Privacy Policy

1. PERSONAL INFORMATION COLLECTED BY InstaMoney AND ITS PURPOSES

1.1 The Company respects each Users’ privacy and recognizes the need to protect their personal data and / or information shared.

1.2 The words “you” or “your” or “User” as used herein, refer to all individuals and/or entities accessing or using the Platform for any reason.

1.3 By accessing, browsing, registering, logging in the Platform, the User acknowledges to have read, understood, and agreed to be bound by this Privacy Policy and affirm their assent to the collection, use, storage, processing of information as set out in this Privacy Policy, as may be amended from time to time.

1.4 To avail the Services on the Platform, Users voluntarily provide us with certain information, including their name, occupation and such related professional details, contact information including phone number and e-mail address, demographic information including postal code, preferences and interests, gender, age, other information related to creating the profile of the User and the like, as part of the registration process whether as a borrower or as a lender on the Platform. You enable the Platform to use the information thus provided, so that the Company is not violating any rights that you might have in sharing your information. This information helps us enhance our Services by allowing us to tailor our Platform to cater to your personal interests or needs and make them more useful and relevant to you. Further, your information is required to create and maintain your account(s) with us and to contact you in case you need support. 

1.5 Such information will be stored and processed by the Company. The sole purpose to obtain such information is to maintain internal records, improve the products and services offered on the Platform, to customize the Platform according to the User’s interests and periodically provide promotional information to Users by e-mails about new products, special offers or other information. Further, from time to time, the Company may also use your information to contact you for market research purposes. We may contact you by e-mail, phone, fax or any other related means of communication. 

1.6 The Company shall obtain documents, details and information with respect to the ‘account holders’ of InstaMoney for carrying out their know-your-customer verification. 

1.7 The Company would collect the following information about you when you use the Platform and without such information we may not be able to provide you with all or any of the requested Services. The information collected is classified into following heads1.:

2. PERSONAL DATA

i) COLLECTION OF USER PROVIDED DATA
The information sought directly from the User is essential for availing certain features on the Platform, and extends to basic contact information including but not limited to the following:

The information sought directly from the User is essential for availing certain features on the Platform, and extends to basic contact information including but not limited to the following:

a) Full name
b) Gender
c) Phone number
d) Aadhaar Card
e) PAN Card
f) E-mail
g) Date of birth
h) Proof of residence
i) Age
j) Interests

ii) COLLECTION OF TRANSACTIONAL SMS INFORMATION:

iii) COLLECTION OF OTHER MOBILE DEVICE PERMISSIONS:

We may further collect the following information, either through the mobile application or other relevant Platform. This information will further be processed and stored with the Company. Permissions to these settings may be essential for adequate running of the relevant Platform and can be managed through the respective User device’s controls. These include:

1. Phone – when you install the App, we store the information we collect with unique identifiers tied to the device you’re using.
2. Camera or Gallery – we require the camera information permission to provide you an easy/smooth experience and to enable you to click photos or record videos of your KYC documents along with other requisite documents and upload the same on the Platform during your loan application journey.
3. Location – we collect only foreground location information from your device to verify the postal code and reduce the risk associated with your account. 

iv) INFORMATION YOU PROVIDE TO US VOLUNTARILY

This extends to personal correspondence, such as e-mails or letters sent by the User. We may also collect additional information at other times, for example, when you provide feedback(s), or post on the Platform, respond to surveys, or communicate with us in any other manner. This information may include your name, e-mail address, mobile number, location, etc. This information is typically used for either personalizing the User’s experience or other reasonably related purposes on the Platform.

v) THIRD PARTY INFORMATION

The Company may also receive information about you through other Users or by third parties with whom the User has consented to sharing correspondence about their activities (“TPI”). It is clarified that InstaMoney does not undertake any obligation to verify if the User has consented to third parties sharing TPI with InstaMoney and any damage arising to the User thereto shall be a matter solely and exclusively between the User and the concerned third party.

vi) INFORMATION WE COLLECT AUTOMATICALLY

The Company shall collect information about you and your use of our Services, your interactions with us, as well as information regarding your devices used to access our Services (such as mobile devices, tablets, and other viewing devices). This information includes, but is not limited to:

1. Your interactions with our e-mail, customer care, and messaging Platform;

2. Information collected/stored via installed mobile applications;

3. Device information like device ID, device model etc. and other unique identifiers;

4. Advertising identifiers, such as those found on mobile devices and tablets, devices that include identifiers; and

5. Information collected via the use of cookies and other technologies.

vii) USER EXPERIENCE AND SUPPORT 

The Company shall identify and use your internet protocol (“IP”) address to help diagnose any problems with our server and to administer our Platform. Your IP address is also used to help identify you and to gather broad demographic information to customize your experience on our Platform. You will occasionally be asked to complete optional online surveys. These surveys may ask for your information such as contact details and demographic information (like pin code, age, etc.). Such data is used to tailor your experience on the Platform, providing you with content and campaigns that we think you might be interested in and to display content and campaigns according to your preferences.

3. PERSONAL FINANCIAL INFORMATION:

3.1 In addition to the above, the Company may collect the following information that may qualify as sensitive personal information. A User providing the information falling under this category expressly consents to its collection and use by the Company and its affiliates for the purposes mentioned herein and in accordance with the other provisions of this Privacy Policy. 

i) Payment information: The Company does not collect any payment information from the Users except for details relating to bank accounts and payment wallets. Such information shall be dealt in accordance with the Terms of Use and Privacy Policy of the Platform. 

ii) Tax Details: All details associated with the above payment modalities for the purposes of paying and depositing tax with the requisite authorities.

 4. COLLECTED INFORMATION USE-CASE

4.1 Without prejudice to uses information detailed above, the Company and the Platform retains the right to use the User’s information for the following purposes:
a) Making available relevant content based on your interest for an improved experience;
b) Assessing and determining the creditworthiness of Users;
c) Respond to your questions or comments;
d) Analyze and understand our audience, improve our services (including our User interface experiences), and optimize content selection, recommendation of algorithms and delivery;
e) Conduct analysis and research to improve our Platform;
f) Advertise Users to participate in interactive features offered through the services on the Platform;
g) Notify Users about the change in terms of service on the Platform; and
e) Send you updates on relevant services.

5. SECURITY

1. 1. We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.

   2. The Company understands how much you care about the privacy and the security of your personal information, and which is why we are committed to respect and protect your privacy and your information shared with us from any unauthorized access or loss. All information gathered on the Platform is securely stored within our database. The database is stored on the servers secured behind a firewall and access to these servers is password protected and is strictly limited. If you know or have reason to believe that your account credentials have been lost, stolen, altered, or otherwise compromised, or in case of any actual or suspected unauthorized use of your account, please contact our grievance officer at cs@lendenclub.com. 

   3. In order to make every effort to ensure that the Users’ experience on the Platform is secure, InstaMoney uses encryption technology to protect the Users against the loss, misuse or alteration of the personal information. 

   4. However, in this digital era, the transmission of information via the internet is never completely impenetrable. Hence, Users should take requisite steps to protect their personal information against any unauthorized access. Such steps include choosing a strong password, signing off after using a shared device, and keeping your log-in details, especially your password, private. the Company and the Platform shall not be held responsible for any lost, stolen, or compromised information or for any activity on your account via unauthorized password usage. Further, the Company disclaims all liability for the breach of any of the User’s data in the event the said User fails to follow or knowingly breaches the below mentioned guidelines for access.

   5. The User may review, correct, update or change their account information at any time. To protect the User’s privacy and security, the Platform will verify the User’s identity before granting access or making changes to the personal information.

8. DATA RETENTION AND ERASURE

8.1 InstaMoney may retain your personal information as long as necessary for the legitimate business interests to provide the Users with the appropriate Services and to comply with our legal obligations. If you no longer want us to use your information, then you can request that we erase your personal information and close your account. Please note that if you request for the erasure of your personal information, we may:

a) Still retain some of your personal information as necessary for our legitimate business interests, such as fraud detection, prevention, and enhancing safety. For example, if we suspend an account for fraud or safety reasons, we may retain certain information from that account to prevent that user from opening a new account in the future.

b) Still retain and use your personal information to the extent necessary to comply with our legal obligations. For example, we may keep some of your information for taxation, legal reporting, and auditing obligations.

9. GENERAL DISCLOSURE

9.1 The Company may disclose or transfer your personal information after retrieving it from the Platform’s database to individual companies, affiliated companies, or third parties in locations around the world for the purposes described in this Privacy Policy. Wherever your personal information is transferred, stored, or processed by the Company, we will take reasonable steps in accordance with the prevailing technology to safeguard the privacy of your personal information. A User may request to cease such disclosure by writing to us subject to the protocol described in clause 7 above. 

10. LINK TO THIRD-PARTY SOFTWARE DEVELOPMENT KIT (“SDK”)

10.1 Our application has a link (https://iapi.algo360.com) to a registered third-party SDK (Algo360) which collects transactional SMS data, on our behalf, from only those users onboarded on our Platform and such data is stored to a secured server to perform 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.

10.2 Our third-party service provider employs separation of environments and segregation of duties and has 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.

10.3 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.

11.1 At times, the Company may make certain personal information available to its third-party strategic partners, or other third parties that help the Platform in marketing and research. When you register with our Platform, you authorize the Platform to exchange the information you provide for the purpose of provision of the services as well as to improve the services and for our marketing aspects. Such exchange of information by the Platform shall be governed by this Privacy Policy.

11.2 The Platform may also carefully select other companies to send you information about their products or services which are related to the services but are not necessary to its operation.

12. ADVERTISING

When we present information to our advertisers to help them understand our audience and confirm the value of advertising on our Platform, it is usually in the form of aggregated statistics on traffic to various pages/ content within our Platform. We use third-party advertising companies to serve advertisements when you visit our Platform. These companies may use information about your visits to this and other websites or applications, in order to provide advertisements about goods and services of interest to you.

13. LEGAL

The Company may disclose personally identifiable information if required to do so by law or in good faith belief that such action is necessary to:

a) Comply with legal process or proceedings or judicial order served on the Platform or its owners.

b) Protect and defend the rights or property of the Platform owners or of the Users of the Platform, or

c) Act under exigent circumstances to protect the personal safety of Users of the Platform, its owners, or the public.

 14. AMENDMENT TO THE PRIVACY POLICY