAN Details, Aadhar Card details and bank details (e.g., gender, age, political preference, education, race or ethnic origin, and other information relevant to user surveys and/or offers). We may also collect personal information that you post in your Offer, Profile, Wants, or Feedback, and any comments or discussions you post in any blog, chat room, or other correspondence site on the Platform or mobile application, or any comments you provide during dispute resolution with other users of the Platform.
User acknowledges that as part of the on-boarding process, the Company or an entity /agency appointed or nominated by the Company (“Verifier”), may undertake background verification checks of the User in order to authenticate inter alia the genuineness and solvency of the User. In light of the above, the User expressly consents to and acknowledges the following:
We don`t collect, read or store your personal SMS from your inbox. We collect and monitor only financial SMS sent by 6-digit alphanumeric senders from your inbox which helps us in identifying the various bank accounts that you may be holding, cash flow patterns, description and amount of the transactions undertaken by you as a user to help us perform a risk assessment which enables us to determine your risk profile and to provide you with the appropriate services. This process will enable you to take financial facilities from the regulated financial entities available on the Platform. This Financial SMS data also includes your historical data.
We collect and monitor the information about the location of your device to provide serviceability of your loan application, to reduce risk associated with your loan application and to provide pre-approved customised loan offers. This also helps us to verify the address, make a better credit risk decision and expedite know your customer (KYC) process. 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 unauthorized device acts on your behalf to prevent frauds.
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 customized loan offers.
We collect a list the Contacts metadata information which includes the number of contacts, count of contacts with phone number, contacts created monthly to detect the fraudulent behavior and assess your credit worthiness. Personal contact information like name of the contacts or phone number of the contacts and other similar information is not collected.
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 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 application journey.
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.
Cookies are small data files that a Website stores on Your computer. We will use cookies on our Website similar to other lending websites / apps and online marketplace websites / apps.
The App has a link to a registered third party SDK which collects data on our behalf and data is stored to a secured server to perform a credit risk assessment. We ensure that our third party service provider takes extensive security measures in order to protect your personal information against loss, misuse or alteration of the data. Our third-party service provider employs separation of environments and segregation of duties and have strict role-based access control on a documented, authorized, need-to-use basis. The stored data is protected and stored by application-level encryption. They enforce key management services to limit access to data. Furthermore, our registered third party service provider provides hosting security – they use industry-leading anti-virus, anti-malware, intrusion prevention systems, intrusion detection systems, file integrity monitoring, and application control solutions.
You may log into our Platform through your Facebook account/ Google Account/ or such option available on the Platform (“Social Account”). If you do so, you must enter the email address and password that you use for your Social account. We will ask that you grant us permission to access and collect your Social Account basic information (this includes your name, profile picture, gender, networks, user IDs, list of friends, date of birth, email address, and any other information you have set to public on your Facebook account). If you allow us to have access to this information, then we will have access to this information even if you have chosen not to make that information public.
We store the information that we receive from Social Account with other information that we collect from you or receive about you.
The respective Social Account controls the information it collects from you. For information about how Social Accounts may use and disclose your information, including any information you make public, please consult the respective Social Account`s privacy policy. We have no control over how any third party site uses or discloses the personal information it collects about you.
We and our third party service providers, which include ad networks, use cookies, web beacons, and other tracking technologies to collect information about your use of our Platform and Services, such as your browser type, your ISP or operating system, your domain name, your access time, the URL of the previous website you visited, your page views, your IP address, and the type of device that you use. We also track how frequently you visit our Platform and use our Services. We use this information (including the information collected by our third party service providers) for Platform analytics (including to determine which portions of our Platform are used most frequently, what our users like/do not like), to assist us in determining relevant advertising (both on and off our Platform), to evaluate the success of our advertising campaigns, and as otherwise described in this policy. Currently, we do not honour browser requests not to be tracked.
Company shall confirm and initiate the execution of the transaction initiated by You upon receiving confirmation from You for the same. If You wish to cancel a transaction on the Platform, You shall contact the platform and raise a request. It is to be noted that You may have to pay a cancellation fee for transactions initiated on the Platform for which work has already been commenced by the payment gateway.
Company may cancel the transaction initiated by You on the Platform, if:
You shall only be able to claim refunds for transactions initiated by You only if You have already pre-paid the fees with respect to such transaction. You shall be eligible to get the refund if Company has cancelled the order because of any reason mentioned under Para 26.2
All decisions with respect to refunds will be at the sole discretion of Company and in accordance with Company`s internal refund policy (Refund Metrix) and the same shall be final and binding. All refunds initiated by Company shall be refunded to the financial source account from which, You have initiated the transaction on the Platform.
Notwithstanding anything contained herein, Company is only responsible for arranging troubleshooting of the users complaints and directing the users to the Financial Partners. The ultimate responsibility of the replacement or refund lies with the Financial Partners.
The amount of a transaction maybe charged back (`Chargeback`) if the transaction is (i) disputed by cardholder; (ii) reversed for any reason; (iii) not authorized by cardholder or if Company or the issuing bank has reason to believe that it is not authorised; or (iv) is considered unlawful or in breach of these Terms and Conditions.
In case of a Chargeback, You will owe Company and will be required to immediately pay Company the amount of any Chargeback and any associated fees, fines or penalties as assessed by the payment gateway, bank, card association or processor. You agree to assist Company when requested to investigate any of your transactions made using the Company Platform. Your failure in providing timely assistance to Company, including without limitation providing documentation, where required within 72 hours, may result in an irreversible Chargeback.
Further in such cases your use of Platform or the entire Company Services maybe blocked for an indefinite period of time as decided by Company on a case-to-case basis.
