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PRIVACY POLICY


INTRODUCTION

The App/ Website is made available by Eduvanz Financing Private Limited registered as Non-Banking Financial Company (NBFC) with Reserve Bank of India (RBI), having its registered office at B/202, Times Square Building, Opp. Mittal Industrial Estate, Andheri Kurla Road, Andheri East, Mumbai - 400 059 owns, manages and operates this platform under brand name “Eduvanz” (hereinafter referred as “Company”, ‘We’, “Us”, “Our”, “Eduvanz”).

In order to facilitate and provide you (and co-applicants, borrowers, guarantors, if any) with the Services through the Eduvanz App or the website we need to collect various data and information from you. The manner in which this data and information is collected, retained, shared, stored, and processed by us, is addressed in this Privacy Policy (“Policy”). By setting up an account on the App or via website, you agree to the processing, storage, usage and sharing of the data provided by you pursuant to this Policy.

We may revise this Policy as well as update the Services, the App and the Website from time to time, so please keep visiting this page regularly to take notice of any changes we make. If you do not agree with any part of this Policy, please stop using our Services immediately. This Policy should be read in consonance with the Terms & Conditions available in the Legal section of our App and website which describe the terms under which we provide our Services and the terms under which you can use our Services.

This Policy, incorporates, and includes our Terms and the Agreement(s) executed by you (and co-applicants, borrowers, guarantors, if any) for availing our Services. Words and phrases not defined in this Policy shall mean the same as provided in the Terms. All references to you (as a user / visitor) shall include references to all including but not limited to co-applicants, covered members or nominees, joint investors, if any.

INFORMATION WE COLLECT

When you use our App, we collect and store your information (personal 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 customized experience and services. This allows us to provide services and features that meets your needs, and to customize our App 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 without telling us who you are or revealing any personal information about yourself. However, to create an Eduvanz account via our website or App, you must provide us with certain basic information required to provide customized services.

Data Collected on Creation of an Account – When you install our app/visit our website, for first time login you provide us with your personal information which includes phone number for mobile number verification & Email. When you create or update your Eduvanz Account, we and/or our third-party loan service providers collect the data you supply to us. This information comprises your name, phone number, email ID, PAN, date of birth, pin code, nature of employment, monthly income, marital status, and relationship with the co-applicant (in case the loan is being sought by more than a single applicant). We or our Lending Partner may request you to supply additional information at a later date to check the accuracy of your information or for any other new feature you want to enjoy on the app.

Financial and KYC Information – We and our Lending Partner collect the data you provide to us when you accept the tentative terms of the loans. This includes your photograph, Aadhaar Number, PAN, parents’ names, bank account number, IFSC, proof of address (which can be your electricity bill, rental/lease agreement, gas bill, passport or driver’s license, or any other document our App or Website may be able to record). We may retrieve your information and records available with third party provider including credit score and liabilities information or information from the KYC Registration Agency, Goods and Services Tax Network (“GSTN”) and National Informatics Centre such as name, KYC details, KYC status, father’s name, occupation, address details and related documents You hereby authorise the Company to download and retrieve any information from governmental and other statutory bodies including but not limited to GSTN and NIC. As a part of our Video Know Your Customer (Video KYC) process, collection of your personal information has become mandatory to ensure the completion and authentication of your KYC. In this regard, permissions for microphone, camera will be mandatorily required.

You may be asked to supply additional information to the Lending Partner in order for your loan application to be processed. Bank statements, goods and services tax reports, wage and income statements, and title documents for the property being financed are examples of such supplementary information.

Information collected through your Device – We may collect and use technical data and related information, including but not limited to, technical information about your device, system and application software, and peripherals, that is gathered periodically to facilitate the provision of software updates, product support and other services to you (if any) related to such Mobile Applications.

When you use our App, the app may automatically collect and store some or all of the following information from your mobile device (“Mobile Device Information”), in addition to the Device Information, including without limitation –

  • Your preferred language and country site
  • IMEI number,
  • SDK version and mobile network information (including carrier name, SIM Serial and SIM Slot.)
  • Your profile information
  • Wi-Fi information.
  • The manufacturer and model of your mobile device (including storage, installed apps, )
  • Your mobile operating system
  • The type of mobile internet browsers you are using
  • Your geolocation
  • Information about how you interact with the Mobile Application and our web site to which the Mobile Application links
  • Transactional SMSs
  • Emails registered on device
  • Phonebook/Contacts
  • Other Non-Personal Information

The Geo Location data is collected from your device to reduce the risk associated with your account. We and our Lending Partner receive location data from you in two ways: (i) when you enter the pin code as part of your Eduvanz Account data; and (ii) when you allow location services on your mobile device. When our App is running in the background of your mobile device, we acquire this info. If you disable location services, you will be unable to use the App.

We also need access to your Contact address book and when you enable us access to your mobile Contact address book, we and our Lending Partner gain access to and record the names and contact information in your address book to facilitate invitations, analyze your phone usage and patterns, and collect late EMI payments. If you disable this access, you will be unable to use the App. We collect all of your phonebook contacts, including their contact names, phone numbers, account types, favorites (starred), and contact labels, as part of the loan process to enrich your financial profile.

We don’t collect or store your personal SMS from your inbox. We only collect financial SMS sent by 6-digit alphanumeric senders from your inbox which helps us in identifying the various accounts that you are holding and the cash flow patterns that you have as a user to help us perform a credit risk assessment which enables us to determine your risk profile and to provide you with the appropriate credit analysis to enable you to take financial facilities from the regulated financial entities and other service providers available on the App. While using the app, it periodically sends the financial SMS information to our affiliate server and to us. Where possible, we indicate the mandatory and the optional fields. You always have the option to not provide your personal information by choosing not to use a particular service or feature on the App. We also collect other identifiable information (your payment card details and transaction histories on the App) from you when you set up a free account with us as further detailed below. While you can browse some sections of our App without being a registered member as mentioned above, certain activities (such as availing of loans from the third-party lenders on the App) requires registration and for you to provide the above details. The App shall 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 App.

We also collect certain other information from you on your visit to our Website such as information about your operating system, browser type, the URL of the previous website you visited, list of third-party applications being used by you, your internet service provider and your IP Address (Non-personal Information). This information cannot be easily used to personally identify you. We use Non-personal Information for the purposes including but not limited to troubleshoot connection problems, administer the Website, analyze trends in the market, gather demographic information, to ascertain how our visitors use our Website, including information relating to the frequency of visits to our Website, average length of visits, pages viewed during a visit, ensuring compliance with the applicable law, co-operating with law enforcement activities, etc. This information is used to improve the Website content and performance. You also agree that Eduvanz may gather usage statistics and usage data from your use of our Website to evaluate your use of our products/services, to improve our products/services, Website content and to ensure that you are complying with the terms of the applicable agreements between you and the Company. The statistics and data collected may or may not be aggregated. These statistics contain no information that can distinctly identify you.

Camera – We require camera access to scan and capture the required KYC documents thereby allowing us to auto-fill relevant fields.

As a part of facilitation of the KYC journey, we require access to your camera to enable you to initiate your KYC process. This permission allows us or our authorised agents to perform your Video KYC while also taking screenshots of your original Officially Verified Documents that you present during your Video KYC journey. Video KYC enables you to complete your KYC digitally, smoothly and efficiently. Your video shall be recorded and retained for regulatory purpose along with the screenshots of original Official Verified Documents.

Microphone – We require microphone permissions to enable a two-way communication between our authorized agent and you for the purpose of performing and completing your Video KYC. Your audio shall be recorded for regulatory purpose.

We may also be working closely with third parties (including, for example, credit information bureaus, business partners, technical sub-contractors, analytics providers, search information providers, title deeds, property verification service providers and valuers) and may lawfully receive information about you and your co-applicant from such sources. Such data may be shared internally and combined with data collected on the App. We may also use the content you have shared publicly, including on third party platforms or applications, to promote our Services (including by quoting your content, reviews and/ or recommendations, or displaying screenshots of your content, reviews and/ or recommendations).

How we use this data: For Enabling the App and its Services; For Loan Processing and KYC Authentication; For Enabling Customer Support; For Research and Development; For Enabling Communications Between You and Us; For enabling Marketing and Outreach; For Automated Decisions; For Legal Compliance and Requirements and For promoting or marketing other products and services offered by us or our affiliates and group companies.

COOKIES

Similar to other commercial web sites, our Website utilizes standard technology called “Cookies” and Web server logs to collect information about how our Website is used. Cookies are small pieces of information that are stored by your browser on your device’s hard drive. Cookies are only read by the server that places them, and are unable to inter alia run programs on your device, plant viruses or harvest your personal information. Cookies allow Web servers to recognize your device each time you return to our Website including the date and time of visits, the pages viewed, time spent at our Website, and the websites visited just before and just after our Website, verify your registration or password information (in case of registered users) during a particular session so that you do not have to input your password multiple times as you navigate the site and suggest products or services that may interest you. This information is collected on an aggregate basis. None of this information is associated with you as an individual.

Most web browsers automatically accept cookies. By changing the options on your web browser or using certain software programs, you can control how and whether cookies will be accepted by your browser. We understands and supports your right to block any unwanted Internet activity, especially that of unscrupulous websites. However, blocking our cookies may disable certain features on our Website and may make it impossible for you to use certain services available on our Website.

SESSION DATA

We automatically log generic information about your device’s connection to the Internet, which we call “session data”, that is anonymous and not linked to any personal information. Session data consists of information such as the IP address, operating system, type of browser software being used by you and the activities conducted by you on our Website. An IP address is a number that lets device attached to the Internet, such as our web servers, know where to send data back to the user, such as the pages of the site the user wishes to view. We collect session data because it helps us analyze things such as the items visitors are likely to click on most, the manner in which visitors click preferences on our Website, number of visitors surfing to various pages on the Website, time spent by the visitors on our Website and frequency of their visit. It also helps us diagnose problems with our servers and lets us better administer our systems. Although such information does not identify any visitor personally, it is possible to determine from an IP address a visitor’s Internet Service Provider (ISP), and the approximate geographic location of his or her point of connectivity.

WHY EDUVANZ COLLECTS DATA

We For Enabling the App and its Service – We use the data collected to personalize, maintain and improve our Services. This includes using the data to:

  • Create and update the Eduvanz Account.
  • Analyze your loan eligibility and estimate your loan terms.
  • Track the disbursement and repayment of the loan.
  • Enable features that allow you to add and remove bank accounts for your loan repayment and disbursements from time to time.
  • Enable features that help you check your loan history, credit scores (as provide on government databases), and other such App features as may be added from time to time.
  • Perform internal operations necessary to provide our Services, including to troubleshoot software bugs and operational problems; to conduct data analysis, testing, and research; and to monitor and analyze usage and activity trends.

For Loan Processing and KYC Authentication – We and/or our Lending Partner and/or service providers use the data to analyze your creditworthiness, loan eligibility, KYC documents, current employment verification and, and the terms of your loans. While we collect the Financial and KYC Information, the Lending Partner is required to individually process the loan requests and verify the KYC documentation received. Failing to process such data means that you cannot be provided any loans. You hereby grant us explicit consent to fetch your KYC (Know Your Customer) details from the Central KYC Records Registry using the details provided by you.

Our Lending Partner also uses the data to track disbursement and repayment of your loan.

For Enabling Customer Support – We use the information to provide customer support, including to resolve your concerns from the use of the Services, and train our customer service executives.

For Research and Development – We may use the data so collected for research, analysis, and product development to improve the UI/UX experience – all of which will ultimately improve how you experience the App. This also helps us develop automated actions to be triggered in certain events, such as when we need to identify if photographs uploaded are not clear, fraud takes place, IFSC is incorrect etc.

For Enabling Communications Between You and Us – We may add features that allow you to call us (through the App or otherwise), similarly, we may also need to contact you (through the App or any other channels that you give us access to, such as WhatsApp or Facebook).

For Marketing and Outreach – We may use the data we collect to market the App and our Services. This includes sharing your feedback, ratings and screen names for purely promotion and marketing purposes. Such promotion and marketing may be done, inter alia, via hoardings, banners, pamphlets, calls, SMSes, emails and other means.

For Automated Decisions – The App may provide automated features for customer responses, reimbursement tracking, etc. As our App grows, we will keep adding more automated features to the App.

For Legal Compliance and Requirements – We may use the data we collect to investigate or address claims or disputes relating to use of our Services, or as otherwise allowed by applicable law, or as requested by regulators, government entities, and official inquiries.

For Product Innovation – We may use the data we collect to offer new products and services for your use.

SECURITY PRECAUTIONS

The Website/App intends to protect your personal information and to maintain its accuracy as confirmed by you. We implement reasonable physical, administrative and technical safeguards to help us protect your personal information from unauthorized access, use and disclosure. For example, we encrypt all sensitive personal information when we transmit such information over the internet. We also require that our registered third-party service providers protect such information from unauthorized access, use and disclosure.

Our App has stringent security measures in place to protect the loss, misuse and alteration of information under control. We Endeavour to safeguard and ensure the security of the information provided by you. We use Secure Sockets Layers (SSL) based encryption, for the transmission of the information, which is currently the required level of encryption in India as per the law.

We blend security at multiple steps within our products with the state-of-the-art technology to ensure our systems maintain strong security measures and the overall data and privacy security design allow us to defend our systems ranging from low hanging issue up to sophisticated attacks.

SHARING OF INFORMATION

Service Providers – We work with third party service providers to execute various functionalities of the App and we may share your information with such service providers to help us provide the App. Some of these functionalities may include:

  • Analyzing transaction behavior and cashflows via your SMSs, bank statements, goods and services tax returns, salary and income statements, income tax returns, basis which your loan offer is generated.
  • Validating and authenticating the official verification documents provided by you.
  • Validating your preferred bank account, as well as transferring the loan amounts to you.
  • E-signing of the loan agreement or sanction letter, populating the loan agreement or the sanction letter. The information shared with these service providers is retained for auditing of the agreements.
  • eNACH set-up to enable autopay.
  • Analyzing customer behaviour, conducting research into customer behaviour and contacting the customers for the said purpose, and to automate our marketing and outreach efforts.
  • Detection and flagging of fraud.
  • Gathering of additional information regarding your bank account and statement details, in case adequate information has not been provided by you or through the other service providers we work with.
  • For manually collecting any sums owed by you to us or our Lending Partner.
  • Validating and authenticating your employment status, employment information and employment duration.

Third Party Services – The App may allow you to connect with other websites, products, or services that we don’t have control over (for example, if we allow you to pay through an external wallet facility then we will have to share your usage information with the facility provider). However, usage of such third-party services is subject to their privacy policies and not within our control. We recommend that you have a look at their privacy policies before agreeing to use their services.

Change in Control – While negotiating or in relation to a change of corporate control such as a restructuring, merger or sale of our assets, we may have to disclose our databases and information we have stored in the course of our operations.

Sharing with Law Enforcement when needed – If any governmental authority or law enforcement officers request or require any information and we think disclosure is required or appropriate in order to comply with laws, regulations, or a legal process.

Anti-Money Laundering Policy – In order to comply with anti-money laundering laws that exist in various jurisdictions we reserve the right to report suspicious transactions to federal, state, provincial or local authorities and law enforcement agencies within those jurisdictions. In exchange for us permitting you to participate in, use and access our Website and services you hereby grant us the right to report any transactions which we deem suspicious, as determined solely by Eduvanz acting in its sole discretion. Examples of a suspicious transaction include but are not limited to use of funds suspected to be derived from illegal activities, any suspected intention to conceal or disguise funds derived from illegal activities, or suspicion that the involvement of our Website and services is in any manner intended to facilitate criminal activity. If for any reason we are of the belief or become aware of any transaction which we deem suspicious in nature, we may without prior notice or explanation to you take the following actions, which are in addition to all other rights and remedies available to us under this Privacy Policy, at law or in equity:

  1. report such transaction to the applicable central, state, provincial or local authorities and law enforcement agencies;
  2. de-activate or terminate your Eduvanz account forthwith;
  3. withhold any funds held in your Eduvanz wallet; and/or
  4. restrict you from registering a Eduvanz account on or with our Website or any of our affiliated websites.

Fraud and Credit Agencies. – When you open a Eduvanz account, at any time we feel it is necessary to do so to protect our financial interests and prevent money-laundering or fraud, we share certain information about you and your Eduvanz account, financial history and transactions as part of our normal business operations with banks, payment facilitator partners, credit/debit card processing services, identity verification service providers and credit reference agencies (including, but not limited to) to identify and verify users, to limit our exposure to fraud and other criminal activities and to manage our financial risk. We can provide you with a list of the credit reference agencies we use upon your written request to the given email-id and contact information below. When conducting identification or fraud prevention checks, the relevant parties may retain a record of our query along with your information and may share this information with other fraud prevention agencies. If you want to know what information these companies hold about you, you can write to them to request access to your information.

DATA RETENTION

We shall retain the information you provide to facilitate your smooth and uninterrupted use of the App/Website, and (i) to provide, improve and personalize our Services; (ii) to contact you about your account and give customer service; (iii) to personalize our advertising and marketing communications; and (iv) to prevent, detect, mitigate, and investigate fraudulent or illegal activities. We do not retain your personal data for longer than required for the purpose for which the information may be lawfully used. For any other information, we may entertain your request for deletion, however, you may not be able to use our Services at all after such deletion.

COMMUNICATIONS FROM EDUVANZ

We may from time to time contact you via calls, SMS, emails, and other communication channels to provide you with information pertaining to our products or services, notifications on updates vis-à-vis our products or services (when we consider it necessary to do so), educational information and promotions. We may also notify you if we need to temporarily suspend the App or Website for maintenance, and keep you informed on security, privacy, or administrative-related communications. By setting up an account on Eduvanz, you consent to us contacting you via call, SMS, push notifications, or through any other communication channel, as we may deem fit.

YOUR RIGHTS REGARDING THE DATA

  1. Right to opt out from push notification
  2. Right to withdraw consent from the app by uninstalling
  3. Right to correct the data if its inaccurate

Please write to us at CustomerService@eduvanz.com if you wish to exercise any of your rights under the Policy. However, please note exercising your rights to opt out or withdrawing consent would be in accordance with internal policies and depending on the status of your product or service availed from us. Our customer service team will inform you further on feasibility of your request depending on internal policies.

CONTACT INFORMATION

In accordance with the Information Technology Act 2000 and rules made thereunder, the name and contact details of the Grievance Officer are provided below:

Details of the Grievance Officer of the Company –

Name: Mr. Harshvardhan Khangarot, Eduvanz Financing Private Limited
Address: B/202, Times Square Building,
Opp. Mittal Industrial Estate,
Andheri Kurla Road, Andheri East,
Mumbai, 400059
Phone: 022-41791756 / +917039298529
Email: harshvardhan.khangarot@eduvanz.com
Time: Monday -Saturday (9.30 am till 8.30 pm)

You may contact the Grievance Officer in relation to any grievances that you may have in relation to this Privacy Policy.

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