In order to facilitate and provide you (and co-applicants, members, nominees, if any) with the Services through the Portal, PFL and third parties as authorised under the Terms need to collect various data and information from you with your prior and explicit consent.
You hereby represent to PFL that:
You must ensure that the Information you provide Us remains accurate and up-to-date at all times.
Your Information will primarily be stored in electronic form however certain data can also be stored in physical form. We may enter into agreements with third parties to store or process your Information or data. These third parties may have their own security standards to safeguard your Information or data and We will, on reasonable basis, require such third parties to adopt reasonable security standards to safeguard your Information.
Information We collect
1. Account Information:
When you set up your account on the Portal, We collect your Information, such as your first and last name, referral code used (if any), address details, photo, email addresses, and telephone numbers.
For certain Services, We may collect identity and Know Your Customer ("KYC") related Information to verify your identity and comply with the customer identification procedures and customer due diligence requirements prescribed under Applicable Laws, such as Permanent Account Number (PAN), photo, Aadhaar related Information (including Aadhaar number, demographic details or Virtual ID) for the purposes of e-KYC authentication with the Unique Identification Authority of India (“UIDAI”) and One Time Password / Pin (OTP). Please note that e-KYC authentication and submission of Aadhaar information is not mandatory, and you may submit other identity documents in place of Aadhaar information, to verify your identity as stipulated under KYC Directions, 2016 issued by the RBI.
3. Information to assess credit worthiness:
(a) Students: Education related Information, such as name of college, year of graduation, college ID card, fee receipt;
(b) Salaried individuals: Employment related Information, such as name of the employer, salary, offer letter, employment ID, and email address issued by the employer;
(c) Self-employed: Information related to the self-employment, such as profession, social media links related to your work, work location and income.
4. Financial Information:
We may collect certain financial Information (such as bank account details or other payment instrument details), rental/lease agreement, gas bill, service or transaction related communications for providing the Services.
We may collect Information related to the electronic device you use to access the Portal, such as your devices’ internet protocol (IP) address, browser type, operating system, software, device type, device ID, device international mobile equipment identity (IMEI) and date and time at which you visit the Portal or avail the Services. This helps Us learn about and verify your identity as well as detect and prevent fraud.
6. Usage of the Portal:
We may collect Information that you may electronically submit when you post on message boards, or information contained in searches, reviews, ratings or comments that you submit or Information about you from other persons or sources, or the details of your visits of the Portal or usage behaviour on the Portal. Such Information may be used by Us to administer the Portal and compute general statistics regarding the use of the Portal. We may also use this Information to share important or relevant updates and information through email and/or SMS, and also prevent communication that might not interest you.
We may need access to the SMS functionality in your device for the purposes of onboarding you in relation to certain Services on your device. We may periodically collect transactional SMSs for the purpose of provision of Services. You may have restricted access to the Portal or the Services available through the Portal, if you disable, withdraw or do not provide this access.
8. Camera and microphone:
We may require access to your device's camera and microphone for a seamless experience, for clicking your selfie, to upload photos, or recording your audio/video, for verification or onboarding / KYC purposes, or for uploading any other necessary documents on the Portal.
We may collect and monitor your location to verify your current address, offer you customized promotions, ensure and check serviceability of Services and to prevent any fraudulent activity. We collect the location data from you in two ways: (i) when you add your pin code on the Portal; or (ii) when you enable such access from your mobile device. We collect this data only when Our Portal is being used. You may have restricted access to the Portal and/or Services available through the Portal, if you disable/withdraw/do not provide this access.
We may require permission so that your documents can be securely downloaded and saved on your phone, and so you can upload any required documents as part of using the Services. This helps in providing a smooth and seamless experience while using the Portal.
11. Feedback Data and Other Data:
We may access and save Information in the following instances:
(a) When you contact Us or We contact you, We may record Information provided by you during such communications or record calls for quality and training purposes;
(b) When you participate in Our referral programs or use any discount codes offered on the Portal and input such data;
(c) When you provide any feedback or comments to Us on the Portal or any other platform.
12. Third Party Information:
We may also work closely with Affiliates (defined below), third party business partners, technical sub-contractors, analytics providers, search information providers, credit information companies, account aggregator etc. and may lawfully receive Information about you from such sources. Such Information may be combined with Information collected on the Portal and such other Information as provided in this Policy.
13. Other Information:
We may also collect your Information via other sources, such as delivery address or contact Information from Our Affiliates and partners, Information from Our payment service providers, public records, publicly available sources or internet sites, vendors, data suppliers and service providers, commercially available marketing lists or registries, telephone directories, social network, news outlets and other related media.
Use of your Information
1. To enable you to access the Portal;
2. To avail the Services We offer to you, including any associated services;
3. To facilitate payments for the transactions you make using the Services;
4. To create, maintain or update your account and verify your identity;
5. To conduct due diligence and KYC and/or such other verifications as mandated under Applicable Laws;
6. To validate, process and share your KYC Information, nominee details, and other legally mandated Information with other regulated entities, financial institutions, or service providers (including lending service providers) engaged by Us to facilitate the Services or for verification by such financial institution for enabling/providing services.
7. To facilitate or confirm payments made by you in relation to the Services;
8. To enhance your user experience in relation to the Portal or the Services, including customisation of the Portal or the Services;
9. To conduct credit checks, screenings, assess your credit worthiness, credit scoring and obtain credit information;
10. To conduct audits, market research, project planning, troubleshooting;
11. To identify and/or detect security breaches or attacks, errors, fraud, money laundering, abuse and other criminal activities, and investigating and taking appropriate remedial action;
12. To provide relevant offers or rewards to you, based on your consumption patterns;
14. To provide functionality, analyse performance, fix errors, bugs, and improve the usability and effectiveness of the Portal;
15. To deliver any administrative notices, alerts, advice, notifications and communication relevant to your use of the facilities on the Portal, through social media (including WhatsApp), SMS and other media;
16. To recommend products or promotional offers to you that might be of interest to you, identify your preferences. We may also use your preferences or details regarding your usage of the Portal for marketing and other promotional activities;
17. To comply with Applicable Laws or requests received from regulators, government, law enforcement or judicial authorities under Applicable Laws or Our contract with a third party;
18. To disclose to Affiliates, Our and their employees, agents and representatives on a need-to-know basis to facilitate provision of Services;
19. To carry out Our obligations and enforcing rights arising from any contracts between Us;
20. To help improve quality and design of Our Portal, including to create new features, promotions, functionality and services;
21. To help improve the Services; or
22. To fulfil any other purpose for which you provide Us the Information and/or for any other purpose with your consent.
Sharing of your information
You hereby explicitly consent to share your Information for the following purposes: -
1. With financial institutions and Financial Partners (including but not limited to banks and Non-Banking Financial Companies), credit information companies, RBI or other regulatory agencies, to facilitate provision of Services, or as may be required under Applicable Laws;
2. With vendors or service providers (including lending service providers), business partners, co-lending partners/financial partners of PFL, Affiliates, to provide you with the Services, facilitate account creation, provide technical or customer support, synchronization of your contacts with the Portal or other software applications, send you communications via emails, messages or tele-call to inform you about the Services, or products, offers or services that may be of interest to you, push notifications to your electronic device on Our behalf, and collect, process and settle payments. We may also use other third parties for activities such as conducting surveys for Us, and may share your information with such third parties;
3. With Our holding companies, subsidiaries, affiliates and other body corporates in Our group (collectively, "Affiliates"), which operate under common ownership or control, subject to Applicable Laws;
4. With a buyer or other successor in the event of a merger, restructuring, reorganization, dissolution or other sale or transfer of some or all the assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which your Information may be amongst the assets transferred.
5. With law enforcement agencies, courts, regulators and/or other governmental organizations which have jurisdiction, to ensure compliance with orders or government directives;
7. In any other circumstances where We have your consent for any other purpose disclosed by Us when you provide the Information.
Third party policies
In general, the third-party service providers used by Us will only collect, use and disclose your information to the extent necessary to allow them to perform the services or activities they provide Us. In such cases, We share the Information securely and use commercially reasonable efforts to ensure that all recipients comply with confidentiality, fidelity and secrecy obligations and sign covenants in this regard.
The list of third-parties collecting Information through the Portal is available at this link, which will be updated from time to time, for your reference.
Our security practices and policies
PFL cannot ensure or warrant the security of any Information you transmit to it and thus, you provide Information at your own risk. Once it receives your transmission, PFL shall endeavour to make reasonable efforts to ensure security on its systems. PFL uses standard security practices and procedures such as secure server software and firewalls to protect your Information from unauthorized access, disclosure, alteration or destruction.
PFL has policies and procedures in place to protect information. All technical and operational security operations are governed and managed through policies. We adhere to all industry good practices on Information and cyber security.
By implementing these Security Practices and Policies, PFL is deemed to have complied with reasonable security practices and procedures. However, this is not a guarantee that such Information will not be accessed, disclosed, altered or destroyed by breach of such firewalls and secure server software. To the extent permissible by law, PFL disclaims any liability related to a security breach or loss of your Information.
In no event, shall PFL be liable for any special, direct, indirect or consequential damages, including, without limitation, lost profits, loss of business opportunity, loss of data in the event of misuse of the Information provided.
PFL makes significant efforts to protect against the loss, misuse, and alteration of the collected information. These measures may include the use of secure server technology. The User must be aware that the internet is not completely secure. Therefore, PFL cannot ensure the security of any Information transmitted to PFL over the internet, and PFL does not accept any liability for any unintentional disclosure of Information.
Products and Website are password‐protected. The Users must not share the passwords with anyone. You shall not undertake any act which amounts to breach of security, and you shall not try to access password-protected area of the Products and Website without proper authorization.
Retention of data, Withdrawal of Consent & Rectification
You can access and review the Information shared by you, after fulfilling the pending contractual obligations, by getting in touch with Us. You can also withdraw, or revoke consent given to Us to process any Information given by you to Us, by writing to Us at email@example.com. Also, you can request deletion of your account on the Portal.
You shall have the right to deny consent for use of specific data on the Portal.
We shall not retain your Information and delete the same if it is no longer required by Us and when there is no legal requirement to retain the same. Do note that multiple legal bases may exist in parallel, and We may still have to retain certain Information as may be required for audit purpose and/or in accordance with applicable law.
In the event any Information provided by you is inaccurate, incomplete or outdated then you should provide Us with the accurate, complete and up to date Information and have Us rectify such Information at Our end immediately. We urge you to ensure that you always provide Us with accurate and correct Information to ensure your use of Our Services is uninterrupted.
Information of Children
We do not knowingly solicit or collect Information from children under the age of 18 years. Use of the Portal is only available for persons who can enter into a legally binding contract under Applicable Laws.
When you visit the Portal, one or more cookies will be sent to the device being used by you to access the Portal. The cookies are either used to improve the quality of the Portal or for storing your preferences as a user, improving search results and tracking user trends. You have the option of disabling cookies via your browser preferences on your device. However, if you disable cookies on your browser, some parts of the Portal may not function effectively.
If you would like to ask about, make a request relating to, or complain about how We process your information, please contact or email Our grievance officer, at one of the addresses below. Our grievance officer will attempt to expeditiously redress your grievances.
For any request, complain, feedback or grievances, please contact: -
Principal Nodal Officer
Name: Arnab Das
Address: 201 and 202, 2nd floor, AP81, Koregaon Park Annex, Mundhwa, Pune - 411 036
Email id: firstname.lastname@example.org
Contact Number: 020 67808090
Grievance redressal Policy: https://poonawallafincorp.com/pdf/Grievance-Redressal-Policy.pdf