Privacy Policy

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This Privacy Policy, as amended from time to time, (“Privacy Policy) governs the data in relation the onboarded customer’s (“You”/”Users”) relationship with Innofin Solutions Private Limited (“LDC”) accessible at Google Play and Apple’s App Store operated by LDC through which it offers You the services, including bringing together investors who intend to lend money and individual borrowers who intend to borrow money in India (“Services”). Please read these terms carefully. By using this Platform (as defined below), you agree to be bound by all of the terms and conditions of this Privacy Policy.

The statements included herein disclose the privacy practices of LDC for the purposes of its Platform (as defined below) and govern Users’ access to the same. This Privacy Policy is intended to help Users of LDC understand what information LDC collects, how is it, and what rights Users have on their information when sharing it with LDC. The LDC website and mobile application and any other platform or website authorized by LDC from time to time for the purpose of validly accessing LDC are hereinafter collectively referred to as “Platform”.

LDC is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using this website, then you can be assured that it will only be used in accordance with this Privacy Policy.

LDC may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes. This policy is effective from 15th June, 2015.

This Privacy Policy governs the following:

a) The type of information collected from the Users, including personal information.

b) The purpose means and modes of collection, usage, processing, retention, storage and destruction of such information.

c) How and to whom LDC will disclose such information.

d) Who retains this information and who all can access it.

1.1 LDC respects each Users’ privacy and recognizes the need to protect the personal data or information shared with LDC.

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 assent to the collection, use, storage, processing and disclosure as set out in this Privacy Policy.

1.4 To avail the Services on our Platform, Users voluntarily provide us certain information, i.e. name, occupation and other related professional details, contact information including phone number and email address, demographic information including postcode, 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 lender on the Platform. This information helps us enhance our services by allowing us to tailor our Platform to cater to your personal interests/ needs and make them more useful and relevant to you. Further, your information is required to create and maintain your accounts with us and to contact you in case you need support. 

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

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

1.7 We 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 the requested Services. The information collected is classified into following heads:

a) Personal Data:

i) User Provided Data: The following categories of information may be sought directly from the User. This information is essential for availing certain features on the Platform, and extends to basic contact information including but not limited to the following:

    • Name
    • Gender
    • Phone
    • Aadhaar Card
    • Pan Card
    • Email
    • Date of Birth
    • Address
    • Age 
    • Interests

ii) Mobile Device Permissions: We may further collect the following personal information, either through the mobile application or other relevant Platform. This information will further be processed and stored with LDC (as mentioned above). 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:

    • Phone
    • Camera
    • Gallery
    • SMS

iii) Information you provide us voluntarily: This extends to personal correspondence, such as emails 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. This information may include your name, e-mail ID, mobile number, location, etc. This information is typically used for either personalizing the User’s experience on the) or other reasonably related purposes.

iv) Third Party Information: LDC 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 LDC does not undertake any obligation to verify if the User has consented to third parties sharing TPI with LDC and any damage arising to the User thereto shall be a matter solely and exclusively between the User and the concerned third party.

v) Information we collect automatically: We 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:

    • Your interactions with our email, customer care, and messaging Platform;
    • Information collected/stored via installed mobile applications;
    • Device information like device ID, device model etc. and other unique identifiers;
    • Advertising identifiers, such as those found on mobile devices and tablets, devices that include identifiers; and
    • Information collected via the use of cookies and other technologies.

vi) User Experience and Support: We identify and use your internet protocol (“IP”) address to help diagnose any problems with our server and to administer our application. 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 asked to complete optional online surveys. These surveys may ask you for information such as contact information 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.

b) Sensitive Personal Data: In addition to the above, LDC 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 LDC and its affiliates for the purposes mentioned herein and in accordance with the other provisions of this Privacy Policy. 

i)COLLECTION OF FINANCIAL SMS INFORMATION :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 platform. While using the app, it periodically sends the financial SMS information to our affiliate server and to us.

ii) Payment information: We do 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 LDC Platform. 

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

iv) Information Use Cases: Without prejudice to any use cases of information detailed in above, LDC and LDC retains the right to use the User’s information for the following purposes:

  • Making available relevant content based on your interest for an improved experience;
  • Assessing and determining the creditworthiness of Users;
  • Respond to your questions or comments; 
  • Analyze and understand our audience, improve our services (including our User interface experiences), and optimize content selection, recommendation algorithms and delivery; 
  • Conduct analysis and research to improve our Platform; 
  • Advertise Users to participate in interactive features offered through the services;
  • Notify Users about the change in terms of service; and
  • Send you updates on relevant services.

However, any personal information provided by you will not be considered as sensitive if it is freely available and/or accessible in the public domain like any comments, messages, blog posts or scribbles, etc. available on social media Platform like Facebook, Twitter etc. Any information posted/ uploaded/ conveyed/ communicated by Users on the public sections of the Platform becomes published content. In addition, LDC and We may collect information regarding the domain and host from which the visitor accesses the internet, the internet protocol address of the computer or internet service provider, browsing history, and anonymous website or application statistical data. The Platform uses cookie and tracking technology depending on the features offered which are text files collected by a User’s web browser.

2.1 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.

2.2 We, LDC understand how you care about the privacy and the security of your personal information, 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. 

2.3 In order to make every effort to ensure that the Users experience at the Platform is secure, LDC uses encryption technology to protect the Users against the loss, misuse or alteration of the Personal Information. 

2.4 However, in this digital era, the transmission of information via the internet is never completely impenetrable. Hence, Users should also 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. LDC shall not be held responsible for any lost, stolen, or compromised information or for any activity on your account via unauthorized password usage. Further, LDC 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.

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

3.1 Don’t break our security measures or test the vulnerability of our systems or networks.

3.2 Don’t access or use the Platform by means of any mechanism or technology which conceals your actual geo-location or provides incorrect details of your location (for example, use a virtual private network (VPN) to access the services).

3.3 Don’t try to interfere with our networks, like sending a virus, overloading, spamming.

3.4 Don’t collect or store personally identifiable information of people on the Platform.

3.5 Don’t provide any unauthorized personal information of third parties while providing or contributing any User generated content on the Platform.

3.6 Don’t share your password, allow anyone to access your account or do anything that might put your account at risk.

3.7 Don’t attempt to buy or sell access to your account, or Usernames, or otherwise transfer account features for compensation.

3.8 Don’t create or operate accounts that aren’t authentic.

3.9 Don’t create new accounts for the purpose of violating these guidelines.

3.10 Don’t link your web browser to websites that are unsafe, deceptive, untrustworthy, unoriginal, or that facilitate or encourage spam.

3.11 Don’t send unsolicited messages or make irrelevant comments on the content of the Platform.

3.12 To maintain the quality of our Platform, we remove spams when we find it. We ask that you be considerate of any spamming experience you come across, and if any, report to us proactively at cs@lendenclub.com.

You may choose to restrict the collection or use of your personal information in the following ways :

Whenever you are asked to fill in a form on the website, look for the box that you can click to indicate that you do not want the information to be used by anybody for direct marketing purposes. If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by writing to or emailing us at cs@lendenclub.com.

LDC may retain your personal information as long as necessary for the legitimate business interests to provide the users 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:

  • 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.
  • 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.

LDC may disclose or transfer your personal information after retrieving it from LDC’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 us, we will take reasonable steps in accordance with 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. 

Our application has a link to a registered third party SDK which collects data (SMS 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.

At times, LDC may make certain personal information available to its third party strategic partners, or other third parties that help LDC in marketing and research. When you register with our Platform, you authorize LDC 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 LDC shall be governed by our Privacy Policy.
LDC 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.

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 ads 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.

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

  • Comply with legal process or proceedings or judicial order served on the Platform or its owners.
  • Protect and defend the rights or property of the Platform owners or of the users of the Platform, or
  • Act under exigent circumstances to protect the personal safety of users of the Platform, its owners, or the public.

LDC may amend this Privacy Policy from time to time without requiring any consent from anyone. If LDC changes this Privacy Policy, the same will be posted on this page so that the user is aware of the Personal Information collected, used and disclosed by LDC. Any changes to the Privacy Policy will be communicated through the Platform. Users are bound by any changes to the Privacy Policy when they use LDC after such changes have been first posted.

11.1 Support

If you require any information or clarification regarding the use of your personal information or this Privacy Policy or grievances with respect to use of your personal information, please email our grievance officer at:

11.2 Indemnity

You agree to defend, indemnify and hold harmless LDC, its subsidiaries, affiliates, licensors, employees, agents, third party information providers and independent contractors against any loss, claims, damages, costs, liabilities and expenses (including, but not limited to, reasonable attorneys’ fees) arising out of or related to any content that you store or otherwise transmit on or through the Platform , your conduct, your use or inability to use the Platform , your breach or alleged breach of the Privacy Policy and the Terms of Use of LDC or of any representation or warranty contained herein, your unauthorized use of the Platform and the User Content, or your violation of any rights of another.

11.3 Conditions of Use

Please note that if you decide to visit our Platform, your visit and any possible dispute over privacy is subject to the Platform’ Privacy Policy, and the Terms of Use of LDC.

11.4 Termination

Notwithstanding anything contained herein, LDC reserves the right, without notice and in its sole discretion, to terminate your account and/or to block your use of the Platform.

11.5 Severance and Waiver

No action of LDC, other than an express written waiver or amendment, may be construed as a waiver or amendment of any of this Privacy Policy. If any clause in this Privacy Policy is found to be unenforceable, wherever possible, it will not affect any other clause and each will remain in full force and effect. this Privacy Policy set out the entire agreement between LDC and you relating to your use of this Platform and supersede and replace any prior agreements we might have between us regarding the Platform. Any rights not expressly granted herein are reserved.

11.6 Disclaimers

The Platform and its user content are provided “As is” and LDC and its directors, employees, content providers, agents and affiliates exclude, to the fullest extent permitted by applicable law, any warranty, express or implied, including, without limitation, any implied warranties of merchantability, satisfactory quality or fitness for a particular purpose. LDC will not be liable for any damages of any kind arising from the use of the Platform. The functions embodied on or in the materials of this website are not warranted to be uninterrupted or without error. LDC makes no warranty that the website or the user content is free from infection by viruses or anything else that has contaminating or destructive properties.

11.7 Governing Law

This Privacy Policy shall be governed by, and construed in accordance with, the laws of India. The Parties agree that if the process of the courts is required to be invoked for enforcement of the clause below, including for seeking of any interim relief prior, during or after invocation of the clause below, the competent courts at Mumbai, India shall have exclusive jurisdiction and both the parties hereto submit to the same. 

Annexure:

SMS – This app periodically collects SMS data like sender names, SMS body, received time and transmits the data to third parties. This data is used to understand your income and spending patterns which help us in credit evaluation and help us in facilitating higher limits, faster approval rates.

Location – This app collects location details one time to verify your location, and current address, to ensure serviceability, and to identify unusual activity to prevent against any fraud. We do not collect location when the app is in the background.

Device – This app collects and monitor specific information about your device including your hardware model, operating system and version, user profile information to uniquely identify the devices and ensure that unauthorized devices are not able to act on your behalf to prevent frauds. We do not collect any unique device identifiers like IMEI or serial number Installed.

Installed Applications – This app periodically collects information about the apps installed on your device to provide better personalized services and improve our credit risk assessment. This information is securely shared with our trusted partner, FinBox, for analysis. Your privacy is important to us, and you can opt out of this data collection at any time.